Improperly Stored Wastes: A Common Problem
Outdated or unknown wastes at a facility are a shockingly common problem, but the cause of improperly stored waste is not always due to negligence on the part of the generator.
Your company may have moved into an old manufacturing facility, and after setting in and taking stock, you might find the previous owners have stuck you with a dozen 55-gallon drums of various unknown hazardous wastes that have been collecting dust in a backroom for years (or worse yet, have been leaking). But once you take over ownership of the property (and you begin to generate waste in your new facility), those barrels of waste now become your responsibility.
Or for instance, your general practice may have a few outdated boxes of medical waste that have been secreted away in a closet that hasn’t been opened for as long as you or any of your employees can remember. In which case, those boxes—which could be full of bio-hazardous, Sharps, of red bag waste—must be dealt with immediately.
If the EPA were to conduct a surprise inspection on your new facility, RCRA non-compliance could mean a violation and sizable fine for your company (not to mention a loss of trustworthiness in the estimation of clients and vendors alike) for outdated or illegally stored waste containers.
These kinds of on-site waste violations certainly are not the fault of the new owner or generator, but they must be dealt with in a lawful manner just the same. So making sure you know the exact rules about the on-site storage of hazardous waste is crucial for most operators, handlers, and generators.
All small-and-large quantity generators must abide by these storage limits. (If you do not know your generator status, you can find more information on that subject here.) Storage time limits officially start once a drop of waste reaches its container.
There are two areas for storing hazardous materials (HAZMAT) waste, one is for very brief storage—the satellite accumulation area—and the other is for longer (but not indefinite) store-housing, the main hazardous waste storage area.
On-Site HAZMAT Storage Rules
Satellite Accumulation Area
The satellite accumulation area or zone is defined as the area at or near the point of generation and which is under the control of the operator of the waste process. “At or near” means that the nominated area is within the facility near the actual process of generation and not hundreds of yards away at another site or in another building.
The main reasoning behind this provision was to provide generators with a little time (3 days to be exact) to move their waste on to the main storage area or to find a suitable off-site removal company to pick it up.
The rules for satellite accumulation are as follows:
- Up to 55 gallons of hazardous waste, or one quart of acute hazardous waste, can be accumulated here;
- Containers of waste in a satellite zone must be correctly dated so when the 72 hour limit for each is reached, the wastes can be sent off to a facility or to the main storage area;
- Must be labeled with the appropriate identifying markers, e.g. “Hazardous Waste”, “Acute Hazardous Waste”, “Corrosive”, “X-Ray Waste”, “Cyanide”; and
- Containers must be kept sealed, except when adding waste.
Main Hazardous Waste Storage Area
The main hazardous waste storage area rules are:
- Small quantity generators (SQG) may store hazardous waste in this area for 180 days;
- Large quantity generators (LQG) may store hazardous waste in this area for no longer than 90 days, until it is to be received by or shipped off to a certified hazardous waste disposal company, or a treatment, storage, and disposal facility (TSDF);
- Containers must be in good working condition and sealed unless removing or adding waste, and must be compatible with the criteria of the waste itself, that is, able to safely withstand and hold its contents;
- Weekly inspections must be conducted and logged in a record-book; and
- The type of hazardous waste or description of the containers contents must be present, along with the date of accumulation (the date used for main storage area is the day when the waste container leaves the satellite accumulation area).
Safeguard Your Company From EPA Violations
Some of the most common EPA and RCRA violations have to do with incorrectly stored wastes, including mixing disparate waste types in the same container, keeping wastes in either storage area longer than the stated time limits, and accumulating more waste than is allowed by your generator status. But the good new is, once your company is aware of the rules on HAZMAT storage, you are unlikely to ever find yourself on the receiving end of an EPA fine.
Removing old, unknown, outdated wastes that are stored on-site at your facility is key to EPA compliance and good business practice.
Need help with Hazardous Waste Removal and Disposal? Call us at 800-936-2311
If you have any questions about hazardous waste storage or you need prompt, cost-effective, and fully complaint removal and disposal services, please give us a call at 800-936-2311 or click here to request a price quote via email.