General Description

A LQG who accumulates hazardous waste for more than 90 days (without an extension) is subject to all TSDF and permitting requirements.

Summary of Federal Requirements

Common acute wastes (aka P-listed wastes) include acrolein, aldicarb, benzoic acid, calcium cyanide, cyanogens, Endrin, Endothall, fluorine, hydrogen cyanide, hydrogen phosphide, nitric oxide, parathion, phosgene, potassium cyanide, sodium azide, tetraethyl lead, Toxaphene, warfarin, and zinc cyanide.

LQGs are required to have an emergency coordinator on the premises or on call at all times.

Container Management

• Containers must be compatible with the waste in them.
• Containers must be kept closed except when waste is actually being added.
• Containers must not be leaking, bulging, rusting, damaged, or dented.

90-day Container Storage

• Containers of hazardous waste must be marked with the date accumulation began and the words HAZARDOUS WASTE. NOTE: The start date is when the first waste is poured/placed into the waste container at the 90-day accumulation point OR, the date the container is filled at a satellite accumulation point.
• Weekly inspections must be conducted at 90 day storage area.
• There must be sufficient aisle space to allow unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of the operation.
• Required equipment is easily accessible and in working condition and is tested to ensure it is in working condition.
• There is internal communications or alarm system capable of providing immediate emergency instruction to personnel.
• There is a telephone or hand-held two-way radio capable of contacting local and emergency responders.
• There are portable fire extinguishers and fire control equipment, including special extinguishing equipment (foam, inert gas, or dry chemicals).
• There is spill control equipment.
• There is decontamination equipment.
• There are fire hydrants or other source of water (reservoir, storage tank, etc.) with adequate volume and pressure, foam producing equipment, automatic sprinklers, or water spray systems.
• When waste leaves the 90-day storage area, it either is going for disposal, treatment, or recycle.

• LQGs may keep waste at a satellite accumulation points (SAP) and meet less stringent storage and labeling requirements. A SAP is defined as at or near the point of generation where wastes initially accumulate and is under the control of the operator of the waste generating process.
• Containers must be in good condition and compatible with the waste stored in them.
• Containers must be kept closed except when waste is being added or removed.
• Containers must be marked HAZARDOUS WASTE or other words that identify contents.
• There should be no more than 55 gal of hazardous waste [this is the total of all the hazardous waste stored at the SAP] or 1 qt of acutely hazardous waste in containers.
• When waste is accumulated in excess of quantity limitations, the excess container must marked with the date the excess amount began accumulating and the excess waste is transferred to a 90-day or permitted storage area within 3 days.
• When a facility has equipment that discharges hazardous wastes to attached containers (i.e. photo processing), the containers that collect such wastes have to be in compliance with the SAP regulations even if the discharging unit is not regulated under RCRA, the attached containers that collect hazardous wastes from the equipment must be in compliance with the SAP regulations, if those containers collect wastes that are listed or characteristic hazardous wastes.

Training

• Personnel must be thoroughly familiar with waste handling and emergency procedures relevant to their responsibilities during normal facility operation and emergencies. NOTE: Regulations do not require training of personnel working in SAPs. Personnel that have access to or work in central accumulation areas, including those that move hazardous waste from a SAP to the 90-day storage area, must be trained. As the ones actually generating hazardous waste, however, personnel working in SAPs need to be familiar enough with the chemicals with which they are working to know when they have generated a hazardous waste so that it will be managed in accordance with the RCRA regulations.

Documentation

• LQGS must have an identification number.
• LQGs must use manifest when sending waste offsite for disposal of recycling.
• LQGs maintain a copy of each signed manifest for 3 yr or until the LQG receives a signed copy from the designated facility which received the waste. Then, the returned signed copy is retained as a record for at least 3 yr from the date the waste was accepted by the initial transporter.
• LQGs are required to keep records of waste analyses, tests, and waste determinations for 3 yr.
• Emergency information is posted at the phone.
• If the waste being disposed of is restricted from land disposal, the manifest files should contain a copy of the LDR notice.
• Documentation of the weekly inspection of the 90-day storage area.
• LQGs must have a contingency plan.
• A record of the time, date, and details of any incident that requires implementing the contingency plan.

Summary of State Requirements

States may define what terms like “at or near” mean in relation to SAPs.

State-by-state guidance concerning hazardous waste can be found at ENVCAP's Hazardous Waste Resource Locator.

Laws and Statutes

The Resources Conservation and Recovery Act, Subtitle C