A little known rule about hazardous waste accumulation

waste storage areaFor those of you who are “small quantity generator” of hazardous wastes, did you know that you can store your waste for up to 270 days without a permit if you decide to ship your waste to a facility that is more than 200 miles away?

Federal regulation 40 CFR 262.34(e) states that if a generator generates between 100 and 1000 kg of hazardous waste in a calendar month (small quantity generator) and he “must transport his waste, or offer his waste for transportation, over a distance of 200 miles or more for off-site treatment, storage or disposal”, he may store his waste for up to 270 days.

The word “must” in the regulation seems to imply that this extension only applies when the generator has no other choice but to ship his wastes to a site that is more than 200 miles away. Someone called into EPA in 1987 and asked if the extension is still valid if there is a facility closer than 200 miles away. In other words, can the generator CHOOSE to ship his waste to a faciity that is more than 200 miles in order to to take advantage of this storage time extension even if there is another disposal facility closer by? 

The answer from EPA is yes.

If you go to EPA’s RCRA Online and type in RCRA online # 13000, you will find an EPA document explaining the rationale for this special extension for small quantity generators.

So this EXTRA 90 days in storage time extension is for you to use if you are a small quantity generator.

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