Small Quantity Generator storage time of 270 days

The normal storage time for SQG is 180 days.

40 CFR 262.34(f) states that if “a generator who generates greater than 100 kilograms but less than 1000 kilograms of hazardous waste in a calendar month and who 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 may accumulate hazardous waste on-site for 270 days or less without a permit or without having interim status.”

If you read the regulation closely, it states that SQG gets the extra 90 days only if he MUST transport his waste over a distance of 200 miles or more. Someone asked EPA the question: What if there is a facility closer than 200 miles away, is it permissible for the generator to ship to one that is more than 200 miles away and still claim the extra 90 days?

EPA’s own guidance document (RCRA Online 9451.1987(04)) provides the answer. The agency does not want to tell a SQG what facility he must choose to dispose of its waste. It leaves it up to the generator to make that decision. For example, if there is a TSDF within 200 miles and a recycling facility outside the 200 miles radius, the SQG is free to pick the recycling facility if it is a better facility for its wastes.

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