Managing Hazardous Waste

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Hazardous Waste Accumulation Time for Generators Fact Sheet

August 2014*

Regulatory Assistance Officer’s Note

This fact sheet was produced by the Department of Toxic Substances Control (DTSC) Regulatory Assistance Officers to provide a simple overview for hazardous waste generators.  Hazardous waste accumulation requirements are discussed in greater detail in the DTSC fact sheets Accumulating Hazardous Waste at Generator Sites and Hazardous Waste Generator Requirements.  We advise you to review these other resources as well.  If you generate waste, you should consult with your Certified Unified Program Agency (CUPA).  Finally, DTSC strongly encourages all businesses generating hazardous waste to consider waste minimization, source reduction and pollution prevention.

How Long can I Accumulate Hazardous Waste in Tanks or Containers? 

The answer depends in part on the total amount of hazardous waste that you generate each month (Cal. Code Regs. Title 22, § 66262.34).

When Does my Accumulation Clock Begin?

Hazardous Waste Generated per Calendar MonthMaximum Allowed Accumulation Time
Less than 1,000 kilograms (2,200 pounds) (Federal term: "Small Quantity Generator") The generator may not hold more than 1 kilogram of acutely or extremely hazardous waste for more than 90 days.180 days or less, or 270 days or less if the waste will be transported 200 or more for treatment, storage, or disposal. (Cal. Code Regs. Title 22, Sec 66262.34(d)).
The quantity of waste held at one time may never exceed 6,000 kilograms (13,200 pounds). Generator must meet the requirements of 40 Code of Federal Regulations section 262.34 subsections (d), (e), and (f).
1,000 kilograms (2,200 pounds) or more (Federal term: "Large Quantity Generator") or 1 kilogram of acutely or extremely hazardous waste90 days or less from the first date on which any amount of hazardous waste begins to accumulate during that month. (Cal. Code Regs. Title 22, Sec. 66262.34 subsection (b)(2)). The generator must also comply with CCR, Title 22, section 66262.34 subsections (a), (c), and (f).
Hazardous Waste Generation RateAccumulation "Clock" Begins
100 kilograms (220 pounds) or less per calendar month, or 1 kilogram of acutely or extremely hazardous waste in any calendar month.The time begins on the date the generator has accumulated 100 kilograms of hazardous waste, or 1 kilogram of acutely or extremely hazardous waste.
More than - 100 kilograms (220 pounds) per monthThe time begins on the first date on which any amount of hazardous waste begins to accumulate during that month.

What is “Satellite Accumulation,” and How are the Requirements Different?

Because of the complexity of the satellite accumulation regulations, the Regulatory Assistance Officers encourage you to contact your Certified Unified Program Agency (CUPA) and/or the Regulatory Assistance Officer in your region.  In brief, a generator may accumulate as much as 55 gallons of hazardous waste, or one quart of acutely or extremely hazardous waste, without a permit and without complying with California Code of Regulations, title 22, section 66262.34 subsections (a), (b), and (c), if:

  1. The waste is accumulated in containers (not tanks) at the initial accumulation point, near or at the generation point, and is under the control of the operator of the process generating it.
  2. The generator does not hold the hazardous waste on-site for more than one year from the initial date of accumulation.
  3. The initial date of accumulation is clearly marked and visible on each container, and the containers are managed according to regulation. (Cal. Code Regs. title 22 §§ 66265.171 66265.17266265.173 subsec. (a))

Within three days of reaching the quantity limits, the generator must mark the container with the date that limit was reached, and comply with the other applicable regulations discussed above.

The generator may use separate containers for different waste streams generated by a given process or group of processes if:

  1. The waste streams are incompatible; 
  2. If using a single container prevents recycling;
  3. If using a single container requires unreasonable procedures; or

If using a single container is not safe for the public, workers or the environment.

A 55-gallon or one quart limit applies to each group of waste streams.  The generator’s determination of the separation of the process wastes is subject to review and approval by DTSC at any time.

If you are considering satellite accumulation, please consult the regulations cited above.  If you are not sure that your accumulation area satisfies the criteria for satellite accumulation, check with your local CUPA and/or the DTSC Regulatory Assistance Officers. 

How do I Label my Accumulation Containers?

To comply with the requirements (Cal. Code Regs. title 22 § 66262.34 subsec. (f)) the generator must ensure that:

1.   In a generator accumulation area, the accumulation start date is clearly marked and visible on each container. 

2.   The accumulation start date is clearly marked and visible on each satellite accumulation container, and satellite accumulation end date is placed on the container when 55 gallons is reached or the container is moved to another area.

3.   Each container is labeled or marked “Hazardous Waste,” and is labeled with the following:

  • the composition and physical state of the wastes;
  • a statement calling attention to the particular hazardous properties of the wastes (toxic, ignitable, reactive, corrosive); and
  • the name and address of the generator.

Accumulation time extensions can be granted under limited conditions.  In most cases, extensions are not granted unless requested before the accumulation period has expired.  DTSC handles applications for storage extensions of RCRA regulated waste.  The CUPAs can grant non-RCRA waste storage extensions.  (Cal. Code Regs. title 22, § 66262.35)

DTSC Regulatory Assistance Officers

If you cannot find the answer to your question in this fact sheet, contact the DTSC Regulatory Assistance Officers.  You can call them at 800-728-6942, or contact them via email at RAO@DTSC.CA.GOV.

DTSC Regulatory Assistance Officers provide informal guidance only regarding management of hazardous waste for the convenience of the public.  Such advice is not binding upon DTSC, nor does it have the force of law.  If you would like a formal opinion on a matter by DTSC, please contact the responsible program office directly.   You should also refer to the statutes and regulations, DTSC Policies and Procedures, and other formal documents.

If you believe that you have received incorrect information from a Regulatory Assistance Officer, please contact External Affairs at (916) 322-0476.

We also encourage you to complete a Cal/EPA Customer Satisfaction Survey (opens new window) so that we may improve our Regulatory Assistance Officers Program.

Other Useful Numbers

For additional information on EPA ID Numbers:
DTSC Generator Information Services Section (916) 255-1136 or (800) 618-6942 (California only) See the “EPA Identification Numbers” fact sheet.

To report illegal disposal or management of hazardous waste, contact:
Your local Certified Unified Program Agency (opens new window) or DTSC Waste-Alert Hotline:  (800) 698-6942 or 911 – only if you see a crime (such as disposal to a storm drain) in progress.