Generator Accumulation Standards
The storage of hazardous waste generally requires a permit under California's Hazardous Waste Control Laws (HWCLs). However, generators may accumulate their hazardous waste without a permit if they meet certain management standards for the accumulation unit and their facility including contingency plans and personnel training. The length of time a generator may accumulate their hazardous waste is based on the category of generator.
Please note: Since SQGs are subject to 40 CFR (federal) requirements not Title 22 (California) requirements regarding accumulation standards, all SQG accumulation standards mentioned below are found in 40 CFR. These standards also apply to generators of 1 kg or less of acute/extremely hazardous waste.
CONTAINERS: LQGs that accumulate hazardous waste in containers are subject to articles 9, 27, 28 and 28.5 of chapter 15 while SQGs are subject to subpart I of part 265 of 40 CFR, except for §§265.176 and 265.178
All containers and tanks (i.e., for LQGs and SQGs) must be labeled "Hazardous Waste", marked with the date accumulation begins and include additional information (e.g., the physical composition of the waste). Generally, the time period for generator waste accumulation starts when hazardous waste is first placed in or on the empty accumulation unit (i.e., tank, container, drip pad, or containment building).
ACCUMULATION TIME LIMITS
LQGs are allowed to accumulate hazardous waste on site for up to 90 days in specified units without obtaining a storage permit, if they comply with the requirements of T22, CCR section 66262.34(a) & (f).
LQGs and SQGs accumulating waste beyond the authorized time limits for their categories become storage facilities subject to the requirements applicable to Owners and Operators of Hazardous Waste Transfer, Treatment, Storage, and Disposal Facilities including permitting. An SQG who accumulates more than 6,000 kg during the authorized period also becomes a storage facility.
Satellite accumulation allows generators to accumulate hazardous waste for up to one year at or near the point where it is initially generated and collected during daily operation thereby exempting generators from the accumulation standards including the 90,180 or 270 day accumulation limits if certain conditions are met.
A person may accumulate up to 55 gallons of hazardous waste or 1 quart of acute hazardous waste at each satellite accumulation area, if it is under the control of the person operating the process that generates the waste. Limited standards, such as labeling and maintaining the container in good condition, apply to satellite areas. Once the 55-gallon or 1 quart limit is exceeded at the satellite area, the excess waste must be dated and moved within three days to the central accumulation area where LQG or SQG accumulation standards apply (or the waste can be shipped directly off site).
OTHER ACCUMULATION STANDARDS
LQGs and SQGs accumulating hazardous waste on site must comply with the preparedness and prevention procedures in Chapter 15, article 3. These requirements include having an emergency coordinator and testing and maintaining emergency equipment.
LQGs must develop and maintain a contingency plan on site, as found in Chapter 15, article 4, which outlines the response procedures necessary to minimize the hazards posed by fires, explosions, or unplanned releases of hazardous waste from the facility (§66262.34(a)(4)). Such a plan is not required for SQGs, although 40 CFR §262.34(d)(5)(iv) outlines appropriate response procedures.
LQGs must comply with the personnel training requirements referenced in §66265.16. These regulations require facility personnel to complete classroom or on-the-job training to become familiar with proper hazardous waste management and emergency procedures for the wastes handled at the facility. SQGs must follow modified personnel training requirements in 40 CFR §262.34(d)(5)(iii).