General Description

• Facilities generate less than 1000 kg [approx. 2200 lb] of non-acute hazardous waste in one calendar month but greater than 100 kg [220 lbs] of non-acute hazardous waste in one calendar month. Onsite accumulation time does not exceed 180 days. Facilities generate less than or equal to 1 kg/mo [2.2 lb/mo] of acute hazardous waste is generated in one calendar month.
• Facilities generate less than or equal to 100 kilograms (220 lbs) of any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute hazardous waste in one calendar month.
• Total onsite accumulation does not exceed more than 6000 kg [approx. 13,227 lb].

If a facility exceeds any of the listed parameters, it must operate as a Large Quantity Generator.

Summary of Federal Requirements

Typically at SQGs, hazardous waste being generated at the facility is first accumulated in Satellite Accumulation Areas/Satellite Accumulation Points (SAA/SAPs) before being transferred to a central accumulation area (i.e., 180-day storage area). In general, whenever hazardous waste is being poured, mixed, spread, or otherwise handled, all personnel involved in the operation must have immediate access (e.g., direct or unimpeded access) to an internal alarm or emergency communication device, either directly or through visual or voice contact with another employee, unless such a device is not required because the generation or accumulation area does not lend itself for safety reasons to have a particular kind of equipment. (NOTE: In the event there is just one employee on the premises while the facility is operating, the employee must have immediate access (e.g., direct or unimpeded access) to a device, such as a telephone (immediately available at the scene of operation) or a hand-held two-way radio, capable of summoning external emergency assistance, unless such a device is not required because the generation or accumulation area does not lend itself for safety reasons to have a particular kind of equipment.)

Satellite Accumulation Points

• SQGs may keep hazardous waste at a satellite accumulation areas/points (SAA/SAP) and meet less stringent storage and labeling requirements. An SAA/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 process generating the waste.

  There has long been debate about the interpretation of the phrases "at or near" in relationship to SAA/SAPs. In the Preamble to the November 2016 rule revision, page 85767, EPA stated that it would not consider a shed outside a building where the waste is initially generated to be "at or near the point of generation." But, implementing regulatory agencies retain the authority in determining what they consider "at or near the point of generation."

  There has also been debate over the meaning of the phrase "under the control of the operator" in relationshio to SAA/SAPs. In the Preamble to the November 2016 rule revision, page 85767, there is a lengthy discussion about the meaning of the phrase "under the control of the operator." EPA believes that there can be more than one operator per SAA over time. For example, as employees change shifts over the course of a day, the role of the operator can be transferred from one employee to another. Likewise, the EPA believes that there can also be more than one operator per SAA at the same time. For example, multiple operators may be running laboratory equipment in the same room and share hazardous waste containers located in a single SAA. However, the term operator does refer to an individual or individuals responsible for the equipment or processes generating the hazardous waste and does not refer to a company or entity as a whole. In relationship to what constitutes "control," EPA stated that the intent of the term is to ensure that someone familiar with the operations generating the hazardous waste is aware of and able to attend to the operations, if needed, while also providing some measure of controlled access.

• Containers must be in good condition and compatible with the waste stored in them. Containers must be kept closed except:
  • when adding, removing, or consolidating waste
  • when temporary venting of a container is necessary on one of the following situations:
    • for the proper operation of equipment
    • to prevent dangerous situations, such as build-up of extreme pressure.

  NOTE: In the Preamble to the November 2016 rule revision, page 85764, EPA stresses it does not intend to create a loophole to the closed container requirement or to allow intentional evaporation of hazardous waste. Rather, the intent of the flexibility is to address the limited cases in which strict adherence to the container closure requirements could substantially increase a risk of a hazardous waste incident rather than decrease it. The flexibility for containers to remain open in specific situations applies only to containers in SAAs.)

• Containers must be marked HAZARDOUS WASTE and with an indication of the contents hazards such as one of the following approaches:
  • the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic), or
  • hazard communication consistent with the Department of Transportation requirements at 49 CFR 172 subpart E (labeling) or subpart F (placarding), or
  • a hazard statement or pictogram consistent with the OSHA Hazard Communication Standard at 29 CFR 1910.1200, or
  • a chemical hazard label consistent with the NFPA code 704.

• The total amount stored in the SAA/SAP does not exceed 55 gal of non-acute hazardous waste or 1 qt of liquid acute hazardous waste or 1 kg (2.2 lb) of solid acute hazardous waste in containers.

• When waste is accumulated in excess of quantity limitations at or near the point of generation the facility has 2 options: ?
  • within 3 consecutive days, upgrade the SAA/SAP so that it complies with the requirements for a central accumulation area (180-day storage area), or ?
  • Remove the excess waste from the SAA/SAP within 3 days to one of the following locations: ?
    • a central accumulation area (180-day storage area) ?
    • an onsite interim status or permitted TSDF ?
    • an off-site designated facility

• 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 SAA/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 SAA/SAP regulations, if those containers collect wastes that are listed or characteristic hazardous wastes.

SQG Central Accumulation Area (aka 180-day Container Storage)

• Containers of hazardous waste must be marked with:
  • the date accumulation began NOTE: The start date is when the first waste is poured/placed into the waste container at the 180-day accumulation point OR, the date the container is filled at a satellite accumulation point. words
  • HAZARDOUS WASTE.
  • an indication of the contents hazards such as one of the following approaches:
    • the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic), or
    • hazard communication consistent with the Department of Transportation requirements at 49 CFR 172 subpart E (labeling) or subpart F (placarding), or
    • a hazard statement or pictogram consistent with the OSHA Hazard Communication Standard at 29 CFR 1910.1200, or
    • a chemical hazard label consistent with the NFPA code 704.

• Containers must be in good condition and not leaking. If a container is not in good condition or the container begins to leak, it must be immediately transferred to a new container in good condition or managed in another compliance manner.

• Containers must be compatible with the waste stored in them.

• Weekly inspections must be conducted at Central Accumulation Area (180 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 in an emergency unless aisle space is not needed for any of these purposes.

• All areas where hazardous waste is either generated or accumulated are equipped with the following unless none of the hazards posed by the waste handled at the facility would require a particular kind of equipment specified below or the actual waste generation or accumulation area does not lend itself for safety reasons to have one or more of the particular kind of specified equipment:
  • internal communications or alarm system capable of providing immediate emergency instruction (voice or signal) to facility personnel.
  • a device, such as a telephone (immediately available at the scene of operations) or a hand-held two-way radio capable of Summoning emergency assistance from local police departments, fire departments, or State or local emergency response teams.
  • portable fire extinguishers and fire control equipment, including special extinguishing equipment (foam, inert gas, or dry chemicals).
  • spill control equipment.
  • decontamination equipment.
  • water at adequate volume and pressure to supply water hose streams, or foam producing equipment, or automatic sprinklers, or water spray systems.

• All communications or alarm systems, fire protection equipment, spill control equipment, and decontamination equipment (where required) is tested and maintained as necessary to ensure proper operation.

• When waste leaves the 180-day storage area, it either is going for disposal, treatment, or recycle.

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 central accumulation area (180-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.

Emergency Response

SQGs are required to have at least one emergency coordinator who is either on the premises or on call at all times with the responsibility of coordinating all emergency response measures. The concept of "on call" is explained as being "available to respond to an emergency by reaching the facility within a short period of time."

The following information must be posted next to telephones or in areas directly involving the generation and accumulation of hazardous waste:

• name and emergency telephone number of emergency coordinator
• location of fire extinguishers and spill control materials
• location of fire alarms (if present)
• telephone number of fire department unless the facility has a direct alarm.

SQGs are required to have at least attempted to make arrangements with the local police department, fire department, other emergency response teams, emergency response contractors, equipment suppliers and local hospitals, taking into account the types and quantities of hazardous wastes handled at the facility. (NOTE: Arrangements may be made with the Local Emergency Planning Committee (LEPC), if it is determined to be the appropriate organization with which to make arrangements.)

As part of attempting to make these arrangements with the local fire department, the SQG must determine the potential need for the services of the local police department, other emergency response teams, emergency response contractors, equipment suppliers and local hospitals. This includes the SQG familiarizing the necessary organizations with the layout of the facility, the properties of hazardous waste handled at the facility and associated hazards, places where facility personnel would normally be working, entrances to roads inside the facility, and possible evacuation routes as well as the types of injuries or illnesses that could result from fires, explosions, or releases at the facility.

Where more than one police or fire department might respond to an emergency, the SQG must attempt to make arrangements designating primary emergency authority to a specific fire or police department, and arrangements with any others to provide support to the primary emergency authority.

NOTE: A facility possessing 24-h response capabilities may seek a waiver from the authority having jurisdiction (AHJ) over the fire code within the facility's state or locality as far as needing to make arrangements with the local fire department as well as any other organization necessary to respond to an emergency, provided that the waiver is documented in the operating record.

• SQGS must have an identification number and, starting in 2021, renotify the EPA every 4 years using EPA Form 8700-12.
• SQGs must use a manifest when sending waste offsite for disposal of recycling.
• SQGs maintain a copy of each signed manifest for 3 yr or until the SQG 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.
• SQGs are required to keep records of waste analyses, tests, and waste determinations for 3 yr.
• 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 central accumulation area (180 storage area).
• SQGS must have records documenting the arrangements with the local fire department as well as any other organization necessary to respond to an emergency and the documentation includes documentation in the operating record that either confirms such arrangements actively exist or, in cases where no arrangements exist, confirms that attempts to make such arrangements were made.

Facilities that were formerly LQGs have been able to scale back to being a SQG by using the universal waste classification for its waste batteries, waste pesticides, or waste fluorescent tubes.

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