As a state with an authorized hazardous waste program under the Resource Conservation and Recovery Act (RCRA) Cal EPA can enact regulations for the management of hazardous waste that are more broad and more strict than those of the USEPA. If you’ve done business in California you know that its regulations pertaining to waste management (not just hazardous waste, but also used oil, universal waste, and non-RCRA hazardous waste) are much more strict than those of the USEPA – or any other state. You’ll also know that the Department of Toxic Substances Control (DTSC), one of six boards/departments within Cal EPA, is responsible for managing the hazardous waste program in California and that CUPAs (Certified Unified The purpose of this article is to focus on just one aspect of California’s hazardous waste regulations: The On-Site Accumulation Time Limit for Generators of Hazardous Waste.
The following table summarizes the accumulation time limits for hazardous waste generators in California
|Pursuant to Title 22 CCR…||If you generate…||Then, without requiring a permit, you may…||On-site accumulation time period begins…|
|66262.34(a) & 66262.34(b)(2)||
||Accumulate hazardous waste on-site for no more than 90 days.||On the first date on which any amount of hazardous waste begins to accumulate.|
||Accumulate hazardous waste on-site for no more than 180 days.Or, no more than 270 days if the treatment, storage, or disposal facility (TSDF) is ≥200 miles away.||On the first date on which any amount of hazardous waste begins to accumulate.|
|66262.34(d) or 66262.34(b)(1)||
||Option 1: Accumulate hazardous waste on-site for no more than 180 days.Or, no more than 270 days if the treatment, storage, or disposal facility (TSDF) is ≥200 miles away.||On the first date on which any amount of hazardous waste begins to accumulate.|
|Option 2: Accumulate hazardous waste on-site for no more than 90 days.||On the date the generator accumulates on-site…≥100 kg of hazardous waste≥1 kg of acute hazardous waste≥1 kg extremely hazardous waste|
|CA Health & Safety Code 25143.13||≤100 kg/mo of solely hazardous waste that is characteristically toxic for silver (D011)||No on-site accumulation time limit.|
|66262.34(c)||Any amount of non-RCRA or RCRA-exempt hazardous waste.||An extension of up to 30 days may be granted pursuant to §66262.35.|
|66262.34(c)||Any amount of a RCRA hazardous waste.||An extension of up to 30 days may be granted for unforeseeable, temporary, and uncontrollable circumstances. The extension may be granted at the discretion of the DTSC on a case-by-case basis.|
|66262.34(e)||Any amount of hazardous waste, acute hazardous waste, or extremely hazardous waste||Accumulate hazardous waste in a Satellite Accumulation Area for no more than one year if the following volume limits are not exceeded in the Satellite Accumulation Area:
|On the first date on which any amount of hazardous waste begins to accumulate.|
RCRA hazardous waste? Non-RCRA hazardous waste? What are these? And why no mention of the three hazardous waste generator status seen in the 40 CFR: Large Quantity Generator, Small Quantity Generator, and Conditionally Exempt Small Quantity Generator? Why the one year time limit for accumulation of hazardous waste in a satellite accumulation area? The answer to these questions – and a lot more questions that aren’t asked here – will have to wait for another day. The way to get answers to your questions about the management of hazardous waste in California:
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