Just like every other state with an authorized hazardous waste program Kansas allows a generator to accumulate hazardous waste without a permit in what is known as a Satellite Accumulation Container. Most states (Missouri and California being exceptions) will allow for the accumulation of hazardous waste in a Satellite Accumulation Container without being subject to the on-site accumulation time limits of a Large Quantity Generator (no more than 90 days) or a Small Quantity Generator (no more than 180 days).
However, Kansas also provides the option of managing your hazardous waste in what the Kansas Department of Environmental Health (KDHE) refers to as a Day Accumulation Container.
Why would I be interested in a Day Accumulation Container?
ANSWER: The Day Accumulation Container provides an option for a hazardous waste generator to accumulate hazardous waste in a small container in a cramped area (eg. a laboratory) with several employees where a single Satellite Accumulation Container is inconvenient. The great advantage to the Day Accumulation Container is that Facility Personnel may accumulate hazardous waste in a container right at their work station (eg. a lab hood) and then transfer the contents to a Satellite Accumulation Container at the end of their shift.
Requirements for Day Accumulation Containers:
- Container capacity no more than six (6) gallons.
- Container is under the direct control of the operator of the work area or work station where it is located. By “direct control”, the KDHE means that the person generating the waste is able to prevent others from adding unknown wastes to it or in other way tampering with the container without the operator’s knowledge.
- Container labeled or marked with the words: “Hazardous Waste”. Simply identifying the waste by name or hazardous waste code is not enough.
- Container is securely closed except when waste is actively being added or removed. A “closed container” will vary depending on the type of container and the characteristics of the waste (eg. vaporizes easily, spill potential, etc.), but typically it requires the container to be closed and sealed so that no vapors are released and that the contents will remain in the container even if it tips over.
- Container must be in good condition and compatible with its contents.
- At the end of every shift (if facility operates more than one shift) or at the end of each work day (if facility operates only one shift/day) the Day Accumulation Container must be emptied into either a Satellite Accumulation Container, a 90 or 180 day accumulation container, or a 90/180 day accumulation tank. The Day Accumulation Container must be emptied at the end of each shift or day whether it is empty or not. Its frequent emptying is the most distinctive requirement of the Day Accumulation Container, and it must be strictly adhered to.
Further Compliance with KDHE Day Accumulation Container Regulations:
- Initial (within 90 days) and annual refresher training is not required for personnel who work only with Day Accumulation Containers, though it is recommended.
- Weekly inspections of Day Accumulation Containers is not required, though it is a good idea to conduct periodic inspections.
In general the Day Accumulation Container is subject to the same requirements as a Satellite Accumulation Container with the additional requirement to empty it every shift/work day.
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Failure to comply with the requirements for a Day Accumulation Container as defined by KDHE will result in the container being considered to be a Satellite Accumulation Area. This means that the container the former Day Accumulation Container (now Satellite Accumulation Container) is emptied into can no longer be a Satellite Accumulation Container since the transfer of hazardous waste from one Satellite Accumulation Container to another is not allowed. Therefore, the former Satellite Accumulation Container must now be managed as a 90/180 day accumulation container, subject to all the regulations (eg. weekly inspections, employee training, on-site accumulation time limits, etc.)
I’ve looked throughout the hazardous waste regulations of the Kansas Department of Health and Environment and I can’t find a single reference to a Day Accumulation Container, what gives?
ANSWER: You won’t find a reference to the Day Accumulation Container in the Kansas Administrative Regulations (or those of the USEPA). You’ll have to look in a KDHE Technical Guidance Document: Container Management for Hazardous Waste Generators HW-2005-G1 (pages 4 & 5).
States can be creative in their interpretation and enforcement of the USEPA hazardous waste regulations. They can also write their own regulations that supersede those of the Federal Government. Be sure you’re in compliance with the regulations of your State when it comes to hazardous waste.
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My Onsite Training is a great way for you and your employees to learn the state regulations that apply to your operations and to learn of state-specific options like Day Accumulation Container in Kansas.