How long may hazardous wastes be kept on site?
May a plant have more than one short-term hazardous waste storage area?
"What is “Satellite Accumulation”?

How long may hazardous wastes be kept on site?

For large quantity generators (LQGs), a container of hazardous waste must be shipped off site within 90 days after it was filled. For small quantity generators (SQGs), a container of hazardous waste must be shipped off site within 180 days after it was filled. For containers larger than 55 gallons, the 90-day or 180-day clock starts as soon as there are more than 55 gallons of hazardous waste in that container. [VHWMR § 7-308(b)(2)] The 90-day or 180-day limit applies to containers that are in storage in the short-term hazardous waste storage area.

May a plant have more than one short-term hazardous waste storage area?

Yes, as long as each area meets the short-term storage area requirements of VHWMR § 7-311.

What is “Satellite Accumulation”?

There are three different handling options for containers that are being filled with hazardous waste. Where the container is located determines how it must be labeled and how soon it must be moved into short-term storage or shipped off site.

Handling Option 1 - Satellite Accumulation
Up to 55 gallons of hazardous waste may accumulate in a container located at or near the point of waste generation and under the control of employees who make the waste. When the container is full or more than 55-gallons have accumulated, within 3 days it must be shipped off site or moved to a short-term hazardous waste storage area. [7-310(a)] The LQG 90-day [SQG 180-day] clock for shipment off-site from the storage area started on the day the container was filled.

Required labeling for satellite accumulation:

"Satellite accumulation" and "shift accumulation containers" in the workplace require only two pieces of information on their labels: [7-310(a)(5]
1) the words "Hazardous Waste"
2) words that identify the contents of the container

Handling Option 2 - Accumulation in the Short Term Storage Area
Hazardous wastes also may be "accumulated" in the short term hazardous waste storage area. In this case, operators using "shift accumulation containers" bring the waste to larger containers in the short-term storage area at the end of each work shift (not to exceed 12 hours). Up to 55 gallons of each waste stream may be accumulated in the storage area before its container is full and the 90-day [180-day] clock starts. This Vermont-specific option is especially useful for hazardous waste streams that accumulate very slowly or are too hazardous to accumulate at or near their point of generation. [7-310(b)]

Required labeling for accumulation in the Short Term Storage Area:

"Accumulation" containers in the hazardous waste storage area must be labeled with: [7-310(b)(2) & (3)]
1) words to identify that it is an accumulation container
2) the point of waste generation
3) the generator's name
4) the generator's address
5) the generator's EPA identification number;
6) the name and hazardous waste identification number(s) of the hazardous waste
7) the words "Hazardous Waste - Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency."

Handling Option 3 - Adding Waste to Containers Already in Storage
The final waste handling option involves filling a container that is in storage in a hazardous waste short term storage area. In this case, the 90-day [180-day] clock started as soon as hazardous waste was placed in the container. The hazardous waste placed in a container maintained under this option may come directly from the point of generation or may be transferred from satellite accumulation containers located elsewhere in the facility. This approach works well for wastes that accumulate quickly and are often shipped off-site long before 90 days [180 days] from their fill date. [7-311]

Required labeling for adding waste to Containers Already in Storage:

Full or partial containers that are "in storage" in a hazardous waste storage area, must be labeled with:
[7-311(f)(1)]
1) the generator's name
2) the generator's address
3) the generator's EPA identification number;
4) the name and hazardous waste identification number(s) of the hazardous waste
5) the date the container was first used to store or accumulate waste
6) the words "Hazardous Waste - Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency."

Updated 08/09/2012