Overview
Volumes of waste in storage exceed satellite accumulation limits (55 gallons or 1 quart of P-listed) or are not stored in the same area where generated
- Laboratories are generally considered to be a single satellite accumulation area with multiple points of generation.
- Accumulations limits apply to all waste in the laboratory.
- Waste must remain “at or near the point of waste generation” and “under the control of the operator of the process generating the waste.”
The quantity of waste that can be accumulated in any single Satellite Accumulation Area (SAA) is limited to 55 gallons for non-acute wastes and one quart for acutely hazardous wastes. Non-acute wastes are all characteristic wastes (D-coded), U-wastes and most F-wastes. Acutely hazardous wastes are P-wastes and F-coded dioxin wastes (F020-F023, F026 and F027). If these quantities are exceeded, then excess material must be removed to a 90-day storage location within 3 days.
Because of the “at or near the point of generation” language, generators are prohibited from moving wastes between SAAs. But, a single SAA may have multiple points of generation. Once a hazardous waste leaves an SAA, it must be destined for a 90-day accumulation area or a permitted off-site facility for treatment, storage or disposal. Movement or consolidation of hazardous waste within a SAA is permissible, as long as the waste remains “at or near the point of waste generation” and “under the control of the operator of the process generating the waste.” In practice, inspectors have interpreted a laboratory to be single SAA with multiple points of generation.
The EHS Hazardous/Radioactive Material Collection Procedures SOP instructs the laboratory to keep waste in the room that it was generated. We have received a violation for waste being moved to a different location that is not under the control of the operator of the process generating the waste (e.g., moving waste to a common room). This is particularly the case if they have to cross a publicly accessed space (hallway) to get to the storage location. Cite this checklist item if waste is being moved from the room in which it is generated to another room while awaiting pickup by EHS.
The satellite accumulation limits apply to all waste within the laboratory from all points of generation. It would be unusual for a laboratory to have any reason to exceed 55 gallons of waste storage if the lab sending HMCTs when waste containers become full. But, it could be relatively easy to exceed the 1-quart of P-listed limit, considering some of the P-listed materials are relatively common (such as sodium cyanide). Be particularly alert to potential P-listed waste. Cite this checklist item if either the 55-gallon or 1-quart quantity limits are exceeded. If you find a violation of this checklist item, promptly notify the Waste Specialist so the excess materials can be promptly removed. A list of common P-listed chemicals can be found in Appendix A of your Training Manual and is attached here.
The hazardous waste regulations do not specify how long waste cans remain in a SAA (e.g., the lab). Conceivably, wastes could accumulate for several years before the quantity limits are reached. A regulatory concern can arise under this circumstance because of the storage prohibition in the land disposal restrictions, where if a waste is stored for more than one year, then the burden of proof is on the owner/operator to show why this is necessary. At UNL, there should not be any reason why a lab would need to store waste for such a long period of time. With the inherent turnover of students, faculty, and staff, it would be hard to argue that a waste stored for a long period of time would still be “under control of the operator”. Bottom line is that labs should actively and consistently manage their wastes for disposal through EHS. If it appears that the lab is not regularly tagging waste for collection by EHS, cite it under WAS11, other waste management concern.