Pam,
As mentioned, your first step is to determine if you are a Large Quantity Generator, Small Quantity Generator, or a Very Small Quantity Generator. The rules get more restrictive and more complicated as you move up in status.
Here is some guidance I provide to my Satelite Accumulation Areas (CAA's), specifically laboratories. IT IS IMPORTANT TO NOTE THAT MICHIGAN HAS NOT YET ADOPTED THE EPA GENERATOR IMPROVEMENT RULES so my guidance is Michigan specific, especially for Labeling.
Jeff
Following these four rules while managing wastes in your Satellite Accumulation Area (SAA) aka, your lab, will go a long way towards keeping us in compliance with the Michigan Department of Environment, Great Lakes, and Energy (EGLE) formally the Department of Environmental Quality (DEQ):
The four L's of hazardous waste -
Labels, Leaks, Lids, Location
Labels - Hazardous waste containers have very specific EGLE labeling requirements while in the SAA. The container must be labeled with:
- The words "Hazardous Waste"
- AND either the chemical contents (spelled out)
- OR the EPA waste codes. Adding the EPA codes, shows we've done a waste characterization (a waste characterization is required at the TIME OF GENERATION with documentation kept on file for 3 years).
Leaks - Compatible hazardous wastes must be collected in compatible containers in good condition.
- Leaking containers must be replaced.
- Waste containers should be stored in secondary spill containment.
Lids - Collection containers must be closed when not adding wastes.
- NO funnels sitting in an open waste carboy or bottle. A funnel that screws onto the bung with a lid that clips closed is acceptable, as long as it is only open when waste is being added.
- Tubing that feeds wastes into a container directly from the equipment needs to be sealed as well (with provisions for pressure relief).
- When the waste container is picked up the lid must be leakproof.
Location - EGLE states "
It is permissible to accumulate ... container(s) at the point of
generation as long as the operator has control of the processes generating the waste."
- The waste container needs to stay near the waste source; it may NOT be stored in another room.
- There is no time limit for accumulation as long as the waste is being regularly added to the container. If you have had a waste container for longer than 365 days, review whether it is "actively" being used or if it should be removed. (Note this is different than our Small Quantity Generator rules which require our Central Accumulation Area to be cleaned out every 180 days).
- Please request a pickup when the lab has accumulated 5 gallons of waste unless you've received prior permission to accumulate more than one 5-gallon container at a time.
- If you accumulate 55-gallons of a specific waste we have 3 calendar days to move it to the Central Accumulation Area.
