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Hazardous Waste Management At 90 Day Hazardous Waste Storage Facilities

A 90 Day Hazardous Waste Storage Facility is an area at which hazardous chemical waste can be accumulated for a limited amount of time without a permit. All waste containers must have accumulation start date and be labeled as Hazardous Waste. Moreover, no waste container should remain in the storage beyond the 90 days including the first day waste was placed in the container.

The satellite accumulation point, on the other hand, is an area at or near the point of generation where waste is initially accumulated and which is under the control of the operator of the process generating the waste; practically every research laboratory where chemical waste is generated.

  • EPA has set the following management standards for hazardous wastes collected at a 90 day hazardous waste storage facility:
  • Containers must be in good condition.
  • The waste being placed in the container must be compatible with the container
  • Containers must be marked with the words HAZARDOUS WASTE and contents.
  • Date when accumulation started must be clearly marked on the label
  • Container must be properly managed to avoid releases
  • Containers must be kept closed at all times except when adding or removing waste.
  • All incompatible wastes must be separated
  • Container and area must be inspected weekly
  • Records of inspection shall be maintained by the operator
  • The operator must be trained in waste management
  • Filled containers must be disposed off properly within 90 days from the time accumulation started (Fill out Waste Disposal Form when container is 90 % full and call EH&S for disposal)
  • Preparedness and prevention plan must be prepared and kept in the area
  • Contingency plan should also be prepared and kept in the area

To ensure that the facility is kept in good condition, RCRA regulations require that the storage area be inspected weekly for the following items.

  • Any leaks, spills and deterioration caused by corrosion or other factors
  • Any bulging of filled containers
  • The presence of word "Hazardous Waste", contents and approximate percent of each content on the label
  • The presence of a working fire extinguisher and telephone in the area
  • The presence of an adequate spill control kit and procedures
  • Inspection records should be maintained onsite for at least three years from the date of the inspection. (You can use the attached log for inspection and record keeping).

The following precautions are required at a 90 day hazardous waste storage facility to prevent container ruptures and leaks:
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  • Do not completely fill a container (Call EH&S (305[5]-6780) for disposal when container is 90 percent full)
  • Protect container from freezing or exposed to excessive heat
  • Ground ignitable hazardous waste to prevent spark generated by static electricity from igniting flammable vapor that may be present
  • Handle drums and other containers with equipment designed for the task
  • Use drum carts designed for the type of containers used by the facility to reduce the likelihood of dropping a container during handling

A 90 Day Hazardous Waste Storage Facility must also be in compliance with the New York City Fire Department (NYCFD) codes. Call EH&S to find out more about these.