National
Environmental
PerformanceTrack
U.S. Environmental Protection Agency
National Environmental Performance Track
RCRA Benefit Fact Sheet
Extended Storage Time for Large Quantity
Generators
What is Performance Track?
The U.S. EPA's National Environmental
Performance Track program is a public-private
partnership that recognizes and drives
environmental excellence. The program
encourages public and private facilities with
strong environmental records to continuously
improve their environmental performance
beyond regulatory requirements while working
collaboratively within their communities.
A core value of Performance Track is that
facilities that demonstrate environmental
leadership should be treated differently from
other facilities in order to encourage greater
environmental innovation and set a positive
example for others to follow.
To foster continuous improvement,
Performance Track offers its members public
recognition and opportunities for regulatory and
administrative benefits that reduce reporting
requirements and other administrative costs,
while maintaining or enhancing existing levels
of environmental protection.
Performance Track RCRA Benefit -
Extended Storage Time for Large Quantity
Generators
Published on April 22, 2004 (69 FR 21737),this
rule provides a benefit under EPA's Resource
Conservation and Recovery Act (RCRA) that
extends on-site storage times for large quantity
generators of hazardous wastes up to 180 days
(and 270 days if the waste is transported 200
miles or more) for the purpose of accumulating
hazardous waste without a RCRA permit or
interim status. As a result, facilities will be able
to reduce the frequency of waste shipments
and the risks associated with shipping waste
through local communities. This fact sheet
provides a summary of this Performance Track
member benefit; for complete information, the
reader is encouraged to read the rulemaking,
which may be found at
http://www.epa.gov/fedrgstr/EPA-
WASTE/2004/April/Dav-22/f9042.htm .
In order to take advantage of this benefit,
Performance Track facilities must adhere to the
following requirements:
D The waste must be managed in
containers, tanks, drip pads, or
containment buildings, in
accordance with the applicable
RCRA requirements, and the
quantity of hazardous waste must
not exceed 30,000 kilograms.
D The generator must maintain
records at the facility for each unit
used for extended accumulation
times and document compliance
with all procedures.
D Each container or tank must be
clearly marked and visible for
inspection with the words
"Hazardous Waste," and the date
upon which each period of
accumulation begins.
D The generator must comply with the
requirements for owners and
operators in 40 CFR Part 265, with
§265.16, and with §268.7(a)(5), and
is exempt from all the requirements
in subparts G and H of part 265,
except for §§265.111 and 265.114.
D The generator must also implement
pollution prevention practices prior to
its hazardous waste recycling,
treatment, or disposal.
D The facility must also complete EPA
Form 8710-17 as part of its
Performance Track Annual
Performance Report, which must be
submitted to the EPA Regional
Administrator and the Director of the
authorized State. The information
must include the total quantity of
each hazardous waste generated,
how it has been managed, the
number of off-site shipments, the
types and locations of destination
facilities, how the wastes were
managed at the destination facilities
(e.g., recycling, treatment, storage,
or disposal), any changes in on-site
or off-site waste management
National Environmental Performance Track RCRA Benefit Fact Sheet
Extended Storage Time for Large Quantity Generators
Updated February 3, 2009
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practices as a result of extended
accumulation times or other pollution
prevention provisions, and any
hazardous waste spills or accidents.
What is the Effective Date?
As with all RCRA regulations, state must first
adopt and become authorized before facilities
may use the extended storage benefit. The
effective date for this rule was April 22, 2004;
however, the effective date for each state will
be different, depending upon when the state
adopts and becomes authorized for the rule.
Interested facilities should contact their states
for more information.
Correction to this Rulemaking
On October 25, 2004, EPA published a
correction to the extended accumulation rule
published on April 22, 2004. The correction
notice clarifies that a facility must notify both the
EPA Regional Administrator and its state
permitting authority should the facility wish to
take advantage of the extended accumulation
time. The correction notice also makes three
minor corrections to the regulatory language as
well as makes several typographical
corrections. The text of this correction notice
may be found at http://www.epa.gov/EPA-
WASTE/2004/October/Dav-25/f23842.htm .
How Do Members Take Advantage Of This
Benefit?
D Member facilities must submit prior
written notice to the EPA Regional
Administrator and the Director of
their state permitting authority of
their intent to extend hazardous
waste accumulation time. Notices
must identify the generator and
facility, state when extended
accumulation will begin, describe the
wastes to be accumulated, list the
units that will be used for that
purpose, and state that the facility
has made all the changes to it
operations, procedures and
equipment necessary to
accommodate the extended time
periods for accumulating hazardous
wastes. The facility must use EPA
Form 8710-18 to notify its intent to
extend accumulation. The form is
available here. For generators who
intend to accumulate for up to 270
days because required transport is
more than 200 miles, the notice
(Form 8710-18) must contain a
certification that an off-site permitted
or interim status treatment, storage,
or disposal (TSD) facility capable of
accepting the waste is not located
within 200 miles.
D EPA recommends that once the
extended accumulation time has
been approved by the authorized
state, the member facility post a sign
at the large quantity generator
storage area indicating they are a
Performance Track facility and have
been approved to store hazardous
waste up to 180 days (or 270 days if
applicable). Further, the facility
should keep in their operating record
any documentation associated with
the extended accumulation time so
that it is readily available to an
inspector.
D If a generator who is a member of
the Performance Track Program
withdraws from the Performance
Track Program, or if the Regional
Administrator terminates a
generator's membership, the
generator must return to compliance
with all otherwise applicable
hazardous waste regulations as
soon as possible, but no later than
six months after the date of
withdrawal or termination.
For More Information Contact:
Mr. Christopher Menen
202-566-2836
menen.chris@epa.gov
http://www.epa.gov/performancetrack
National Environmental Performance Track RCRA Benefit Fact Sheet
Extended Storage Time for Large Quantity Generators
Updated February 3, 2009
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