EP A5 3 0-R-03 -002f
RCRA, SUPERFUND & EPCRA CALL CENTER MONTHLY REPORT
June 2003
1. Start Dates on Large Quantity Generator Tanks
A large quantity generator (LQG) accumulates hazardous waste in both tanks and containers.
The generator labeled each container with the date upon which the accumulation period began
in accordance with 40 CFR Section 262.34(a)(2). Must this LQG also mark the accumulation
start date on tanks that are used to accumulate hazardous waste?
The LQG must also mark hazardous waste accumulation tanks with the date upon which the
hazardous waste accumulation period begins. Although this requirement is not cited in Section
262.34(a)(2), EPA intended for both tanks and containers to be marked with accumulation start
dates (51 FR 10146, 10160; March 24, 1986). This requirement ensures that LQGs accumulate
hazardous waste in accordance with the 90-day accumulation time limit.
RO 14683

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