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operation. Further, generators are allowed to accumulate <br /> hazardous waste on-site in tanks or containers for up to 90 <br /> days without being required to obtain interim status or a <br /> permit (40 CFR 262.34). It should be noted,however, that <br /> 90-day generators must comply with the technical standards of <br /> Part 265, Subpart J (for tanks), and Subpart I (for <br /> containers), as well as certain emergency response and <br /> personnel training provisions. If the accumulation period <br /> before the waste is introduced into the recycling unit exceeds <br /> 90 days, the generator will need to obtain interim status or a <br /> permit for such storage. <br /> Wastes or residues from recycling activities are <br /> considered to be newly generated wastes and therefore are also <br /> allowed a 90 day accumulation period without a permit. Note <br /> that these wastes are also "derived from" wastes and are <br /> assigned the same EPA waste codes as the spent solvent from <br /> which they are derived (40 CFR 261.3 (c)(2)(i)). <br /> You also indicate in your letter that ETG will not be <br /> subject to the Part 268 land disposal restriction requirements <br /> since a permit is not required. However,you should note that <br /> the Part 268 standards apply independent of the permit program, <br /> and any such requirements that are applicable to a particular <br /> waste (e.g.,the solvent still bottoms) must be compiled with <br /> regardless of the §262.34 accumulation provision. <br /> I hope this information will be helpful to you. If you <br /> have further questions please feel free to call Frank McAlister <br /> at (202) 382-4740. <br /> Sincerely yours, <br /> Original Document signed <br /> Joseph S. Carra <br /> Director <br /> Permits and State Programs Division <br /> RO 13280 <br />