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Page 4 of 9 Answer : Three days means three consecutive days. It does not mean three working days or three business days. Originally, the Agency had proposed to use 72 hours as the time limit but realized that determining when 72 hours had elapsed would have required placing both the date and time of day on containers. In the final rule the Agency switched to using three days so that generators only need to date containers that hold the excess of 55 gallons of hazardous waste (or 1 quart of acute hazardous waste).3 4. Question : If an SAA has a full 4-gallon container of hazardous waste, does the generator have to remove the container from the SAA within three days of being filled? Answer : No. There is no federal requirement that full containers of hazardous waste be removed from an SAA within three days of being filled. Only the excess of 55 gallons of hazardous waste (or the excess of 1 quart of acutely hazardous waste) must be removed within three days. 5. Question : The container management standards of 265.173(a) state, "A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste." Does this mean that hazardous wastes have to be managed and/or disposed in the containers in which they were originally accumulated? Answer : No. Generators may transfer hazardous waste between containers to facilitate storage, transportation, or treatment.4 For example, a generator may wish to consolidate several partially full containers of the same hazardous waste from an SAA into one container before transferring it to a central accumulation area. Generators also may transfer hazardous waste between containers in central accumulation areas. However, the 90-day or 180-day "clock" for accumulation does not restart if the hazardous waste is transferred to another container. 6. Question : Do containers in SAAs have to comply with the air emission standards of Part 265 Subparts AA, BB, and CC? Answer : No. Containers in SAAs are not required to comply with the air emission standards of Part 265 Subparts AA, BB, and CC.5 Likewise, SQGs are not required to comply with the air emission standards at their 180-day accumulation areas. LQGs, however, are required to comply with the RCRA air emission standards at their 90-day accumulation areas. Therefore, when an LQG transfers waste from an SAA to a 90-day central accumulation area, the applicable portions of the air emission standards of Part 265 Subparts AA, BB, and CC must be met at the 90-day central accumulation area. https://yosemite.epa.gov/osw/rcra.nsf/documents/8c9f6dc8b378a2f585256e9900723a8b 10/4/2016