Free Tool

RCRA Storage Deadline Calculator

Calculate your exact 90-day, 180-day, or 270-day hazardous waste deadline from the accumulation start date, with built-in CAA/SAA logic and a live countdown.

Date the first drop of waste entered the container.

When does the clock start?

For CAAs, the clock starts the moment waste first enters the container.

For SAAs, you have 3 days to move a full container to the CAA. The 90/180-day clock begins the moment it is moved or the 3-day window ends.

Example shown

Shipment Deadline:

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-- days remaining
-- days elapsed -- day limit

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Understanding the RCRA 90-Day Rule

Don't let administrative errors lead to six-figure EPA fines. Here is how the accumulation time limit works.

Large Quantity Generators (LQG)

If you generate more than 1,000 kg (2,200 lbs) per month, you have 90 days. Day 0 is the date waste first entered the container.

Small Quantity Generators (SQG)

If you generate between 100 kg and 1,000 kg per month, you have 180 days (or 270 if shipping >200 miles).

The "3-Day" SAA Rule

When an SAA container is full, you have 3 calendar days to move it to a CAA. The storage clock starts the moment it arrives.

Frequently Asked Questions

Common questions about RCRA accumulation time limits.

What happens if I miss the 90-day deadline?

Exceeding the 90-day limit means your facility is technically operating an unpermitted hazardous waste storage facility (TSDF). As of January 8, 2025, EPA civil penalties can reach $93,058 per day, per violation — and inspectors do not issue warnings before citing overdue containers.

Does the storage clock start when the drum is full or first used?

For Central Accumulation Areas (CAA), the clock starts the exact moment the first drop of waste enters the container — not when it is sealed or full. For Satellite Accumulation Areas (SAA), the 90/180-day clock does not start until the volume limit (55 gallons for non-acute waste, 1 quart for acute waste) is exceeded.

Can I get an extension on the 90-day limit?

Yes, but only under strict conditions. Under 40 CFR 262.17(b), LQGs may apply to the EPA Regional Administrator for a 30-day extension if unforeseen, temporary, and uncontrollable circumstances (e.g., a TSDF shutdown, major weather event) prevent timely removal. The request must be submitted before the 90-day deadline expires.

Does the 90-day rule apply to Small Quantity Generators?

No. SQGs are allowed 180 days under 40 CFR 262.16 (or 270 days if the nearest appropriate TSDF is more than 200 miles away). Only LQGs — facilities generating 1,000 kg or more of hazardous waste per month — face the strict 90-day limit.

What does "Day 0" mean for the accumulation clock?

Day 0 is the Accumulation Start Date — the day waste first enters the container in a Central Accumulation Area. This date must be physically written on the container label that same day. If the label is dated retroactively (e.g., when the drum was full), it is a falsified record and can significantly increase penalty severity during an inspection.

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