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 after a limit is exceeded to move waste to a CAA. The 90/180-day clock begins when 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 1,000 kg (2,200 lbs) or more per month, you have 90 days. Day 0 is the date waste first entered the container.

Small Quantity Generators (SQG)

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

The "3-Day" SAA Rule

When an SAA limit is exceeded, you have 3 calendar days to move excess waste to a CAA. The storage clock starts once 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 can subject your facility to hazardous waste storage permitting rules. As of January 8, 2025, EPA civil penalties can reach $93,058 per day, per violation — and EPA may cite overdue containers without first issuing a warning.

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

For Central Accumulation Areas (CAA), the clock starts when waste first 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 limit (55 gallons non-acute, 1 quart liquid acute, or 1 kg solid acute) 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 prevent timely removal. SQGs have a similar option under 40 CFR 262.16(d).

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 waste is shipped 200 miles or more for off-site treatment, storage, or disposal). 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 marked or labeled on the container and visible for inspection under the SQG and LQG accumulation rules. Retroactive dating (e.g., waiting until the drum is full) can significantly increase penalty risk.

Is the calculator methodology available?

Yes. This tool uses TypeScript helpers based on selected federal EPA RCRA generator and accumulation rules. The implementation is available on GitHub.

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