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Common Violations in Hazardous Waste Satellite Accumulation Areas

Common Violations in Hazardous Waste Satellite Accumulation Areas

The US EPA regulations at 40 CFR 262.34(c) – known as the Satellite Accumulation Area (SAA) regulations even though the word “satellite” is not used – are designed to allow a generator of hazardous waste to accumulate a limited amount of hazardous waste onsite for an unlimited period of time.  This can be done without regard to the accumulation time limits for their respective generator status:

  • Large Quantity Generator (LQG) of hazardous waste:  ≤90 days for onsite accumulation/storage of hazardous waste.
  • Small Quantity Generator (SQG) of hazardous waste:  ≤180 days for onsite accumulation/storage of hazardous waste.

A Conditionally Exempt Small Quantity Generator (CESQG) of hazardous waste is allowed to accumulate hazardous waste onsite for an unlimited period of time and therefore would likely find no use for an SAA.

Advantages to accumulating hazardous waste in Satellite Accumulation Areas:

  • May accumulate hazardous waste onsite for an unlimited period of time.  Check with your State however; Missouri is one I am aware whose SAA regulations contain more restrictions than the Federal.
  • Not required to conduct a weekly inspection.
  • Not required to comply with the RCRA air emission standards of §265, Subparts A, B, & C.
  • Annual training is not required for facility personnel whose only exposure to hazardous waste is in SAA’s.
  • May be more than one container and may be more than one type of hazardous waste.
  • No limit to the number of SAA’s or total waste accumulated in SAA’s facility-wide.

Restrictions and requirements for using Satellite Accumulation Areas:

  • Limited to ≤55 gallons of hazardous waste per SAA.
  • May accumulate hazardous waste solely in containers as defined at §260.10.  Accumulation in tanks, containment buildings, or drip pads is not allowed.
  • Container must be labeled “Hazardous Waste” or other words to identify the contents, eg:  “Paint & Solvent Waste”.
  • Container must be closed except when adding or removing waste.
  • Container must be at or near the point of generation where waste initially accumulates; and,
  • Under the control of the operator of the process generating the waste.
  • When the limit of 55 gallons is reached:  (1) date the container.  (2)  three calendar days to move the container to a Central Accumulation Area (CAA or 90/180 Day Accumulation Area).

The Top 5 Satellite Accumulation Area violations:

  • Failure to keep the container closed except when adding or removing hazardous waste.
  • Failure to mark the container with the words, “Hazardous Waste” or other words describing the contents.
  • Container is not at or near the point of generation.
  • Storing >55 gallons of hazardous waste.
  • Not dating a container with hazardous waste above the 55 gallon threshold.
  • Not moving a dated container from the SAA to a CAA within 3 calendar days.  Note:  this is not 3 business days, and it is not 3 twenty-four hour periods.

Check with your State to ensure compliance.  Or, contact me with questions about management of hazardous waste in SAA’s, CAA’s, or in general.