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Counting Hazardous Waste Accumulation for Generator Status – Satellite Accumulation Areas

Counting Hazardous Waste Accumulation for Generator Status – Satellite Accumulation Areas

The US EPA regulations that allow for the management of hazardous waste in Satellite Accumulation Areas (SAA’s) provides great flexibility to hazardous waste generators who are able to take advantage of the regulations at 40 CFR 262.34(c).  Benefits include:

  • No on-site accumulation time limit (check with your State to confirm this).
  • No requirement for weekly inspections of SAA’s.
  • Training not required for facility personnel who work only at SAA’s.
  • RCRA air emission standards at 40 CFR 265, Subpart AA, BB, & CC don’t apply.

That should be enough, but some mistakenly think that there is one more benefit:  The hazardous waste accumulated in SAA’s does not count toward your monthly hazardous waste generator status determination.  This is mistaken.  Hazardous waste in SAA’s does count towards your monthly hazardous waste generator status; here’s why:

A generator of hazardous waste is required to count all the hazardous waste generated in their facility in a calendar month to determine their generator status unless specifically exempted.  Wastes that are not required to be counted towards generator status are identified in 40 CFR 261.5(c) and in a past article of mine:  Counting Hazardous Waste to Determine Generator Status.  Hazardous wastes accumulated in SAA’s are not included in this list of excluded wastes and must therefore be included in your monthly determination of your hazardous waste generator status (RO 14703 – #12 of the FAQ’s).

Determination of your hazardous waste generator status is an early important step.  If you are a Large Quantity Generator of hazardous waste (LQG) you must also train facility personnel annually to ensure compliance with the RCRA regulations.  Contact me for a free consultation of your RCRA & DOT HazMat Employee training needs.