The EPA regulations for the management of hazardous waste in “Satellite Accumulation Areas”, which, incidentally doesn’t define or use the term “Satellite Accumulation Areas” can be found at 40 CFR 262.34(c).  Here we learn the seven most important requirements to maintain compliance:

1. No more than 55 gallons of hazardous waste or one quart of acutely hazardous waste.
2. In containers.
3. At or near the point of generation where the waste initially accumulates.
4. Waste is under the control of the operator of the process generating the waste.
5. Comply with 40 CFR parts:  265.171 – Condition of Containers, 265.172 – Compatibility of Waste with Container, and 265.173(a) – Closed Container.
6. Mark container with the words “Hazardous Waste” or other words that identify the contents (ie. Waste Flammable Paint).
7. When volume threshold from #1 is reached, generator has three (3) days to comply with applicable regulations as a generator of hazardous waste (either large quantity generator or small quantity generator).

#7 stated another way:  When the volume threshold is reached the container must be closed, labeled “Hazardous Waste” and the date marked on the container.  Within three days the container must be moved to the Central Accumulation Area (aka:  90/180 day accumulation area).  What is meant by “three days”?  Pursuant to RCRA On-Line FAQ’s:

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).

So, as an example, today is Thursday, May 10th and sometime tonight on second shift a container in an SAA reaches the 55 gallon threshold.  The operator, being properly trained and informed, closes the container, marks the date (4.10.12) on the exterior, and goes home.  If the container is not moved to the CAA on the 11th, by the time you arrive for work on Monday May 14th – only two business days later, but four consecutive days – you’ve got yourself a violation of the regulations.

It’s little things like this that can be misunderstood and result in violations.  It is these aspects of the regulations that I pride myself on covering in my RCRA Training for Hazardous Waste Personnel.  I perform the same service for HazMat Employees who require triennial training by the DOT.  Whether it’s public/open enrollment or on-site, I can provide the training you need in one day.