Satellite Accumulation
LQGs and SQGs may accumulate up to 55 gallons (gal) of hazardous waste or 1 quart (qt) of acutely hazardous waste in containers at or near any point of generation where the wastes initially accumulate and away from the generator’s central storage area for an unlimited amount of time if certain conditions are met. Storing waste away from the central storage area is referred to as “satellite accumulation.” Satellite accumulation time standards require the generator to (40 CFR 262.34(c)(2)):
- Keep the containers under the control of the operator of the process generating the waste
- Label each container as “Hazardous Waste” or with other words to identify the container’s contents (e.g., “spent toluene solvent” or “green tank waste”).
- Comply with the use and management of container regulations found at 40 CFR 265.171, 40 CFR 265.172, and 40 CFR 265.172(a) (i.e., the container must be in good condition, compatible with the hazardous waste placed in it, and always closed except when adding or removing waste).
- Mark the container with the date that the 55-gal or 1 qt limit was reached before transferring it from the satellite accumulation area.
- Transfer the waste, once the 55-gal or 1-qt level has been reached, within 3 days to a container in the central storage area, or send the waste off-site for additional treatment, storage, and disposal.
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Satellite accumulation is intended by EPA for industries that generate small amounts of hazardous waste in numerous locations at a facility. It allows generators to accumulate small amounts of hazardous waste until the 55-gal or the 1-qt limit has been reached. Once the quantity limit is reached, the generator has 3 days to move the container to the facility’s central accumulation area where it can remain for the applicable amount of time (90 days for LQGs; up to 180 or 270 days for SQGs.).
On-Site Storage Management
While the accumulation rule sets forth specific requirements applicable to LQGs and SQGs, individually (not discussed here), the rule also requires both classes of generators to comply with the following requirements:
Hazardous waste determination. While not specifically mentioned in the accumulation time rule, determining whether a generated waste is hazardous is key to determining what class of generator you are and, in the case of SQGs, whether you have surpassed the quantity restrictions of the accumulation rule. All generators who manage hazardous waste on-site must make this determination. Generators determine whether their waste is hazardous by: reviewing the EPA lists in Subpart D of 40 CFR 261 to see if the waste in question has been identified by EPA as a hazardous waste, by sampling and analyzing the waste for hazardous characteristics, or by using judgment and knowledge of the waste. If the waste is hazardous and has not been excluded from hazardous waste regulations under 40 CFR 261.4, then the generator must manage the waste in compliance with applicable regulations, including those for storing hazardous waste on-site without a permit.
Identification and labeling. All containers must be marked with the date the storage period began (which must be visible for inspection). Although not specified in the rule, EPA also requires that all tanks be marked with the date that the storage period began. Both containers and tanks must be labeled or marked clearly with the words “Hazardous Waste.”
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EPA ID number. All generators that generate more than 100 kg of hazardous waste per month are required to have an EPA identification (ID) number. Some states may also require CESQGs to obtain an EPA ID number.
Preparedness and prevention plan. Generators must comply with the interim-status preparedness and prevention requirements under 40 CFR 265, Subpart C. These requirements specify emergency equipment and require that the facility have response team available to respond to a fire, explosion, or release of hazardous waste.
Land disposal restrictions (LDRs). Generators must determine if the hazardous waste must be treated before it can be land disposed, thereby making it subject to all applicable LDRs of 40 CFR 268. For example, LQGs and SQGs that manage and treat prohibited waste or contaminated soil in tanks, containers, or containment buildings in order to meet applicable LDR treatment standards of 40 CFR 268.40 must develop and follow a written waste analysis plan that describes the procedures they will carry out to comply with the treatment standards. The waste analysis plan must comply with the requirements set forth at 40 CFR 268.7(a)(5) (40 CFR 262.34(a)(4), 40 CFR 262.34(d)(4), and 40 CFR 268.1(b)).