Satellite Accumulation—An Area of Concern for Hazardous Waste Generators

Yesterday we discussed some common hazardous waste container violations inspectors often uncover when inspecting hazardous waste generator facilities. Today we will take a special look at problems generators incur when using satellite accumulation areas.

Note. Many states’ hazardous waste container requirements are stricter than the federal regulations. Always make sure that you are in compliance with your state hazardous waste regulatory requirements.

If you are a hazardous waste generator, you are more than likely storing waste in containers without a permit pending the waste being shipped off-site. However, as a generator, you know that some wastes may accumulate very slowly. If you were required to ship 90 or 180 days from the date you first put waste in the container, you would be shipping a container holding a very small amount of waste.

To eliminate this situation, you can designate the container a satellite accumulation container. Satellite accumulation allows a hazardous waste generator to slowly accumulate up to 55 gallons (gal; 550 pounds (lb)) of nonacute hazardous waste and/or either 1 quart of liquid acute hazardous waste or 1 kilogram (kg; 2.2 lb) of solid acute hazardous waste provided that specific requirements are met. The containers must be “at or near any point of generation where wastes initially accumulate which is under the control of the operator of the process generating the waste for an unlimited amount of time” (40 CFR 262.15).

Often found violations of satellite accumulation area (SAA) requirements include:

• The absence of operator control of the process generating the waste;
• Failure to list the date the satellite container reaches its accumulation limit; and
• Failure to remove the waste from the SAA within 3 days of exceeding the quantity limitations.

Operator Control

The U.S. Environmental Protection Agency (EPA) provided some guidance concerning what “operator control” means in the preamble of the new Hazardous Waste Generator Improvements Rule. It means if the operator:

• Controls access to an area, building, or room that the SAA is in, such as with entry by access card, key, or lock box; or
• Accumulates waste in a locked cabinet and controls access to the key, even if the cabinet is stored inside a room to which access is not controlled.

Accumulation Limit Date

The accumulation start date for satellite accumulation is the date the drum is filled. You have 3 consecutive calendar days from this date to move the drum to your permanent storage area and 90 to 180 days from this date (depending on your generator size) to move the waste off-site.

Time Limit for Removing Exceeded Waste

When you exceed the specified accumulation limits for nonacute or acute hazardous waste accumulated in the SAA, you must either:

• Comply with the central accumulation area (CAA) requirements that apply to your generator size within 3 consecutive calendar days; or
• Remove the excess waste from the SAA within 3 consecutive calendar days to:
  • Your facility’s CAA;
  • An on-site interim status or permitted treatment, storage, and disposal facility (TSDF); or
  • An off-site designated facility (e.g., TSDF).

During the 3-consecutive-calendar-day period, you must continue to comply with the SAA accumulation standards. Be sure to mark any container holding the excess accumulation of hazardous waste with the date the excess amount began to accumulate.