Guidelines for HW Satellite Accumulation Areas
Many small and large quantity generators (SQG and LQG) produce hazardous waste (HW) in multiple locations throughout their facility. This waste can then be sent to a central storage location or can be stored in small amounts in areas called hazardous waste satellite accumulation areas. The EPA defines a satellite accumulation area (SAA) as a hazardous waste storage location 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.
SAAs provide flexibility to generators that accumulate waste in various locations. However, the convenience of SAAs comes with a small regulatory burden. Below is a list of requirements for SAA’s as stated in 40 CFR 262.15.
Volume:
- Generators can accumulate up to 55 gallons of HW in an accumulation area.
Containers:
- The container holding the waste must be in appropriate and in good condition (40 CFR§ 265.172)
- If a container begins to leak, the generator must transfer the hazardous waste into a container that is in good condition and move it to the central accumulation area for disposal.
- The container must always remain closed unless actively adding, removing, or consolidating waste.
- The container must be labeled with the words “Hazardous Waste”, an indication of the contents, and an indication of the hazard(s) of the contents.
- Examples of hazard identification include but are not limited to, DOT and NFPA hazard labels.
*For additional information on DOT and NFPA labeling see 49 CFR 172 E and 29 CFR 1910.1200 respectively.
Incompatible Wastes:
- Incompatible wastes cannot be placed in the same container.
- Hazardous waste must not be placed in an unwashed container that previously contained hazardous waste.
- Containers holding incompatible wastes must be separated from each other by any practical means.
*For additional information on incompatible wastes, see 40 CFR 265 appendix V.
Removal/Disposal:
- Once the generator has determined the SAA full or ready to be disposed of, the containers must be moved to the appropriate area within 3 consecutive calendar days (72 hours). In the event that a container is not full but has a generation date on the HW label, the container must be removed from the SAA within 3 consecutive calendar days as well.
- The waste can be taken to a central accumulation area, an on-site interim status or permitted treatment/disposal facility, or an off-site treatment/disposal facility.
FAQs:
Q: How many waste streams can be present in an SAA?
A: There is no limit to the number of waste streams that can be present in an SAA. However, the volume limit remains the same. A maximum of 55 gallons per waste stream may be present.
Q: Can you move hazardous waste from one SAA to another?
A: No, SAA containers or the contents of the containers can only be moved to the central accumulation area.
Q: How long can waste be accumulated at a satellite accumulation point?
A: One year.
For more information about HW SAAs or HW compliance items, free to reach out to Carter Venable at Carter@StevensEHS.com to get started
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