Satellite Accumulation Points

40 CFR 262.34(c) allows hazardous waste generators to accumulate waste in a 55-gallon container at or near the place of generation. This is known as the satellite accumulation point (SAP) Once the container is full, the generator has 3 days to move it to the central storage area – at which time the usual (90 days or 180 days) accumulation time starts. By the way, you cannot store waste in a SAP for longer than one year in California.

While it is permissble to have more than one SAP if you generate wastes at different locations, it is illegal for waste generator to move waste from one  SAP to another. Doing so would defeat the purpose of having SAPs in the first place – reduce frequencies of waste movement within the plant.

Using your satellite accumulation points (SAP)

Federal and state regulations allow you to accumulate up to 55 gallons of hazardous wastes at the point of generation before moving to your central storage area. Once the 55 gallons limit is reached, you have 3 days to move the waste to the central storage area and that’s when your 90-day or 180/270 day clock starts – depending on your waste generator status. So the SAP concept can extend your storage time limit by quite a bit.

If you are in California, you cannot store waste at your SAP area for more than a year even if you have not reached the 55-gallon limit. 

The operator at the point of generation MUST have total control over the waste. The container at theSAP must have the words “hazardous waste” on it. However, you are NOT required to do weekly inspection of your waste at the SAP area as you would at your central storage area.

Some generators ship their wastes out to the Treatment Storage Disposal Facility directly from the SAP – bypassing the central storage area altogether. This eliminates the possibility of being cited for not having weekly inspection at the central storage area.

Hazardous Waste Violations

On January 7, 2008, the U.S. Environmental Protection Agency issued a press release saying that it has fined Admiral Transportation of City of Industry, Calif., $15,000 for violating federal hazardous waste regulations. The violations uncovered by EPA during an inspection in April 2006 included: 

• Failure to comply with labeling requirements for containers of hazardous wastes;
• Storage of hazardous waste without a permit for a period exceeding 90 days;
• Failure to close hazardous waste containers;
• Failure to submit biennial reports;
• Failure to conduct weekly inspections of hazardous waste areas;
• Failure to properly dispose of hazardous waste.

These are very common hazardous waste violations. Click here for a list of the 13 most common RCRA violations and practical ways you can avoid them. Note that EPA cited the facility for storing hazardous wastes without a permit because the facility exceeded its storage time limit of 90 day. The RCRA regulations are exemption based. You are allowed to do certain things (such as storing hazardous wastes on-site) without the need for a RCRA permit as long as you comply with certain conditions (such as not storing them for more than 90 days if you are a large quantity generator). So as soon as this facility exceeded the storage time limit, the exemption became invalid and it was operating a Treatment Storage and Disposal Facility (TSDF) without a permit. 

Another violation was on failure to conduct weekly inspection of the waste storage area. This too is a very commonly cited violations. One way to ensure compliance with this requirement is to make sure your weekly checklist is simple to fill out and the person who is responsible for doing it has some ownership of it. Make sure that person understands why this must be done every week. And if you discover any discrepency during your inspection, make sure you have a procedure to correct these problems in a timely fashion. Here is a sample checklist that is simple. 

Note that it is rather unusal for EPA Region 9 to be involved in enforcement action in California. The common practice is for the local agencies to get involved first. There may have been other circumstances that led to EPA’s involvement.