A few words about “satellite accumulation area”

Have you ever been in a situation where you find yourself lugging buckets of hazardous waste from the place where your generate it to your central storage area? There is a much easier way around this problem. It is called the satellite accumulation area (SAA).

There is a rule under EPA’s RCRA regulations that allows you to accumulate up to 55 gallons of hazardous wastes at or near the point of generation without “activating” the 90-day or 180-day storage time limit. That’s your SAA. You can have more than one SAA but each one cannot have more than 55 gallons. So if you are generating two incompatible waste streams at one location, you can have two separate containers to accumulate the two wastes but the total volume cannot be more than 55 gallons. (Note: If you have acute hazardous wastes, the total volume at your SAA is one quart.)

To take advantage of this special rule, you must following a few requirements:

First of all, the SAA must be “at or near the point of waste generation” and also “under the control of the operator of the process generating the waste.” The commonly accepted interpretation of the phrase “under the control of the operator” is that the waste container must be in the line of sight of the operator . That’s also EPA’s interpretation. If the waste has to be stored out of sight of the operator due to safety reason – say in a shed outside the building but near the place of generation – then access to the shed must be through a lock controlled by the operator.

The container must also be in good condition (40 CFR 265.171) and wastes stored at the SAA must be compatible (40 CFR 265.172) and the containers must be kept closed (40 CFR 265.173 (a)).

The requirement to keep container “closed” except when adding or removing waste is a problematic one for many generators. The rule says that “a container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste”. It does not specifically define the word “closed”.  However, when EPA came up with the rule back in 1980, it intended the word “closed” to mean “vapor tight and spill proof”. So if you screw a large funnel into the bunghole of a container and pour your waste into the drum through the funnel, is that vapor tight and spill proof? If you are storing some highly volatile solvents in the container, is that funnel system vapor tight? If the container gets tipped over, is the funnel system spill proof? Whether you will be cited depends on the content in your container and your state inspector’s interpretation of the word “closed”.  To be on the safe side, you may want to consider putting a shut-off valve between your funnel and the drumhead.

The container should also be labeled “hazardous waste”.

Once the 55-gallon container is full (or the 55 gallon limit is reached if you have more than one container), you have three days to move any excess waste to your central storage area where you will start your regular 90 or 180 days storage time limit. That’s what the regulations say. In reality, it means that unless you remove your 55 gallons from your SAA – either to your central storage area or directly to a final treatment and disposal facility – you will not be able to accumulate any more waste in your SAA for longer than 3 days. So that’s what most people do. They move the 55 gallons to the central storage area and start accumulating in the SAA anew. The net effect is that the SAA extends your on-site accumulation time for the 55 gallons by a significant amount.

Note; If you are in California, state rule (Title 22 CCR 66262.34 (e)(1)(B)) limits the time you can keep your waste at the SAA to one year or when the 55 gallons volume is full – whichever comes first. That is just one of the many additional state environmental requirements you have to live with for being in California.

Another benefit of the SAA is that you do not need to conduct weekly inspection at the site as you do at your central storage areas. (By the way – failure to conduct weekly inspection at the central storage area is one of the most frequently cited CRA violations.) Some generators actually ship their wastes that have been accumulated at the SAA directly out the door thereby skirting the weekly inspection requirement altogether. The disadvantage of this arrangement is the additional shipping costs.

There is an excellent EPA guidance document on this topic.

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