Satellite Accumulation Quantity, Number of Containers & Diversified Waste

Background:

Satellite Accumulation Areas (SAA) are used in most industrial facilities. These accumulation areas must be at or near the point of generation, and under the control of the operator. The number of containers is not limited as long as the total volume of waste does not exceed the 55-gallon limit. This is total waste not any one waste. Waste containers must be compatible with the waste, kept in good condition, and labeled with the words “Hazardous Waste” or words that identify the contents of the container. Also the containers must be kept closed except when adding or taking away materials. These rules apply to areas where multiple containers are in the area.

Discussion

While state agencies can have more stringent requirements in the federal regulations. The requirements for SAA are fewer than for <90 style=""> In RCRA Online Memo 14703, “Frequently asked Questions about Satellite Accumulation Areas”. In this document the EPA has stated:

“In contrast, additional requirements for SAAs are limited to:

1. Generators must label satellite containers of hazardous waste with the

words “Hazardous Waste” or “with other words that identify the contents

of the containers.” (262.34(c)(1)(ii))

2. When a generator accumulates more than 55 gallons of hazardous waste

(or 1 quart of acute hazardous waste), the generator must (262.34(c)(2)):

• mark the container with the date on which 55 gallons (or 1 quart of

acute hazardous waste) is exceeded, and

• remove the excess of 55 gallons (or 1 quart of acute hazardous

waste) within three days or comply with the 90-day area or 180-day

area regulations, as appropriate.

Question: SQGs must conduct training in accordance with 262.34(d)(5)(iii) and

LQGs must conduct training in accordance with 265.16. Do the RCRA

regulations require training of personnel working in SAAs?

Answer: No. The RCRA regulations do not require training of personnel

working in SAAs.7 Personnel that have access to or work in central accumulation

areas, including those that move hazardous waste from a SAA to a central

accumulation area, must be trained. As the ones actually generating hazardous

waste, however, personnel working in SAAs need to be familiar enough with the

chemicals with which they are working to know when they have generated a

hazardous waste so that it will be managed in accordance with the RCRA

regulations.

Regulatory Citation:

The Technical Guidance Memo (RCRA Online #12973), and regulatory language found in 264.194, and 265.193 is referenced.

Interpretation:

Secondary containment for piping systems carrying hazardous waste need daily inspections but need not have secondary containment except where threaded joints or packed flanges are involved. The use of Teflon synthetic, tape sealed “bags,” provides leak detection and will contain small leaks and spills. However, these bags may not be sufficient with some States.