Expert Advice > Blog Post > Making Sense of Satellite Accumulation

Making Sense of Satellite Accumulation

by Karen

Does trying to understand satellite accumulation [40 CFR 262.15] send you into orbit? If so, read on for information that will help keep your feet on the ground. It’s not rocket science. With some planning and the right equipment, you can comply while keeping costs down to earth.

What Does “Satellite Accumulation” Mean?

Satellite accumulation allows Small and Large Quantity Generators (SQGs and LQGs) to collect and store up to 55 gallons of hazardous waste or one quart of acutely hazardous waste at or near the point of generation without a permit and without triggering the accumulation time limits imposed in Central Accumulation Areas (CAAs). These quantities apply to each satellite accumulation area (SAA).

It’s All About Managing Your Containers

The above sounds simple enough. But you need to make sure that the containers in each SAA are being properly managed. This includes:

The container needs a good location. When setting up your SAA, keep it away from floor drains, walkways and exits.
The container must be closed when it’s not in use. When you’re storing hazardous waste, you need to keep a lid on it. That means if you remove the bungs on a closed-head drum or the bolt ring and lid from an open-head drum, you have to replace them properly. Latching steel funnels and drum lids provide quick, easy access and make it easier to keep the drums closed.
The container must be under the control of the operator generating the waste. Simply put, someone needs to be in charge of the SAA. Typically, this is a person who works in that general area. The SAA should be within that person’s view, not around the corner or tucked in a closet. When the operator is absent, the area should be secured to help prevent improper additions to the waste collection container(s). Ways of restricting access include padlocking drum lids and funnels or storing them in a covered secondary containment system.
The container must be properly labeled. Each container in the SAA must bear the words “Hazardous Waste,” as well as a description of the type of waste within. This can be handwritten, or pre-printed labels may be used. Just keep in mind that some solvents or chemicals will make labels illegible or affect adhesive and cause the labels to detach.
The container must not exceed the allowable volume. Any excess beyond the maximum volume (55 gallons of hazardous waste or one quart of acute hazardous waste) must be moved to the CAA, to an on-site interim status location or permitted TSDF, or to an off-site designated facility within three calendar days [40 CFR 262.15(a)(6)]. In all practicality, most facilities will move the full container, not just the excess, to the CAA for recycling or disposal and start a new one.

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In addition to these requirements, consider any other regulations that might apply specifically to the types of wastes that will be accumulated in these areas. For example, if you will be collecting flammable liquids, OSHA regulations (29 CFR 1910.106) and NFPA codes require you to bond and ground the containers to prevent static electricity from building to unsafe levels [NFPA 30, 18.5.2.2].

To expand on the relationship between a SAA and the CAA, below is a side-by-side comparison of elements for each type of area. It should help you understand when to choose one area over the other for storing hazardous waste.

Accumulation Areas Compared

	Satellite Accumulation Areas 40 CFR 262.15	Central Accumulation Areas Requirements for SQGs 40 CFR 262.16	Central Accumulation Areas Requirements for LQGs 40 CFR 262.17
Volume of Waste that May be Accumulated	Up to 55 gallons of non-acute hazardous waste and/or 1 quart of liquid acute hazardous waste, or 1 kg of solid acute hazardous waste. Wastes in excess of 55 gallons of non-acute, 1 quart of liquid acute hazardous waste, or 1 kg of solid acute hazardous waste must be properly labeled, marked with an accumulation start date and moved to a CAA, TSDF or off-site designated facility within 3 consecutive calendar days	May never exceed 6,000 kg (13,200 pounds)	Any volume may be stored
Time Limits	None at the federal level. Some states have time restrictions.	No more than 180 days, unless the waste must be transported more than 200 miles	No more than 90 days
Location	At or near the point of generation where the waste initially accumulates; and under the control of the operator of the process that generates the waste	Any	Any
Number of Locations	No limits on the number permitted	No limits on the number permitted	No limits on the number permitted
Containers	Must be compatible with the waste and in good condition	Must be compatible with the waste and in good condition	Containers must meet applicable air quality requirements of 40 CFR 265, Subparts AA, BB and CC. Containers must be in good condition and compatible with wastes. Containers holding ignitable or reactive wastes must be located at least 50 feet from the facility’s property line unless the local authority having jurisdiction provides a written approval for it to be less than 50 feet. Precautions must be taken to prevent accidental ignitions or reactions.
Leaks from Containers	The generator must immediately transfer the hazardous waste to another container that is in good condition, or transfer and manage the waste in a CAA	The generator must immediately transfer the hazardous waste to a container that is in good condition or manage it in another appropriate manner	The generator must immediately transfer the hazardous waste to a container that is in good condition or manage it in another appropriate manner
Incompatible Wastes	Incompatible wastes must not be placed in the same container and must be protected from other materials that are accumulated in the area	Incompatible wastes may not be placed in the same container	Incompatible wastes may not be placed in the same container
Closed Containers	Containers must be kept closed, except when wastes are being added or removed, or when it is necessary to vent pressure	Containers must be kept closed, except when wastes are being added or removed	Containers must be kept closed, except when wastes are being added or removed
Container Labels	Containers must be marked or labeled “Hazardous Waste” and have an indication of the hazards of the contents	Containers must be marked or labeled with the words “Hazardous Waste” and an indication of the hazards of the contents. Containers must also be marked with an accumulation start date. This information must be clearly visible when containers are inspected	Containers must be marked or labeled with the words “Hazardous Waste” and an indication of the hazards of the contents. Containers must also be marked with an accumulation start date. This information must be clearly visible when containers are inspected
Handling	n/a	Containers must not be opened, handled or accumulated in a manner that may rupture the container or cause it to leak	Containers must not be opened, handled or accumulated in a manner that may rupture the container or cause it to leak
Inspections	n/a	Containers must be inspected at least weekly for leaks or signs of deterioration	Containers must be inspected at least weekly for leaks or signs of deterioration
Preparedness and Prevention	Same as the applicable SQG or LQG requirements for Central Accumulation Areas	The facility must be maintained and operated to minimize the possibility of fires, explosions and hazardous waste releases and have adequate aisle space for emergency response equipment. The facility must also have an internal communication or alarm system to alert personnel of emergencies; a way to call for external emergency assistance; fire extinguishing equipment; spill control and decontamination equipment; and sufficient volumes of water with pressure sufficient to operate fire suppression equipment. Facilities must also make arrangements with local response authorities	The facility must have a contingency plan and be maintained and operated to minimize the possibility of fires, explosions and hazardous waste releases and have adequate aisle space for emergency response equipment. The facility must also have an internal communication or alarm system to alert personnel of emergencies; a way to call for external emergency assistance; fire extinguishing equipment; spill control and decontamination equipment; and sufficient volumes of water with pressure sufficient to operate fire suppression equipment. All equipment must be tested and maintained to make sure it will properly operate in an emergency. Facilities must also make arrangements with local response authorities
Emergency Procedures	Same as the applicable SQG or LQG requirements for Central Accumulation Areas	At least one employee must be available or on call to coordinate emergency response. The name and phone number of the emergency coordinator, location of emergency response equipment and phone number of the local fire department must be posted near telephones or in areas where wastes are accumulated. All employees must be trained to handle wastes properly as well as their roles during an emergency. The emergency coordinator must respond to fires or call the fire department. If hazardous waste spills, it must be contained as soon as possible and cleaned properly. If a spill reaches water, the NRC must be contacted.	At least one employee must be available or on call to coordinate emergency response, act as a liaison with outside responders, file appropriate reports and ensure cleanup of spills. The name and phone number of the emergency coordinator, location of emergency response equipment and phone number of the local fire department must be posted near telephones or in areas where wastes are accumulated. All employees must be trained to handle wastes properly, as well as their roles during an emergency. The emergency coordinator must respond to fires or call the fire department. If hazardous waste spills, it must be contained as soon as possible and cleaned up properly. If a spill reaches water, the NRC must be contacted.

TAGS: Hazardous Waste

Karen

Karen D. Hamel CSP, CET, WACH, is a regulatory compliance professional, trainer and technical writer. She has more than 25 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 200 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP), Certified Environmental health and Safety Trainer (CET), Walkway Auditor Certificate Holder (WACH), OSHA-Authorized Outreach Trainer for General Industry, Community Emergency Response Team (CERT) trainer and hazmat technician. She serves on the Blair County, PA LEPC. Her specialties include a wide variety of environmental, safety, emergency response, risk management, DOT and NIMS topics. She conducts trainings and seminars at national conferences and webinars for several national organizations. For regulation or product information, we can be reached at 1-800-HOT-HOGS (468-4647) or by email at xtechnical@newpig.com.

17 Comments

Nicksays:
11/24/2015 at 1:27 pm Reply
I was under the impression that you could accumulate hazardous waste up to 1 year at a satellite accumulation area and up to 55 gallons; once the satellite accumulation drum was full or the 1 year limit reached, then business has 3 days to move the waste to the hazardous waste accumulation area and dispose of this waste within the time frame that the hazardous waste generator is subject to (SQG, LQG). So a business doesn’t have to move their drum within 90 days as indicated here.
- Brittanysays:
  11/30/2015 at 12:24 pm Reply
  Hi Nick!
  
  Thanks for your comment! Under the federal regulation, there is no time restriction for satellite accumulation areas – but some states do have more stringent requirements and have added time restrictions.
  
  You are correct: The 90 day time limit applies to Large Quantity Generator’s waste collection areas, not SAAs. Great catch! Thank you!
  
  The “three day rule” is a little more complicated. When a container in a SAA contains 55 gallons of hazardous waste (or one quart of acute hazardous waste) only the excess beyond the 55 gallons (or one quart) must be moved to the hazardous waste accumulation area and handled/disposed of within the appropriate time limit for the generator’s status [40 CFR 262.34(c)(2)]. But, in all practicality, most facilities will move the full container (not just the “excess”) to the central waste storage area for recycling or disposal and start a new one.
  
  Hope this answers your question and concern! If not, please leave another comment and we can help you further!
  
  Thanks,
  Brittany
Matthew Philmansays:
04/20/2016 at 12:40 pm Reply
I know you’re limited to 55 gallons for an SAA, but can you have more than one SAA with up to 55 gallons each or is it 55 gallons total among multiple SAAs?
- Brittanysays:
  04/21/2016 at 5:38 pm Reply
  Hi Matthew,
  
  Thanks for commenting! There is no limit to the number of SAAs that a facility can have. You are limited to accumulating up to 55 gallons of hazardous waste or one quart of acute hazardous waste at each SAA, as outlined in question 10 of this memorandum.
  
  Hope this information helps! If you have any other questions, do not hesitate to leave another comment.
  
  Thanks,
  Brittany
Mariasays:
05/01/2016 at 7:54 pm Reply
Hello. Does the 55-gallon hazardous waste drum in our satellite accumulation area require a secondary containment? We are in Carol Stream, Illinois. Thank you.
- Brittanysays:
  04/22/2016 at 9:49 am Reply
  Hi Maria,
  
  Thank you for your comment. According to 40 CFR 264.175, containers of hazardous waste must have secondary containment in case the primary container fails. Satellite accumulation areas fall under this category. For your 55 gallon drum, you will need 55 gallons of secondary containment capacity. Secondary containment systems can take many forms and will depend on where your satellite accumulation area is.
  
  Hope this answers your question! If you have any additional questions, please leave another comment.
  
  Thanks,
  Brittany
szamba betonowesays:
05/19/2016 at 11:27 am Reply
Howdy would you mind letting me know which
web host you’re working with? I’ve loaded your blog in 3 completely different web browsers and I must say this blog
loads a lot quicker then most. Can you suggest a good hosting provider at a reasonable
price? Thank you, I appreciate it!
- Brittanysays:
  05/23/2016 at 9:22 am Reply
  Good morning,
  
  Thank you for your comment. Unfortunately we cannot share that information. We do appreciate you spending some time on our site.
  
  Thanks,
  Brittany
Evan Logansays:
01/08/2018 at 12:20 pm Reply
These are Great!
- Brittanysays:
  01/08/2018 at 7:12 pm Reply
  Thanks for the feedback!
Coreysays:
01/17/2018 at 4:24 pm Reply
Can you describe a side-by-side type comparison of how an SAA vs an Accumulation site needs to be managed? I guess more specifically, labeling the area (not the container), and inspections?

Thank you in advance,

Corey K.
- Brittanysays:
  03/05/2018 at 5:00 pm Reply
  Hi Corey,
  
  There aren’t really any specific requirements for the labeling of each area, but most facilities will label the areas as a best management practice. Labeling areas is helpful as a reminder for employees, as well as a visual indication to help any outside responders who may be called upon for help during an emergency. In the post is a side-by-side comparison of the requirements for containers in each type of area.
  
  Thanks for asking!
Stephaniesays:
08/21/2019 at 2:14 pm Reply
Fantastic article; thanks! How are waste limits handled when both solid and liquid wastes are stored in the SAA? Would a 30 gallon drum of solid waste + 25 gallon drum of liquid waste trigger the 55 gallon limit? Or are limits for solids and liquids considered separately?
- Isabella Andersensays:
  09/23/2019 at 11:01 am Reply
  Hi there. Great question, thanks for asking! In a document provided to regional inspectors, the EPA clarified that more than one waste stream is permitted in a single satellite accumulation area (see question 9). However, no matter how many containers are in a single satellite accumulation area, the total volume of all the containers cannot exceed 55 gallons.
  
  So, in your scenario; you could have a 30-gallon drum for solid waste and a 25-gallon drum of liquid waste in the same satellite accumulation area, as long as both waste streams meet the other criteria: at or near the point of generation, etc.
  
  Thanks,
  Isabella
David Creasays:
07/06/2021 at 1:38 pm Reply
Thank you for the reminder. We changed drums and I had not gotten the new ones labeled.
- Isabella Andersensays:
  07/07/2021 at 11:19 am Reply
  Happy to help!
Leighsays:
10/27/2021 at 11:33 am Reply
Well articulated! Thank you for sharing!