• Making Sense of Satellite Accumulation
  • Karen

    Karen D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer and technical writer for New Pig. She has more than 22 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 100 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP), Walkway Auditor Certificate Holder (WACH), Community Emergency Response Team (CERT) trainer and hazmat technician. She also serves on the Blair County, Pa., LEPC and has completed a variety of environmental, safety, emergency response, DOT and NIMS courses, including Planning Section Chief. She has conducted seminars at national conferences and webinars for ASSE and other national organizations. She can be reached at 1-800-HOT-HOGS (468-4647) or by email karenea@newpig.com.

  • 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

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    • 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.

      Below is a side-by-side comparison of the requirements for containers in each type of area.

      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 acumulation 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 genration where the waste initially accumulates; and under the xontrol 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 deterioation Containers must be inspected at least weekly for leaks or signs of deterioation
      Preparedness and Prevention Same as the applicable SQG or LQG requirements for Central Accumulation Areas The faciilty 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 sufficent volumes of water with pressure sufficient to operate fire suppression equipment. Facilities must also make arrangements with local response authorities The faciilty 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 sufficent 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 employe 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 deprtment 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. 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 deprtment 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.

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