Does trying to understand satellite accumulation [40 CFR 262.34(c)] send you into orbit? If so, read on. We’ve outlined what you need to know to keep your feet on the ground.
What Does “Satellite Accumulation” Mean?
Satellite accumulation allows you to collect and store as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste at or near the point of generation for 90 days or less without a permit. Sounds simple enough. It’s managing your containers that make or break you with compliance. Here are three main points to consider:
- The container must be kept closed when it’s not in use.
If you’re storing hazardous waste, you need to keep a lid on it. The means you can’t remove the bungs on a closed-head drum or the bolt ring and lid from an open-head drum and not put them back on properly. Latching steel funnels and drum lids provide quick, easy access and keep the drums closed and in compliance.
- The container must be under the control of the operator generating the waste.
Simply put: you can’t make a mess putting the waste into the container and once it’s in there, you need to keep it in there. If you’re pouring into a closed-head drum, burpless funnels eliminate splashbacks and spills. And don’t forget secondary containment. Pallets, decks and spill berms can help you control drips and spills. Make sure you choose containment that’s compatible with the liquid you’re storing and that you have adequate sump to contain 100 percent of the largest container or 10 percent of the total volume.
- The container must be properly labeled.
This sounds like a no-brainer, but your label must clearly state what’s in your drum and you need to use labels made for the job. Some labels can become illegible if they make contact with certain solvents or chemicals. Or the liquid can affect the adhesive and cause the label to fall off.
When you’re setting up your satellite accumulation, keep it away from floor drains, walkways and exits. Consider padlocking drum lids and funnels if you need to restrict access or store them in a covered secondary containment system.
Satellite accumulation isn’t rocket science. With some planning and the right equipment you can keep your costs down-to-earth — and stay compliant.