Making Sense of Satellite Accumulation

Expert Advice > Blog Post > Making Sense of Satellite Accumulation

Making Sense of Satellite Accumulation
by Karen
Does trying to understand satellite accumulation [40 CFR 262.34(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.

Use these PIG products to keep your hazardous waste and satellite accumulation areas under control:
Patented design delivers fast, no-splash pouring and one-handed access for easy reg compliance.

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Label drums with appropriate contents to keep satellite accumulation areas compliant avoid dangerous errors.

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Low-profile pallet with sump catches leaks, drips and spills while keeping drum tops and accessories within reach.

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TAGS: Hazardous Waste

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 karenh@newpig.com.

8 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