• Making Sense of Satellite Accumulation
  • New Pig Technical Team

    Our Tech Team is a group of experts that is dedicated to answering all your regulation questions! We can be reached at 1-800-HOT-HOGS (468-4647) or by email at xtechnical@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!


  • 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.


  • 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.


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    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.


  • 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.


  • 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!

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