Making Sense of Satellite Accumulation

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.

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.

This article was previously featured on New Pig's blog.

What Does “Satellite Accumulation” Mean?

It’s All About Managing Your Containers

Accumulation Areas Compared

Browse Spill Control & Containment from New Pig

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