In the complex landscape of hazardous waste management, satellite accumulation areas (SAAs), which are different from Central Accumulation Areas (CAAs), offer flexibility for hazardous waste generators. The SAA regulations look simple enough to comply with but are often misunderstood by operators. For EHS professionals at industrial facilities and laboratories which generate hazardous waste, understanding the regulation, learning from the most common mistakes, and complying with best management practices (BMPs) will ensure compliance with environmental regulations and lower risk.
What Does Regulation Require?
SAA requirements for hazardous waste generators are outlined in 40 CFR §262.15 and summarized below. At the federal level, the SAA provisions allow hazardous waste generators, namely large quantity generators (LQGs) and small quantity generators (SQGs), to accumulate hazardous waste at or near the point of generation (POG) up to a certain amount, as long as the SAA is under control of the operator. This provides flexibility for generators, as accumulated waste may stay near the POG without being moved to a CAA. The key requirements are as follows:
1. Accumulation Limits: Generators may accumulate up to 55 gallons of non-acute hazardous waste or 1 quart of acute hazardous waste in each SAA. Once these thresholds are exceeded, the entire container or the excess must be moved to a CAA within three calendar days.
2. Container Condition and Compatibility Standards: Satellite accumulation may only occur in containers with a maximum capacity of 55 gallons (not in tanks, drip pads, etc). Containers must be compatible with the hazardous waste that it is designed to contain and be in good condition. If there is a leak, the generator must immediately transfer the hazardous waste to a container that is not leaking and in good condition or immediately transfer the hazardous waste to a CAA.
3. Container Operation: Containers must be closed at all times (including funnels, as described below), except when adding, removing, or consolidating the hazardous waste; or for temporary venting of the container, as necessary to properly operate the process or prevent dangerous situations.
4. Container Labeling: Containers must be marked/labeled in accordance with the following requirements in a SAA:
a. The words “Hazardous Waste”
b. An indication of the hazards of the contents (e.g., hazardous waste characteristic, OSHA pictogram, DOT placard)
c. The label must be dated once the accumulation limit (55 gallons of non-acute hazardous waste or 1 quart of acute hazardous waste) is reached
5. Preparedness and Prevention, and Emergency Response Requirements: All SAAs must comply with the following requirements:
i. Emergency Equipment: Equipping facilities with appropriate communication systems (internal alarms, telephones for external contact), fire extinguishers, spill control, decontamination equipment, and adequate water for fire suppression. This equipment must be periodically tested and maintained.
ii. Access & Aisle Space: Ensuring hazardous waste personnel have immediate access to alarms and maintaining clear aisle space for emergency responders and equipment.
iii. Local Authority Coordination: Documenting attempts to arrange cooperation with local emergency services (fire, police, hospitals).
1. Facilities must have an emergency coordinator available on-site or on-call at all times.
2. Posted Information: Key emergency details must be posted near SAAs, including the emergency coordinator’s name and number, location of safety equipment, and fire department number (if no direct alarm).
3. Employee Training: All employees must be thoroughly familiar with waste handling and emergency procedures.
4. Coordinator Responsibilities: The emergency coordinator or designee is responsible for responding to all emergencies:
a. Fires: Contacting the fire department or using an extinguisher.
b. Spills: Containing and cleaning up hazardous waste and contaminated materials promptly.
c. Off-site Threats: Immediately notifying the National Response Center (800-424-8802) for any release that could threaten human health outside the facility.
6. Location and Control: SAAs must be located at or near the point of generation and under the control of the operator. This ensures immediate response in event of an emergency and reduces the risk of spills or mismanagement.
Once the SAA reaches the accumulation limit, it must either be moved to a CAA within 3 calendar days, or the excess waste must be removed within 3 calendar days to a CAA or treatment facility. The date on which the excess waste began accumulating must also be marked on the label.
Note that state regulations may prescribe more stringent requirements (e.g., in California, the initial date of satellite accumulation must be marked for SAAs and there is a 365-day accumulation time limit). As such, remember to check your state’s regulations to confirm the specific requirements.
Common Compliance Mistakes & Recommendations
Common violations cited during regulatory inspections are outlined below, along with Trinity’s recommended practices:
1. Failure to properly label hazardous waste accumulation containers.
a. Recommendation 1: To generally streamline compliance, use a CAA label for your SAA container. Ensure that operators are properly trained to comply with hazardous waste regulations.
b. Recommendation 2: If you are a laboratory accumulating waste in SAAs, ensure that containers attached to laboratory equipment are closed, labeled, and dated.
2. Failure to close containers when not adding or removing waste.
a. Recommendation 1: Ensure that operators are properly trained to comply with hazardous waste regulations. Consider having the last person each shift or day check the SAA container is closed.
b. Recommendation 2: For funnels:
i. If the funnel screws on to the container: ensure that they are screwed in securely and that the cover is latched when not adding/removing waste.
ii. If the funnel is designed to be removed: ensure that the funnel is removed and that the bung is securely closed.
3. Failure to make a proper hazardous waste determination.
a. Recommendation: Complete a systematic review of all your waste streams and document waste determinations in a waste management plan. Update the waste management plan after all process changes.
4. Exceeding the SAA accumulation quantity limit
a. Recommendation: If there is just one waste stream in the SAA, use a 55-gallon container for accumulation. If there are multiple waste streams in a SAA, cap the total capacity of all containers to 55 gallons (e.g., 1 30-gallon drum and 5 5-gallon buckets).
b. Recommendation 2: Multiple SAAs are allowable if they are distinct from one another. As a Best Management Practice (BMP), designate them SAA1, SAA2, etc. using signage. Ensure they are separated by distance (at least 3 feet), and mark each area using tape on the floor.
5. Waste cannot be moved from one SAA to another. It must be moved from a SAA to a CAA or shipped to the Treatment, Storage, and Disposal Facility (TSDF).
a. Recommendation: Once the SAA accumulation limit is reached, ensure that operators are trained to move the container or excess to a CAA or ship the waste directly to the TSDF. If operators are moving hazardous waste from SAA to another SAA before reaching the accumulation limit, train them to transfer the SAA waste to the CAA.
6. Once a SAA holds more than 55 gallons of waste, the excess waste must be dated and moved to the container storage area in three days.
a. Recommendation: Once the SAA accumulation limit is reached, ensure that operators are trained to move the container or excess to a CAA within three calendar days. If they move the container, make sure that they update the label on the container. Consider using the same label for CAA and SAA so it is easy to add the accumulation start date if the SAA is moved to the CAA.
7. Accumulating too much waste in one SAA.
a. Recommendation: SAA are defined by the POG corresponding to a process. Ensure that each POG only has one associated SAA.
8. The SAA is not under the control of the operator.
a. Recommendation: SAA should only be established in locations that are near a POG where operators routinely work near a process and can maintain line of sight to the container
9. Not integrating SAA amounts into generator status tracking.
a. Recommendation: Since generator status is determined monthly based on the amount of hazardous waste generated, facility waste tracking logs/spreadsheets should account for generation in SAAs as well. Be sure not to double count the SAA hazardous waste when moved to CAA.
Best Management Practices (BMPs)
Trinity recommends that EHS processionals implement the following BMPs at their facilities to minimize compliance risk when it comes to generating hazardous waste in SAAs.
Employee Training and Engagement
Ensure that operators complete hazardous waste training once they start the job and annually. Well trained operators who are informed on the relevant hazardous waste regulations and who are empowered to take ownership of their process go a long way in helping with compliance in SAAs. Additionally, Trinity recommends incorporating hands-on exercises (spot the violation, real time waste container labeling, etc.) into the periodic hazardous waste training.
Waste Management Plan and Waste Management Procedures
Develop a facility-wide waste management plan to assist operators with waste determinations and waste management. Review and update the waste management plan periodically and when there are process changes. Use the waste management plan to accompany facility-specific SOPs for hazardous waste compliance, including waste handling and operational procedures in SAAs.
Container Management
Work with your waste vendor to only have containers which are compatible with wastes in the SAAs at your facility. As part of operators’ daily checks or EHS personnel’s weekly CAA inspections, have them ensure that the container is in good condition, closed, not leaking, and properly labelled. SAA inspections are not required to be documented. Use secondary containment as practical.
Labeling and Signage
Consider simplifying labeling by using color-coded labels or pictograms to quickly convey hazard information. Additionally, posting signage at/around SAA containers may help operators identify the correct container to deposit hazardous waste in, if multiple containers are used.
Very Small Quantity Generators Compliance
While VSQGs are not subject to regulation under 40 CFR §262.15, it is recommended that VSQGs comply with the SAA labeling requirements regardless, as regulators will still enforce labeling requirements.
Digital Tracking Systems
Implementing digital tools for tracking waste accumulation amounts can streamline compliance and provide documentation of accumulation rates.
Conclusion
Satellite accumulation areas are a practical and compliant way to manage hazardous waste at the point of generation. However, they require diligent oversight, robust procedures, and a culture of continuous improvement. By aligning regulatory knowledge with best management practices, EHS professionals can ensure safe, efficient, and compliant hazardous waste operations.
If your facility needs help implementing the BMPs listed above, reviewing compliance with the common compliance mistakes, or answering any other questions regarding hazardous waste management and compliance, please contact your local Trinity office or Regina DiLavore.
