From the archives of the Enforcement and Compliance Listserv for Hazardous Waste Generators
Nov. 30, 2009
Satellite Accumulation of Hazardous Waste
The management of hazardous waste in satellite accumulation is very beneficial to businesses in most instances. There are reduced requirements for hazardous waste stored in satellite accumulation because these hazardous wastes are managed at or near the point of origination and under the direct control of the operator. For instance, secondary containment is not required at the satellite accumulation area and the proper shipping name does not have to be on the satellite accumulation container. Hazardous waste generators can simply mark the satellite containers "Hazardous Waste," use the EPA waste code (e.g. F003 for a spent xylene solvent), the shipping description, or identify the contents of the container (i.e. "Waste Xylene").
In Missouri, containers of hazardous waste in satellite storage must also be labeled with the beginning date of satellite accumulation. This date is important because hazardous waste can only be stored in satellite accumulation for one year. At the end of the one year time period, the hazardous waste must be sent to either 90-day storage for large quantity generators, 180-day or 270-day storage for small quantity generators, or the waste must be shipped off-site. Another benefit of storing wastes in satellite accumulation areas is that the containers do not have to be packaged, labeled, and marked according to U.S. Department of Transportation regulations.
Unlike other states that only allow up to 55 gallons total in satellite accumulation, Missouri allows generators to have up to 55 gallons of hazardous waste, or 1 kilogram of acutely hazardous waste, per waste stream in satellite accumulation. However, only one container per waste stream is allowed so if you use and fill a 5-gallon bucket in your satellite accumulation area it must be moved to storage. Once a container in satellite accumulation is full or you have accumulated 55 gallons, you have three days to move the hazardous waste from satellite accumulation to your storage area. Containers in satellite accumulation must be in good condition, compatible with the wastes they are holding, and kept closed except when adding or removing wastes. For more information, please review our fact sheet on satellite accumulation at http://www.dnr.mo.gov/pubs/pub2215.htm
June 30, 2007
New Fact Sheet on Satellite Accumulation
To increase efforts to provide environmental assistance to Missouri businesses, we are updating and producing more fact sheets on topics that you need to know. Our newest publication is Hazardous Waste Satellite Accumulation and can be found at /pubs/pub2215.htm. It is written in easy to understand language and gives an overview of how to best manage your satellite accumulation areas.
May 31, 2007
Marking Satellite Containers
You have several options when marking hazardous waste stored in satellite accumulation areas. According to 10 CSR 25-5.262(2)(C)3, hazardous waste containers in satellite accumulation areas must be marked with "Hazardous Waste," the EPA waste code, shipping description, description of contents ("waste toluene"), or other words that identify the contents of the containers. Also, unlike hazardous waste in 90 or 180-day storage, hazardous waste in satellite accumulation areas does NOT need to be labeled or marked according to U.S. Department of Transportation regulations.
March 10, 2006
As promised in the last listserv, here are some commonly asked questions and answers on satellite accumulation areas:
Q. Do satellite accumulation area requirements apply to Conditionally Exempt Small Quantity Generators? A. No, Conditionally Exempt Small Quantity Generators do not need to follow satellite accumulation area requirements.
Q. Is there a maximum time a container can be in a satellite accumulation area? A. In Missouri, each container of hazardous waste has a one-year time limit in satellite accumulation areas. When you start a container you must identify the contents and the beginning date of accumulation.
Q. Can a business have 55 gallons of multiple non-acute hazardous waste streams in a single satellite accumulation area or is 55 gallons the maximum total volume for all containers in a designated satellite accumulation area? A. You may have 55 gallons for each waste stream generated, but you must have only one container per waste stream. Once filled you have three days to remove the waste from the satellite accumulation area. For those three days after filling the container it is possible that you could have two containers from one waste stream in a single satellite accumulation area.
Q. Do I have three working days or just three days (72 hours) to remove hazardous waste from a satellite accumulation area once a container is full? A. You only have three days (72 hours). It is important to plan ahead, especially over holidays and before shut down periods.
Q. Are businesses required to have a secondary containment for satellite accumulation areas? A. No, businesses are not required to have a secondary containment for satellite accumulation areas.
Q. Do you require any signage that an area is being managed as a satellite accumulation area? A. No, but it is good idea to clearly indicate the area as a satellite accumulation area.
Q. Are there a maximum number of satellite accumulation areas that a generator is allowed to have? A. No, you may have as many satellite accumulation areas as you have hazardous waste generation points.
Q. How do you define 'near the point of generation'? Can you offer any guidelines that businesses should follow? A. Hazardous waste in a satellite accumulation area must be under the control of the operator of the process that generated the waste. Usually that means in the line of sight of the operator and in the same building. This last statement may be modified on a case by case basis. Exceptions can be made if the waste is dangerous and must placed in a separate locked building.
Q. Are threaded funnels with latching lids acceptable for meeting the 'closed' requirements for containers in satellite accumulation areas? A. The funnels must be capable of keeping vapors and liquid waste from escaping, even if the drum is knocked over. Visit closed containers for more details.
Q. Can I move waste from one satellite accumulation area to another satellite accumulation area? A. No, movement of waste from one satellite accumulation area to another is not allowed.
Q. Can a one cubic-yard bag be a satellite storage container? A. You may use a one cubic-yard bag as a satellite storage container as long as it fulfills the basic container requirements. The container must be in good condition, be compatible with the waste, and remain closed unless adding waste or removing waste. It is important to remember that you are limited to 55 gallons of non-acute hazardous waste or one kilogram of acute hazardous waste. The cubic-yard bag would need to be removed from the satellite storage area when it reaches the volume limit (i.e. you can not fill up the cubic-yard bag because it would be over the 55 gallon limit).
March 2, 2006
Hazardous waste satellite accumulation areas allow for reduced storage requirements for your business (primarily being able to store waste longer and no weekly waste storage inspection). But what exactly is a satellite accumulation area? A satellite accumulation area is where small quantities of wastes are initially generated and accumulated throughout a business. For instance, your business makes and packages paint. You may have one point of generation at the location where the paint is mixed, one point of generation at the location where the paint is packaged, and one point of generation at the location where your in-house laboratory tests the quality of the paint. Each location can have its own satellite accumulation area.
Satellite accumulation areas must
- be near the point of generation
- be under the control of the generator of the waste (i.e. in the line of sight of the generator and in the same building)
Businesses can identify the satellite accumulation area by painting lines on the floor, roping off the area, hanging signs, etc. It is helpful to both employees and inspectors if you distinguish the satellite accumulation area from the regular 90-day or 180-day waste storage area by appropriate signage.
In Missouri there are a few special requirements for waste stored in satellite accumulation areas. The maximum volume per waste stream that can be accumulated is 55 gallons for nonacute waste and one kilogram for acutely hazardous waste. Hazardous waste can be stored for up to one year in a satellite accumulation area and should be marked to identify the contents and the beginning accumulation date. Within three days of filling a container, or once the year is up, hazardous waste from a satellite accumulation area must be moved to the 90-day or 180-day waste storage area. As with all hazardous waste storage, the containers must be compatible with the waste they store, in good condition, and closed unless adding or removing waste.
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