Hazardous Waste Satellite Accumulation

Waste Management Program fact sheet
05/2020
Division of Environmental Quality Director: Ed Galbraith
PUB2215

This fact sheet and the accompanying table provide general information about Missouri’s satellite accumulation regulations. Please be aware the Code of State Regulations (CSR) currently offers two options for managing hazardous waste in satellite accumulation areas; however each satellite accumulation area at a facility must be operated under only one of these options: 1) according to 40 CFR § 262.34(c) which is adopted by reference, or 2) according to a manner specific to Missouri. Regulations for both options can be found at 10 CSR 25-5.262(2)(C)3.

What is satellite accumulation?

Satellite accumulation is the storage of hazardous waste at the point of generation. Businesses generating hazardous waste are allowed to store small amounts of hazardous waste at or near the equipment or process generating the waste and under the immediate control of the operator of the process generating the waste. Satellite accumulation areas do not have to meet the full requirements applying to central accumulation areas or hazardous waste permitted storage areas.

What are the requirements for Satellite Accumulation Areas?

Federal and state regulations require hazardous waste generators to meet specific standards for storing hazardous wastes as summarized below. If a satellite accumulation area does not meet these conditions, the facility could be violating the federal regulations in 40 CFR § 265.31 (which Missouri incorporates) and have an increased risk of fire, release or other emergency. Currently the CSR provides two options for managing a satellite accumulation area; Federal (Option 1) and State (Option 2) which are adopted by reference into the CSR. A facility with more than one satellite accumulation area may use a single option or both so long as each satellite accumulation area follows the regulations for a single specified option.

The following apply to all satellite accumulation areas:

The generator must also comply with the requirements and conditions of either option noted below:

Option 1 - operating according to 40 CFR § 262.34(c) incorporated by reference.

Option 2 - specific to 10 CSR 25-5.262(2)(C)3 – This option differs from the federal regulations by allowing up to 55 gallons per wastestream per satellite accumulation area, but limiting storage time to one year. Notification is no longer required to use this option therefore any satellite accumulation area in which a container that is not full has been dated will be assumed to be operating under this option and inspected in accordance to 10 CSR 25-5.262(2)(C)3.

Satellite Accumulation Regulation Summary

OPTION ONE - FEDERAL OPTION TWO - STATE
Allows up to 55 gallons total of all waste streams in an
area-40 CFR 262.34(c) (Note: volume limit, no time limit)
Allows up to 55 gallons of each waste stream in an area-
10 CSR 25-5.262(2)(C)3 (Note: volume and time limit)
Allows multiple containers of each wastestream (federal
interpretation)
Allows only one container per waste stream-(MO codifi ed
its interpretation)-10 CSR 25-5.262(2)(C)3.B
  NOTIFICATION to state-of choice of MO option and
renotifi cation of decision change-10 CSR 25-5.262(2)
(C)3.A
Mark the container with the date on which 55 gallons (or 1
quart of acute hazardous waste) is exceeded-262.34(c)(2)
Mark the container with the date on which 55 gallons (or 1
quart of acute hazardous waste) is exceeded-262.34(c)(2)
Containers are at or near any point of generation-262.34(c)(1) Containers are at or near any point of generation-262.34(c)(1)
Under the control of the operator of the process generating the
waste-262.34(c)(1)
Under the control of the operator of the process generating the
waste-262.34(c)(1)
Containers in good condition-265.171 Containers in good condition-265.171
Waste compatible with containers-265.172 Waste compatible with containers-265.172
Containers kept closed, except when adding/removing
waste-265.173(a)
Containers kept closed, except when adding/removing
waste-265.173(a)
Mark the container with the words “Hazardous Waste” or other
words identifying the contents-262.34(c)(1)(ii)
Mark the container with the words “Hazardous Waste” or other
words identifying the contents-262.34(c)(1)(ii)
  Mark each container with its beginning date of accumulation
-10 CSR 25-5.262(2)(C)3.C
  Container stored in a satellite area for more than one year
must be removed within three calendar days if any one of the
following occurs:
1. One year has passed since the accumulation start date
2. The container is full, OR
3. The container has reached its volume limit-10 CSR 25-
5.262(2)(C)3.D.(I)(II) and (III)
Remove the excess of 55 gallons (or 1 quart of acute
hazardous waste) within three days or comply with the 90-day
area or 180-day area regulations, as appropriate-262.34(c)(2)
Containers of hazardous waste removed from the satellite
accumulation area must be taken to the generator
storage area, shipped offsite for proper hazardous waste
management, or managed in accordance with an approved
hazardous waste permit or certifi cation at the site-10 CSR 25-
5.262(2)(C)3.E
May start a new container during the 3 day excess storage
period if meeting all other requirements above-Federal
guidance
May start a new container during the 3 day excess storage
period if meeting all other requirements above-10 CSR 25-
5.262(2)(C)3.E