Hazardous Waste Program fact sheet
Division of Environmental Quality Director: Ed Galbraith

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 all satellite accumulation areas 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. The default option (Option 1) is to meet the federal requirements which are adopted by reference into the CSR. To qualify for the Missouri-specific option (Option 2), the generator must fill out and return a Notification of Regulated Waste Activity (NORWA) (MO 780-1164) form to the Missouri Department of Natural Resources. All satellite accumulation areas at the generator’s location must operate under the same requirements, meaning a generator may not use Option 1 at one satellite accumulation area and Option 2 at another, but instead must choose one and use it consistently throughout the facility.

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, and also requiring a notification to the department of the generator’s intent to use this option.

For More Information, Contact the Compliance/Enforcement Section at:
1-800-361-4827 or 573-751-7560

Additional Information:
Notification of Regulated Waste Activity form (MO 780-1164)  http://dnr.mo.gov/forms/780-1164-f.pdf
Satellite Accumulation Table http://dnr.mo.gov/pubs/pub2215/pub2215SatelliteAccumulationattachment.pdf
Code of Federal Regulations  http://www.ecfr.gov/cgi-bin/ECFR?page=browse
Missouri Code of State Regulations for Department of Natural Resources  http://www.sos.mo.gov/adrules/csr/current/10csr/10csr
Missouri Revised Statutes  http://www.moga.mo.gov/mostatutes/statutesAna.html