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Summary:
- A satellite accumulation area is space around your facility where you can store hazardous waste temporarily before proper disposal.
- You can store up to 55 gallons of compatible non-acute hazardous waste (or 1 qt. of liquid acute hazardous waste/1 kg of solid acute hazardous waste) in SAA areas without obtaining a permit.
- Don’t store or mix incompatible waste products in the same container.
- Ensure you store hazardous waste away from floor drains to avoid groundwater pollution.
- You must clearly mark and label with words “Hazardous Waste” and describe the contents.
When managing the collection, accumulation, storage and disposal of hazardous waste materials, compliance with the law and industry best practices is essential. For waste generators in the small and large categories, there are satellite accumulation areas or SAAs you must be aware of.
What Is Satellite Accumulation?
If you’re a company that is considered to be a small or large quantity generator, satellite accumulation allows you to accumulate up to 55 gallons of on-site hazardous waste without requiring a special permit. In addition, this allows you to avoid activating time limits related to Central Accumulation Areas (CAAs). The waste you accumulate is typically in steel drums and other specialized containers, although custom shipping boxes can be useful for transporting non-damaged and non-leaking waste.
Very Small, Small and Large Quantity Generators
If you generate hazardous waste as a business, whether you’re classified as a very small, small or large quantity generator (VSQG, SQG, or LQG) depends on the quantity of hazardous waste or acutely hazardous waste that you produce monthly.
According to the EPA, if you produce less than 100 kg of hazardous waste per month, you’re a very small quantity generator.
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If you generate more than 100 kg of hazardous waste per month, but less than 1,000 kg, you’re a small quantity generator. Among other requirements, a small quantity generator may “accumulate hazardous waste on-site for 180 days without a permit (or 270 days if shipping a distance greater than 200 miles).” The quantity of waste that you may accumulate on-site can never exceed 6,000 kg.
Finally, a large quantity generator produces 1,000 kilograms of hazardous waste or more per month. In a central accumulation area (CAA), LQGs are subject to additional requirements, such as limiting on-site waste accumulation to 90 days.
Inspection Procedures
While VSQGs don’t require periodic inspections, it’s best to conduct them periodically to protect your employees and work environment. However, SQG and LQG must inspect all containers weekly to ensure no signs of leakage or deterioration.
Waste Responsibility
However, a waste generator doesn’t necessarily need to produce the waste. According to the EPA, for example, a contractor who removes residue from the inside of a product storage tank is the first person to cause the waste to become subject to regulation rather than the owner or producer of the waste. Under these circumstances, both the contractor and the producer become jointly responsible for managing the waste. As a result, both can be held liable should complications arise with the handling or disposal of the waste.
What to Know About Containers
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How you store your hazardous waste and organize your containers directly affects your ability to manage hazardous waste materials safely, efficiently and in compliance with the law. You’ll need to keep the rules regarding satellite accumulation areas in printed physical form and readily accessible. These rules should always be in proximity to the SAA.
Biohazardous and radioactive waste must not be stored in SAAs or near other types of hazardous materials. Always segregate these materials to avoid cross-contamination.
Do not store or mix incompatible wastes in the same containers. As with biohazardous and radioactive wastes, these products must be segregated at all times.
1. Location matters.
When establishing your satellite accumulation area, you need to ensure your hazardous waste containers are not located near exits or floor drains. If they leak, the materials should not be able to enter the wastewater system. Hazardous materials may pass through water treatment plants, causing groundwater pollution. This should be part of your general containment strategy.
2. Containers must remain closed when not in use.
To maximize safety and prevent cross-contamination or spillage, you should ensure you’re keeping your shipping barrels and other containers closed when access to the materials contained therein isn’t immediately necessary. You should only open the lids to these containers when loading and unloading them.
3. Maintain control.
All hazardous waste containers must be under the control of the waste generator. An individual must be assigned to manage the satellite accumulation area at all times, assuming responsibility for the proper storage and disposal of hazardous materials. When the responsible person is unavailable, the SAA should be secured. Physical access-control measures can prevent harmful additions to the waste collected and tampering. For example, you can padlock drum lids or store containers in locked or covered locations.
4. Do not exceed the maximum permissible volume.
The SAA is specifically intended for the storage of 55 gallons of hazardous waste. If you exceed this quantity, you need to relocate the hazardous waste that you’re storing to a CAA, an interim status location on the waste-generation site, a permitted TSDF (Treatment, Storage, and Disposal Facility) or an off-site designated facility within three calendar days.
5. Clearly mark and label.
According to the law, the SAA container must be clearly marked with the words “Hazardous Waste.” Furthermore, all labels must accurately describe 100% of the stored contents. Ensure you select a label that is resistant to becoming illegible due to chemical contamination.
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Waste Management Needs
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At Air Sea Containers, we specialize in the manufacture and sale of products that allow you to safely store and manage hazardous and non-hazardous materials, ensuring you’re always in compliance with the law. This includes the use of corrugated hazmat boxes for waste management in satellite accumulation areas. In addition to the proper equipment, however, you must also be aware of the legal requirements to be in compliance.
