Memo Detail

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RCRA Online Number: 14703
Title: FREQUENTLY ASKED QUESTIONS ABOUT SATELLITE ACCUMULATION AREAS
Document Date: 2004-03-17
To: RCRA Directors, Regions 1-10
From: Springer
Description: Summary of generator accumulation regulations. Both LQGs and SQGs may establish satellite accumulation areas (SAA). Waste in excess of 55 gallons or 1 quart of acute hazardous waste must be removed within three days. When a generator exceeds 55 gallons or 1 quart acute hazardous waste, the container must be dated. The generator must date container again when it is moved to central accumulation area. Three days means three consecutive days. There is no federal requirement that full containers of hazardous waste be removed from an SAA within three days of being filled. Generators may transfer hazardous waste between containers to facilitate storage, transportation, or treatment. Containers in SAAs do not have to comply with the air emission standards of Part 265 Subparts AA, BB, and CC. Inspections of SAAs are not required if SAA meets 262.34(c) requirements. Personnel working in SAAs not required to have training. It is permissible to have more than one waste in an SAA and more than one container of hazardous waste in an SAA. The regulations do not limit the total number of SAAs at a generator facility. Generators may not move hazardous wastes between SAAs. A single SAA may have multiple points of generation. Generators must include all hazardous waste in their SAAs in monthly quantities for determining their generator status. Containers attached to equipment discharging hazardous waste must comply with SAA regulations and is a point of generation. Small containers (vials or tubes) may be placed in properly labeled larger containers. (SEE ALSO: 75 FR 12989, 12994; March 18, 2010)
Regulatory Citation(s): 261.5(d), 261.5(c), 262.34(a)
Official ORCR Policy: Yes
Associated Topic(s): Containers, Generators, Large Quantity Generators (LQG), Small Quantity Generators (SQG)