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If a generator accumulates more than the satellite limit, when should they date the container?

When exceeded, not started.

What is meant by 3-days?

Three days means three consecutive days. It does not mean working days or business days.

Originally the EPA proposed 72-hours as the time limit, but realized that determining when 72-hours elapsed would require the container to have both date and time labeled.

The leg of a PPE suit is hanging out from under the secured lid of a container. Is the container open or closed?

Open.

Do containers in satellite areas have to comply with air emission standards?

No.

Do satellite containers need to be inspected?

The do not need to be although we recommend that you that you do so on a regular basis anyway.

Can a facility have more than one satellite accumulation area?

Yes, The regulations do not limit the number of SAAs. Likewise, the regulations do not limit the total volume of waste that can be accumulated at various SAAs. Regulation only limits to 55 gallons (1 quart) per SAA.

Can a satellite accumulation area contain more than one container?

Yes, It is permissible  to have more than one container, as well as more than one waste type in a SAA. Good management practice dictates how this should be done. SAA is limited to a total volume of 55 gallons (1 quart).

When a facility has equipment that discharges hazardous waste to an attached container, do the attached containers need to be in compliance with satellite accumulation regulations?

Yes.

Are the dirty uniform bins considered satellite accumulations of hazardous waste?  What about maintenance gloves?

No, Contaminated wipes, gloves, or uniforms being commercially laundered and subsequently reused are not discarded; therefore, they are not a hazardous waste.

So, how many could you answer correctly?

Today we are going to explore the ever exciting world of accumulation container standards, rules, and types! We will be focusing on the differences between and rules associated with satellite accumulation vs. 90-day. We will also be offering a short quiz available for download at the end of this post.

So to begin, we will talk about satellite accumulation. A generator can accumulate up to 55 gallons of hazardous waste in containers that are:

  • At or near point of generations, and
  • Under the control of the operator.

Acute hazardous waste accumulation is limited to 1 quart. All containers must be labeled with the words “hazardous waste” or with other words that accurately identifies the contents.

When containers in a satellite accumulation area exceed their limits of 55 gallons or 1 quart the container must be dated. The excess or the entire container then must be removed within 3 days. Otherwise, the site must be managed as a 90-day.

And as always, all container management standards apply; meaning that all containers must be in good condition, closed, labeled, and segregated for compatibility.

In a 90-day, a generator can accumulate for up to 90 days with no volume limits. There are, however, additional standards that must be complied with. See the table below for a comparison of applicable standards.

Accumulation Standards

As you can see, there are more standards that must be followed if you are a 90-Day generator. That said, it is important to note that this blog post is not intended to serve as an all-inclusive guide to standards. It is always best to check with local government and 40 CFR for the most up-to-date information.

If you ever find yourself with a spare minute you should do a quick Google search for things to stop doing, things you do that make you look dumb, etc. It’s a pretty common theme in the blogosphere. Don’t believe me? Check out a couple of my favorites before reading on.

Number one on my list is, “15 Grammar Goofs That Make You Look Silly” (this one is even in a handy infographic). Another good one is “10 Things You Need to Stop Doing Today to be Happier.” Pretty good, right? I think the great thing about this kind of post is that we are so used to being told what to do that it is a bit of a novelty to see information presented in this less conventional way.

That said, I thought I would jump on the bandwagon and list out six mistakes you may be making, in the area of hazardous waste regulations, manifests, and more, that you should really try to stop;

1. Neglecting state regulations when dealing with hazardous wastes. While RCRA regulates hazardous waste management on a national level, you can still get yourself and your company into trouble if you don’t know about and adhere to individual state regulations.

2. Not properly closing hazardous waste containers. Always remember, if contents would spill out in the event of an overturn the container is considered open.

3. Using hazardous waste storage containers that are too old/not in ideal condition. As a general rule, know that if the container becomes damaged, deteriorated, or begins to leak, the wastes should be transferred to a container that is in good condition.

4. Having inadequate aisle space in your container storage area. Adequate aisle space must be maintained to allow unobstructed movement in response to an emergency as well as to perform weekly inspections.

5. Not performing weekly storage area inspections. This was one of the points covered in our Top 10 Hazardous Waste Violations eBook. It is vital to perform these inspections in order to maintain RCRA compliance.

6. Failing to follow compliance documentation rules. This includes, having a contingency plan, having personnel training program and records, having documentation of inspections, having copies of manifests and LDR forms, having biennial reports, having waste analyses/determinations, and having a documented waste minimization program on site.

So what do you think? Are you still making any of these mistakes? And perhaps most importantly, if you are what plans do you have so you can cease making them?