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Satellite Accumulation Areas vs. 90-Days: Part 1

In Tuesday’s post we mentioned that the labeling and marking rules can be different for containers in Satellite Accumulation Areas (SAAs). We will cover that (as well as some other specifics of SAAs) in today’s post. It’s important to cover the guidelines for SAAs prior to covering those for 90-days so generators can make sure they are managing their accumulation areas properly.

According to 262.34(c)(1), “a generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in 261.33(e) in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or interim status and without complying with paragraph (a) of this section provided he:

  • Complies with 265.171, 265.172, and 265.173(a) of this chapter; and
  • Marks his containers either with the words “Hazardous Waste” or with other words that identify the contents of the containers.”

So in laymen’s terms, an SAA can be utilized to store up to 55 gallons of hazardous waste (or up to 1 quart of acutely hazardous waste) for an unlimited time and with only some of the requirements needed for 90-day areas. In order to store waste in an SAA the EPA requires that you:

  • Keep your containers in good condition,
  • Ensure that the waste being stored is compatible with the container type,
  • Keep containers closed unless you are adding or removing waste,
  • Make sure you handle containers in such a way that you are preventing leaks or spills, and
  • Mark containers with the words “Hazardous Waste,” or other identification of contents.

The less stringent and numerous regulations for SAAs attract a lot of generators which can cause problems. Most often, these problems arise from generators storing in waste they have designated as an SAA but which is not actually applicable to that designation. For an accumulation area to be an SAA very specific requirements must be met. Firstly, only waste which is generated at the SAA can be stored there. An SAA cannot be used as “temporary staging areas for wastes collected from other areas.” Secondly, an SAA must be located at or near the point of generation. So if waste is generated in a lab the containers should also be located in the lab.

If a generator accumulates more than the limit of 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) at an SAA the EPA requires that they:

  • “Mark the container holding the excess accumulation of hazardous waste with the date the excess amount began accumulating,” and,
  • “Move the container holding the excess accumulation to a container storage area within 3 days.”

And remember, if a generator incorrectly manages a 90-day storage area as an SAA they will be in violation of EPA regulations. For more information about managing waste in 90-day areas keep reading our blog!

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Alternate Waste Container Types for CAAs and SAAs

In talking about closed container guidelines in central and satellite accumulation areas we have been sticking with drums as the primary container type. Since drums are not the only option though, today we will cover some other container types you could use in CAAs or SAAs and what constitutes them as closed.

Other container types applicable to storage in CAAs and SAAs include “bags, durable sacks made of woven synthetic material (polysacks), boxes, twenty cubic yard roll-off boxes or containers, one cube yard heavy duty cardboard boxes with a plastic liner (Gaylord boxes), semi-trailers used to manage solid and semi-solid hazardous wastes, and stainless steel and plastic totes in wire cages to handle liquid hazardous wastes.” Each option has a different method for closing.

Generally speaking, the EPA considers these types of containers “closed” when they are sealed to the extent that hazardous wastes and emissions will be kept inside the container. They use the example of wet paint filters accumulated in bags. “A bag containing dry paint filters may be considered closed when the neck of the bag is tightly bound. However, a bag containing solvent laden wet paint filters would generally not be an acceptable container unless the bag was double lined and the bag could be sealed sufficiently to prevent leaks and emissions.”

Roll-off containers may also be used to hold waste in accumulation areas. According to the EPA, “Large roll-off containers, such as 10 by 20 foot containers, are often used for the accumulation of large volume waste streams, such as F006 sludges from electroplating operations and inorganic wastes where volatility is not an issue.” There are some roll-off containers that are made with lids that open and close. In the case of such containers it would be considered closed when the lid is shut and has a good seal around the rim.

The EPA notes that, “From an operational and practical standpoint, these types of containers are generally located inside the facility where a roof or ceiling and walls protect the container from outside elements. Once the containers are completely full, [they] may be covered with tarps and moved outside to a staging area for subsequent management…EPA generally views these situations as both practical and sufficient to meet compliance with 40 CFR 265.173(a).”

If, however, a roll-off container is kept outdoors while receiving waste it is important that generators keep tarps closed when not adding or removing waste to ensure no condensation can enter the container. The EPA warns that even a small amount of water can be enough to leach hazardous constituents from the waste that could leak out of the roll off.

Roll-off containers holding wastes that contain volatile organic compounds (VOCs) are subject to even stricter requirements. The EPA dictates that, “if a roll-off container is not in light material service then use of a tarp with no visible holes or gaps or open spaces (e.g., a cover and closure device that forms a continuous barrier over the container) is an example of a suitable Level 1 control device. However, use of tarps in this instance is also subject to 40 CFR 264.1086(c)(2) for permitted units and 40 CFR 165.1087(c)(2) for LQGs, which requires closure suitable to weather conditions, including exposure to wind, moisture and sunlight.

If the roll-off container is in light material service, then Level 2 controls are required under Subpart CC. Examples of container loading procedures that meet Level 2 controls include using a submerged-fill pipe or other submerged-fill method to load liquids into the container or a vapor-balancing system or a vapor­ recovery system to collect and control the vapors displaced from the container during filling operations. The use of a tarp would not be an acceptable Level 2 control device.”

Quoted and cited information (unless otherwise noted) for this blog post was gathered from the EPA Memorandum on Closed Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Closed Container Guidelines in SAAs: Part 1

Earlier this week we discussed the guidelines for closed containers in central accumulation areas (CAAs). If you’ll remember, the purpose of these guidelines is to prevent spills and minimize emissions from volatile wastes. Today we are going to talk about what guidelines exist for containers in satellite accumulation areas or SAAs. In particular, we will be covering the closed container guidelines for containers accumulating liquid hazardous wastes in SAAs. Containers containing solid and semi-solid wastes will be covered in a later post.

Unlike CAAs (where waste is often stored after the fact) SAAs are locations in a facility where waste is generated and accumulates in a container. 40 CFR 262.34(c)(1) and (c)(2) set forth the requirements for generators that accumulate hazardous waste in an SAA, including the requirement that the generator must accumulate the waste in a container that is “closed” except when adding or removing waste.

The situation that raises the most questions about closed containers is management of liquid hazardous wastes or free liquids. This includes items like spent organic solvents. These waste accumulations bring up the most questions because so many generators use liquid solvents in their production or manufacturing processes.

The three primary risks associated with liquid hazardous wastes accumulated in containers are risks from inhalation, risk of potential buildup of vapors in the container, and risk of an accidental spill of material. Since the purpose of the closed container guidelines is to minimize emissions and avoid spills, ignitions, or mixing of wastes it is imperative that generators have systems in place to keep containers closed and to prevent leaks or ruptures.

Generally, a container collecting liquid hazardous wastes in an SAA is “closed” when “all lids are properly and securely affixed to the container, except when wastes are actually being added to or removed from the container.” The reasoning behind making sure the lid is totally covering the container is to prevent any volatile emissions from being released and to prevent a spill in the chance case that a container is tipped over.

The EPA recognizes that the frequency with which materials may be added to or removed from a container makes securing lids with snap rings, securely capping bungholes, and/or fastening the lid on by other means inconvenient. That said it is still important that the container is covered tightly. They provide the following advice:

“We believe containers holding free liquids, or liquid hazardous waste, in the SAA would meet the regulatory definition of “closed” through a variety of approaches. For example, special funnels with manually or spring closed lids or other similar closing devices could be used for closed-head drums or closed-top drums (e.g., containers that have two bung holes with non-removable lids).

Similarly, funnels used to add or remove liquid hazardous wastes from these containers would be screwed tightly into the bunghole and fitted with a gasket, if necessary, to seal the funnel lid firmly closed. In some cases, the funnel lids for closed-head drums and closed­ top drums may be fitted with a locking mechanism. This keeps the lid in a closed position. All other openings on the drum lid should generally be properly closed or capped.

Another alternative is the use of a funnel with a one-way valve that allows hazardous waste to enter the container, but prohibits the waste or emissions from exiting the container… Liquid hazardous wastes also can be accumulated in open-head drums or open-top containers (e.g., where the entire lid is removable and typically secured with a ring and bolts or a snap ring) and meet the definition of “closed,” provided the rings are clamped or bolted to the container.

In some situations, the container could be considered closed if the lid covers the container top securely even though the rings are not clamped or bolted. Several states take this approach, and EPA believes it reflects a reasonable interpretation of the regulations.”

Quoted and cited information (unless otherwise noted) for this blog post was gathered from the EPA Memorandum on Closed Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Attached Waste Containers & Satellite Accumulation

Last Thursday we posted a collection of questions and answers related to hazardous waste containment. One question was as follows:

“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?” 

With the answer being “Yes.”

After posting we received a comment that asked a very good question:

“If the container is attached, why wouldn’t it be considered ‘part of the process’?”

While I sent an answer to the person who asked the question initially, I thought it might be beneficial to explain the answer more fully today so everyone has access. Because I was not certain of the answer, I went to our Director of Corporate Compliance and Safety for clarification. This is what I learned.

The question asked can be addressed by a Memorandum issued by Robert Springer, USEPA Office of Solid Waste on March 17, 2004 and answered as follows:

Yes. Even if the discharging unit is not regulated under RCRA, the attached containers that collect hazardous wastes from such equipment must be in compliance with the Satellite Accumulation Area regulations, if those containers collect wastes that are listed or characteristic hazardous wastes. Waste containers in Satellite Accumulation Areas must be:

      • In good condition (265.171)
      • Compatible with their contents (265.172)
      • Labeled with “words that identify the contents of the container” or the words “hazardous waste” (262.34(c)(1)(ii)).

In addition, the containers in Satellite Accumulation Areas must be closed, except when adding or removing hazardous waste (265.173(a)). Generators would not be required to keep such containers closed while hazardous waste is being added to the container; but generators would need to keep them closed when the hazardous waste is not being discharged to the attached container.

The container(s) attached to such equipment is a point of generation. It is possible for there to be multiple pieces of equipment within one Satellite Accumulation Area, and thus multiple points of generation within a single Satellite Accumulation Area, provided all the pieces of equipment are “at or near” each other and “under the control of the operator of the process generating the waste.” Under this scenario, the total amount of hazardous waste in the Satellite Accumulation Area would be limited to 55 gallons (or 1 quart of acute hazardous waste) and a generator would be allowed to consolidate like hazardous wastes from multiple discharging units.

Now the question becomes one of whether something is “integral to the process”…,

There may be occasion where waste is being generated in a container. The most important thing to remember in these cases is that regulations can vary from state to state. The State of Colorado, for example, has issued guidance about whether certain pieces of equipment are satellite accumulation or not:

‘In-process waste does not need to be managed as a satellite accumulation area. In-process waste refers to waste that is continuously generated and is an integral part of the system generating the waste, or waste that is accumulated during a process and is moved to a satellite-accumulation or 90-day area at the end of a work shift. For example, consider a machine shop which grinds metals parts on a lathe. The lathe includes a recirculating solvent cleaning bath which is an attached, hard-plumbed integral part of the system. The waste generated by this system is considered in-process. Once the cleaning bath is removed from the lathe, the waste solvent must be moved to a satellite-accumulation or 90-day area. Another example could be a container for waste generated by a High Pressure Liquid Chromatograph which is physically connected to the HPLC. Once the container is full and/or removed or disconnected from the HPLC, the waste must be moved to a satellite-accumulation or 90-day area. A third example of accumulating waste during a process could be a group of six employees working at the same bench, cleaning equipment with listed solvents on a Q-tip. Each employee has a one-gallon collection container for used Q-tips at their work station. At the end of the work shift, the employees consolidate their one-gallon containers in a 55-gallon container located at the end of the work bench. In this example, the one-gallon containers are considered a collection point for in-process waste and the 55-gallon container is considered a satellite accumulation area. “Integral to the process” is the primary condition for in-process waste, and may include a hard-plumbed container or other physical connection; however, physical connection is not a required condition (see above Q-tip example).’

Our best suggestion is for the generator to consider any guidance that they may have received from their state regulatory officials as to whether or not the container would be satellite accumulation or not as it would be dependent upon the state interpretation. It is possible that under certain circumstances and activities, the satellite provisions would prevail and will be entirely dependent on the specific situation.

And please remember, it is important to note that this blog 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.