Satellite Accumulation Area (SAA) Requirements 

Satellite accumulation areas (SAA) are addressed in the regulations. Satellite accumulation is temporary accumulation of restricted amounts of hazardous waste by Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) at or near the point of initial generation and under the control of the operator. SAAs allow LQGs and SQGs to accumulate hazardous wastes for longer periods of time than would be allowed at a Central Accumulation Area. SAAs are intended for use in areas of hazardous waste generation where the generation rate is so slow that a full drum may not be accumulated within 90 or 180/270 days, as applicable, or where moving wastes immediately upon generation to a central accumulation is not practicable.

SAA Waste Accumulation Amounts and Limits 

SAAs can be used to manage no more than 55 gallons of non-acute hazardous waste and/or 1 kilogram solid (or 1 quart liquid) of acute hazardous waste at any one time as required. Multiple container management (i.e., several smaller containers for multiple waste streams) may be used that do not exceed a total of 55 gallons of hazardous waste (and/or 1 quart of acutely hazardous waste) for a single satellite area. Each point of hazardous waste generation can have one satellite accumulation area.

Excess Waste Requirements for SAA

Once the 55 gallons of non-acute hazardous waste and/or 1 kilogram solid (or 1 quart liquid) of acute waste is exceeded, the generator must date the excess and remove the excess within three (3) consecutive calendar days. The excess waste must be moved to the central accumulation area (the 90-day for LQGs or 180/270-day for SQGs accumulation area). The generator must date the container again, so that it can be moved off-site within 90 or 180/270 days. Waste may not be transferred from one satellite accumulation area to another satellite accumulation area.

SAA Designation and Procedures

Satellite accumulation area must be “at or near the point of generation” and the waste must be “under the control of the operator of the process generating the waste”. The determination of “at or near” and “under the control of the operator” will be evaluated by DEQ on a generator-by-generator and SAA-by-SAA basis.

All satellite accumulation areas operated by SQGs must meet the Preparedness and Prevention regulations and Emergency Procedures. All satellite accumulation areas operated by LQGs must meet the Preparedness, Prevention and Emergency Procedures. These requirements are clarifications to what currently occurs and generators should work with their local emergency responders to determine what, if any, actually has to be modified to comply with this provision.

In an SAA, close all containers except when adding, removing waste, or consolidating waste. Temporary venting of a container may occur as necessary for the proper operation of equipment, or to prevent dangerous situations, such as build-up of extreme pressure with DEQ approval.

Containers in SAAs must be marked with the words "Hazardous Waste" as well as an indication of the hazards of the contents. Previously SAA containers were allowed to be labeled with “other words to describe the contents.” This is no longer allowed. Hazards of the contents to be placed on the label can be the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic); hazard communication consistent with the Department of Transportation (DOT) labeling requirements or placarding requirements; a hazard statement or pictogram consistent with the OSHA Hazard Communication Standard or a chemical hazard label consistent with the National Fire Protection Association Code 704. This is designed to communicate the risks to workers, waste handlers and emergency responders.

Containers of incompatible waste at SAAs must be segregated, but total volume/weight restrictions for an SAA cannot be exceeded.

Ensure waste is compatible with other wastes in the container and the type of containers. Incompatible wastes, or incompatible wastes and materials (examples provided in here) must not be placed in the same container, unless it complies with these conditions. Hazardous waste must not be placed in an unwashed container that previously held an incompatible waste or material (examples provided here), unless it first complies with these regulations. A container holding a hazardous waste that is incompatible with any waste or other materials accumulated nearby in other containers must be separated from the other materials or protected from them by any practical means. Similarly, the generator must use a container made of or lined with materials that will not react with, and is otherwise compatible with, the hazardous waste to be accumulated, so that the ability of the container to contain the waste is not impaired.

Immediately transfer waste from a leaking container to a container in good condition or immediately transfer the waste and manage it in the central accumulation area.