Ever had to lug buckets of hazardous waste from where it was generated to a central storage area? There is a much easier way. It is called the satellite accumulation area (SAA).

EPA's RCRA regulations allow the accumulation of up to 55 gallons of hazardous wastes at or near the point of generation without activating the 90- or 180-day storage time limit. This is an SAA. More than one SAA is allowed, but each one cannot have more than 55 gallons. So if two incompatible waste streams are generated at one location, they must be placed in separate containers, but the total volume cannot be more than 55 gallons. (Note: If there are acute hazardous wastes, the total volume at the SAA is limited to one quart.)

As might be expected, there are a few requirements:

1. Keep it in sight

First of all, the SAA must be "at or near the point of waste generation" and also "under the control of the operator of the process generating the waste." The commonly accepted interpretation of the phrase "under the control of the operator" is that the waste container must be in the line of sight of the operator. That's also EPA's interpretation. If the waste has to be stored out of the operator's sight of the operator for safety, e.g. in a shed, then access to the shed must be through a lock controlled by the operator.

The container also must be in good condition (40 CFR 265.171), wastes stored at the SAA must be compatible (40 CFR 265.172) and the containers must be kept closed (40 CFR 265.173 (a)).

2. Keep it labeled and 'closed'

The requirement to keep containers closed except when adding or removing waste is a problematic one for many generators. The rule says that "a container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste." It does not specifically define the word "closed."

When EPA came up with the rule in 1980, it intended the word to mean "vapor tight and spill proof" [sic]. So if a large funnel is screwed into the bunghole of a container and waste is poured into the drum through it, is that vapor-tight and spill-proof? If some highly volatile solvents are stored in the container, is that funnel system vapor-tight? If the container gets tipped over, is the funnel system spill-proof? Citations will be issued depending on the content in the container and the state inspector's interpretation of the word "closed." To be on the safe side, consider putting a shut-off valve between the funnel and the drumhead.

Make sure to properly label all containers.

3. When full, move it or don't use it

Once the 55-gallon container is full (or the 55-gallon total limit is reached with more than one container), any excess waste must be moved to the central storage area within three days, where the regular 90- or 180-day storage timer must begin.

4. Inspections

Another benefit of the SAA is that specified weekly inspections are not needed, as they are at central storage areas. (By the way, failure to conduct weekly inspection at the central storage area is one of the most frequently cited RCRA violations.) Some generators actually ship their wastes that have been accumulated at the SAA directly out the door, avoiding the weekly inspection requirement altogether.

There is an excellent EPA guidance document on this topic. Go to EPA's RCRA Online website and download document number RO 14703. PE