Frequent Questions

What regulations apply to generators of hazardous waste managed at satellite accumulation areas?

The satellite accumulation provisions allow for reduced requirements for hazardous waste accumulated in containers at or near any point of generation (§262.34(c)).  A generator may accumulate up to fifty-five gallons of hazardous waste or one quart of acutely hazardous waste at each satellite accumulation area if it is under the control of the person operating the process that generates the waste (§262.34(c)).  Limited standards, such as labeling, keeping the containers closed and maintaining containers in good condition, apply to satellite areas (§262.34(c)(1)(i) and (ii)).  Once the generator exceeds the volume limits, the excess waste must be dated and moved within three days to the central accumulation area. At the central accumulation area, the waste must be managed in accordance with the fuller hazardous waste accumulation standards in §262.34.

Additional guidance on satellite accumulation is available in the following documents:

Memo, Springer to Regions; March 17, 2004 (RCRA Online 14703)
Memo, Cotsworth to Regions; August 16, 2002 (RCRA Online 14618)
Monthly Call Center Report Question; December 2001 (RCRA Online 14587) [PDF 8K]
Monthly Call Center Report Question; December 1999 (RCRA Online 14418)
Monthly Call Center Report Question; February 1999 (RCRA Online 14337)
Memo, ShapiRCRA Online to Boykin; May 1, 1996 (RCRA Online 14029)
Monthly Call Center Report Question; February 1996 (RCRA Online 13777)
Memo, ShapiRCRA Online to Dolce; February 10, 1994 (RCRA Online 11812)
Memo, Lowrance to Redington; February 23, 1993 (RCRA Online 11728)
Monthly Call Center Report Question; October 1990 (RCRA Online 13410)
Monthly Call Center Report Question; April 1990 (RCRA Online 13365)
Memo, Lowrance to Kirk; August 2, 1989 (RCRA Online 11452)
Memo, Lowrance to Duprey; October 27, 1988 (RCRA Online 11373) [PDF 4K]
Memo, BRCRA Onlinewn to Bradford; February 11, 1987 (RCRA Online 12859)

Note: On November 28, 2016, EPA published the Hazardous Waste Generator Improvements Final Rule, which makes several revisions to the hazardous waste generator regulations. These revisions may affect the information provided in this FAQ. The final rule and additional information, including a fact sheet, frequent questions, and a webinar recording and slides, are available at www.epa.gov/hwgenerators/final-rule-hazardous-waste-generator-improvements.

The Hazardous Waste Generator Improvements Final Rule is effective on May 30, 2017; however, implementation in a particular state depends on the state’s authorization status. A discussion of the effect that this final rule will have on state authorization is available on page 85801 of the rule. Information about how the rule will affect the requirements in this FAQ in a particular state is best obtained from the state hazardous waste program. A list of state hazardous waste programs is available at www.epa.gov/hwgenerators/links-hazardous-waste-programs-and-us-state-environmental-agencies.

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