Frequent Questions

If a facility has multiple satellite accumulation areas SAAs, can hazardous waste be moved from one SAA to another?

No. Generators may not move hazardous wastes between SAAs. Once a hazardous waste leaves an SAA, it must be destined for a central accumulation area that is regulated under 262.34(a) or (d) or for final treatment or disposal at a facility with a permit or interim status.

However, a single SAA may have multiple points of generation. Movement or consolidation of hazardous waste within an SAA is permissible, as long as it remains "at or near" the "point of generation" and "under the control of the operator of the process generating the waste."

In addition, a generator may have more than one 90-day or 180-day central accumulation area, and the regulations do not prohibit the movement of hazardous waste from one fully regulated central accumulation area to another, as long as the hazardous waste remains on-site. However, the 90-day or 180-day "clock" for accumulation does not restart if the hazardous waste is moved to another central accumulation area. Additional guidance on satellite accumulation is available in the following documents:

Memo, Springer to RCRA Directors; March 17, 2004 (RCRA Online #14703)
Monthly Call Center Report Question; February 1999 (RCRA Online #14337)
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