Frequent Questions

A facility generates hazardous waste and subsequently places that hazardous waste in 1-gallon containers at or near the point of generation before consolidating that waste into a 55-gallon drum for accumulation. Does RCRA allow multiple initial accumulati

The satellite accumulation area (SAA) provisions allow a generator to accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in 40 CFR 261.33(e) in containers at or near the point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the hazardous waste, without a permit of interim status, provided the generator complies with the 262.34(c)(1)(i) and (ii).

It is permissible to have more than one container of hazardous waste in an SAA. The regulations do not limit the number of hazardous wastes or the number of containers that can be placed in an SAA. The regulations limit only the total volume of hazardous waste at a single SAA to 55 gallons (or 1 quart of acutely hazardous waste). If either of the specified volumes is exceeded, the generator must comply with 262.34(c)(2).

 It is also permissible for generators to transfer hazardous waste between containers to facilitate storage, transportation, or treatment. For example, a generator may wish to consolidate several partially full containers of the same hazardous waste from one SAA into one container before transferring it to a less than 90-day or less than 180-day storage area. 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 generating the waste.” It is not possible for EPA to delineate for all situations what constitutes a single SAA versus what constitutes separate SAAs.

Generators may not move hazardous waste 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 of disposal at a facility with a permit or interim status. A generator may consolidate hazardous wastes from multiple SAAs at a central accumulation area. (Memo, Springer to Regions; March 17, 2004 (RCRA Online #14703).

Additional information is available in the following guidance documents:

Memo, Weddle to Ware; November 1, 1993 (RCRA Online #11791)
Monthly Call Center Report Question; June 1983 (RCRA Online #12116)  

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