a
Generators
of
$
1000
kg/
month
of
hazardous
waste
or
>
1
kg/
month
of
acute
hazardous
waste
are
large
quantity
generators
(
LQGs).
Generators
of
>
100
kg/
month
but
<
1000
kg/
month
of
hazardous
waste
are
small
quantity
generators
(
SQGs).
Generators
of
#
100
kg/
month
of
hazardous
waste
and
#
1
kg/
month
of
acute
hazardous
waste
are
conditionally
exempt
small
quantity
generators
(
CESQGs)
and
are
regulated
under
40
CFR
261.5.
The
regulations
for
CESQGs
are
not
discussed
in
this
memo.
MEMORANDUM
SUBJECT:
Frequently
Asked
Questions
about
Satellite
Accumulation
Areas
FROM:
Robert
Springer,
Director
Office
of
Solid
Waste
TO:
RCRA
Directors,
EPA
Regions
1­
10
Purpose
The
purpose
of
this
memo
is
to
reiterate
and
clarify
the
Environmental
Protection
Agency's
(
EPA)
regulations
under
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
hazardous
waste
management
program
regarding
satellite
accumulation
areas
(
SAAs).
For
convenience,
this
memo
pulls
together
answers
to
many
of
the
frequently
asked
questions
EPA
receives
regarding
SAAs.
Many,
but
not
all,
of
the
questions
in
this
memo
have
been
answered
by
EPA
in
previous
letters
and
documents.
For
those
questions
that
have
been
answered
previously,
citations
to
relevant
memos
and
Federal
Register
preambles
are
provided
in
numbered
endnotes.

Summary
of
Generator
Accumulation
Regulations
When
accumulating
hazardous
waste
on­
site,
large
quantity
generators
(
LQGs)
must
comply
with
40
CFR
262.34(
a)
and
small
quantity
generators
(
SQGs)
must
comply
with
40
CFR
262.34(
d)
to
avoid
the
requirement
to
obtain
a
hazardous
waste
treatment,
storage,
or
disposal
permit.
a
LQGs
may
accumulate
hazardous
waste
on­
site
without
interim
status
or
a
permit
for
up
to
90
days,
while
SQGs
have
up
to
180
days
to
accumulate
hazardous
waste
without
interim
status
or
a
bSmall
quantity
generators
who
must
transport
hazardous
waste
>
200
miles
for
treatment,
storage
or
disposal
may
accumulate
waste
on­
site
for
270
days
without
a
permit
or
interim
status
(
262.34(
e)).
Large
quantity
generators
of
F006
may
accumulate
hazardous
waste
on­
site
for
180
days
without
a
permit
or
interim
status
provided
the
conditions
of
262.34(
g)(
1)­(
4)
are
met.

2
permit.
b
The
Agency
sometimes
refers
to
these
generator
accumulation
areas
as
"
90­
day"
or
"
180­
day"
areas,
or
"
central
accumulation"
areas.

The
satellite
accumulation
provisions
allow
generators
to
accumulate
up
to
55
gallons
of
hazardous
waste
(
or
1
quart
of
acute
hazardous
waste)
in
containers
that
are:

°
at
or
near
any
point
of
generation,
and
°
under
the
control
of
the
operator,

with
fewer
requirements
than
for
central
accumulation
areas,
provided
the
generator
complies
with
the
requirements
of
262.34(
c).

When
a
generator
accumulates
hazardous
waste
on­
site
in
containers,
the
regulations
for
90­
day
areas,
180­
day
areas
and
SAAs
all
refer
generators
to
the
container
management
standards
in
Part
265
Subpart
I.
The
table
below
identifies
the
sections
of
Part
265
Subpart
I
that
must
be
followed
in
each
case:

Table
1
Container
Management
Standards
for
Generators
Section
of
Part
265
Subpart
I
Satellite
accum.
area
180­
day
area
(
SQG)
90­
day
area
(
LQG)

265.171
Condition
of
containers
YES
YES
YES
265.172
Compatibility
of
waste
with
containers
YES
YES
YES
265.173
(
a)
Keep
closed,
except
when
adding/
removing
waste
YES
YES
YES
(
b)
Handle
containers
to
avoid
ruptures
and
leaks
no
YES
YES
265.174
Inspections
no
YES
YES
265.176
Special
requirements
of
ignitable
or
reactive
wastes
no
no
YES
265.177
Special
requirements
for
incompatible
wastes
no
YES
YES
265.178
Air
emission
standards
no
no
YES
3
In
addition
to
the
container
standards
indicated
above,
the
regulations
for
both
SQGs
and
LQGs
have
requirements
for
container
labeling;
personnel
training;
preparedness
and
prevention;
emergency
procedures;
and
waste
analysis
plans
when
treating
hazardous
waste
on­
site
to
meet
the
land
disposal
restriction
(
LDR)
treatment
standards.
LQGs
also
must
have
contingency
plans
while
SQGs
must
not
accumulate
more
than
6000
kg
of
hazardous
waste
on­
site
at
any
one
time.

In
contrast,
additional
requirements
for
SAAs
are
limited
to:

1.
Generators
must
label
satellite
containers
of
hazardous
waste
with
the
words
"
Hazardous
Waste"
or
"
with
other
words
that
identify
the
contents
of
the
containers."
(
262.34(
c)(
1)(
ii))

2.
When
a
generator
accumulates
more
than
55
gallons
of
hazardous
waste
(
or
1
quart
of
acute
hazardous
waste),
the
generator
must
(
262.34(
c)(
2)):

°
mark
the
container
with
the
date
on
which
55
gallons
(
or
1
quart
of
acute
hazardous
waste)
is
exceeded,
and
°
remove
the
excess
of
55
gallons
(
or
1
quart
of
acute
hazardous
waste)
within
three
days
or
comply
with
the
90­
day
area
or
180­
day
area
regulations,
as
appropriate.

Frequently
Asked
Questions
about
Satellite
Accumulation
Areas
1.
Question:
Can
small
quantity
generators
establish
SAAs
according
to
262.34(
c)
for
their
hazardous
waste?

Answer:
Yes.
Both
LQGs
and
SQGs
may
take
advantage
of
the
reduced
requirements
while
hazardous
waste
is
in
SAAs,
provided
it
is
managed
in
accordance
with
all
the
provisions
of
40
CFR
262.34(
c).
1
If
an
SQG
or
LQG
accumulates
more
than
55
gallons
of
hazardous
waste
(
or
1
quart
of
acute
hazardous
waste)
at
an
SAA,
the
excess
must
be
removed
within
three
days.
If
after
that
period,
the
excess
is
not
removed,
LQGs
must
comply
with
262.34(
a)
and
SQGs
must
comply
with
262.34(
d),
with
respect
to
the
excess
amounts.

2.
Question:
If
a
generator
accumulates
more
than
55
gallons
of
hazardous
waste
(
or
1
quart
of
acute
hazardous
waste)
at
an
SAA,
when
should
the
generator
date
the
container(
s)?
When
55
gallons
of
hazardous
waste
(
or
1
quart
of
acute
hazardous
waste)
is
exceeded,
or
when
the
container
is
moved
to
the
central
accumulation
area?

Answer:
When
55
gallons
of
hazardous
waste
(
or
1
quart
of
acute
hazardous
waste)
is
exceeded
in
an
SAA,
the
generator
needs
to
date
the
container,
so
that
the
generator
can
4
move
the
excess
to
the
90­
day
or
180­
day
area
within
three
days
(
262.34(
c)(
2)).
Then
when
3
days
have
passed,
or
when
the
container
is
moved
to
the
central
accumulation
area,
the
generator
needs
to
date
the
container
again,
so
that
it
can
be
moved
off­
site
within
90
or
180
days
(
262.34(
a)(
2)
and
262.34(
d)(
4),
respectively.
(
Of
course,
the
container
does
not
need
to
be
dated
after
it
is
removed
from
the
SAA
if
the
excess
waste
is
moved
directly
to
a
permitted
or
interim
status
unit.)
This
means
that
an
LQG
has
up
to
93
days
and
a
SQG
has
up
to
183
days
for
on­
site
accumulation
time
once
55
gallons
of
hazardous
waste
(
or
1
quart
of
acute
hazardous
waste)
has
been
exceeded
at
the
SAA
­
up
to
three
days
in
the
SAA,
followed
by
up
to
90
or
180
days
in
the
central
accumulation
area.
2
3.
Question:
When
a
generator
accumulates
more
than
55
gallons
of
hazardous
waste
(
or
1
quart
of
acute
hazardous
waste)
at
an
SAA,
the
excess
of
55
gallons
(
or
the
excess
of
1
quart
of
acute
hazardous
waste)
needs
to
be
removed
from
the
SAA
within
three
days.
What
is
meant
by
"
three
days"?

Answer:
Three
days
means
three
consecutive
days.
It
does
not
mean
three
working
days
or
three
business
days.
Originally,
the
Agency
had
proposed
to
use
72
hours
as
the
time
limit
but
realized
that
determining
when
72
hours
had
elapsed
would
have
required
placing
both
the
date
and
time
of
day
on
containers.
In
the
final
rule
the
Agency
switched
to
using
three
days
so
that
generators
only
need
to
date
containers
that
hold
the
excess
of
55
gallons
of
hazardous
waste
(
or
1
quart
of
acute
hazardous
waste).
3
4.
Question:
If
an
SAA
has
a
full
4­
gallon
container
of
hazardous
waste,
does
the
generator
have
to
remove
the
container
from
the
SAA
within
three
days
of
being
filled?

Answer:
No.
There
is
no
federal
requirement
that
full
containers
of
hazardous
waste
be
removed
from
an
SAA
within
three
days
of
being
filled.
Only
the
excess
of
55
gallons
of
hazardous
waste
(
or
the
excess
of
1
quart
of
acutely
hazardous
waste)
must
be
removed
within
three
days.

5.
Question:
The
container
management
standards
of
265.173(
a)
state,
"
A
container
holding
hazardous
waste
must
always
be
closed
during
storage,
except
when
it
is
necessary
to
add
or
remove
waste."
Does
this
mean
that
hazardous
wastes
have
to
be
managed
and/
or
disposed
in
the
containers
in
which
they
were
originally
accumulated?

Answer:
No.
Generators
may
transfer
hazardous
waste
between
containers
to
facilitate
storage,
transportation,
or
treatment.
4
For
example,
a
generator
may
wish
to
consolidate
several
partially
full
containers
of
the
same
hazardous
waste
from
an
SAA
into
one
container
before
transferring
it
to
a
central
accumulation
area.
Generators
also
may
5
transfer
hazardous
waste
between
containers
in
central
accumulation
areas.
However,
the
90­
day
or
180­
day
"
clock"
for
accumulation
does
not
restart
if
the
hazardous
waste
is
transferred
to
another
container.

6.
Question:
Do
containers
in
SAAs
have
to
comply
with
the
air
emission
standards
of
Part
265
Subparts
AA,
BB,
and
CC?

Answer:
No.
Containers
in
SAAs
are
not
required
to
comply
with
the
air
emission
standards
of
Part
265
Subparts
AA,
BB,
and
CC.
5
Likewise,
SQGs
are
not
required
to
comply
with
the
air
emission
standards
at
their
180­
day
accumulation
areas.
LQGs,
however,
are
required
to
comply
with
the
RCRA
air
emission
standards
at
their
90­
day
accumulation
areas.
Therefore,
when
an
LQG
transfers
waste
from
an
SAA
to
a
90­
day
central
accumulation
area,
the
applicable
portions
of
the
air
emission
standards
of
Part
265
Subparts
AA,
BB,
and
CC
must
be
met
at
the
90­
day
central
accumulation
area.

7.
Question:
Section
265.174
of
Subpart
I
requires
that
containers
be
inspected
at
least
weekly
for
leaks
and
deterioration
caused
by
corrosion
or
other
factors.
Both
LQGs
and
SQGs
must
inspect
containers
in
their
central
accumulation
areas.
Are
SQGs
or
LQGs
required
to
inspect
hazardous
waste
containers
in
SAAs?

Answer:
No.
Inspections
of
containers
(
whether
weekly
or
some
other
frequency)
in
SAAs
are
not
required,
so
long
as
the
provisions
of
262.34(
c)
are
met.
6
Section
265.174,
which
requires
inspections,
is
not
among
the
provisions
listed
in
262.34(
c)
for
SAAs
(
see
Table
1).
However,
the
SAA
regulations
do
require
that
waste
containers
in
an
SAA
must
be
under
the
control
of
the
operator
of
the
process
generating
the
waste,
in
good
condition
(
265.171),
compatible
with
its
contents
(
265.172),
and
closed
except
when
adding
or
removing
waste
(
265.173),
which
should
achieve
the
goal
of
inspections:
containers
that
are
free
of
leaks
and
deterioration.

8.
Question:
SQGs
must
conduct
training
in
accordance
with
262.34(
d)(
5)(
iii)
and
LQGs
must
conduct
training
in
accordance
with
265.16.
Do
the
RCRA
regulations
require
training
of
personnel
working
in
SAAs?

Answer:
No.
The
RCRA
regulations
do
not
require
training
of
personnel
working
in
SAAs.
7
Personnel
that
have
access
to
or
work
in
central
accumulation
areas,
including
those
that
move
hazardous
waste
from
a
SAA
to
a
central
accumulation
area,
must
be
trained.
As
the
ones
actually
generating
hazardous
waste,
however,
personnel
working
in
SAAs
need
to
be
familiar
enough
with
the
chemicals
with
which
they
are
working
to
know
when
they
have
generated
a
hazardous
waste
so
that
it
will
be
managed
in
accordance
with
the
RCRA
regulations.
6
9.
Question:
The
preamble
to
the
final
rule
that
added
262.34(
c),
states,
"...
only
one
waste
will
normally
be
accumulated
at
each
satellite
area."
8
Can
there
be
more
than
one
hazardous
waste
at
an
SAA?
Can
there
be
more
than
one
container
at
an
SAA?

Answer:
Yes.
It's
permissible
to
have
more
than
one
hazardous
waste
in
an
SAA.
Likewise,
it's
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
acute
hazardous
waste).
If
there
are
multiple
containers
of
hazardous
waste
in
an
SAA,
each
container
must
be
labeled
in
accordance
with
262.34(
c)(
1)(
ii).

Because
the
Agency
did
not
anticipate
that
generators
would
accumulate
multiple
hazardous
wastes/
containers
in
an
SAA,
a
cross­
reference
to
the
requirements
for
the
safe
storage
of
incompatible
wastes
was
not
included
as
part
of
the
container
management
standards
for
SAAs.
Nevertheless,
good
management
practices
clearly
dictate
that
incompatible
wastes
should
be
stored
separately.
Furthermore,
in
the
event
that
any
wastes,
including
incompatible
wastes,
are
stored
in
such
a
way
that
they
may
pose
an
imminent
and
substantial
threat
to
health
or
the
environment,
§
7003
of
RCRA
allows
the
Agency
to
take
enforcement
action
to
eliminate
the
threat.

10.
Question:
Can
a
facility
have
multiple
SAAs?

Answer:
Yes.
The
regulations
do
not
limit
the
total
number
of
SAAs
at
a
generator's
facility.
Likewise,
the
regulations
do
not
limit
the
total
amount
of
hazardous
waste
that
can
be
accumulated
at
various
SAAs
across
a
facility.
The
regulations
limit
only
the
volume
of
hazardous
waste
that
can
be
accumulated
at
a
single
SAA
to
55
gallons
(
or
1
quart
of
acute
hazardous
waste).

It's
not
possible
in
a
memo
for
the
Agency
to
delineate
for
all
situations
what
constitutes
a
single
SAA
versus
what
constitutes
separate
SAAs.
The
regulations
state
that
a
generator
may
accumulate
hazardous
waste
"
in
containers
at
or
near
any
point
of
generation
where
wastes
initially
accumulate,
which
is
under
the
control
of
the
operator
of
the
process
generating
the
waste."
For
additional
guidance
about
the
Agency's
intent,
refer
to
the
preamble
to
the
final
rule
for
SAAs,
which
states,
"
Certainly...
a
row
of
full
55
gallon
drums
spaced
5
feet
apart
along
the
factory
wall,"
is
not
a
row
of
distinct
SAAs,
but
is
one
SAA.
9
7
11.
Question:
If
a
facility
has
multiple
SAAs,
can
hazardous
waste
be
moved
from
one
SAA
to
another?

Answer:
No.
Generators
may
not
move
hazardous
wastes
between
SAAs.
10
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.

12.
Question:
Do
generators
have
to
include
the
hazardous
waste
in
SAAs
in
the
monthly
quantities
for
determining
generator
status
(
i.
e.,
SQG
or
LQG)?

Answer:
Yes.
Generators
must
include
all
the
hazardous
waste
in
the
various
SAAs
in
their
monthly
quantities
for
determining
generator
status.
11
Sections
261.5(
c)
and
(
d)
identify
hazardous
wastes
that
do
not
have
to
be
counted
when
determining
generator
status.
Hazardous
waste
stored
in
SAAs
is
not
on
this
list;
therefore,
hazardous
waste
in
SAAs
must
be
included
in
the
generator's
monthly
quantity
determination.

13.
Question:
When
a
facility
has
equipment
that
discharges
hazardous
wastes
to
attached
containers,
do
the
containers
that
collect
such
wastes
have
to
be
in
compliance
with
the
SAA
regulations?

Answer:
Yes.
Even
if
the
discharging
unit
is
not
regulated
under
RCRA,
the
attached
containers
that
collect
hazardous
wastes
from
such
equipment
must
be
in
compliance
with
the
SAA
regulations,
if
those
containers
collect
wastes
that
are
listed
or
characteristic
hazardous
wastes.
Waste
containers
in
SAAs
must
be:

°
in
good
condition
(
265.171)
°
compatible
with
their
contents
(
265.172)
°
labeled
with
"
words
that
identify
the
contents
of
the
container"
or
the
words
"
hazardous
waste"
(
262.34(
c)(
1)(
ii)).
8
In
addition,
the
containers
in
SAAs
must
be
closed,
except
when
adding
or
removing
hazardous
waste
(
265.173(
a)).
Generators
would
not
be
required
to
keep
such
containers
closed
while
hazardous
waste
is
being
added
to
the
container;
but
generators
would
need
to
keep
them
closed
when
the
hazardous
waste
is
not
being
discharged
to
the
attached
container.

The
container(
s)
attached
to
such
equipment
is
a
point
of
generation.
It
is
possible
for
there
to
be
multiple
pieces
of
equipment
within
one
SAA,
and
thus
multiple
points
of
generation
within
a
single
SAA,
provided
all
the
pieces
of
equipment
are
"
at
or
near"
each
other
and
"
under
the
control
of
the
operator
of
the
process
generating
the
waste."
Under
this
scenario,
the
total
amount
of
hazardous
waste
in
the
SAA
would
be
limited
to
55
gallons
(
or
1
quart
of
acute
hazardous
waste)
and
a
generator
would
be
allowed
to
consolidate
like
hazardous
wastes
from
multiple
discharging
units.

14.
Question:
If
a
facility
has
very
small
containers
(
e.
g.,
vials
or
tubes)
of
hazardous
waste
that
are
too
small
to
label
with
the
words
"
hazardous
waste"
or
"
other
words
that
identify
the
contents
of
the
container,"
how
should
the
containers
be
labeled?

Answer:
Generally,
we
would
expect
the
small
containers
to
be
placed
in
properly
labeled
larger
containers,
which
would
have
the
added
benefit
of
secondary
containment
should
the
small
containers
break.
However,
other
approaches
that
would
achieve
the
same
result
also
would
be
acceptable.

Additional
Information
Please
note
that
this
letter
discusses
only
the
federal
hazardous
waste
regulations.
States
that
are
authorized
to
implement
the
RCRA
program
may
have
regulations
that
are
different
than
the
federal
regulations
provided
they
are
not
less
stringent
than
the
federal
program.
Please
consult
your
state
regulatory
requirements.
If
you
have
questions
about
the
federal
hazardous
waste
regulations
discussed
in
this
memo,
please
contact
Kristin
Fitzgerald
at
(
703)
308­
8286
or
Fitzgerald.
Kristin@
epa.
gov.
9
1.
April
1990;
RCRA/
Superfund
Hotline
Monthly
Report;
RCRA
Online
#
13365.

2.
October
1990;
RCRA/
Superfund
Hotline
Monthly
Report;
RCRA
Online
#
13410.

3.
December
20,
1984;
49
FR
49568;
Final
Rule;
Docket
#
RCRA­
1984­
0028.

4.
November
1,
1993;
Weddle
to
Ware;
RCRA
Online
#
11791.

5.
February
1996;
RCRA/
Superfund
Hotline
Monthly
Report;
RCRA
Online
#
13777.

6.
December
1999;
RCRA/
Superfund
Hotline
Monthly
Report;
RCRA
Online
#
14418
7.
December
20,
1984;
49
FR
49570;
Final
Rule;
Docket
#
RCRA­
1984­
0028.

8.
December
20,
1984;
49
FR
49570;
Final
Rule;
Docket
#
RCRA­
1984­
0028.

9.
December
20,
1984;
49
FR
49569;
Final
Rule;
Docket
#
RCRA­
1984­
0028.

10.
February
1999;
RCRA/
Superfund
Hotline
Monthly
Report;
RCRA
Online
#
14337.

11.
February
10,
1994;
Shapiro
to
Dolce;
RCRA
Online
#
11812.

To
obtain
Federal
Register
notices,
search
EPA's
E­
docket
at
www.
epa.
gov/
edocket.

To
obtain
references
other
than
Federal
Register
notices,
search
RCRA
Online
at
www.
epa.
gov/
rcraonline.
Endnotes
for
Q&
A
Portion
of
FAQ
