Satellite Accumulation and Labeling Requirements for Region VII

John M. BakeriSi Environmental

Consulting Services Manager

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RCRA Hazardous Waste Container Management Requirements

Generators are required to containerize hazardous waste.

Each container must be compatible

with the hazardous waste to be placed into the container.

Each container must be in good condition; no deep creases, dents, severe rust or corrosion, and be of adequate strength and integrity to contain the waste.

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RCRA Hazardous Waste Container Management Requirements

Each container must be clearly and legibly stenciled, labeled, or marked with the words “Hazardous Waste”

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RCRA Hazardous Waste Container Management Requirements

Containers must be closed at all times unless adding waste to or removing waste from.• Lids must be tightly

closed.• Bungs must be

wrench-tightened.• Rings/collars must be

clamped/wrench-tightened.

• Funnels must be secured into the drum and lids secured.

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“Closure Failures”

Hazardous Waste Satellite Accumulation

Satellite accumulation is the storage of hazardous waste at the point of production.

Businesses that produce hazardous waste are allowed to store small amounts of hazardous waste at or near the equipment or process that generated the waste.

Satellite accumulation is

allowed when the hazardous waste is stored in an area under immediate control of the operator of the process that generates the waste.

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Satellite Accumulation

Generators may accumulate up to 55 gallons of HW or 1 quart of acutely hazardous waste in an area near the point of generation and under the control of the operator.

Container must be marked with the words “Hazardous Waste”

Must remain closed except when adding or removing HW

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Hazardous Waste Satellite Accumulation

Satellite accumulation areas do not have to meet the full requirements that apply to non-satellite or hazardous waste permitted storage areas.

Satellite accumulation drums are usually not dated until the container is full. This is true in KS, NE, and IA. However, some states have alternative satellite container dating requirements. For instance in Missouri, the hazardous waste is dated at the beginning of waste satellite accumulation and can be kept in satellite accumulation for up to one year before the facility has to meet the generator requirements for storing hazardous waste.

Always check with State requirements for Satellite Accumulation dating requirements

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Satellite Accumulation

When container is full, or exceeds the area quantity limits, or is no longer under the control of an operator, or has become a storage container...

Mark the accumulation start date

Move to HW storage area within 3 days

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Satellite AccumulationFinal thoughts:

Satellite containers do not require weekly or monthly inspection; only “hazardous waste storage containers”..

A satellite accumulation container must not accumulate more than 55 gallons of hazardous waste, even if the capacity is greater than 55 gallons.

A satellite accumulation hazardous waste

container cannot be moved from one satellite accumulation area to another.

Federal regulations allow more than one satellite accumulation container in an area, however, in Kansas, there must be only one container for each type of hazardous waste at each point of generation.

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