Love comes and goes, but hazardous waste is forever. Properly managing hazardous waste in a Satellite Accumulation Area (SAA) takes more effort than a typical summer fling.
Generators must mark hazardous waste satellite area containers with as many as three
different dates. Knowing when to date satellite containers is crucial to properly manage hazardous waste and comply with RCRA time and quantity limits for accumulation areas.
1st Date: Satellite “Initial” Date
First dates can be awkward. Luckily, satellite area container prefer not to be tied down by labels.
Keeping track of when a container first starts holding hazardous waste may be important for your management procedures, but nothing in the Federal RCRA regulations requires you to mark this date on the container.
RCRA programs prohibit generators from accumulating hazardous waste in satellite areas for more than a year and require marking an accumulation start date on the container. California and Pennsylvania are two examples. If your state requires this, this first date marking must make clear it is the “initial” start date to distinguish it from the other dates discussed below.
2nd Date: SAA “Excess” Date
Every budding relationship needs clear boundaries.
When a generator accumulates hazardous waste in a satellite area in excess of the limits for satellite areas (55 gallons for non-acute wastes, or 1 quart or 1 kg for acutely hazardous wastes) “the generator must mark the container holding the excess accumulation of hazardous waste with the date the excess amount began accumulating.”
Once any satellite area quantity limit is exceeded, the generator has three days
to either transfer the excess waste to a central accumulation (CAA) area or ship it offsite to an authorized treatment, storage, or disposal facility (TSDF). [40 CFR 262.15(a)(6)]
3rd Date: Central Accumulation Area "Start" Date
Once you hit the 3rd date, it’s time to take things to the next level.
Generators must mark containers with "the date upon which each period of accumulation begins..." This means that a container must be marked with the date the generator:
- Moves a waste container from a satellite area to a central accumulation area; or
- Starts to accumulate waste directly in a central accumulation area, without using a satellite area.
[40 CFR 262.16(b)(6)(i)(C) and 262.17(a)(5)(i)(C)]
Depending on your generator status and situation, you may accumulate hazardous waste in a central accumulation area for up to 90, 180, or even 270 days. The date starts the clock ticking. Before this time limit is up, a generator must either ship the waste to an off-site TSDF or treat the waste to render it non-hazardous.
The Federal RCRA regulations allow the generator to remove (or obliterate) the SAA “excess” date and replace it with the CAA accumulation “start” date. A few states, however, require generators to continue counting out from the “excess” date rather than indicate a new “start” date.
If you forget these dating rules, the consequences will be more severe than your partner sneaking out the window of a restaurant bathroom. The maximum civil penalty for RCRA violations recently increased to $76,764 per day, per violation–and you can't go Dutch on that bill.
Live RCRA Hazardous Waste Classes Start 8/18
Join Lion instructors for comprehensive, in-person training to help satisfy EPA’s RCRA training mandate for all hazardous waste personnel. Develop the expertise you need to manage your site’s hazardous waste from cradle-to-grave and leave with Lion’s unmatched resources and reference material to inform your decision making.
RCRA Hazardous Waste Management Workshop
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Take RCRA training from anywhere! Lion presents initial and refresher RCRA training in a live webinar format throughout Summer 2021.
Webinar: RCRA Hazardous Waste Management
Webinar: RCRA Hazardous Waste Management Refresher
Learn more about RCRA Satellite Areas:
RCRA Basics: Hazardous Waste Satellite Areas
3 Wrong Ways to Place RCRA Satellite Areas
Emergency Preparedness in Hazardous Waste Satellite Areas