Search

Can a RCRA Satellite Area Be Inside a Central Accumulation Area?

Posted on 7/18/2022 by Roseanne Bottone

The RCRA hazardous waste regulations make an important distinction between two types of areas within a facility that generates hazardous waste—satellite accumulation areas (SAA) and central accumulation areas (CAA).

The RCRA rules for satellite areas allow personnel to manage hazardous waste “at or near any point of generation where wastes initially accumulate...” according to a streamlined set of requirements, for a limited time (40 CFR 262.15).

Once the waste is moved to a central accumulation area, the generator must comply with storage time limits and more detailed regulations for container management, inspections, and hazard communication. A central accumulation area can be placed just about anywhere—a warehouse, a room, a cage, a shed, a trailer, or any other appropriate location.

Can a RCRA Satellite Area Be Inside a Central Accumulation Area?

Can a Satellite Area Be Inside of a Central Accumulation Area?

There is no prohibition against managing satellite containers in the same area where you’ve set up a central accumulation area.

While we mostly think of hazardous waste satellite areas and central accumulation areas as distinct and separate areas, there are scenarios where a satellite area could be inside of a central accumulation area.

Let’s suppose you manage your CAA containers in a large room. In the same room, you have a repair station or a small production process that generates hazardous waste. It would be more convenient for your workers to accumulate this waste in a separate container right where it’s being generated and take more time to fill it up.

Best Management Practices

If you elect to manage a satellite area within your CAA, a good management practice would be to make it immediately evident that the satellite container is being managed differently from the CAA containers. It should be obvious to the official performing an inspection that these areas are distinct.

What can you do to ensure this? You might put up some sort of barrier like a portable railing module, roping, or cones. You could post signage or apply a large label indicating “SATELLITE CONTAINER” or something similar.

You might even put tape down on the floor delineating the SAA.

Clearly distinguishing between your satellite area and the central accumulation area will demonstrate that you are knowledgeable about the regulations and their practical application. This can go a long way toward showing an inspector that you are compliant with RCRA and are managing your waste in a way that protects human health and the environment.

RCRA Training Considerations

Although formal RCRA training not necessarily required for operators who manage only satellite containers, it would be prudent to train your operators to ensure they are fully aware of the required SAA conditions for managing hazardous waste.

Also, if the same operators move the containers to the CAA (even if it’s just a few feet away), they must be trained according to the RCRA training requirements for hazardous waste personnel at large or small quantity generator facilities.

Note: States that are authorized to oversee their own RCRA programs may enforce requirements that are more stringent than the Federal hazardous waste regulations. Before making decisions about compliance in central or satellite areas, generators should consult the state regulations or a compliance point-of-contact to ensure they are not violating any state-specific standards.

Upcoming RCRA Compliance Workshops

Join an expert Lion instructor for in-person training when Lion’s premier hazardous waste workshop comes to a city near you in 2022.

RCRA Hazardous Waste Management Workshop
Orlando Aug. 1–2
Houston Aug. 22–23
Chicago Oct. 3–4
St. Louis Oct. 17–18
Atlanta Oct. 24–25
Charlotte Nov. 7–8
Philadelphia Dec. 5–6
Hartford Dec. 12–13

Can't join us in person this year?
Train online at your own pace or sign on for a live, instructor-led webinar.
 

Tags: hazardous waste management, RCRA, satellite areas

Find a Post

Compliance Archives

Lion - Quotes

Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.

Amanda Schwartz

Environmental Coordinator

I can't say enough how pleased I was with this course! Everything finally makes sense.

Kim Graham

Lab Manager

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

I like the consistency of Lion workshops. The materials are well put together and instructors are top notch!

Kevin Pylka

Permitting, Compliance & Environmental Manager

My experience with Lion classes has always been good. Lion Technology always covers the EPA requirements I must follow.

Steven Erlandson

Environmental Coordinator

Having the tutorial buttons for additional information was extremely beneficial.

Sharon Ziemek

EHS Manager

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time.

Kimberly Arnao

Senior Director of EH&S

I had a positive experience utilizing this educational program. It was very informative, convenient, and rewarding from a career perspective.

John Gratacos

Logistics Manager

Very well structured, comprehensive, and comparable to live training seminars I've participated in previously. I will recommend the online course to other colleagues with training requirement needs.

Neil Luciano

EHS Manager

Download Our Latest Whitepaper

This guide will help you identify 25 of the most -cited errors in RCRA training, recordkeeping, hazardous waste ID, container management, universal waste, and laboratories.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.