Nearly every manufacturing process generates some type of waste. Large machines are notorious for creating generous volumes of waste coolant. Parts washing generates dirty solvent. Distilling causes residual sludges. When hazardous, these wastes all need to be properly handled in accordance with EPA's waste generator requirements.
But what about all of those other little jobs? Smaller facilities or specialized processes may not generate drum loads or tank loads of hazardous waste at a time, but the wastes still must be handled properly to help ensure worker safety and environmental compliance.
If small amounts of wastes are generated from a process, however, it doesn't make sense to have everyone trekking to the other end of the facility or across the loading dock to a remote waste collection area at the end of every shift to dump their small container of waste into a collection drum.
Also, because EPA has set accumulation time limits that start when the first drop of waste hits the drum, generators sometimes may not accumulate a full drum of a given waste stream within the time limitation imposed on containers in waste collection areas.
Following the federal requirements for satellite accumulation areas (SAAs) can help generators simplify waste collection efforts by allowing wastes to be collected at or near the point of generation, without the time limits imposed on traditional waste storage areas.
Time Limits and Labeling
Under EPA's SAA regulations [40CFR 262.34(c)], generators are permitted to accumulate up to 55 gallons of hazardous waste, (defined in 40 CFR 251.20 and 261.30) or 1 quart of acutely hazardous waste [defined in 40 CFR 261.33(e)] without time limits.
Containers in SAAs must be marked with the words “hazardous waste” or with verbiage identifying the contents of the container [40 CFR 262.34(c)(1)(ii)]. If the waste is in a small container, such as a vial, that cannot be labeled, labeling the container that subsequently will hold the vial is sufficient. This has the added benefit of secondary containment if the vial happens to break.
When accumulation limits (55 gallons or 1 gallon of acutely hazardous waste) have been reached, the excess waste must be removed from the area within 3 days. In a memorandum, EPA clarified that “3 days” means 3 consecutive days: not 3 working days or 3 business days.
Although the regulations do not state that the full container needs to be moved from the SAA within 3 days (only the “excess” needs to be handled in that time frame), if the full container is removed from the SAA, it needs to be dated when it is moved to a centralized collection area. This ensures that it will be properly handled or moved off-site within the 90- or 180-day generator time limitations for storage without a permit.
The waste collection container must be stored at or near the area where the waste is generated. EPA does not specify a distance, to allow for some flexibility in areas where it may not be practical to place a waste collection drum directly beside the exact point where the waste is generated.
For example, if the waste is generated on one end of an 8-foot workbench, it may be acceptable to have the waste collection drum at the opposite end of the bench if there is not room for the collection drum at the end of the bench where work is being performed.
The collection container may not, however, be separated from the process by a wall or other barrier because it needs to be “under the control of an operator” who is familiar with the process and has been trained to manage the container. Because of this, centralized or remote waste collection locations cannot be considered SAAs.
Although it is not common in most facilities, it is permissible to have more than one collection container in a single SAA. The most common reason for having more than one container is if more than one waste stream is being created at the same generation point.
When more than one container is located in a single SAA, the total volume in all of the containers within the single SAA may not exceed 55 gallons (or 1 quart, if acutely hazardous.) Each container needs to be properly labeled so that wastes are kept segregated. This especially is important if incompatible wastes are being collected.
There is no limit to the number of SAAs a facility may have, but each SAA must comply with all of the applicable regulations.
Generator Status and Other Concerns
Utilizing SAAs may offer an extension of sorts for accumulation time limits, however, the volume of waste in each SAA throughout the facility must be recorded and included in the facility's monthly waste generator reports.
Generators may transfer wastes from several partially full containers at various SAAs into one container before transferring that container to a central accumulation area. They may not, however, transfer wastes from one SAA to another.
When wastes are not being transferred into or out of the collection container, the container needs to be kept closed to prevent the contents from being spilled if the container is accidentally tipped over. This can be accomplished by replacing the container's caps or lid, or with funnels, lids or other devices marketed for this purpose.
Because wastes are being accumulated, it also is a good idea to place a spill tray or absorbent materials under the container or containers in the SAA to capture nuisance leaks and drips that tend to accumulate in areas where liquids are transferred.
Waste collection containers also must be compatible with their contents and be in good condition so as to avoid spills due to container deterioration. Although routine inspections specifically are not required for SAAs, regular inspections by the operator in control of the process can help ensure that these criteria are met.
For facilities that have embraced lean manufacturing or lean enterprise, SAAs save several “non-value added” trips to remote waste collection areas until the waste reaches a point (a full drum in most cases) where it is more practical to transfer it.
While few would argue that EPA's waste regulations are complex, the flexibility of SAAs helps many generators control and handle the small amounts of wastes generated at various processes throughout their facility in a much more practical manner than the standard waste accumulation regulations.
Karen Hamel is the technical education manager for New Pig Corp. She is a graduate of the University of Pittsburgh and has over 12 years of experience helping EHS professionals find solutions to their environmental, health and safety issues. She is HAZWOPER technician-level-certified and serves in the Blair County, PA LEPC. She can be reached at 1-800-HOT-HOGS (468-4647) or by email at [email protected].