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Ms. Janet Ortiz October 31, 1995 Page 4 3. Total facility vs waste stream specillc. The first paragraph of your response is incorrect and should be deleted. The quoted statute, HSC section 25123.3(dx3), applies to waste initially held at a satellite accumulation area and is not relevant to the less than or equal to 100 kg/mo issue. Scripps is incorrect in interpreting that the 100 kg limit is waste stream specific. As noted above, the only waste stream specific limit in the regulations or Management Memo is the 55-gallon satellite accumulation area limit for compatible wastes. The quoted #EO-93-008-MM note "there is no accumulation time limit for generators who have not accumulated 100 kg of hazardous waste" applies to the total quantity on the generators site (including all locations). It is only available to generators of less than or equal to 100 kg/mo and does not apply to any wastes which were originally kept in a satellite accumulation area, which are subject to the one-year time limit. 4. Total onsite accumulation time for wastes first held in a satellite accumulation area. To avoid confusion, I have quoted both your response and the Scripps question because our interpretation is considerably different from your response. Scripps Question: "Please provide guidance relative to waste initially accumulated under the provisions of satellite accumulation and then removed to our "90-day accumulation" area. How long may we hold this waste? Is the amount of time that we may hold this waste dependent on the quantity possessed (waste stream specific) or the amount of all wastes generated or accumulated in a one-month period." San Diego Response: 'For satellite accumulation areas, hazardous waste may be held at the initial point of accumulation for up to one year (provided the 55 gallon/] quart limit is not reached). If the site generates 100 kg of total hazardous wastes or more per month, hazardous waste must be removed within 90 days of the initial transfer to the "90-day accumulation" area No hazardous waste may be held at an initial "satellite accumulation" point or a "90-day accumulation" area for more than one year regardless of how much hazardous waste the site generates-" DTSC Response to Scripps question: All waste accumulated in a satellite accumulation area must be removed from the generator site within one year of the initial date of accumulation. The one-year limit applies to the total holding time at the generator site, not just in the satellite accumulation area. This provision applies to all sizes of generators. Therefore, if a generator were to accumulate waste in a satellite accumulation area for one year (provided the 55 gallon/1 quart limit, per compatible waste stream, is not reached), the waste must be removed immediately from the entire generator site and could not be further accumulated in a 90-day area. The waste may either be moved offsite or to an onsite permitted storage area. S/e abed `•Nvgl:ol 00- L-unr `•S6SUZt S08 `.vdno/1Jm HilVIH HInNd 0A :A8 luaS