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Page 1 of 9 Faxback and Close IdF DBLookun MEMORANDUM SUBJECT: Frequently Asked Questions about Satellite Accumulation Areas FROM: Robert Springer, Director Office of Solid Waste TO: RCRA Directors, EPA Regions 1-10 Purpose The purpose of this memo is to reiterate and clarify the Environmental Protection Agency's (EPA) regulations under the Resource Conservation and Recovery Act (RCRA) hazardous waste management program regarding satellite accumulation areas (SAAs). For convenience, this memo pulls together answers to many of the frequently asked questions EPA receives regarding SAAB. Many, but not all, of the questions in this memo have been answered by EPA in previous letters and documents. For those questions that have been answered previously, citations to relevant memos and Federal Register preambles are provided in numbered endnotes. Summary of Generator Accumulation Regulations When accumulating hazardous waste on-site, large quantity generators (LQGs) must comply with 40 CFR 262.34(a) and small quantity generators (SQGs) must comply with 40 CFR 262.34(d) to avoid the requirement to obtain a hazardous waste treatment, storage, or disposal permit.a LQGs may accumulate hazardous waste on-site without interim status or a permit for up to 90 days, while SQGs have up to 180 days to accumulate hazardous waste without interim status or a permit.b The Agency sometimes refers to these generator accumulation areas as " 90-day" or "180-day" areas, or"central accumulation" areas. The satellite accumulation provisions allow generators to accumulate up to 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) in containers that are: • at or near any point of generation, and • under the control of the operator, with fewer requirements than for central accumulation areas, provided the generator complies with the requirements of 262.34(c). https://yosemite.epa.gov/osw/rcra.nsf/documents/8c9f6dc8b378a2f585256e9900723a8b 10/4/2016