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Page 3 of 9 2. When a generator accumulates more than 55 gallons of hazardous waste (or 1 quart of acute hazardous waste), the generator must (262.34(c)(2)): - mark the container with the date on which 55 gallons (or 1 quart of acute hazardous waste) is exceeded, and - remove the excess of 55 gallons (or 1 quart of acute hazardous waste) within three days or comply with the 90-day area or 180-day area regulations, as appropriate. Frequently Asked Questions about Satellite Accumulation Areas 1. Question : Can small quantity generators establish SAAs according to 262.34(c) for their hazardous waste? Answer : Yes. Both LQGs and SQGs may take advantage of the reduced requirements while hazardous waste is in SAAs, provided it is managed in accordance with all the provisions of 40 CFR 262.34(c).1 If an SQG or LQG accumulates more than 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) at an SAA, the excess must be removed within three days. If after that period, the excess is not removed, LQGs must comply with 262.34(a) and SQGs must comply with 262.34(d), with respect to the excess amounts. 2. Question : If a generator accumulates more than 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) at an SAA, when should the generator date the container(s)? When 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) is exceeded, or when the container is moved to the central accumulation area? Answer : When 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) is exceeded in an SAA, the generator needs to date the container, so that the generator can move the excess to the 90-day or 180-day area within three days (262.34(c)(2)). Then when 3 days have passed, or when the container is moved to the central accumulation area, the generator needs to date the container again, so that it can be moved off-site within 90 or 180 days (262.34(a)(2) and 262.34(d)(4), respectively. (Of course, the container does not need to be dated after it is removed from the SAA if the excess waste is moved directly to a permitted or interim status unit.) This means that an LQG has up to 93 days and a SQG has up to 183 days for on-site accumulation time once 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) has been exceeded at the SAA - up to three days in the SAA, followed by up to 90 or 180 days in the central accumulation area.2 3. Question : When a generator accumulates more than 55 gallons of hazardous waste (or I quart of acute hazardous waste) at an SAA, the excess of 55 gallons (or the excess of 1 quart of acute hazardous waste) needs to be removed from the SAA within three days. What is meant by "three days"? https://yosemite.epa.gov/osw/rcra.nsf/documents/8c9f6dc8b378a2f585256e9900723a8b 10/4/2016