Common Satellite Accumulation Areas Violations

A common source of RCRA violations during facility inspections is hazardous waste containers, and waste containers in Satellite Accumulation Areas (SAAs) can be significant contributors to the issues. Training and awareness can greatly reduce the occurrence of SAA issues. The items listed below are the most common issues observed in SAAs; most can be eliminated by very simple actions, such as writing a date or placing a cap on the container.

Common satellite accumulation area mistakes include:

1. Failure to mark the accumulation start date on the label when waste is initially placed in the container. Other start date issues include:
   1. Not showing month, day, AND year
   2. Changing the date when adding add’l waste
2. Unlabeled containers:
   1. No labeling at all
   2. Label missing information
      1. Contact information
      2. List of waste components in container
      3. Accumulation start date (see #1)
      4. Illegible writing

3. Transferring waste between SAAs
   1. Moving from one lab to another
4. Open containers
   1. Cap or lid not tightly secured
   2. Funnel left open in mouth of container
   3. Open bucket or pail
5. Use of chemical formulas instead of chemical names on the label
6. Exceeding the 1-year storage limit
7. Having duplicate (or multiple) containers of the same waste
8. SAA not located at or near the point of generation
9. Use of inappropriate containers
   1. Containers that have severe rusting, denting, bulging, and structural defects

Why are these requirements important? They make the lab (or studio) a safer place for everyone, and they can save you from the financial pain of fines leveled by the inspecting agency.