December 2024 

Satellite accumulation allows a hazardous waste generator to accumulate limited quantities of hazardous waste for up to one year at or near the point of waste generation. Generators can choose to comply with the satellite accumulation requirements in California Health and Safety Code (HSC) 25123.3(d) and Title 22 of the California Code of Regulations (22 CCR) 66262.15 instead of the small quantity generator (SQG) requirements in 22 CCR 66262.16(b) or the large quantity generator (LQG) requirements in 22 CCR 66262.17(a). The information on this page summarizes the major requirements that generators accumulating hazardous waste in satellite accumulation areas (SAAs) must comply with.

The Satellite Accumulation Requirements

According to 22 CCR 66262.15(a), a generator may accumulate as much as 55 gallons of non-acute hazardous waste, 1 quart of liquid acutely hazardous waste, 1 kg of solid acutely hazardous waste, or 1 quart of extremely hazardous waste at or near the point of generation of that waste (referred to as the satellite accumulation area, or “SAA”) for up to one year. The SAA must be under the control of the operator of the process generating the waste. The generator must also comply with the following requirements:

1. The waste must be accumulated in containers. Tanks may not be used for satellite accumulation per HSC 25123.3(d)(2). The generator must use containers that are in good condition and that are compatible with the hazardous waste(s) being generated in the SAA per 22 CCR 66262.15(a)(1) and (2).
2. The containers in the SAA must remain closed (unless the generator is adding or removing waste, or temporarily venting the container if necessary) per 22 CCR 66262.15(a)(4).
3. Per 22 CCR 66262.15(a)(5), a container in an SAA must be clearly marked with:
   • The words “Hazardous Waste”;
   • The composition and physical state of the wastes;
   •  An indication of the hazards of the container’s contents;
   •  The name and address of the generator; and
   •  The date that hazardous waste accumulation began.
4. Per 22 CCR 66262.15(a)(7)-(8), the generator must meet the preparedness, prevention, and emergency procedure requirements pursuant to 22 CCR 66262.16(b)(6) and (7) (for SQG facilities) or 22 CCR, Division 4.5, Chapter 12, Article 9 (for LQG facilities).
5. The generator must not hold the hazardous waste on-site for more than one year from the initial date of accumulation per 22 CCR 66262.15(a)(9). If the hazardous waste is moved to the facility’s central accumulation area before the one year time limit is is reached, the generator must comply with the sooner of the one year time limit or the applicable SQG or LQG accumulation time limit. See the section below titled “What Happens When a Generator Exceeds the Quantity Limits in an SAA?” for more information on when the SQG or LQG accumulation time limit begins for satellite accumulated wastes.

Accumulating Multiple Containers or Waste Streams in an SAA

Generators are not restricted from using multiple containers to accumulate hazardous waste in an SAA, nor from accumulating multiple waste streams in an SAA. However, the combined total amount of hazardous waste being accumulated in the SAA must not exceed the quantity limits from 22 CCR 66262.15(a) described above. Additionally, incompatible wastes generated and stored in the same SAA must be placed in separate containers per 22 CCR 66262.15(a)(3)(A), and containers holding hazardous wastes that are incompatible with other wastes or materials in the SAA must be separated and protected from those wastes and materials by any practical means per 22 CCR 66262.15(a)(3)(c).

What Happens When a Generator Exceeds the Quantity Limits in an SAA?

Within three days of exceeding the quantity limits, the generator must move hazardous waste from the SAA to the facility’s central accumulation area so that the SAA does not store excess amounts of hazardous waste. The generator must clearly mark the hazardous waste that was moved to the central accumulation area with the date on which the satellite accumulation quantity limit was exceeded and must manage the waste according to the SQG requirements in 22 CCR 66262.16(b) or the LQG requirements in 22 CCR 66262.17(a), as applicable. This includes complying with the applicable SQG or LQG accumulation time limit, which begins on the date that the satellite accumulation quantity limit was exceeded. However, per 22 CCR 66262.15(a)(9), a generator may never hold the waste on site for more than one year from the date it began being accumulated in the SAA, even if it is moved to the facility’s central accumulation area. As such, the generator must comply with the sooner of the one year satellite accumulation time limit or the applicable 90/180/270 day time limit for hazardous wastes moved from an SAA to a central accumulation area.

If you are considering satellite accumulation, please consult the regulations cited above. If you are not sure that your accumulation area satisfies the criteria for satellite accumulation, check with your local CUPA and/or the DTSC Regulatory Assistance Office.