Waste Storage
I cannot find a straight answer online regarding how long you can hold accumulated satellite area waste in a 55-gallon drum. Reading the regulation, it sounds like I can accumulate until my 55-gallon is full. I would then move to central accumulation and begin the 90-day limit. Does it matter how long it takes to fill? Is there an upper limit for this satellite area?
Phrased another way: How long may I accumulate waste in a 55-gallon drum if the waste is near a process away from my central accumulation area (which has a 90-day limit)?
Comments (11)

It does not matter how long you take to fill the drum in your satellite area. It takes my team nearly 6 months to fill a 55 gallon drum. They (inspector) are going to look at the date on the drum (SQG and LQG) in the satellite area and then the one in the 90/180 day holding area for compliance.

Check out this site https://www.epa.gov/hwgenerators/hazardous-waste-generator-regulatory-summary
It has the summary table for the 40 CFR part 262.

The way I read the EPA regs is that it don't matter if the drum is filled. Not only are they looking at quantity but only allowed a set amount of time to accumulate for that particular collection. 180 days for SGQ extendable to 270 if disposal is over 200 miles. 90 days for LGQ. If you aren't filling the drum in that set amount of time are you classified correctly based on how much waste your producing? When you start your collection point for that 55 gallon drum you should mark it with the start date so you know when it has reached time limit if applicable. This is federal regs though your particular state could be more stringent.