The document summarizes new rules changes from the Missouri Department of Natural Resources (MDNR) regarding hazardous waste regulations. Key changes include: 1) Generators are now allowed to accumulate up to 55 gallons of each non-acute hazardous waste stream or 1 quart of acute hazardous waste in satellite accumulation areas, with additional requirements like marking containers with accumulation start dates. 2) Generators have more flexibility in managing railcars containing hazardous waste onsite for up to 10 additional days according to an approved railcar management plan. 3) Indoor storage of ignitable waste containers within 50 feet of the property line now has exceptions if certain fire safety provisions are met, like fire-rated walls and automatic suppression systems.

1. REGFORM Hazardous Waste Seminar
November 5, 2014
Missouri Interpretation - Satellite Accumulation Areas
and Other Options Under the New Rules

2. What’s New – Rule Changes
• Based upon 2012 “no stricter than” legislation
260.373 RSMo
• MDNR required to identify regulations that are stricter than the federal rules (in certain subject
areas)
• MDNR propose amendments to eliminate stricter than provisions from the rules
• Provisions identified as more strict, but no amendments proposed become “null and void” on
December 31, 2015

3. What’s New – Rule Changes
• Proposed Amendments filed May 15, 2015
• Missouri Register, volume 40, number 10, pages 626-670
• Hazardous Waste Management Commission approved Final
Orders of Rulemaking on August 20, 2015
• Order of Rulemaking published November 2, 2015
• Missouri Register, volume 40, number 21, pages 1575-1594
• Final Rules effective 30 days after publication in the Code of
State Regulations (approximately December 30, 2015)

4. What’s New – Satellite Accumulation
10 CSR 25-5.262(2)(C)3 was amended
• Manage accumulation in accordance with 40 CFR
262.34(c); or
• Utilize Missouri specific requirements to
accumulate hazardous waste in satellite areas

5. Federal Satellite Accumulation 40 CFR 262.34(c)
Accumulate up to 55 gallons of non-acute (1 quart acute)
hazardous waste at or near the point of generation and under the
control of the operator- 40 CFR 262.34(c)1
• Condition of containers - 40 CFR 265.171
• Compatibility of waste with containers - 40 CFR 265.172
• Closed container except when adding/removing – 40 CFR
265.173
• Labeling and waste removal – 40 CFR 262.34(c)1ii.
• Hazardous Waste or other properly identifying verbiage on the container
• Accumulation date for excess waste and remove within 3 days

6. Federal Satellite Accumulation 40 CFR 262.34(c)
Satellite Accumulation Requirements
• Accumulation start date not required
• No time limit for accumulation
• Limited to 55 gallons (non-acute), 1 quart (acute) hazardous
waste in total (all waste streams combined)

7. Missouri Specific Satellite Accumulation Requirements – 10
CSR 25-5.262(2)(C)3
Allow accumulation of up to 55 gallons of each non-acute hazardous
waste stream or 1 quart acute hazardous waste in the same satellite
accumulation area with the following conditions.
• Comply with applicable requirements of 40 CFR 262.34(c)
• Notify the MDNR that the facility will be complying with the
Missouri specific requirements (updated Notification of Regulated
Waste Activity Form)
• All satellite accumulation areas at the facility must operate under
the same procedure

8. Missouri Specific Satellite Accumulation Requirements – 10
CSR 25-5.262(2)(C)3
• One container per waste stream
• Containers must be marked with beginning date of satellite
storage
• Containers removed from satellite accumulation area:
• 1 year has passed since accumulation start date
• Container is full
• Container has reached its volume limit

9. Missouri Specific Satellite Accumulation Requirements – 10
CSR 25-5.262(2)(C)3
• Containers removed from satellite area must be handled in accordance
with the following:
• Taken to the generator storage area;
• Shipped off-site for proper management/disposal; or
• Managed on-site in accordance with an approved hazardous waste permit or certification.
• In lieu of 40 CFR 262.34(c)(2), within 3 days, generator may start a new
satellite accumulation container
• 40 CFR 262.34(a)(1)(iii) is not incorporated (i.e. drip pads)
• Generators that accumulate more than 6000 kg of ignitable or reactive
waste may elect to comply with 10 CSR 25-7.264(2)(I) in lieu of 40 CFR
265.176 (i.e. 50’ property line setback)

10. What’s new (or at least flexible) – Railcar Management
10 CSR 25-7.264(3) – Management of Railcars
• Allows for an additional 10 days to off-load railcars received at a
permitted facility
• Facility must develop and manage railcars in accordance with a
railcar management plan

11. What’s new (or at least flexible) – Container Storage of
Ignitable Waste 10 CSR 25-7.264(2)(I)5
• 50 feet property line set back for indoor storage of containers
• Exceptions if certain provisions are enacted:
• Exposing walls, doors, and windows have certain fire ratings in accordance with the National Fire Protection Agency (NFPA)
• Construction of exterior walls shall provide for ready access during fire-fighting operations
• Automatic Fire suppression system
• Pre-connected hose lines
• Federal Dept. of Transportation or NFPA containers used in the area
• Maintain minimum isle space of 4 feet
• Explosive gas concentrations monitored continuiously

12. Questions, Comments and Thanks!
Rob Morrison, P.E.
Barr Engineering Co.
1001 Diamond Ridge, Suite 1100
Jefferson City, Missouri 65109
573.638.5025(office)/573.797.0857(cell)
rmorrison@barr.com