Prior to the Generator Improvements Rule, the waste accumulated in a SAA was not subject to the preparedness, prevention, and emergency procedure regulations; but that’s changed. Under the revised regulations all areas of a facility where hazardous waste is generated, accumulated, or treated is subject to the regulations of §262, Subpart M or §262.16(b)(8-9). That, of course, includes hazardous waste in a SAA.

The purpose of this article is to explain the regulations at 40 CFR 262.15(a)(7-8) that expand the applicability of the preparedness, prevention and emergency procedure regulations to the satellite accumulation area.

Before we begin…

• This is one article in a series that reviews all of the changes made to §262.15 by the Generator Improvements Rule.
• The location of these regulations within Title 40 of the Code of Federal Regulations (CFR) was changed by the Generator Improvements Rule. The satellite accumulation area regulations were located at 40 CFR 262.34(c), they are now found at 40 CFR 262.15.
• Read: Preparedness, Prevention, and Emergency Procedures for Small Quantity Generator of Hazardous Waste
• Read: Preparedness, Prevention, and Emergency Procedures for Large Quantity Generator of Hazardous Waste
• FAQ: What is a satellite accumulation area?
• FAQ: What is a central accumulation area?

Scope and Applicability:

• Accumulation of hazardous waste in a SAA is an option for both a large quantity generator of hazardous waste (LQG) and a small quantity generator of hazardous waste (SQG). Very small quantity generators of hazardous waste (VSQG) don’t have to comply with SAA regulations per §262.14(a).
• Both a large quantity generator of hazardous waste (LQG) and a small quantity generator of hazardous waste (SQG) are required to comply with the preparedness, prevention, and emergency procedures of 40 CFR 262, subpart M for a LQG and §262.16(b)(8-9) for a SQG.

• These new regulations were created by the Generator Improvements Rule, which may not yet be adopted by your state. FAQ: What is the status of the Generator Improvements Rule in my state?
• A generator may accumulate either or both of the following in a SAA:
  • Acute hazardous waste
  • Non-acute hazardous waste (aka: hazardous waste).

40 CFR 262.15(a)(7):

(7) All satellite accumulation areas operated by a small quantity generator must meet the preparedness and prevention regulations of §262.16(b)(8) and emergency procedures at §262.16(b)(9).

40 CFR 262.15(a)(8):

(8) All satellite accumulation areas operated by a large quantity generator must meet the Preparedness, Prevention and Emergency Procedures in subpart M of this part.

What’s it mean?

USEPA added paragraphs (7) and (8) to §262.15 to clarify that the preparedness, prevention, and emergency procedures for LQGs and SQGs now extend to any SAA on-site as well as CAAs.

• Read: Preparedness, Prevention, and Emergency Procedures for Small Quantity Generator of Hazardous Waste
• Read: Preparedness, Prevention, and Emergency Procedures for Large Quantity Generator of Hazardous Waste

Conclusion:

A short – and easy – article for me, but one with a significant impact. In addition to extending their applicability to the SAA, the requirements of the preparedness, prevention, and emergency procedures themselves were changed by the Generator Improvements Rule. If you are a LQG or SQG with hazardous waste in a SAA, make certain you read my articles and comply with the new regulations, now applicable to your SAA(s).