Generators that accumulate waste in a satellite accumulation area (SAA) must comply with the regulations of 40 CFR 262.15. This includes maintaining waste below certain volume and/or weight thresholds and then complying with specific requirements when those thresholds are exceeded. Prior to the Generator Improvements Rule the regulations specifying generator requirements after the threshold weight or volume was exceeded in a SAA were not clear; the revised regulations change this.
The purpose of this article is to explain the regulations at 40 CFR 262.15(a)(6) that more clearly state the generator options for managing “excess waste” in a satellite accumulation area.
Generators of hazardous waste may accumulate acute hazardous waste and/or non-acute hazardous waste in containers in a satellite accumulation area (SAA). Prior to the Generator Improvements Rule USEPA used separate volume thresholds for these two wastes: one quart or fifty-five gallons, respectively. When the volume threshold is exceeded, the generator must take certain actions within a certain time-frame to continue in compliance with the SAA regulations of 40 CFR 262.15. Revisions of the Generator Improvements Rule added a weight threshold for acute hazardous waste accumulated in a SAA.
The purpose of this article is to explain the regulations at 40 CFR 262.15(a) that provide a maximum weight for the accumulation of acute hazardous waste in a SAA.
Prior to May 30, 2017 the Federal regulations of the USEPA lacked a clear definition of the term “acute hazardous waste”. That changed with the implementation of the Generator Improvements Rule. (more…)