generator improvements rule

Examples of the Meaning of “Under the Control of the Operator”

Examples of the Meaning of “Under the Control of the Operator”

The previous regulations for accumulation of hazardous waste in a satellite accumulation area (SAA) and those revised by the Generator Improvements Rule, do not define the term, “under the control of the operator”. In an effort to assist generators to better understand this term and to foster improved compliance with the SAA regulations, USEPA provided examples in the preamble to the proposed rule and requested comments on additional practices that would constitute “under he control of the operator.” These examples were provided in the preamble to the final rule.

The purpose of this article is to provide examples of “under the control of the operator” accepted by USEPA for compliance with satellite accumulation area regulations of 40 CFR 262.15.

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USEPA Rescinds Memo Regarding Accumulating Reactive Hazardous Waste Away From the Point of Generation

USEPA Rescinds Memo Regarding Accumulating Reactive Hazardous Waste Away From the Point of Generation

USEPA’s RCRA Online is a source for memos and guidance from USEPA regarding the hazardous waste regulations. In a memo dated January 13, 1988, USEPA wrote that a storage shed located outside of a building where a reactive hazardous waste (D003) is initially generated could be considered a SAA (RO 11317). The Generator Improvements Rule rescinded this memo and revoked this interpretation.

The purpose of this article is to explain the USEPA changing its interpretation of “at or near the point of generation” by rescinding an earlier interpretation.

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Generator May Choose to Manage Hazardous Waste in a Satellite Accumulation Area

Generator May Choose to Manage Hazardous Waste in a Satellite Accumulation Area

The satellite accumulation area (SAA) regulations provide an option for generators to manage hazardous waste containers instead of in a central accumulation area (CAA). Containers managed in a SAA are not required to comply with many of the regulations applicable to the large quantity generator (LQG) and small quantity generator (SQG).

Revisions to these regulations by the Generator Improvements Rule now clarify the option to manage hazardous waste in a SAA and the relief from regulation it provides.

The purpose of this article is to explain the rewording of 40 CFR 262.15(a) clarifying the generator option to manage hazardous waste in a SAA or CAA.

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Responding to Leaking or Damaged Containers in the Satellite Accumulation Area

Responding to Leaking or Damaged Containers in the Satellite Accumulation Area

Based on a recommendation from commenters, USEPA made a minor wording change to 40 CFR 262.15(a)(1) to explicitly require an immediate response to a leaking or damaged container in a satellite accumulation area (SAA). The revised regulations also clarify the applicable regulations if the container is moved to a central accumulation area (CAA). This change is part of the many revisions to generator regulations made by the Generator Improvements Rule.

The purpose of this article is to explain the addition of the word “immediately” and other language to 40 CFR 262.15(a)(1) regarding containers that are not in good condition or begin to leak.

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Applicability of Preparedness, Prevention, & Emergency Procedures to Satellite Accumulation Area

Applicability of Preparedness, Prevention, & Emergency Procedures to Satellite Accumulation Area

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.

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USEPA Modifies the Language for Generator Options When the Maximum Volume or Weight is Exceeded in a Satellite Accumulation Area

USEPA Modifies the Language for Generator Options When the Maximum Volume or Weight is Exceeded in a Satellite Accumulation Area

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.

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USEPA Provides a Maximum Weight for Acute Hazardous Waste Accumulation in a Satellite Accumulation Area

USEPA Provides a Maximum Weight for Acute Hazardous Waste Accumulation 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.

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USEPA Clarifies “three days” for Removal of Hazardous Waste From Satellite Accumulation Area to Central Accumulation Area

USEPA Clarifies “three days” for Removal of Hazardous Waste From Satellite Accumulation Area to Central Accumulation Area

Generators who accumulate hazardous waste in a satellite accumulation area (SAA) are likely familiar with the requirement to remove waste from the SAA to the central accumulation area (CAA) when the threshold volume is reached. A generator may also be aware this must be done within three (3) days. The previous SAA regulations at 40 CFR 262.34(c)(2) vaguely indicated this removal be accomplished, “within three days”. Under the Generator Improvements Rule, the USEPA amended the regulations to replace the term “three days” with “three consecutive calendar days”.

The purpose of this article is to explain the regulations at 40 CFR 262.15(a)(6) that require the removal of excess hazardous waste from a satellite accumulation area within three consecutive calendar days.

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Closed Containers in the Satellite Accumulation Area

Closed Containers in the Satellite Accumulation Area

Prior to the Generator Improvements Rule the regulations for generators accumulating hazardous waste in a satellite accumulation area (SAA) required containers accumulating hazardous waste to be kept closed except when necessary to add or remove waste. Under the new rule, hazardous waste containers in a SAA may remain open under limited circumstances.

The purpose of this article is to explain the regulations at 40 CFR 262.15(a)(4) that allow for limited exceptions to the closed container requirements in a satellite accumulation area. (more…)
Special Requirements for Incompatible Wastes and Materials in Satellite Accumulation Area

Special Requirements for Incompatible Wastes and Materials in Satellite Accumulation Area

When first developing the satellite accumulation area (SAA) regulations in 1984 (hello Knight Rider!) the U.S. Environmental Protection agency (USEPA) inadvertently failed to account for the small quantity generators (SQG) and large quantity generators (LQG) of hazardous waste that might accumulate incompatible waste in a SAA. In the Generator Improvements Rule it fixed this oversight.

The purpose of this article is to explain the regulations of 40 CFR 262.14(a)(3) – created by the Generator Improvements Rule – that now require SQGs and LQGs to comply with special requirements for incompatible wastes accumulated in a satellite accumulation area. (more…)