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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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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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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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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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…)