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…
FAQ: Must the “Operator” of a satellite accumulation area be a single individual?
Background: The satellite accumulation area (SAA) regulations of the US. Environmental Protection Agency (USEPA) at 40 CFR 262.15 mandate that the container of hazardous waste in the SAA be “under the control of the operator of the process generating the…
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…
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…
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…
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,…
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…
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…
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…
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,…