Both Large and Small Quantity Generators of hazardous waste (LQG & SQG respectively) are required to conduct weekly inspections of their hazardous waste accumulation areas; typically referred to as Central Accumulation Areas (CAA’s) or 90 (for LQG’s) or 180 (for SQG’s) day accumulation areas.  I was recently at an LQG and was told by the EHS Coordinator that the weekly inspection took her almost 5 hours to complete.  The reason?  The inspection included more than 50 Satellite Accumulation Areas (SAA’s) distributed throughout the sprawling facility.  My observation that weekly inspections are not required for SAA’s caught her by surprise.  “Are you sure?” she asked.

Yes I am.

The Federal regulations for managing hazardous waste in an SAA can be found at 40 CFR 262.34(c).  The baseline requirements are known to most:

• No more than 55 gallons of hazardous waste or 1 quart of acute hazardous waste in a single SAA.
• In a container at or near the point of generation where the waste initially accumulates.
• Under the control of the operator of the process generating the waste.

While waste accumulates in the SAA, the generator must comply with other routine container requirements:

• 40 CFR 265.171:  Containers in good condition.
• 40 CFR 265.172:  Container compatible with waste.
• 40 CFR 265.173(a):  Container kept closed except when adding or removing waste.
• Mark container with the words “Hazardous Waste” or other words that describe the contents (check with your State on this point specifically since some require additional information to be included).

While the waste is maintained in the SAA in compliance with the above, it is not subject to the requirements of 40 CFR 262.34(a) 0r (d); these are the regulations that refer to the weekly inspection requirements of  40 CFR 265.174.  Therefore, proper maintenance of hazardous waste in an SAA precludes the requirement for weekly inspections.

Additional requirements kick-in when the SAA volume thresholds of 55 gallons for hazardous waste or 1 quart for acute hazardous waste are reached; at that point the generator must…

• Date the container.
• Move it to the CAA within 3 calendar days.  Note:  not 72 hours or 3 business days.
• Once moved to the CAA, the generator may re-date the container and then begin the 90 or 180 day accumulation time period.
• Once moved to the CAA, the container becomes subject to all the standard hazardous waste generator requirements of 40 CFR 262.34(a).

Weekly inspections of waste containers (both hazardous waste and acute hazardous waste) are an option, not a requirement.  Decide for yourself if the benefit from inspections is worth your time and effort.  For more information about SAA’s, review this US EPA FAQ’s on the subject.

I pride myself in providing a training service that not only complies with the regulations (training is required for LQG’s at 40 CFR 265.16) but also gives you information you can use (see above) to make your job of environmental compliance easier.  Please review my schedule of open enrollment training events or contact me to schedule on-site training.