In this month's newsletter I identify and explain the revisions to Satellite Accumulation of Hazardous Waste Under the Generator Improvements Rule. See below to make sure you are in compliance.
Changes to Satellite Accumulation of Hazardous Waste Under the Generator Improvements Rule
The Generator Improvements Rule – (still not adopted by your state?) – made several revisions to the generator requirements for management of hazardous waste in a satellite accumulation area (SAA). A generator that accumulates hazardous waste in a SAA will likely see at least one change to their compliance due to these revisions. If you are interested in seeing all the revisions in one place, read more here.Or, see below for a summary of each revision and a link to an article specific to that revision.
Special Requirements for Incompatible Wastes and Materials in Satellite Accumulation Area
USEPA Clarifies "three days" for Removal of Hazardous Waste From Satellite Accumulation Area to Central Accumulation Area
A single word added to the regulations clarifies long-standing USEPA policy. Now there can be no doubt: A generator has three consecutive calendar days to remove “excess waste” from the SAA. Learn more by reading this article.
USEPA Provides a Maximum Weight for Acute Hazardous Waste Accumulation 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
Once the applicable weight or volume threshold for accumulation of hazardous waste in a SAA is reached, the generator must remove the “excess waste” within a specified time. USEPA revisions clarify the options available to a generator removing "excess waste" from the SAA. Read more.
Mark or Label Containers in Satellite Accumulation Area to Indicate the Hazards of the Contents
Generator May Choose to Manage Hazardous Waste in a Satellite Accumulation Area
If it wasn’t clear before that the accumulation of hazardous waste in a SAA instead of or in addition to a CAA is an option available to the generator, it is now. Also, if it wasn’t clear that compliance with the provisions of the SAA exemption provide relief from most other hazardous waste generator regulations, it is now. Read this article clarifying the generator option to manage hazardous waste in a SAA or CAA
USEPA Rescinds Memo Regarding Accumulating Reactive Hazardous Waste Away From the Point of Generation
From the publication of the memo in 1988 until the effective date of the Generator Improvements Rule in May 2017, USEPA allowed the accumulation of hazardous waste in a SAA not “at or near the point of generation” (e.g., a storage shed outside of the building where the waste was generated) if the distance was necessary due to safety concerns. No more. This change impacts other aspects of compliance with SAA regulations. Be sure to stay on top of these revisions.
Examples of the Meaning of “Under the Control of the Operator”
In the preamble to the proposed rule, USEPA requested from commenters examples of what it considered to be “under the control of the operator” for accumulation of hazardous waste in a SAA. USEPA provided a few examples of its own to clarify what it intends by this undefined – but critically important – term. Learn more here.
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