printreg,July,2004Satellite Accumulation of Haz Waste

printreg, July, 2004
Satellite Accumulation of Haz Waste


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From: Debra Jacobson(
djacobson@istc.illinois.edu)
Date: Date: Wed, 07 Jul 2004 13:46:46
Satellite Accumulation Container Inspection Requirements

Containers being managed according to the option known as "satellite accumulation" at 262.34(c) are not required to be inspected weekly. The weekly inspection requirement is located at 40 CFR 265.174, and satellite containers are not required to comply with that requirement. The inspection requirement applies to hazardous waste being accumulated by generators who are complying with 262.34(a), the 90-day accumulation option for large quantity generators, or 262.34(d), the 180 - 270 day option for small quantity generators.

Some states do require satellite container inspections. And, it is never a bad thing to go above and beyond the regulations, since they are only identifying the minimum requirements, but in this case, it is up to the waste generator (or the state environmental agency) to decide if they are necessary or not. Moreover, containers at satellite accumulation areas could be subject to inspections that are specified in your facility's storm water pollution prevention plan or spill prevention, control, and countermeasures plan.

Ref.: 40 CFR 262.34 http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=64d02c42129df5112b21dd65dcf759f3&rgn=div6&view=text&node=40:23.0.1.1.3.2&idno=40

40 CFR 265.174 http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=64d02c42129df5112b21dd65dcf759f3&rgn=div6&view=text&node=40:23.0.1.1.6.9&idno=40

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=edff43a328d465d2b088babfacb33765&rgn=div6&view=text&node=49:2.1.1.3.7.3&idno=49

Source: Environmental Resource Center's Reg of the Day.



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