Can satellite accumulation areas (SAAs) be located near one another?
Yes, as long as the satellite accumulation areas are separate, are at or near the point or points of generation and are under the operators’ control. For example, a container of paint gun cleaner may be in one SAA and be located near a container of paint booth filters, which is in another SAA, as long as they are at or near the points of generation and under the control of the operators. Note: This interpretation is consistent with EPA’s policy, as stated in a March 2004 memo to EPA Regional Directors, except that the memo references the preamble to the final federal rule for SAAs [“… certainly…a row of full 55 gallon drums spaced 5 feet apart along the factory wall is not a row of distinct SAAs, but is one SAA”.] However, the hazardous waste rules do not specify a distance requirement, so the DNR’s position is that the decision should be left to the facility, as long as the SAA requirements in s. NR 662.034(3) or 662.192(4) Wis. Adm. Code are met.
