How close to the process does my satellite accumulation area have to be and how far apart do satellite accumulation areas have to be from one another?
Unfortunately, there are no definitive answers to these questions. The EPA requires the generator to keep the waste “at or near” the point of generation [40 CFR 262.34(c)]. When the EPA wrote the “satellite,” or “point of generation” rules, it never defined what “at or near” means. This is an issue that is frequently left up to state or even local inspectors’ discretion. The EPA attempted to clarify the definition of “satellite area” in the December 20, 1984 Federal Register where they finalized this option [49 FR 49569]. Several commenters requested guidance on the definition of satellite areas on the grounds that EPA has not adequately defined what it means by satellite areas. Others argued the concept is unenforceable without a precise regulatory definition. One commenter raised the possibility of a generator storing 55-gallon drums 5 feet apart along the wall of his facility in an attempt to circumvent further regulatory responsibilities. Satellite areas are those places where wast
Related Questions
- Under the satellite accumulation area (SAA) regulations of 40 CFR 262.34(c) may working containers be taken from multiple labs (i.e., SAAs) to another SAA for consolidation?
- Can a facility have more than one satellite accumulation area (SAA)?
- Can satellite accumulation areas (SAAs) be located near one another?
