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3 Wrong Ways to Place RCRA Satellite Areas

Posted on May 15, 2021 by Roseanne Bottone and Roger Marks

The RCRA regulations specify that a hazardous waste satellite area may be located “at or near” any point-of-generation (POG) where wastes initially accumulate. Unlike some terms and phrases that US EPA defines explicitly and in detail within its rules, the term “at or near” is not defined anywhere in the RCRA regulations.

In the absence of an explicit definition for “at or near,” hazardous waste generators must interpret the regulations for themselves. Left to their own devices—generators get creative.

Below are three figurative “methods” for answering the question: “How far can a satellite area be from the point-of-generation?” All of them are imperfect for their own reasons, and we’ll discuss why. Lastly, we’ll fill you in on what inspectors actually look for when assessing satellite areas.

Wrong Way #1: "The Line-of-Sight Method"

hazardous waste satellite areas line of sightThis one might be the best of the bunch, but it’s still imperfect. The “line of sight” method posits that if you can see the satellite container from the point of generation, then the two are close enough together. That seems reasonable enough at first glance, so why might this be a problem?

The satellite rules in 40 CFR 262.15 require that waste containers in satellite areas remain “under the control of the operator.” While an operator may be able to see a container located far away on the shop floor, he or she may not be able to “control” the container (More on that in a moment).

Conversely, s/he may have total control over a container located two feet away but something (e.g., stored product, shelving, a screen, another piece of equipment, etc.) may block the view.

Wrong Way #2: "The Frisbee Toss"

How far can you throw a frisbee? The idea here is that if you can throw a frisbee from the point of generation to the satellite container, then the two are close enough together. Now that’s some creative thinking!

Throwing a frisbee (or anything else) around hazardous waste containers is a bad idea on its face. This "rule," of course, is meant to be figurative. It's also true that some of us can throw a frisbee very far, as evidenced below by professional Disc Golf player Garret Guthrie on this YouTube channel:
 

566 feet! It might be difficult to convince an inspector that the landing spot of that frisbee throw is best place for a hazardous waste satellite area. 

Wrong Way #3: "Hold Your Breath"

This “wrong” method posits that if you can make it from the point of generation to the satellite area without breathing, then they are close enough together.

RCRA satellite areas hold your breathAccording to Guinness World Records, Budimir Šobat set a world record by holding his breath for 24 minutes and 37.36 seconds in Croatia on 27 March 2021. If Budimir came to work at your site, he could set off from the POG and get all the way back to town in that time.

We don’t need to tell you why holding your breath and speed-walking around the shop floor is a bad idea.

Regardless, this figurative method won't help you determine how far a satellite area should be from your point of generation.

What Inspectors Really Look For

It's a safe bet that when an environmental inspector visits your facility, he or she will not throw frisbees around or hold their breath to verify compliance with RCRA.

So what do inspectors really look for when it comes to satellite areas compliance?

In conjunction with the concept of “at or near,” inspectors look for operator control over the hazardous waste storage devices in satellite areas. While constant operator surveillance is not required under the satellite regulations, the operator must ensure the containers are secure.

When inspecting satellite areas, inspectors will seek to determine if the operator controls the waste. They will want to see that facility personnel:
  • Observe the container regularly
  • Properly mark the container
  • Maintain the container in good condition and keep it closed
  • Monitor quantities
  • Locate the container in a low-traffic area
  • Restrict unauthorized access to prevent others from adding unknown or incompatible wastes
  • Protect the container from potential damage (e.g., from forklift accidents or knock-overs)
  • Control when and where the container is moved

Choosing a Location for Your Satellite Area 

To decide where to locate your satellite container(s), consider these four broad factors:
  1. Practicality: Is the container easily accessible to the operators that need to add waste to it?
  2. Safety: Does the placement of the container impede movement or cause a hazard?
  3. Control: Can the operator of the process generating the waste meet the control conditions discussed above?  
  4. The ability to defend your reasoning: Can you make your case to an inspector if challenged?
The hazardous waste satellite area rules in 40 CFR 262.15 are designed to make managing waste easier for the generator. When you position your satellite container, ask yourself if you are using the option in a way that clearly protects human health and the environment.

In-person RCRA Training Returns in 2021!   

Network with your peers and keep your RCRA expertise sharp when Lion presents the two-day RCRA Hazardous Waste Management Workshop in Houston, Dallas, Chicago, St. Louis, Pittsburgh, and Cincinnati in August and September 2021. Save your seat now to help meet EPA's annual training mandate for hazardous waste personnel (40 CFR 262.17). 

Can’t join us live? Train online at your own pace, or join us for a live, instructor-led webinar. Visit Lion.com/RCRA to see all your options and help satisfy EPA’s annual training mandate for hazardous waste personnel
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