Can a RCRA Satellite Area Be Inside a Central Accumulation Area?
The RCRA rules for satellite areas allow personnel to manage hazardous waste “at or near any point of generation where wastes initially accumulate...” according to a streamlined set of requirements, for a limited time (40 CFR 262.15).
Once the waste is moved to a central accumulation area, the generator must comply with storage time limits and more detailed regulations for container management, inspections, and hazard communication. A central accumulation area can be placed just about anywhere—a warehouse, a room, a cage, a shed, a trailer, or any other appropriate location.
Can a Satellite Area Be Inside of a Central Accumulation Area?There is no prohibition against managing satellite containers in the same area where you’ve set up a central accumulation area.
While we mostly think of hazardous waste satellite areas and central accumulation areas as distinct and separate areas, there are scenarios where a satellite area could be inside of a central accumulation area.
Let’s suppose you manage your CAA containers in a large room. In the same room, you have a repair station or a small production process that generates hazardous waste. It would be more convenient for your workers to accumulate this waste in a separate container right where it’s being generated and take more time to fill it up.
Best Management PracticesIf you elect to manage a satellite area within your CAA, a good management practice would be to make it immediately evident that the satellite container is being managed differently from the CAA containers. It should be obvious to the official performing an inspection that these areas are distinct.
What can you do to ensure this? You might put up some sort of barrier like a portable railing module, roping, or cones. You could post signage or apply a large label indicating “SATELLITE CONTAINER” or something similar.
You might even put tape down on the floor delineating the SAA.
Clearly distinguishing between your satellite area and the central accumulation area will demonstrate that you are knowledgeable about the regulations and their practical application. This can go a long way toward showing an inspector that you are compliant with RCRA and are managing your waste in a way that protects human health and the environment.
RCRA Training ConsiderationsAlthough formal RCRA training not necessarily required for operators who manage only satellite containers, it would be prudent to train your operators to ensure they are fully aware of the required SAA conditions for managing hazardous waste.
Also, if the same operators move the containers to the CAA (even if it’s just a few feet away), they must be trained according to the RCRA training requirements for hazardous waste personnel at large or small quantity generator facilities.
Note: States that are authorized to oversee their own RCRA programs may enforce requirements that are more stringent than the Federal hazardous waste regulations. Before making decisions about compliance in central or satellite areas, generators should consult the state regulations or a compliance point-of-contact to ensure they are not violating any state-specific standards.
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