Search

3 Wrong Ways to Place RCRA Satellite Areas

Posted on 5/14/2021 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 got 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.

Here are three “wrong” ways to determine where you may place your hazardous waste storage container in relation to where the waste is generated to comply with the satellite area accumulation regulations.

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

satellite areas RCRA 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 his view.

Wrong Way #2: The Frisbee Toss

How far can you throw a frisbee? If you can throw a frisbee from the point of generation to the satellite container, the thinking goes, it’s close enough. Now that’s some creative thinking!

Throwing a frisbee (or anything else) around hazardous waste containers is a bad idea on its face. It's also true that some people 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 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 earned the world record for holding his breath for 24 minutes and 37.36 seconds, in Sisak, 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 can be from your point of generation.

What Inspectors Really Look For

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 keeping 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
 
 
 

Find a Post

Compliance Archives

Lion - Quotes

Amazing instructor; real-life examples. Lion training gets better every year!

Frank Papandrea

Environmental Manager

I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!

George Chatman

Hazardous Material Pharmacy Technician

The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

The course was very well structured and covered the material in a clear, concise manner.

Ian Martinez

Hazmat Shipping Professional

The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable.

Marc Bugg

Hazardous Waste Professional

The instructor was very patient and engaging - willing to answer and help explain subject matter.

Misty Filipp

Material Control Superintendent

The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information.

Morgan Bliss

Principal Industrial Hygienist

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.

Rachel Stewart

Environmental Manager

I attended training from another provider and learned absolutely nothing. Lion is much better. Hands down.

Nicole Eby

Environmental Specialist

Download Our Latest Whitepaper

Your hazmat paperwork is the first thing a DOT inspector will ask for during an inspection. From hazmat training records to special permits, make sure your hazmat documents are in order.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.