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RCRA, SUPERFUND & EPCRA HOTLINE MONTHLY REPORT
1. Inspection of Satellite Accumulation Containers
A large quantity generator (LQG) that is accumulating hazardous waste on-site for 90 days or less in containers must comply with 40 CFR Part 265, Subpart I (§262.34(a)(1)(i)). Section 265.174 of Subpart I requires owners and operators to inspect containers weekly for leaks and deterioration caused by corrosion or other factors. Are LQGs required to inspect hazardous waste containers in satellite accumulation areas at or near the waste’s point of generation in accordance with §262.34(c)?
Hazardous waste containers used to accumulate hazardous waste at or near any point of generation (“satellite accumulation”) and in compliance with §262.34(c) are not required to be inspected weekly. A generator accumulating hazardous waste in satellite accumulation areas must comply with §§265.171, 265.172, and 265.173(a) (§262.34(c)(1)(i)). These requirements include that a LQG ensure that the containers are in good condition, that the waste is compatible with the containers, and that the containers are kept closed except when necessary to add or remove waste. In addition, if the container begins to leak the generator must transfer the waste to a container that is in good condition. Section 265.174, regarding weekly inspection, is not a requirement for containers of hazardous waste in a satellite accumulation area. Therefore, LQGs are not required to conduct a weekly inspection of containers in satellite accumulation areas so long as they comply with the provisions of §262.34(c). Authorized states may require weekly inspection of containers in satellite accumulation areas, as states may have more stringent requirements than the federal regulations.