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Enforcement in New England

Movement of Hazardous Wastes to Storage Areas

This statement has been developed to provide Pfizer Inc with Regional EPA guidance to facilitate future compliance at the Groton, Connecticut facility.

Containers of hazardous waste that are being moved from satellite storage areas to 90-day or greater-than 90-day storage areas may sometimes need to be staged at a loading dock, platform or another similar type area. Could Pfizer store hazardous waste at such a location for up to 72 hours as specified in 40 C.F.R. §262.34(c)(2)?

Forty C.F.R. § 262.34 (c)(2) allows a 72 hour period for the transfer of hazardous waste from a satellite area to a 90-day or greater-than 90-day storage area once the volume of waste in a satellite area exceeds the 55-gallon limit. This provision requires that during this 72-hour storage period, the satellite containers must remain "at or near" the point of generation and must be in compliance with the remaining satellite accumulation provisions. Thus, hazardous wastes must be either stored in a satellite storage area, a 90-day, or a greater-than 90-day storage area. Therefore, a facility cannot store hazardous wastes in a staging area while the waste is in transit to a hazardous waste storage area, even during the 72-hour period. If, in the process of moving containers directly from a satellite storage area to a longer term storage area, containers must be placed on a loading dock, the containers must be attended by personnel trained with the appropriate level of hazardous waste training to perform the task and may be located in such an area for a very brief period of time (i.e., no longer than 60 minutes).


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