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Enforcement in New England

Satellite Accumulation

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

Pursuant to 40 C.F.R. § 262. 34(c)(1), "a generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in § 261.33(e) in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or interim status and without complying with paragraph (a) of [§ 262.34]." These areas are commonly known as "satellite accumulation areas." "Satellite areas are those places where wastes are generated in the industrial process or the laboratory and where those wastes must initially accumulate prior to removal to a central area." 49 Federal Register 49568 at 49569 (December 20, 1984). In Connecticut, containers in satellite accumulation areas must be marked with the words "hazardous waste" and other words that identify the contents of the container such as the chemical name. RCSA § 22a-449(c)-102(a)(2)(E).

EPA has made clear that the 55-gallon limit applies to the total quantity of non-acutely hazardous waste accumulated in a satellite area. In a letter dated August 2, 1989, from Sylvia Lowrance, Director, Office of Solid Waste, to T.R. Kirk, Fehr-Graham & Associates (OSWER Dir. 9453.1989(08)), EPA responded to a question concerning whether the 55-gallon limit on hazardous waste applied to the total quantity of hazardous waste accumulated at a satellite location, or if it applied to each waste stream accumulated at a satellite location. EPA stated, "The 55-gallon limit applies to the total of all the non-acutely hazardous waste accumulated at a satellite accumulation area." In addition, in the preamble to the final satellite accumulation rule, EPA explicitly stated that the 55-gallon limit on non-acutely hazardous waste applies to each satellite accumulation area." See 49 Fed. Reg. 49568, 49569 (December 20, 1984).

Neither the regulations nor the preamble to the regulations expressly defines the terms "at or near the point of generation" or "under the control of the operator" with reference to the distance from the point of generation or the level of control required. Therefore, the Region evaluates each situation on a case-by-case basis in order to determine if a storage area qualifies as a "satellite accumulation" area. In order to be considered satellite accumulation containers, containers of hazardous waste must be both "at or near" the point of generation and "under the control of the operator." Waste management scenarios specific to Pfizer's operations are discussed below.

  1. Hazardous wastes stored in Buildings 4 and 48 outside of laboratories where the wastes were generated. In Buildings 4 and 48, Pfizer stored containers of hazardous waste outside of the laboratory in which the waste was generated. The Region does not consider such storage to be legitimate satellite accumulation because the accumulation container is not "at or near" the point of generation and is not "under the control of the operator." Satellite accumulation containers must be located in the room where the waste is generated. If Pfizer has significant operational and/or safety concerns which it believes might warrant a different storage arrangement, it should contact the Region in writing. The Region will consider an exception on a case-by-case basis.
  2. Similar hazardous wastes generated at many locations within Building 150 or 171 and stored in a single container that is located either within or outside the building. In Buildings 150 and 171, Pfizer generated hazardous waste at many locations within each building and then stored the wastes in a single container located at a central point within the building. Such storage does not qualify as satellite accumulation because the satellite container is not "at or near" the point of generation and is not "under the control of the operator." Pfizer must either manage the container in the central location as a 90-day hazardous waste storage area or maintain satellite accumulation containers at each point where waste is generated.
  3. Hazardous wastes generated at different points around the facility and stored in central location. Pfizer generated waste sandblast grit and paint and oil waste in many locations around the facility and stored the waste in locked cages in Building 31A. Such storage does not constitute satellite accumulation because the storage container is not "at or near" the point of generation and is not "under the control of the operator" of the process generating the waste. These wastes, generated at various locations around the facility and stored in a central location, must be managed in accordance with the requirements for a 90-day hazardous waste storage area. An exception to this requirement would be for wastes which meet the definition of "universal wastes." See letter from Sylvia Lowrance, Director, Office of Solid Waste to Mr. D.B. Redington, Monsanto Company, dated February 23, 1993. The Region does not consider the sandblast grit, paint waste or waste oil to be "universal wastes."
  4. Hazardous wastes generated in process/lab equipment. If, during the course of a laboratory experiment, hazardous wastes are removed from the process vessel and collected in a beaker or small container directly next to an experiment, such container will be considered a satellite accumulation container. Nonetheless, the waste in that container may then be placed in a larger container in the same laboratory, into which other compatible wastes from the same laboratory may be placed, as long as the larger container is at or near the point of generation, under the control of one of the operators in the laboratory who is generating such waste, and the total amount of waste in the containers does not exceed 55 gallons. The larger container referred to in the previous sentence will also be considered a satellite container.


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