[RCRA 40 CFR 262.34(c)] Satellite Accumulation Container Inspection Requirements
Containers being managed according to the option known as “satellite
accumulation” at 262.34(c)
are not required to be inspected weekly. The weekly inspection requirement is
located at 40
CFR 265.174, and satellite containers are not required to comply with that
requirement. The inspection requirement applies to hazardous waste being accumulated
by generators who are complying with 262.34(a),
the 90-day accumulation option for large quantity generators, or 262.34(d),
the 180 - 270 day option for small quantity generators.
Some states do require satellite container inspections. And, it is never a
bad thing to go above and beyond the regulations, since they are only identifying
the minimum requirements, but in this case, it is up to the waste generator
(or the state environmental agency) to decide if they are necessary or not.
Moreover, containers at satellite accumulation areas could be subject to inspections
that are specified in your facility’s storm water pollution prevention
plan or spill prevention, control, and countermeasures plan.