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Page 5 of 9 7. Question : Section 265.174 of Subpart I requires that containers be inspected at least weekly for leaks and deterioration caused by corrosion or other factors. Both LQGs and SQGs must inspect containers in their central accumulation areas. Are SQGs or LQGs required to inspect hazardous waste containers in SAAs? Answer : No. Inspections of containers (whether weekly or some other frequency) in SAAs are not required, so long as the provisions of 262.34(c) are met.6 Section 265.174, which requires inspections, is not among the provisions listed in 262.34(c) for SAAs (see Table 1). However, the SAA regulations do require that waste containers in an SAA must be under the control of the operator of the process generating the waste, in good condition (265.171), compatible with its contents (265.172), and closed except when adding or removing waste (265.173), which should achieve the goal of inspections: containers that are free of leaks and deterioration. 8. Question : SQGs must conduct training in accordance with 262.34(d)(5)(iii) and LQGs must conduct training in accordance with 265.16. Do the RCRA regulations require training of personnel working in SAAs? Answer : No. The RCRA regulations do not require training of personnel working in SAAs. Personnel that have access to or work in central accumulation areas, including those that move hazardous waste from a SAA to a central accumulation area, must be trained. As the ones actually generating hazardous waste, however, personnel working in SAAs need to be familiar enough with the chemicals with which they are working to know when they have generated a hazardous waste so that it will be managed in accordance with the RCRA regulations. 9. Question : The preamble to the final rule that added 262.34(c), states, "...only one waste will normally be accumulated at each satellite area."g Can there be more than one hazardous waste at an SAA? Can there be more than one container at an SAA? Answer : Yes. It's permissible to have more than one hazardous waste in an SAA. Likewise, it's permissible to have more than one container of hazardous waste in an SAA. The regulations do not limit the number of hazardous wastes or the number of containers that can be placed in an SAA. The regulations limit only the total volume of hazardous waste at a single SAA to 55 gallons (or 1 quart of acute hazardous waste). If there are multiple containers of hazardous waste in an SAA, each container must be labeled in accordance with 262.34(c)(1)(ii). Because the Agency did not anticipate that generators would accumulate multiple hazardous wastes/containers in an SAA, a cross-reference to the requirements for the safe storage of incompatible wastes was not included as part of the container management standards for SAAs. Nevertheless, good management practices clearly dictate that incompatible wastes should be stored separately. Furthermore, in the event that any wastes, including incompatible wastes, are stored in such a way that https://yosemite.epa.gov/osw/rcra.nsf/documents/8c9f6dc8b378a2f585256e9900723a8b 10/4/2016