McMorsel: Clarifying satellite
accumulation "at or near the POG."

Near and yet so far. Huh?

Satellite accumulation containers must be “at or near” the point of generation (POG) of the waste and “under the control of the operator of the process generating the waste.” [§262.15(a)] But how is “at or near” defined? And what does “under the control of the operator” mean? Must satellite accumulation containers or areas be locked? EPA provided some guidance on these issues in the preamble to the generator improvements rule [81 FR 85766-7], and we have a white paper on that rule, summarizing this guidance and more. Visit our website and find more compliance morsels.

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