printreg,August,2004Hazwaste Container Management Essentials

printreg, August, 2004
Hazwaste Container Management Essentials

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From: Gary Jones (
Date: Sun, 8 Aug 2004 21:11:39
Source: 07/15/2004

Hazwaste Container Management Essentials

One of the most common management units used for hazardous waste storage is the hazardous waste container, basically because it is less expensive and generally less difficult to manage than other units. Nevertheless, hazardous waste container management violations are the most frequent regulatory violations cited, particularly violations by hazardous waste generators. Are you sure that you are in full compliance with your requirements? Do you know what a container is? Do you understand the definition of an "empty container"? Are you required to have a permit?

If you are an owner or operator of a treatment, storage, and disposal facility (TSDF) or a generator who accumulates hazardous waste, there are specific requirements you must meet.

This article will help you understand the federal container management rules applicable to both TSDF owners and operators storing hazardous waste in containers and generators accumulating hazardous waste on-site in containers. Your state may have additional requirements or variations of the federal rules (see sidebar).

Who Needs a Permit?

Owners and operators of hazardous waste TSDFs with containers must have a RCRA TSDF permit in order to operate.

Large quantity generators (LQG) and small quantity generators (SQG) using containers to store or treat hazardous waste are exempt from the RCRA permit requirements, provided they comply with the RCRA hazardous waste rules for accumulation time, quantity of waste stored, and container handling.

What Is a Container?

The RCRA hazardous waste regulations define a container as "any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled." The definition is intentionally broad to encompass all different types of portable devices that may be used to handle hazardous waste. Containers may be 55-gallon tanks, barrels, tanker trucks, a railroad car, and even a small bucket or test tube.

Container Operating Standards
* All containers used to hold hazardous waste are required to be in "good" condition.
* Containers holding hazardous waste must be closed at all times, except when adding or removing waste.
* Containers must be clearly marked with the words "HAZARDOUS WASTE," and with the date you began to collect waste in that container.
* Containers holding ignitable or reactive waste must be at least 50 feet from the facility property line.
* Maintaining 4 to 5 feet of aisle space between containers provides for easy inspections and movement of personnel and equipment, and allows an open 85-gallon salvage drum to be placed over a leaking container and then flipped to hold the container contents.
* All containers and container areas must be inspected for leaks or corrosion at least weekly. (Inspection records need to be kept for 3 years following the date of inspection.)
* The addition of absorbent material to waste in a container or the addition of waste to absorbent in a container must occur at the time waste is first placed in the container.
* Air emissions standards require TSDF owners and operators receiving a container to visually inspect the container, its cover, and closure device. The inspection must occur on or before the date the container is accepted.

Container Compliance Tips
* Whenever possible, store the waste in the container it was shipped in. This may be the container the product came in. It saves work and eliminates the possibility of spills during waste transfer.
* Let your employees choose the type of closure device that will work best for them.
* Although stacking drums is allowed, regulators strongly recommend placing a stabilizing material between drums and stacking no more than two drums high.
* Hang your inspection log on a clipboard in the storage area. When it is full, file it in your permanent records.
* To avoid waste spills from destroying your label, place the label on the side of the container away from the bung. You may also wish to protect labels by applying a thin coat of varnish, covering them with clear packing tape, or enclosing them in a plastic pouch designed for that purpose.
* In order to determine the compatibility of waste with your container, ask your transporter and disposal facility for recommendations based on the intended disposal method for the waste. The DOT Hazardous Materials Table at 49 CFR 172.101 may help you determine what type of container to use. A barrel manufacturer or reconditioner may also be able to help you.

Containment System

The containment system requirements only apply to permitted facilities and not to interim status facilities. Because generators storing or treating hazardous waste on-site without a permit follow the interim container standards, such generators are not required to have a containment system for their containers. TSDF storage areas in which solid and free liquids are stored must have a containment system with the following:
* Solid base. Floors must be impervious to leaks, spills, and precipitation.
* Drainage control. Storage area should be sloped or designed to drain and remove liquids from leaks, spills, or precipitation.
* Capacity standard. The containment system must have the capacity to contain 10 percent of the container volume, or the volume of the largest container, whichever is greater.
* Run-on prevention. Run-ons into the containment system must be prevented.
* Removal of overflow. Spilled or leaked waste and accumulated precipitation must be removed as soon as possible to prevent overflow of the containment system.

Air Emissions Standards

EPA adopted air emissions standards to reduce organic air emissions from certain hazardous waste activities, including process vents, equipment leaks, and certain tanks, surface impoundments, and containers. These air emissions standards apply to permitted and interim status TSDFs with containers and LQGs that store hazardous waste on-site in containers without a permit in accordance with the generator accumulation time rules.

What Is 'Empty'?

There are three separate regulatory standards for rendering a container or inner liner "RCRA empty," based on whether the container holds:
Hazardous waste
Compressed gas that is a hazardous waste
Acute hazardous waste

Hazardous Waste

A hazardous waste container is empty if:
* All the waste has been removed that can be removed by pouring, pumping, or suction; and
* No more than 1 inch (in.), equivalent to 2.5 centimeters, of residue remains (commonly referred to as the "1-inch rule"); or
* No more than 3 percent by weight of total capacity of the container remains if the container is less than or equal to 110 gallons in size; or
* No more than 0.3 percent by weight of the total capacity of the container if the container is greater than 110 gallons.

Note: The empty-by-weight standards are often used when there is a mixture of liquid and solid hazardous waste.

Compressed Gas Containers holding compressed gases that are hazardous wastes are considered empty when the pressure in the container approaches atmospheric pressure. This requires opening the container with proper precautions.

Acutely Hazardous Waste A container used to hold an acute hazardous waste is empty if one of these three conditions has been met:
* It has been triple-rinsed using solvent capable of removing the hazardous waste.
* It has been cleaned by another method that has been shown to remove the acutely hazardous waste.
* In the case of a container, the inner liner that prevented contact of the hazardous waste has been removed.

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