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Closed Containers and Spill Prevention

We’ve been talking a lot recently about closed container guidelines. We covered recommendations for containers in central accumulation areascontainers holding liquids in satellite accumulation areas, and containers collecting solid or semi-solid wastes in satellite accumulation areas. Today we’re going to cover why closed container guidelines are so important and what best practices you could have in place to help ensure your containers stay closed.

The main point is that closed containers prevent spills. While it is true that regulations allow for flexibility in the definition of closed that in no way means you should not be diligent about keeping your containers from spilling. The first best practice the EPA suggests is making sure that your containers are located in low traffic areas. This means away from things like forklifts. Doing so reduces the number of opportunities for accidental tipping over and/or spilling of drums. They recommend this practice in both CAAs and SAAs.

The second suggestion involves containers with lids that are not securely affixed (with a bolted ring clamp or locked funnel lid). The EPA recommends that generators secure these containers with a chain or strap to a wall or building support column to keep them from tipping over and/or spilling. This is especially important in areas where seismic activity is a danger. If no building support is available then the EPA suggests strapping the containers together to keep them from overturning. A larger group of drums is less prone to overturning than a single one. They do caution that generators must “continue to comply with the SAA requirements that the container be located at or near the point of generation and not exceed the quantity limitation of 55 gallons.”

The third best practice, while not required in 40 CFR, is still a good system to have in place. Using secondary containment systems for accumulating hazardous wastes can be an inexpensive (in the case of using a pan or tub to collect ay release or spill that could occur when adding or removing waste) and effective for catching wastes from a leaky container. Additionally, valve vents or level indicators can be used to prevent pressure buildup after adding liquids to drums. Level indicators in particular can help to prevent overfilling a container which could result in unsafe working conditions and a pricey cleanup project.

The last tip is more a reminder than a best practice. It is that regulations require containers to be closed (except when adding or removing waste) even when a plant is not operating. This is because spill and emission prevention is vital 24/7. It’s true that most accidents don’t occur when a plant is closed or inactive but regulations still require containers to be closed in order to prevent volatile emission releases. The EPA also states that, “requiring an operator to secure the cover or lid using snap rings, capping the bungholes, or securely fastening the container with other types of covers or lids is not time­ consuming and adds protection for the facility when it is closed down for the weekend or periods of inactivity.”

Does your company have any other best practices for keeping containers closed? Have you found anything that works better than the ideas provided by the EPA? If so, we would love to hear about them, just let us know in the comments section!

Quoted and cited information (unless otherwise noted) for this blog post was gathered from the EPA Memorandum on Closed Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Alternate Waste Container Types for CAAs and SAAs

In talking about closed container guidelines in central and satellite accumulation areas we have been sticking with drums as the primary container type. Since drums are not the only option though, today we will cover some other container types you could use in CAAs or SAAs and what constitutes them as closed.

Other container types applicable to storage in CAAs and SAAs include “bags, durable sacks made of woven synthetic material (polysacks), boxes, twenty cubic yard roll-off boxes or containers, one cube yard heavy duty cardboard boxes with a plastic liner (Gaylord boxes), semi-trailers used to manage solid and semi-solid hazardous wastes, and stainless steel and plastic totes in wire cages to handle liquid hazardous wastes.” Each option has a different method for closing.

Generally speaking, the EPA considers these types of containers “closed” when they are sealed to the extent that hazardous wastes and emissions will be kept inside the container. They use the example of wet paint filters accumulated in bags. “A bag containing dry paint filters may be considered closed when the neck of the bag is tightly bound. However, a bag containing solvent laden wet paint filters would generally not be an acceptable container unless the bag was double lined and the bag could be sealed sufficiently to prevent leaks and emissions.”

Roll-off containers may also be used to hold waste in accumulation areas. According to the EPA, “Large roll-off containers, such as 10 by 20 foot containers, are often used for the accumulation of large volume waste streams, such as F006 sludges from electroplating operations and inorganic wastes where volatility is not an issue.” There are some roll-off containers that are made with lids that open and close. In the case of such containers it would be considered closed when the lid is shut and has a good seal around the rim.

The EPA notes that, “From an operational and practical standpoint, these types of containers are generally located inside the facility where a roof or ceiling and walls protect the container from outside elements. Once the containers are completely full, [they] may be covered with tarps and moved outside to a staging area for subsequent management…EPA generally views these situations as both practical and sufficient to meet compliance with 40 CFR 265.173(a).”

If, however, a roll-off container is kept outdoors while receiving waste it is important that generators keep tarps closed when not adding or removing waste to ensure no condensation can enter the container. The EPA warns that even a small amount of water can be enough to leach hazardous constituents from the waste that could leak out of the roll off.

Roll-off containers holding wastes that contain volatile organic compounds (VOCs) are subject to even stricter requirements. The EPA dictates that, “if a roll-off container is not in light material service then use of a tarp with no visible holes or gaps or open spaces (e.g., a cover and closure device that forms a continuous barrier over the container) is an example of a suitable Level 1 control device. However, use of tarps in this instance is also subject to 40 CFR 264.1086(c)(2) for permitted units and 40 CFR 165.1087(c)(2) for LQGs, which requires closure suitable to weather conditions, including exposure to wind, moisture and sunlight.

If the roll-off container is in light material service, then Level 2 controls are required under Subpart CC. Examples of container loading procedures that meet Level 2 controls include using a submerged-fill pipe or other submerged-fill method to load liquids into the container or a vapor-balancing system or a vapor­ recovery system to collect and control the vapors displaced from the container during filling operations. The use of a tarp would not be an acceptable Level 2 control device.”

Quoted and cited information (unless otherwise noted) for this blog post was gathered from the EPA Memorandum on Closed Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Closed Container Guidelines in SAAs: Part 1

Earlier this week we discussed the guidelines for closed containers in central accumulation areas (CAAs). If you’ll remember, the purpose of these guidelines is to prevent spills and minimize emissions from volatile wastes. Today we are going to talk about what guidelines exist for containers in satellite accumulation areas or SAAs. In particular, we will be covering the closed container guidelines for containers accumulating liquid hazardous wastes in SAAs. Containers containing solid and semi-solid wastes will be covered in a later post.

Unlike CAAs (where waste is often stored after the fact) SAAs are locations in a facility where waste is generated and accumulates in a container. 40 CFR 262.34(c)(1) and (c)(2) set forth the requirements for generators that accumulate hazardous waste in an SAA, including the requirement that the generator must accumulate the waste in a container that is “closed” except when adding or removing waste.

The situation that raises the most questions about closed containers is management of liquid hazardous wastes or free liquids. This includes items like spent organic solvents. These waste accumulations bring up the most questions because so many generators use liquid solvents in their production or manufacturing processes.

The three primary risks associated with liquid hazardous wastes accumulated in containers are risks from inhalation, risk of potential buildup of vapors in the container, and risk of an accidental spill of material. Since the purpose of the closed container guidelines is to minimize emissions and avoid spills, ignitions, or mixing of wastes it is imperative that generators have systems in place to keep containers closed and to prevent leaks or ruptures.

Generally, a container collecting liquid hazardous wastes in an SAA is “closed” when “all lids are properly and securely affixed to the container, except when wastes are actually being added to or removed from the container.” The reasoning behind making sure the lid is totally covering the container is to prevent any volatile emissions from being released and to prevent a spill in the chance case that a container is tipped over.

The EPA recognizes that the frequency with which materials may be added to or removed from a container makes securing lids with snap rings, securely capping bungholes, and/or fastening the lid on by other means inconvenient. That said it is still important that the container is covered tightly. They provide the following advice:

“We believe containers holding free liquids, or liquid hazardous waste, in the SAA would meet the regulatory definition of “closed” through a variety of approaches. For example, special funnels with manually or spring closed lids or other similar closing devices could be used for closed-head drums or closed-top drums (e.g., containers that have two bung holes with non-removable lids).

Similarly, funnels used to add or remove liquid hazardous wastes from these containers would be screwed tightly into the bunghole and fitted with a gasket, if necessary, to seal the funnel lid firmly closed. In some cases, the funnel lids for closed-head drums and closed­ top drums may be fitted with a locking mechanism. This keeps the lid in a closed position. All other openings on the drum lid should generally be properly closed or capped.

Another alternative is the use of a funnel with a one-way valve that allows hazardous waste to enter the container, but prohibits the waste or emissions from exiting the container… Liquid hazardous wastes also can be accumulated in open-head drums or open-top containers (e.g., where the entire lid is removable and typically secured with a ring and bolts or a snap ring) and meet the definition of “closed,” provided the rings are clamped or bolted to the container.

In some situations, the container could be considered closed if the lid covers the container top securely even though the rings are not clamped or bolted. Several states take this approach, and EPA believes it reflects a reasonable interpretation of the regulations.”

Quoted and cited information (unless otherwise noted) for this blog post was gathered from the EPA Memorandum on Closed Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Closed Container Guidelines in CAAs

If you remember, last week we gave a brief introduction to Closed Container Guidelines. These guidelines were created in order to address continued confusion in the hazardous waste generator community concerning what constitutes a container as closed. According to the EPA, “the existing federal RCRA Subtitle C container regulations do not define ‘closed container.’” Because of this many states have promulgated their own regulations. That being said, while this post will help you with the federal suggestions it is imperative that you check with your state government concerning any regulations. 

The individual state guidance combined with feedback from the Office of Enforcement and Compliance Assistance (OECA), EPA regions, and comments from the 2004 Advanced Notice of Proposed Rulemaking (ANPRM) were used to create these guidelines.

These guidelines in combination with any state regulations aim to address the goal set forth in the original 1980 preamble, to prevent spills and minimize emissions from volatile wastes. The guidance focuses on two separate parts; containers of waste in central accumulation areas (CAAs) and containers of waste in satellite accumulation areas (SAAs). Today we will be covering the regulations for containers in CAA’s.

Once a hazardous waste has been generated from plant processes (including the accumulated hazardous waste from SAA’s) they are sent to the CAA. According to the EPA, “a CAA is a location where hazardous waste containers are kept according to the generator accumulation requirements at 40 CFR 262.34(a) and 40 CFR 262.34(d) without a facility having to obtain a RCRA storage permit or having interim status.” CAAs are located either outdoors within a facility boundary or inside but away from production operations. Regulations require that containers in CAA’s must be closed unless waste is being added to or removed from them. Additionally, they must be stored and handled in a way that ensures they will not rupture or leak.

The EPA points out that containers storing wastes that are subject to Subpart CC regulations are significantly more detailed due to concerns about volatile organic compounds (VOCs) and their potential release into the atmosphere. For standard 55 gallon drums, however, the EPA suggests the following: “a container [should] be properly secured with snap rings tightly bolted, bungholes capped, and, where appropriate, pressure-vacuum relief valves to maintain the containers internal pressure and avoid explosions.”

While these are only federal guidelines and not explicit rules it is still best to practice them. Doing so can help you to ensure compliance and avoid a spill situation. Keep checking the blog for further information on closed containers in SAAs, spill prevention, and more.

Quoted and cited information (unless otherwise noted) for this blog post was gathered from the EPA Memorandum on Closed Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

An Introduction to Closed Container Guidance

In December of 2009 the EPA issued guidance for both Large Quantity and Small Quantity Generators concerning how to decide when a container is “closed.” The guidance is pertinent whether waste is being accumulated in central accumulation areas (CAA) or satellite accumulation areas (SAA) or at RCRA permitted interim facilities. Today we will be providing an overview of this EPA guidance but keep reading in coming weeks for more in-depth looks at guidelines for specific storage areas and container types.

To begin we need to understand that the EPA defines a container as “any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled.” The regulations in 40 CFR 265 require containers that are holding hazardous waste to be closed during storage and open only when adding or removing waste. Additionally, it stipulates that containers must not be opened, stored, or handled in a way that would cause the container to rupture or leak.

Typically, like in the case of 55 gallon drums, the EPA recommends that a container cover is, “properly secured with snap rings tightly bolted, bungholes capped, and, where appropriate, pressure-vacuum relief valves to maintain the containers internal pressure and avoid explosions.”

A container accumulating free liquids or liquid hazardous waste is considered closed when all openings or lids are properly and securely affixed to the container unless waste is being added or removed from said container. A container holding solid or semi-solid hazardous wastes is closed when, “there is complete contact between the lid and the rim all around the top of the container.” Generally speaking, the EPA considers a container closed when it is, “sealed to the extent necessary to keep the hazardous waste and associated air emissions inside the container.”

The reasoning behind the closed container guidelines is explained in the preamble to the final rule created in 1980. It states:

“…Its purpose is, as it was originally, to minimize emissions of volatile wastes, to help protect ignitable or reactive wastes from sources of ignition or reaction, to help prevent spills, and to reduce the potential for mixing of incompatible wastes and direct contact of facility personnel with waste. While many commenters argued and the Agency agrees that storage may properly be conducted in open tanks and surface impoundments, requiring containers to be kept closed does not unnecessarily restrict storage options. All containers have lids or some other closure device, and keeping containers closed whenever possible is simply a matter of good operating practice. It is not expected that containers of hazardous waste need be opened routinely to inspect the waste or the container for reasons other than to add or remove waste.”

What this means is that you can view container regulations as akin to performance standards intended to minimize the risk for potential spills, leaks, or air emissions. So remember to keep your containers closed. If you have tips or strategies let us know in the comments!

Quoted and cited information (unless otherwise noted) for this blog post was gathered from the EPA Memorandum on Closed Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.