Tips for Hazardous Waste Container Inspections

You may remember from our post and eBook on the Top 10 Hazardous Waste Generator Violations that “Failure to Perform Weekly Inspections of Hazardous Waste Storage Areas,” is among the most common ways generators violate EPA regulations. 

Weekly container inspections are imperative to protect you, your company, and the health and safety of the public. By performing your weekly inspections you can identify any issues that may arise and stop sills before they happen.

The EPA recommends that companies develop and maintain a standard inspection checklist that can be used during each weekly inspection. This checklist should be detailed and include both the labeling and management procedures in place at your facility. 

We have prepared a checklist (with some additional tips) which can be downloaded by clicking the button below. 

This checklist can be modified to fit the needs of your facility but remember that at the very list you need to address the following:

  • Any leaks or staining coming from containers;
  • Condition of your containers including noting any dents, bulging, and/or corrosion; 
  • Proper labeling—this should include a clearly marked start date as well as the words “Hazardous waste.”  Any other relevant information about the waste should also be indicated on the label.
  • Management practices such as aisle space and drum stacking.

Remember, these inspections are very important in both protecting your company from committing a violation and ensuring the protection of human health and the environment. Inspections should be detailed and methodical and should always be performed by a fully trained individual.

The EPA provides the following tips for conducting your weekly container inspections:

  • “Follow the inspection checklist – make detailed notes if you find something wrong.
  • Be thorough. Check the tops of drums to look for waste residue or corrosion.
  • Walk all the way around containers – check entire storage area.
  • Check containment area for stains.
  • Note anything unusual in containment area – even if it might not be a problem.
  • If problems are found, get the problem taken care of immediately.
  • Keep a logbook of the facility’s inspection checklist.”


Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste 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.

Tips For Managing Incompatible, Ignitable, and/or Reactive Wastes

When managing containerized wastes that are incompatible, ignitable, or reactive there are even stricter regulations that must be adhered to. According to §265.177, “a storage container holding a hazardous waste that is incompatible with any waste or other materials stored nearby in other containers, piles, open tanks, or surface impoundments must be separated from the other materials or protected from them by means of a dike, berm, wall, or other device.”  So in layman’s terms, if a generator has containers that are holding wastes which are incompatible he or she must physically separate the two waste types in order to keep them from contacting and potentially reacting with other wastes or materials.

In addition to this, there are special requirements for ignitable or reactive wastes. Firstly, these types of wastes must be stored at least 50 feet from a facility’s property line. You may have seen that many facilities stack their drums along the fence line in order to maximize storage space; this, however, is not an option for storing ignitable or reactive wastes. The reasoning behind keeping these types of waste well within the boundary lines of a facility are twofold. Firstly, they reduce the risk of the general public being able to reach or come in contact with the waste (additionally protecting them from any harm in the chance of an explosion), and secondly, if a release of the hazardous waste occurs the distance will help to prevent waste from migrating offsite. Besides the distance issue, there are a few more key regulations to follow.

According to 40 CFR §265.17(a), “the owner or operator must take precautions to prevent accidental ignition or reaction of ignitable or reactive waste. This waste must be separated and protected from sources of ignition or reaction including but not limited to: Open flames, smoking, cutting and welding, hot surfaces, frictional heat, sparks (static, electrical, or mechanical), spontaneous ignition (e.g., from heat producing chemical reactions), and radiant heat. While ignitable or reactive waste is being handled, the owner or operator must confine smoking and open flame to specially designated locations. “No Smoking” signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste.”

To break that down, wastes that are ignitable or reactive must be managed to prevent fire or explosions. At a minimum this means a generator needs to keep these types of waste away from:

  • Fire;
  • Hot surfaces such as machinery engines;
  • Sunlight or radient heat;
  • Frictional heat (keep drums stationary to help with this, never drag or pull drums along the ground);
  • Cutting and welding operations;
  • Sparks from static electricity or electrical operations;
  • And in the case of some reactive wastes, water.

And finally, smoking must be banned and signs stating “No Smoking,” must be posted in all areas where reactive or ignitable wastes are managed.

As far as best management practices go, the EPA provides the following advice:

  1. “Use a funnel or hose to add or transfer wastes to drums. This will prevent spills. Remember to rinse the funnel and characterize the rinse water (a dedicated funnel would not have to be rinsed).
  2. If you notice a leak, or a container is in poor condition, transfer the waste to a new container immediately.
  3. Keep containers cool and dry.
  4. Make sure all container storage areas are clearly marked — keep ignitable/reactive wastes in their own area.
  5. Don’t stack ignitable/reactive wastes.
  6. Make sure to open and close steel drums with a spark proof bung wrench.
  7. Don’t push, roll, or drag containers. Use the right equipment to move the drums.
  8. Make sure the drums are easy to reach – keep an open aisle space so that people and equipment can move freely.
  9. Don’t drive equipment (trucks, forklifts) into container storage areas unless you are moving containers.
  10. Keep the containers in a ‘containment area’ to hold spills. Containment can be provided by dikes, berms, or walls.”

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste 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.

Satellite Accumulation Areas vs. 90-Days: Part 1

In Tuesday’s post we mentioned that the labeling and marking rules can be different for containers in Satellite Accumulation Areas (SAAs). We will cover that (as well as some other specifics of SAAs) in today’s post. It’s important to cover the guidelines for SAAs prior to covering those for 90-days so generators can make sure they are managing their accumulation areas properly.

According to 262.34(c)(1), “a generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in 261.33(e) in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or interim status and without complying with paragraph (a) of this section provided he:

  • Complies with 265.171, 265.172, and 265.173(a) of this chapter; and
  • Marks his containers either with the words “Hazardous Waste” or with other words that identify the contents of the containers.”

So in laymen’s terms, an SAA can be utilized to store up to 55 gallons of hazardous waste (or up to 1 quart of acutely hazardous waste) for an unlimited time and with only some of the requirements needed for 90-day areas. In order to store waste in an SAA the EPA requires that you:

  • Keep your containers in good condition,
  • Ensure that the waste being stored is compatible with the container type,
  • Keep containers closed unless you are adding or removing waste,
  • Make sure you handle containers in such a way that you are preventing leaks or spills, and
  • Mark containers with the words “Hazardous Waste,” or other identification of contents.

The less stringent and numerous regulations for SAAs attract a lot of generators which can cause problems. Most often, these problems arise from generators storing in waste they have designated as an SAA but which is not actually applicable to that designation. For an accumulation area to be an SAA very specific requirements must be met. Firstly, only waste which is generated at the SAA can be stored there. An SAA cannot be used as “temporary staging areas for wastes collected from other areas.” Secondly, an SAA must be located at or near the point of generation. So if waste is generated in a lab the containers should also be located in the lab.

If a generator accumulates more than the limit of 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) at an SAA the EPA requires that they:

  • “Mark the container holding the excess accumulation of hazardous waste with the date the excess amount began accumulating,” and,
  • “Move the container holding the excess accumulation to a container storage area within 3 days.”

And remember, if a generator incorrectly manages a 90-day storage area as an SAA they will be in violation of EPA regulations. For more information about managing waste in 90-day areas keep reading our blog!

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste 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.

Tips for Waste Container Marking and Labeling

If you are a hazardous waste generator than you know that once you’ve placed any hazardous waste into a container it becomes necessary to properly mark and label that container. According to the EPA, a hazardous waste generator is only allowed to accumulate or store waste on-site for less than 90 days if they do not have a permit. This 90-day limit begins the moment the container becomes full. There are a couple of exceptions to the 90-day rule.

For example, if you are a small quantity generator (SQG) and you are shipping your wastes more than 200 miles away you can store waste for up to 270 days. If you’re shipping less than 200 miles away, you only have 180 days. Differing time frames aside, the important thing is that you must be able to prove to an inspector that your waste is within its storage time window.

The way you can ensure your ability to prove so is by properly dating your container. §262.34(a)(2) states that “the date upon which each period of accumulation began [must be] clearly marked and visible for inspection on each container.” Additionally, you must clearly mark and identify the container with the words “Hazardous Waste.” The one exception is for hazardous waste containers in a satellite accumulation area which we will cover in a later post.

The Ohio EPA provides the following advice for keeping your hazardous waste labels in good shape, “Pay attention to container labels. Make sure they are filled out and in good condition. If a label gets torn or becomes difficult to read, replace it. If you store hazardous waste containers outside, check labels during your inspections to ensure they haven’t fallen off or become damaged.”

In addition to the EPA regulated markings it is important to follow any state regulations as well as making sure to comply with any and all labeling requirements set forth by the Department of Transportation (DOT). DOT labels must be filled out before the container can be shipped off site. This label will exactly identify the waste including its name, characteristics, and handling requirements.

It’s not just having the labels on the container that is important though. You must also think about where on the container you place them. Proper placement is important so that labels are not missed by handlers. Labels must appear in their entirety and should not be placed near any other markings on the surface. They should always be visible (so never place them on the bottom of a container).

“If the waste has multiple hazards associated with it multiple labels should be displayed next to each other. The DOT recommends a six- inch space (15 cm) between labels. The label designating the primary hazard should be above and to the left of the label designating the subsidiary hazard.” [1]

Finally, the EPA provides the following tips for marking/labeling your containers:

  • Have all personnel use the same method (e.g., handwritten, prepared labels) to label containers. Make sure all handlers know what the markings mean.
  • Besides the start date and the words “Hazardous Waste,” include information about contents (e.g., toxic, reactive, incompatible).
  • Apply DOT labels to the container when waste is first placed in the container. The label will be in place for shipment and provides information about the waste to drum handlers.
  • Before reusing containers, make sure all old markings/labels are washed off or blacked out.

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste 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.

How do I Choose the Right Waste Container?

On Tuesday we wrote about the importance of waste characterization when it comes to containerized waste. In that post we touched briefly on the need for using an appropriate type of container to store your waste; today we’re going to look at that a little closer.

So, once a generator has their waste properly characterized they will know if it is incompatible or reactive with other waste types or even different types of containers. Once they know this, they can move on to choosing the best container in which to store their waste.

The first thing to consider when choosing your contain type is the quantity of waste you will be generating. If you know you will only be generating 20 to 25 gallons of waste than a 30-gallon drum would be more practical than a 55-gallon drum. Alternately, if you are storing contaminated gloves, coveralls, or other personal protective equipment (PPE) a 55-gallon drum would probably work best. Once you’ve decided on your container size you can move on to choosing the material your container will be made out of.

We’ve mentioned before that some wastes can actually have a negative reaction with the container they are placed in. For example, a highly corrosive waste can react with a steel drum and lead it to erode. This could make the drum leak and allow for a spill of the waste. In order to avoid this, corrosive wastes should be stored in plastic drums or plastic lined steel drums. This will prevent the waste from coming into contact with an incompatible material. As the EPA points out, “to prevent drum failure, carefully “match” the right waste with the right container.” If you are unsure if your waste and drum are compatible consult a corrosion resistance guide.

Now you’re almost in the clear but there is one more thing to consider when choosing your container. What do you do if your container once held an incompatible waste? According to §265.177(b) you are allowed to put wastes into unwashed containers that once held an incompatible waste but only if you meet the following specified conditions:

“…the mixture or commingling of incompatible wastes, or incompatible wastes and materials, must be conducted so that it does not:

  1. Generate extreme heat or pressure, fire or explosion, or violent reaction;
  2. Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to threaten human health;
  3. Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosions;
  4. Damage the structural integrity of the device or facility containing the waste; or
  5. Through other like means threaten human health or the environment.”

If you cannot meet these conditions then you must make sure that the waste or material that was previously held in your container is compatible with the new waste you will be placing into it. Finally, the EPA provides the following tips for safely putting your wastes into containers:

  1. “Make sure you know which wastes are reactive and/or incompatible. Keep these wastes away from each other. Put them in separate containers.
  2. Make sure the container cannot be harmed by the waste.
  3. If you rinse out containers onsite, be aware that rinse water generated from drum washing must be contained and characterized prior to disposal.
  4. If you frequently reuse containers, consider “assigning” wastes to certain containers. This will allow you to reuse the container without washing.
  5. Use a funnel to prevent spills, and do not use the same funnel for all wastes.
  6. Certain chemicals may need room for expansion, or they may require zero headspace depending on the characteristics of the waste and storage conditions (e.g., temperature fluctuations).”

Quoted and cited information for this blog post was gathered from the EPA Handbook for Hazardous Waste 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

Container Management & Hazardous Waste Characterization

Before you can put a waste in a container you have to ensure that you will be managing it safely. To do this, you need to know exactly what the waste you’re dealing with is comprised of/what it can do. You need to know answers to questions like, “is it toxic?” You need to determine whether or not waste handlers will need special personal protective equipment (PPE) to handle it. You will need to identify what, if any, other chemical it might react with to avoid potential explosions or fires. And especially before putting your waste in a container you need to be sure it is not corrosive in order to prevent it eating through the container you choose. All this said, it is vital that a waste be characterized before it is placed into a container.

In their manual on container management, the EPA states that there are two ways a generator can go about characterizing a waste:

  1. Generators can sample the waste and analyze it to identify any potential issues, or
  2. Generators can, “identify the waste based on process knowledge,” meaning they could look into the constituents in the process that created the waste and use the knowledge of any characteristics those constituents have to determine whether it is likely that the produced waste also has that or those characteristics.

Additionally, they provide some best practice tips for waste characterization including, looking at a material safety data sheet (MSDS) if one is available. When looking at the MSDS pay special attention to areas marked, “physical property, reactivity, fire and explosion hazard, and special protection information.”

Another best practice is related to the second way to characterize a waste. “If a product being used in a process meets one or more hazardous characteristics, the waste generated may exhibit some of the same characteristics.”

Finally, “be aware of any changes in a production process which could alter the composition of the waste generated.” But what do you do if the waste you need to characterize is already in a container? The EPA provides some tips for that too:

  1. “Pay attention to marking/labeling which may indicate that a material is flammable, corrosive, etc.
  2. Always check with your supervisor before handling unknown drums, or drums which you feel are labeled or marked incorrectly.
  3. Look at a material safety data sheet (MSDS) if it is available.
  4. If waste is in a plastic drum it is a good indication the waste may be corrosive.”

It is also important to remember that wastes which exhibit signs of corrosivity, combustibility, flammability, oxidization, poison, reactivity, or toxicity may require specialized equipment to manage. Once you’ve got your waste characterized, it’s time to put it into the proper container.

During the characterization of your waste you should have learned if it was reactive or incompatible with another waste. This is a vital step because before you can put your waste into a container you must identify and segregate and incompatible or reactive wastes in order to prevent fires or explosions. According to the EPA, “The regulations state that incompatible wastes cannot be placed in the same container, unless you comply with other requirements found in §265.17(b). This prevents the wastes from reacting with each other (e.g., exploding, catching on fire).”

There can be exceptions if you’re putting incompatible wastes in the same containers while being pursuant to the conditions found at §265.17(b). To do this you must:

  1. “Keep the waste from becoming too hot (this will prevent fire or explosions);
  2. Keep the wastes from producing toxic and/or flammable mists, gases, fumes, or dust (this will prevent workers from being exposed to the waste and will prevent fire or explosions);
  3. Make sure that mixing the incompatible wastes won’t damage the container – the container won’t rupture or bulge; and
  4. Demonstrate that mixing the wastes won’t threaten workers, or the environment in any way.”

And remember that you should always get the okay from your supervisor or environmental coordinator before you mix any materials or wastes.

Quoted and cited information for this blog post was gathered from the EPA Handbook for Hazardous Waste 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 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 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.