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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.

Attached Waste Containers & Satellite Accumulation

Last Thursday we posted a collection of questions and answers related to hazardous waste containment. One question was as follows:

“When a facility has equipment that discharges hazardous waste to an attached container, do the attached containers need to be in compliance with satellite accumulation regulations?” 

With the answer being “Yes.”

After posting we received a comment that asked a very good question:

“If the container is attached, why wouldn’t it be considered ‘part of the process’?”

While I sent an answer to the person who asked the question initially, I thought it might be beneficial to explain the answer more fully today so everyone has access. Because I was not certain of the answer, I went to our Director of Corporate Compliance and Safety for clarification. This is what I learned.

The question asked can be addressed by a Memorandum issued by Robert Springer, USEPA Office of Solid Waste on March 17, 2004 and answered as follows:

Yes. Even if the discharging unit is not regulated under RCRA, the attached containers that collect hazardous wastes from such equipment must be in compliance with the Satellite Accumulation Area regulations, if those containers collect wastes that are listed or characteristic hazardous wastes. Waste containers in Satellite Accumulation Areas must be:

      • In good condition (265.171)
      • Compatible with their contents (265.172)
      • Labeled with “words that identify the contents of the container” or the words “hazardous waste” (262.34(c)(1)(ii)).

In addition, the containers in Satellite Accumulation Areas must be closed, except when adding or removing hazardous waste (265.173(a)). Generators would not be required to keep such containers closed while hazardous waste is being added to the container; but generators would need to keep them closed when the hazardous waste is not being discharged to the attached container.

The container(s) attached to such equipment is a point of generation. It is possible for there to be multiple pieces of equipment within one Satellite Accumulation Area, and thus multiple points of generation within a single Satellite Accumulation Area, provided all the pieces of equipment are “at or near” each other and “under the control of the operator of the process generating the waste.” Under this scenario, the total amount of hazardous waste in the Satellite Accumulation Area would be limited to 55 gallons (or 1 quart of acute hazardous waste) and a generator would be allowed to consolidate like hazardous wastes from multiple discharging units.

Now the question becomes one of whether something is “integral to the process”…,

There may be occasion where waste is being generated in a container. The most important thing to remember in these cases is that regulations can vary from state to state. The State of Colorado, for example, has issued guidance about whether certain pieces of equipment are satellite accumulation or not:

‘In-process waste does not need to be managed as a satellite accumulation area. In-process waste refers to waste that is continuously generated and is an integral part of the system generating the waste, or waste that is accumulated during a process and is moved to a satellite-accumulation or 90-day area at the end of a work shift. For example, consider a machine shop which grinds metals parts on a lathe. The lathe includes a recirculating solvent cleaning bath which is an attached, hard-plumbed integral part of the system. The waste generated by this system is considered in-process. Once the cleaning bath is removed from the lathe, the waste solvent must be moved to a satellite-accumulation or 90-day area. Another example could be a container for waste generated by a High Pressure Liquid Chromatograph which is physically connected to the HPLC. Once the container is full and/or removed or disconnected from the HPLC, the waste must be moved to a satellite-accumulation or 90-day area. A third example of accumulating waste during a process could be a group of six employees working at the same bench, cleaning equipment with listed solvents on a Q-tip. Each employee has a one-gallon collection container for used Q-tips at their work station. At the end of the work shift, the employees consolidate their one-gallon containers in a 55-gallon container located at the end of the work bench. In this example, the one-gallon containers are considered a collection point for in-process waste and the 55-gallon container is considered a satellite accumulation area. “Integral to the process” is the primary condition for in-process waste, and may include a hard-plumbed container or other physical connection; however, physical connection is not a required condition (see above Q-tip example).’

Our best suggestion is for the generator to consider any guidance that they may have received from their state regulatory officials as to whether or not the container would be satellite accumulation or not as it would be dependent upon the state interpretation. It is possible that under certain circumstances and activities, the satellite provisions would prevail and will be entirely dependent on the specific situation.

And please remember, it is important to note that this blog is not intended to serve as an all-inclusive guide to standards. It is always best to check with local government and 40 CFR for the most up-to-date information.

15 Point Summary: Containerized Hazardous Waste Regulations

The following list of regulatory requirements for containerized hazardous wastes is taken from the supplimental information included in our RCRA training seminar booklets. While these points serve as a good summary, it is important to remember to be vigilant on keeping up to date with both national and state regulations.

1. Containers used for holding hazardous waste must be in good condition. If the container becomes damaged, deteriorated or begins to leak, the wastes should be transferred to a container that is in good condition.

2. Containers used for holding hazardous waste must not be deteriorated by the waste. The container or liner must be compatible with the wastes to be stored.

3. Each container must be labeled or marked clearly with the words “Hazardous Waste”.

4. The accumulation start date for each container is to be marked clearly on each container. The accumulation start date marking must be visible for inspection.

5. Containers holding hazardous wastes must always be closed during storage. The only time containers can be opened is to add or remove waste.

6. Containers holding hazardous wastes are to be managed to avoid rupturing or damaging the container, or otherwise causing the container to leak.

7. Areas where ignitable or reactive wastes are stored should be located at least 50 feet from the facility property line.

8. Ignitable or reactive wastes are to be separated and protected from sources of ignition or reaction (e.g., open flames, smoking, cutting, welding, hot surfaces, frictional heat, sparks, and radiant heat).

9. “No Smoking” signs are to be posted wherever there is a hazard from ignitable or reactive wastes.

10. Incompatible wastes, or incompatible wastes and materials must not be placed in the same container for storage purposes. Further, hazardous waste cannot be placed in an unwashed container that previously held an incompatible waste or material.

11. Incompatible hazardous wastes and hazardous wastes incompatible with nearby materials must be separated or protected from each other by means of a dike, berm, wall, or separated by sufficient distance.

12. Emergency equipment is required to be available at each accumulation area. We recomend the following:

  • a.) Internal communications or alarm
  • b.) Telephone or two-way radio
  • c.) Portable fire extinguishers
  • d.) Fire control equipment
  • e.) Spill control equipment
  • f.) Decontamination equipment
  • g.) Water at adequate volume and pressure

For a list of the federally required equipment check 40CFR §265.32.

13. Adequate aisle space in the container storage area is to be maintained to allow unobstructed movement in response to an emergency, as well as to perform weekly inspections.

14. Weekly inspections must be made of container storage areas, looking for leaks or other evidence of actual or pending releases.

15. Containerized wastes are to be shipped to off-site (commercial) Hazardous Waste Management (HWM) facilities within 90 days of the accumulation start date. Small Quantity Generators (100-1000 kg/mo category) are allowed 180 day accumulation period. The SQG accumulation period is extended to 270 days when the wastes are shipped to HWM facilities that are over 200 miles from the SQG.