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.

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.

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.

A Q&A About Hazardous Waste Containers

If a generator accumulates more than the satellite limit, when should they date the container?

When exceeded, not started.

What is meant by 3-days?

Three days means three consecutive days. It does not mean working days or business days.

Originally the EPA proposed 72-hours as the time limit, but realized that determining when 72-hours elapsed would require the container to have both date and time labeled.

The leg of a PPE suit is hanging out from under the secured lid of a container. Is the container open or closed?


Do containers in satellite areas have to comply with air emission standards?


Do satellite containers need to be inspected?

The do not need to be although we recommend that you that you do so on a regular basis anyway.

Can a facility have more than one satellite accumulation area?

Yes, The regulations do not limit the number of SAAs. Likewise, the regulations do not limit the total volume of waste that can be accumulated at various SAAs. Regulation only limits to 55 gallons (1 quart) per SAA.

Can a satellite accumulation area contain more than one container?

Yes, It is permissible  to have more than one container, as well as more than one waste type in a SAA. Good management practice dictates how this should be done. SAA is limited to a total volume of 55 gallons (1 quart).

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?


Are the dirty uniform bins considered satellite accumulations of hazardous waste?  What about maintenance gloves?

No, Contaminated wipes, gloves, or uniforms being commercially laundered and subsequently reused are not discarded; therefore, they are not a hazardous waste.

So, how many could you answer correctly?

Hazardous Waste Accumulation Containers

Today we are going to explore the ever exciting world of accumulation container standards, rules, and types! We will be focusing on the differences between and rules associated with satellite accumulation vs. 90-day. We will also be offering a short quiz available for download at the end of this post.

So to begin, we will talk about satellite accumulation. A generator can accumulate up to 55 gallons of hazardous waste in containers that are:

  • At or near point of generations, and
  • Under the control of the operator.

Acute hazardous waste accumulation is limited to 1 quart. All containers must be labeled with the words “hazardous waste” or with other words that accurately identifies the contents.

When containers in a satellite accumulation area exceed their limits of 55 gallons or 1 quart the container must be dated. The excess or the entire container then must be removed within 3 days. Otherwise, the site must be managed as a 90-day.

And as always, all container management standards apply; meaning that all containers must be in good condition, closed, labeled, and segregated for compatibility.

In a 90-day, a generator can accumulate for up to 90 days with no volume limits. There are, however, additional standards that must be complied with. See the table below for a comparison of applicable standards.

Accumulation Standards

As you can see, there are more standards that must be followed if you are a 90-Day generator. That said, it is important to note that this blog post 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.

Containerized Waste Compatibility

Hazardous waste containers and storage areas are designed with specific intent. The container is for holding the waste and the storage area is to prevent escape of release from a container. The regulations intend to ensure that wastes are,

  • Compatible with construction of the container,
  • Compatible with other waste placed in the container,
  • Stored in a containment area designed to prevent releases from the containers from reaching the environment.

One of the first things to make sure of is that your containers are in good condition. Containers that are deteriorating or leaking must not be used and waste must be removed or transferred from the defective containers.

After making sure your containers are in good shape, you must make sure that the container type is compatible with the type of waste held within. The term incompatible waste refers to a hazardous waste which is unsuitable for placement in a container because it may cause damage to the container or inner liner; or when mixed with other waste in the container under uncontrolled conditions might produce:

  • Heat or pressure,
  • Fire or explosion,
  • Violent reaction, or
  • Toxic dusts.

Containers used to store hazardous waste must be made of or lined with materials that will not react with the waste and are otherwise compatible with the waste. Incompatible waste must not be placed in the same container. This includes unwashed containers that previously held an incompatible waste or material.

It is not just in containers that you must think of compatibility, though. Incompatible wastes are to be kept separate from each other in storage. Incompatibles must be kept separate by dike, berm, wall, and separated by sufficient distance. It helps to remember the 2 row minimum rule.  Incompatible materials must be 2 rows apart, separated by a row compatible to both.

Compatibility is so important because accidentally mixing incompatible wastes can have very dangerous ramifications. Always be sure to check and double check that you are not inadvertently mixing incompatible wastes. And remember, this information may not be all-inclusive and it is always best to check 40 CFR and your state regulations for the most up-to-date information. Keep reading our blog for more information about containerized wastes.

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.