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.