8 BMPs for Hazardous Waste Containers

Violations of container management standards are very common and cited often by agency inspectors as the most common of regulatory violations, particularly by hazardous waste generators. Anyone who handles hazardous waste should be aware that many inspectors go to hazardous waste accumulation or storage areas first when conducting an inspection.

A recent example of an enforcement action occurred at a hazardous waste facility in Texas, which paid a $22,400 penalty for Resource Conservation and Recovery Act (RCRA) violations related to management of hazardous waste containers. According to the EPA, the facility failed to properly label hazardous waste containers, failed to clean multiple spills from the container holding area, and failed to meet secondary containment requirements.

Note. These BMPs reflect certain federal standards for hazardous waste container management. They do not address all the requirements for containers. Also, your state may have stricter hazardous waste container management requirements that are not reflected in theses BMPs.

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BMPs for Hazardous Waste Containers

1. Know your waste. Once a waste is generated, characterize it before you put it in a container. This can be done by sampling and analyzing the waste or by process knowledge (i.e., you know the constituents in the process and, therefore, you can use that knowledge to determine if the resulting waste has characteristics that could make it hazardous). Also, you can:
   1. Look at safety data sheets (SDSs). Some information areas on the SDS to look for are physical property, reactivity, fire and explosion hazard, and special protection information.
   2. Consider that if a product being used in a process meets one or more hazardous characteristics, the waste generated may exhibit some of the same characteristics.
   3. Be aware of any changes in a production process, which could alter the composition of the waste generated.

2. Select the correct container. You must make sure to match the waste with the correct type of container. For example, highly corrosive wastes will react with a steel drum—the drum may fail and waste may be released. So how can you safely store corrosive wastes? Use plastic drums or plastic-lined steel drums to safely store corrosive wastes. Also, if a container has been used to store waste or other materials, you must make sure that the waste or material previously held in the container is compatible with the waste you are going to put in the container.

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3. Put waste in the container safely. Make sure you know which wastes are reactive and/or incompatible. Keep these wastes away from each other, in separate containers. Also:
   1. Make sure the waste cannot harm the container.
   2. If you rinse out containers onsite, be aware that rinse water generated from drum washing must be contained and characterized prior to disposal.
   3. If you frequently reuse containers, consider “assigning” wastes to certain containers. This will allow you to reuse the container without washing.
   4. Use a funnel to prevent spills, and do not use the same funnel for all wastes.
   5. 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).

4. Properly mark and label the container. Large quantity generators (LQGs) of hazardous waste can only accumulate or store most waste on-site for up to 90 days without a permit (F006 wastes can be accumulated longer under certain conditions). The 90 -day limit starts when waste is first placed in the container, unless the container is in a satellite accumulation area. In that case, the 90-day time period begins when the container is full. If your facility is a small quantity generator (SQG) shipping wastes more than 200 miles, you can store wastes for up to 270 days. If less than 200 miles, you can store up to 6,000 kilograms of waste up to 180 days. You must be able to prove to inspectors that you have not exceeded the time limit for accumulation. To do this:
   1. Have all personnel use the same method (e.g., handwritten, prepared labels) to label containers. Make sure all handlers know what the markings mean.
   2. Besides the start date and the words “Hazardous Waste,” include information about contents (e.g., toxic, reactive, incompatible).
   3. Apply U.S. Department of Transportation (DOT) labels to the container when waste is first placed in the container. The label will be in place for shipment and will provide information about the waste to drum handlers.
   4. Before reusing containers, make sure all old markings and labels are washed off or blacked out.

Tomorrow, we’ll follow up with four additional BMPs for hazardous waste containers.