Container Management ASTSWMO. Conference & Training

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1 Container Management ASTSWMO 2010 Hazardous Waste Managers Conference & Training June 30,2010

2 Overview Purpose Background Existing Standards d Common violations Closed Container Guidance Container Guidance Issues Test your knowledge Conclusions 7/6/2010 2

3 Purpose Assist regions and states in implementing the hazardous container management standards. Promote consistency in implementation of the container management standards. 7/6/2010 3

4 Container Management Background May 19, 1980 preamble minimize emissions of volatile wastes, help protect ignitable or reactive waste from sources of ignition or reaction, help prevent spills, and reduce the potential ti for mixing i of incompatible wastes and direct contact of facility personnel with waste. Keep containers closed with lids or some other closure device except when adding or removing the waste. 7/6/2010 4

5 Existing Regulations Containers in less than 90 day storage areas (a)(1)(i) Container condition ( ) Container and waste compatibility ( ) Container closure ( ) Container area inspections ( ) Air emissions (265 Subpart AA, BB, CC) (a)(2) Mark the accumulation date (a)(3) Label with the words hazardous waste 7/6/2010 5

6 Existing Regulations Containers in satellite accumulation area (c)(1)(i) Container condition ( ) Container and waste compatibility ( ) Container closure ( ) (c)(1)(ii) Mark containers as hazardous waste or other words that identify the contents. 7/6/2010 6

7 Common Violations (a)(1)(i) (a)(2) (a)(3) (c)(1)(i) (c)(1)(ii) (a) (b) /6/2010 7

8 Closed Container Guidance Background Advanced Notice of Proposed Rulemaking April 22, 2004 Evaluated EPA s hazardous waste generator regulatory program. Commenters selected closed containers as major issue needing clarification. 7/6/2010 8

9 Background (continued) Definition of container A container is defined under 40 CFR as any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled. Management of containers at 40 CFR (a) A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste. 7/6/2010 9

10 Closed Container Guidance Less than 90 day storage area: Location where hazardous waste containers are kept according to the generator accumulation requirements at 40 CFR (a) and (d) without a facility having to obtain a RCRA storage permit or having interim status. Regulations require containers be closed when not adding or removing hazardous waste. Recommend containers be closed securely while in the storage area to prevent spills or releases. Hazardous waste no longer added to containers. 7/6/

11 Closed Container Guidance Satellite Accumulation area (SAA) Location within a facility where the initial generation of a hazardous waste occurs and where the hazardous waste is accumulated in a container. Regulations require accumulation in a closed container, except when adding or removing waste from the container. Up to 55-gallons may be accumulated in a SAA. 7/6/

12 Liquid Hazardous Waste Satellite Accumulation Areas Management poses three potential problems Risks from inhalation Risks from the potential ti buildup of vapors Risks from an accidental spill EPA considers a container accumulating free liquids or liquid hazardous waste closed when all openings or lids are properly and securely affixed to the container, except when wastes are actually being added to or removed from the container. 7/6/

13 Liquid Hazardous Waste (continued) Purpose of securely affixing lid to container is to prevent release of volatile emissions and prevent a spill if the container is tipped over. Because hazardous waste may be added frequently to a container in a SAA, it may not be practical to secure the cover using snap rings, securely cap the bungholes or securely fasten the container with other types of covers or lids during working hours. 7/6/

14 Liquid Hazardous Waste (continued) Containers in SAA would meet definition of closed by using special funnels with manually or spring closed lids. 7/6/

15 Liquid Hazardous Waste (continued) Open-head drums or open-top p containers meet the definition of closed provided the rings are clamped or bolted to the container. In some situations, the container could be considered closed if the lid covers the container top securely even though the rings are not clamped or bolted. 7/6/

16 Liquid Hazardous Waste (continued) We recommend (if appropriate to the situation) Containers be located in areas with little or no vehicular traffic, such as forklifts Containers without securely affixed lids be secured to a wall or building support with a chain or strap. (e.g. compressed gas containers) Where no building support is available, containers be strapped together to prevent overturning. 7/6/

17 Liquid Hazardous Waste (continued) Good management practices Use secondary containment Use valve vents or level indicators to prevent unnecessary pressure buildup after the addition of liquids in drums 7/6/

18 Solid and Semi-Solid Solid Hazardous Waste Containers of solid or semi-solid waste would be considered closed as long as there is complete contact between the lid and the rim all around the top of the container. Example: Containers with covers opened by a foot pedal. 7/6/

19 Other types of containers Bags Durable sacks made of woven synthetic ti material (polysacks) Boxes Twenty cubic yard roll-off boxes or containers One cubic yard heavy duty cardboard boxes with a plastic liner (gaylord boxes) Semi-trailers used to manage solid and semi- solid hazardous waste Stainless steel and plastic totes in wire cages to handle liquid hazardous waste 7/6/

20 Other types of containers (continued) These containers would be considered closed when they are sealed to the extent necessary to keep the hazardous waste and associated air emissions inside the container. 7/6/

21 Large roll-off off containers Used to accumulate large volume waste streams, such as F006 sludges from electroplating operations and inorganic wastes where volatility is not an issue. When waste is not being added, the container would be closed when lids are shut and have a good seal around the rim. If a tarp is used on the roll-off, it is important to keep the tarp closed when not receiving waste so precipitation will not enter the container. 7/6/

22 Large roll-off containers (Continued) Some containers continuously or intermittently add hazardous waste Usually remain open while connected to a device such as a funnel, baghouse, or filter press. Containers should be capable of catching and retaining all of the material during transfer from the device to the container to avoid spills or releases. 7/6/

23 Potential Issues with Guidance Containers intermittently adding hazardous waste. Under what circumstances can they remain open? Types of facility operation/containers used most likely dictate t answer. Potential conflicts with weekly inspections regulations at 40 CFR Will strapping of containers limit a facility s ability to comply with weekly inspections? Guidance vs. Enforcement discretion Working hours vs. facility closed or nonoperational. 7/6/

24 Summary of Closed Container Guidance Guidance on the term closed container for purposes of complying with 40 CFR (a) and 40 CFR (a). Information and examples of what we consider acceptable practices to meet the closed container requirements. Not a rule and not legally ll enforceable. Does not replace any existing laws or regulations. Designed to help regulators and regulated community. Guidance was signed December 3, /6/

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