Hazardous Waste Containers… How Closed is Closed?
A generator accumulating hazardous waste in containers must do so in compliance with state and federal regulations. Specifically, the federal rules are found at 40 CFR Part 265, Subpart I, Use and Management of Containers. The management of a container of hazardous waste includes several notable provisions:
Condition of containers: The container of hazardous waste must be in good condition. If it begins to leak, the hazardous waste must be transferred to a container that is in good condition.
Compatibility of waste with container: The container must be made of or lined with materials which are otherwise compatible with the hazardous waste to be stored, e.g., don’t store waste acid in metal drums or waste acetone in plastic drums.
Management of containers: A container of hazardous waste must always be closed during storage, except when adding or removing waste or stored in a manner which may cause the container to leak.
Inspections: Containers must be inspected at least weekly, looking for leaks and other deterioration.
Special requirements for ignitable or reactive waste: Containers of hazardous waste holding ignitable or reactive waste must be located at least 50 feet from the facility's property line.
The third item, management of containers, requires that containers always be closed during storage, except when it is necessary to add or remove waste. Note that the purpose of the closed container requirement is to minimize emission of volatile wastes and to prevent spills.
What is considered "closed" may vary with the waste involved. Specifically, different requirements apply for preventing spills of liquids versus solids. This can differ depending on the following considerations as the Michigan Department of Environment, Great Lakes, and Energy (EGLE) applies the following principles when evaluating what is necessary for a container to meet the "closed" requirement:
Containers not being actively handled to add or remove waste must have an affixed cover regardless of whether it contains solids or liquids.
If the waste is solid, the container cover must be in good condition and placed squarely on the container so that there are no apparent cracks or gaps between the lid and the container, but it need not be secured, e.g., a snap ring is not required to be secured on a drum containing solid hazardous waste.
If the waste is liquid, all openings of the container must be covered with the cover securely affixed to the container. Containers for hazardous waste liquids will be considered closed when bungs and rings are in place or the container is equipped with a funnel and a funnel stem valve or a gasketed and lockable funnel lid.
The type of container must be considered when applying these principles. For example, what is "placed squarely on the container" or "affixed" would vary between a roll-off box and a 55-gallon drum.
CFR has been helping companies navigate the hazardous waste container closure rules for over 30 years. Contact CFR for guidance in waste compliance.