December 18, 2017
New Hazardous Waste Container Requirements Summarized
The November 28, 2016 generator improvements rule [81 FR 85732] has made some significant changes to the rules for managing hazardous waste in containers. The following table summarizes the new requirements for hazardous waste containers once your state has adopted the rule.
Design and Management Standards for Hazardous Waste Containers
Container requirement | Satellite accumulation containers | SQG 180/270-day containers | LQG 90-day | TSD facility |
|---|---|---|---|---|
Containers must be marked with “Hazardous waste” and an indication of the hazards of the contents1 | Y | Y | Y | Y |
Containers must be marked with the accumulation/storage start date | N | Y | Y | Y |
Containers must be marked with hazardous waste codes | N | Y2 | Y2 | Y |
Containers must be in good condition; where rusting, cracking, leaking, etc. are observed, wastes must be transferred to a different container or otherwise managed to prevent releases | Y | Y | Y | Y |
Materials of construction of containers or liners must be compatible with the waste placed in them | Y | Y | Y | Y |
Containers must be closed at all times, except when adding or removing wastes; additionally, the container must be managed in a way that prevents rupturing or leaking | Y3 | Y | Y | Y |
Containers must be inspected weekly for leaks or other deterioration | N | Y | Y | Y |
Containers areas must be provided with secondary containment | N | N | N | Y4 |
Containers holding D001 ignitable or D003 reactive waste must be located at least 15 meters (50 feet) from the facility’s property line5 | N | N | Y6 | Y |
Incompatible wastes must not be placed in the same container (this includes a restriction on placing wastes in unwashed containers that have incompatible residues in them); containers holding wastes that are incompatible with other wastes or materials stored nearby must be segregated | Y | Y | Y | Y |
When container accumulation/storage areas will no longer receive hazardous waste, they must be closed; all hazardous wastes and residues must be removed, and containers, liners, and contaminated soil must be decontaminated or removed | N | N | Y | Y |
Containers must conform with the air emission standards of Part 264/265, Subparts AA, BB, and CC | N | N | Y | Y |
Containers must comply with preparedness, prevention, contingency plan, and emergency procedures | Y | Y7 | Y | Y |
N = No, not required; Y = Yes, required.
1 Examples of an indication of the hazard(s) associated with the contents include the applicable hazardous waste characteristic(s), a DOT label or placard, an OSHA hazard statement or pictogram, or an NFPA hazard label.
2 Hazardous waste codes are required on these containers prior to shipping the waste offsite.
3 Satellite accumulation containers must be closed at all times except when adding, removing, or consolidating waste. Such containers may also be open when venting the container is necessary (e.g., for proper equipment operation or to prevent dangerous situations such as pressure build-ups). The regs at §262.15(a)(4) do not specifically require that the container be managed in a way that prevents rupturing or leaking, but this would be a best management practice.
4 Secondary containment is required at RCRA-permitted container storage areas only. It is not required if the container is 1) used to store a hazardous waste that contains no free liquids; and 2) the storage area is sloped or otherwise designed and operated to drain and remove run-on/precipitation, or containers are elevated or are otherwise protected from contact with accumulated liquid.
5 In addition, the facility 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 the following: open flames, smoking, cutting and welding, hot surfaces, frictional heat, sparks, spontaneous ignition, and radiant heat. While ignitable or reactive waste is being handled, the facility 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.
6 Unless written approval to accumulate the waste in the restricted area is 1) obtained from the fire code authority, and 2) maintained in the LQG records as long as the waste is in the area. See also RO 14840.
7 These containers are not subject to full contingency plan requirements but only to provisions in §262.16(b)(9).
Source: McCoy and Associates, Inc.
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Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.
This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.
