February 13, 2015
Segregation of Incompatible Wastes in Containers
Three regulatory requirements address incompatibility issues for hazardous wastes managed in containers:
- Incompatible wastes must not be placed in the same container—This §§264/265.177(a) requirement notes that incompatible wastes may not be stored together in the same container unless such storage results in no deleterious reaction as described in §§264/265.17(b).
- Hazardous waste must not be placed in an unwashed container that previously held an incompatible waste or material—Guidance for this §§264/265.177(b) requirement notes there are many situations in which it is acceptable to place waste in unwashed containers. Therefore, it would be unnecessary and burdensome to require all containers be washed between each use. EPA expects owners and operators will institute some means of identifying the previous contents of empty containers, such as labels, records, segregated storage, or tests if empty containers are not routinely washed. Further, it is necessary for owners and operators to train their employees sufficiently to recognize incompatible wastes if they are going to place hazardous wastes in unwashed containers. [EPA/530/R-80/037]
- A container holding a hazardous waste that is incompatible with any other waste or materials stored nearby in other containers must be separated from the other waste or materials by means of a dike, berm, wall, or other device—Since leakage of containers could cause incompatible waste to commingle in storage areas, §§264/265.177(c) require containers holding incompatible wastes be separated from one another by physical barriers (e.g., dikes, berms, walls, or other devices). EPA noted, however, if separated sufficiently, leaking wastes will not commingle. Therefore, containers holding incompatible wastes may be separated from one another by a sufficient distance to prevent commingling in the event of leakage. This relatively inexpensive precautionary measure will help prevent one source of potentially dangerous reactions, which can cause fires, explosions, and gas emissions as a result of mixing incompatible wastes from leaking containers. [EPA/530/R-80/037]
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This document addresses issues of a general nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with the environmental 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.