January 13, 2012

EPA Publishes Questions and Answers Resulting From Closed-Container Guidance

Containers, including satellite accumulation containers, must be closed during storage except when it is necessary to add or remove waste. [§§264/265.173(a)] While no definition of “closed” is provided in the regulations, EPA explained that the purpose of this requirement is “to minimize emissions of volatile wastes, to help protect ignitable or reactive wastes from sources of ignition or reaction, to help prevent spills, and to reduce the potential for mixing of incompatible wastes and direct contact of facility personnel with waste.” [May 19, 1980; 45 FR 33199]

In an effort to provide clarity and facilitate compliance with this closed-container requirement, EPA published Guidance on 40 CFR 264/265.173(a): Closed Containers on December 3, 2009. [RO 14810] After publishing this guidance, the agency received three questions that it addressed in a November 2011 Q&A document [RO 14826]:

Note that RO 14810 is no longer available on RCRA Online but has been replaced with RO 14826.


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