DEEP: H/W Container Management

Hazardous Waste Container Management

Purpose
This fact sheet answers general questions and provides basic information on hazardous waste container management.  The information addresses the requirements applicable only to large quantity generators ("LQGs"). The hazardous waste container management requirements are found in Section 22a-449(c)-102(a)(1) of the Regulations of Connecticut State Agencies ("RCSA"), incorporating the federal hazardous waste regulations in 40 CFR 262.30 – 262.34, 40 CFR 265.170 – 265.178 , and 40 CFR 264.175.

This fact sheet is not intended to supersede the applicable regulations. You should refer to the appropriate statutes and regulations for specific regulatory language.  It is your responsibility to comply with all applicable laws and regulations.

What is a Hazardous Waste Container?

How Must Hazardous Waste Containers Be Managed?

What are the Requirements for Areas Where Containers are Stored?

How Long May Hazardous Waste Containers Remain On-site?

When Does the Storage Time Limit Begin?

What are Satellite Accumulation Containers?

What are the Requirements for the Management of Satellite Containers?

How Must Containers Be Prepared for Shipment Off-Site?

Are There Special Container Management Requirements for Other Wastes?


What is a Hazardous Waste Container?
Containers are portable devices used for collecting, storing, treating and transporting hazardous waste. They can be of any size that can be easily moved. Some common examples include: five-gallon safety cans, 55-gallon drums and 30-cubic-yard roll-offs.  Containers do not include stationary tanks.  Tanks that are used to store hazardous wastes are subject to separate requirements in 40 CFR 265.190 – 265.202.


How Must Hazardous Waste Containers Be Managed?
Containers of hazardous waste must be managed as follows:

  • The containers must be in good condition.  If a container becomes damaged or begins to leak, the waste must be transferred to another container.

  • The containers must be compatible with the waste stored in them (e.g., storage of acids in plain steel drums or solvents in plastic drums would not be acceptable).

  • The containers must remain closed, except when adding or removing waste.

  • Containers must not be opened, handled, or stored in a manner which may rupture the containers or cause them to leak.

  • Containers must be inspected at least weekly, looking for leaks and for deterioration caused by corrosion or other factors.  (For more information on inspection requirements, see the DEEP web page Hazardous Waste Inspection Requirements.)

  • Ignitable or reactive wastes must be stored at least 50 feet from the facility property line.

  • Wastes that are incompatible with each other must not be placed in the same container. In addition, wastes must not be placed in an unwashed container that previously held an incompatible waste or material.

  • Containers holding wastes that are incompatible with a waste or other material stored nearby must be separated from them by a dike, berm, wall, or other similar device (such as a pre-fabricated spill containment pallet).

  • Containers holding certain wastes with volatile organic compounds (“VOCs”) must be managed in accordance with the air emissions standards in 40 CFR 265.1080 – 265.1090.  More information about these air emissions requirements is available on the U.S. EPA’s website.

  • Containers must be marked with the words "hazardous waste" and other words that identify the contents of each container, such as "flammable", "acid", "alkaline", "cyanide", "reactive", "explosive", "halogenated solvent" or the chemical name.  If marking of containers less than one gallon in size is infeasible, the locker, rack, or other device used to store the container may be marked with this information instead.

  • Containers must be marked with the date of accumulation (i.e., the date waste was first placed in each container). For wastes that are first accumulated in satellite containers, the date of accumulation begins when the waste is moved from the satellite accumulation area to the hazardous waste container storage area. The hazardous waste marker described in the Pre-Transport Requirements section at the end of this fact sheet may be used to meet the requirements for marking containers "Hazardous Waste" and with the accumulation date.

  • Adequate aisle space must be maintained between containers to allow for unobstructed movement of personnel, fire protection equipment, and decontamination equipment in the event of an emergency.  A minimum of 30-inch aisle space is recommended.

What are the Requirements for Areas Where Containers are Stored?
Containers must be stored in areas that have secondary containment to prevent run-off of accumulated liquids. The base of the area must be free of cracks and gaps, and must be sufficiently impervious to contain leaks, spills, and accumulated precipitation until the collected material is detected and removed.  A base is considered “impervious” if it is:

  • Capable of preventing spilled or accumulated liquids from migrating or seeping into the environment.

  • Compatible with the hazardous wastes and any other materials stored on it.  For example, an uncoated asphalt base would not be considered compatible with oil- or solvent-based wastes since these wastes can soften and penetrate the asphalt.  Similarly, an uncoated concrete base would not be compatible with corrosive hazardous wastes, since these wastes can attack and damage the concrete.

  • If necessary, coated with a protective material (e.g. an epoxy coating) to prevent penetration or absorption of wastes or other materials into the base.

  • Free of floor drains, catch basins, or similar structures that would allow wastes and accumulated liquids to escapes the secondary containment system.  “Blind” sumps (i.e., sumps with no outlets) are allowed, however, provided they meet the provisions in the above bullets.

Secondary containment systems must also be able to contain the volume of the largest container or 10% of the volume of all containers in storage (whichever is greater). Secondary containment may be achieved in a variety of ways including installing berms around the storage area, or using pre-fabricated spill containment pallets.

The area must be designed to prevent liquids from coming in contact with the containers.  This may be done by constructing a slope in the base to allow liquids to drain away from the containers, or placing the containers on raised platforms (e.g., racks or pallets). Liquid in the containment system must be removed as soon as possible and tested to determine if it is hazardous.

Storage areas must be designed to prevent run-on (rain water, flooding, etc), or have excess containment capacity to contain the run-on, in excess of the containment volume noted above.  It is recommended that outdoor storage areas be covered (roofed) to prevent the accumulation of rainwater in the storage area.

Emergency response equipment that is appropriate for the types of waste generated must be available, and kept in good working condition. Some examples include fire extinguishers, absorbents, non-sparking shovels, overpack containers and personal protective equipment. There must be a communications system nearby which can be used to summon help in the event of an emergency. This could be a telephone, radio, alarm system, or similar system.

Precautions must be taken to prevent accidental ignition or reaction of ignitable or reactive wastes.  In particular, ignitable wastes must be separated from sources of ignition.  “No Smoking” signs must be posted in areas where ignitable hazardous wastes are stored.

If an LQG site shuts down operations, or discontinues the use of a container storage area, there are certain “generator closure” requirements that the LQG must comply with to ensure that all wastes and waste residues are removed, and to ensure the proper cleanup of any releases that may have occurred.  The DEEP’s Generator Closure Guidance Document provides step-by-step instructions on how container storage areas should be closed. LQGs must complete closure of a container storage area within 180 days after the last container of waste is placed in that storage area.

How Long May Hazardous Waste Containers Remain On-site?
An LQG may store most hazardous wastes on-site for no longer than 90 days.  On or before this date, the LQG must arrange to have the waste shipped off-site by a permitted hazardous waste transporter to a permitted Treatment, Storage or Disposal Facility (TSDF).

However, LQGs may store one particular type of hazardous waste for longer than 90 days.  In particular, LQGs may store wastewater treatment sludges from electroplating operations (EPA Waste Code F006) for up to 180 days, if these sludges are being sent off-site for metals recovery.  If the sludges are being sent to a metals recovery facility that is more than 200 miles away, the LQG may store the sludges for up to 270 days.  To qualify for either of these longer storage timeframe, an LQG must do the following:

  1. Implement pollution prevention practices that reduce the amount of any hazardous constituents in its F006 waste.

  2. Ensure that the F006 waste is legitimately recycled through metals recovery.

  3. Accumulate no more than 20,000 kilograms (44,000 pounds) of F006 waste on-site at any one time.

  4. Manage the containers as described in the remainder of this fact sheet.
When Does the Storage Time Limit Begin?
The time limit begins when the first drop of waste is placed in the container. If the waste is collected in satellite accumulation containers, the time limit starts after the containers are transferred from the satellite accumulation area to a fully-regulated storage area.

What are Satellite Accumulation Containers?
Satellite containers are containers that are located at or near the process that generates the waste, and that are under the control of the operator of the process generating the waste. They are used for the routine collection of waste from a specific process, such as a production spray paint booth where waste paint and thinners are continually generated.  Satellite containers are not subject to the same requirements as regular storage containers, but may instead be managed under a special set of reduced requirements.

What are the Requirements for the Management of Satellite Containers?
Satellite containers must be managed as follows:
  • The containers must be in good condition.  If a container becomes damaged or begins to leak, the waste must be transferred to another container.

  • The containers must be compatible with the waste stored in them (e.g., storage of acids in a plain steel drum or solvents in a plastic drum would not be acceptable).

  • The containers must be marked with the words "hazardous waste" and other words that identify the contents of each container, such as "flammable", "acid", "alkaline", "cyanide", "reactive", "explosive", "halogenated solvent" or the chemical name.  If marking of containers less than one gallon in size is infeasible, the locker, rack, or other device used to store the container may be marked with this information instead.

  • The containers must remain closed, except when adding or removing waste.

  • The total amount of waste stored in container(s) within a satellite accumulation area may not exceed 55 gallons, or one quart of acutely hazardous waste listed in 40 CFR 261.33(e). Once this 55-gallon limit is exceeded, the container(s) must be moved to a fully-regulated container storage area within 72 hours and managed in compliance with all of the requirements for hazardous waste containers.

  • If you are shipping the hazardous waste in the same container that it is initially accumulated in, you must also comply with the Pre-Transport Requirements described in the last section of this fact sheet.
Although there is no storage time limit for satellite containers, DEEP strongly recommends that wastes not be stored in satellite areas for any longer than is necessary to facilitate the initial collection of the waste.  The longer that wastes are stored in satellite containers, the more likely it is that containers may become damaged or leak, or that a spill may occur.  If wastes are generated in very small amounts, it is advisable to use smaller-sized containers (e.g., a 5-gallon safety can as opposed to 55-gallon drum) to minimize the length of storage.  When this smaller container becomes full, the container can be taken to a fully-regulated storage area, and the contents transferred to a full-sized container.

NOTE:  hazardous wastes may not be moved from one satellite accumulation area to another.  Wastes generated in satellite accumulation areas may only be taken to a fully-regulated storage area.

How Must Containers Be Prepared for Shipment Off-Site?
Hazardous waste container requirements include “Pre-Transport” provisions that reference certain  U.S. Department of Transportation (DOT) Hazardous Materials regulations. These requirements include:
  • Packaging - The hazardous waste must be packaged in containers that meet U.S. DOT requirements (see above link).

  • Labeling - Each container must have the proper DOT label (e.g., corrosive, flammable liquid, oxidizer, etc).

  • Marking - Each container of 110 gallons or less must be marked with the following words:

    HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, contact the nearest public safety authority or the Environmental Protection Agency.
    Generators name and address:
    [write in the business name and address]
    Manifest Document Number: [write in the manifest number]

    Pre-printed hazardous waste markers are readily available from hazardous waste transporters and a variety of commercial vendors (e.g., chemical and safety supply companies).

  • Placarding – Transportation vehicles hauling hazardous waste off-site must have the proper U.S. DOT hazard placard(s) posted on them. Most transporters have their own placards; however it is your responsibility to ensure that the proper placards accompany your shipment.
  • Universal Wastes and Used Oil. The Universal Waste Rule allows certain commonly-generated wastes to be managed under a special, reduced set of requirements.  The wastes have their own container management requirements. Connecticut's used oil regulations also have a separate set of container management requirements for non-hazardous used oils.

  • Recyclable Materials.  RCSA Sections 22a-449(c)-102(a)(2)(D) and (F), and -106(b)(1)(A) have special marking requirements for certain recyclable materials that are exempt from most hazardous waste requirements.  In particular, containers of these recyclable materials must be marked so as to clearly identify their contents, and be marked with the date of initial accumulation.  The recyclable materials that are subject to these requirements include those that are exempt under 40 CFR 261.2(c) and 261.2(e) and 40 CFR 266.70.

For further information, please contact the DEEP’s toll-free Compliance Assistance (COMPASS) hotline at 1-888-424-4193, or send us an email.

Content Last Updated January 31, 2013