EPA Issues Guidance Document for Closed Containers

To help hazardous waste generators better understand what constitutes a closed container, EPA recently issued a guidance document to help clarify appropriate actions that can be taken to comply with the requirements of 40 CFR 264.173.

Closed container regulations apply to small- and large-quantity generators of hazardous wastes. Under this regulation, containers holding hazardous waste must be "kept closed, except when necessary to add or remove hazardous wastes." [40 CFR 264.173(a)] The regulation further states that the containers "must not be opened, handled or stored in a manner which may rupture the container or cause it to leak." [40 CFR 264.173(b)]

For large-quantity generators of hazardous wastes with VOC content, other regulations also apply. If wastes are stored in Level 1 containers (portable containers with a capacity greater than 26.4 gallons and less than or equal to 121.5 gallons,) the containers must be "equipped with a cover and closure devices that form a continuous barrier over the container openings such that when the cover and closure devices are secured in the closed position there are no visible holes, gaps or other open spaces in the interior of the container." [40 CFR 264.1086(c)]

The EPA closed container guidance document draws upon a number of state-issued guidance documents as well as feedback from the public and several EPA regional offices. Guidance is provided for both liquid and solid hazardous wastes stored in either central accumulation or satellite accumulation areas.

A central accumulation area (CAA) is a location in a facility where hazardous waste is kept until it can be transported offsite for recycling or disposal. Containers stored in these areas need to be kept securely closed to prevent emissions, leaks and spills.

The EPA encourages facility owners to have plans to help ensure that operations in or near the CAA do not cause containers to be damaged or ruptured while they are being stored or when they are moved to or from the CAA.

EPA allows hazardous wastes to be temporarily stored in locations other than central accumulation areas. Under the provisions for satellite accumulation areas (SAAs), hazardous wastes may be accumulated "at or near the point of generation where wastes initially accumulate," and "under the control of the operator of the process" [40 CFR 262.34(c)(1)].

Up to 55 gallons of hazardous waste or one quart of acutely hazardous waste may be stored at an SAA, and there are no limits at the federal level to the number of wastes that can be collected at any given SAA. Containers in SAAs must be properly labeled and kept closed when waste is not being added or removed.

According to the EPA, "Management of liquid hazardous wastes in containers poses three potential problems: risks from inhalation, risks from the potential buildup of vapors, and risk from an accidental spill." Keeping containers closed can help protect against all three of these problems.

Containers storing liquid hazardous wastes in SAAs are considered to be closed when, "all openings or lids are properly and securely affixed." The EPA acknowledges, however, that it isn't always practical to secure bolt rings or bung caps several times a day, and suggests the following:

For closed head containers:

• Funnels, screwed tightly into a bung opening, with manually or spring closed lids that are fitted with a gasket and locking mechanism to keep the lid sealed when not in use
• Using a funnel with a one-way valve that prevents waste or emissions from exiting the container
• Keeping bung caps closed / capped except during fluid transfer

For open head containers:

• A cover that completely and securely covers the top
• A lid and ring that is completely bolted or clamped onto the container

Spent absorbents, solvent-contaminated wipers, aerosol cans and batteries are all examples of solid and semi-solid wastes that may be accumulated in SAAs.

The EPA considers a container in an SAA holding solid or semi-solid hazardous waste to be closed if:

• there is complete contact between the lid and the rim around the top of the container. Lids with continuous gaskets and fusible plugs or those that help collect fugitive vapors make collecting solvent-laden rags and spent sorbents faster and safer.
• the cover makes complete contact between the lid and top rim of the container

For all containers in SAAs, generators must be aware that all seals can erode over time and should be periodically checked and replaced as necessary.

Due to their location near processing areas and other "points of generation," and the fact that SAAs are areas where materials are being transferred, spills are likely. The following tips can help minimize occurrences:

• Locate SAAs in areas with limited forklift or cart traffic
• If containers cannot be fitted with lids, consider chaining or strapping them to the wall to secure them and help prevent the containers from tipping
• Use secondary containment devices to capture leaks and spills
• Vent containers to help prevent pressure build-up
• Use level indicators or overflow prevention devices to minimize container overfills

According to the EPA, keeping containers properly closed "is simply a matter of good operating practice" and compliance with this standard will help make your workplace cleaner and safer.