EPA Issues Guidance Document for Closed Containers

Hazardous waste generation is dangerous, which is why the Environmental Protection Agency (EPA) requires facilities to keep waste in closed containers. To help hazardous waste-generating facilities better understand and comply with closed container regulations, the EPA has issued a guidance document.

Closed container regulations [40 CFR 264.173]. apply to both small- and large-quantity hazardous waste generators. The regulations require hazardous waste containers to be “kept closed, except when necessary to add or remove hazardous wastes.” Containers “must not be opened, handled or stored in a manner which may rupture the container or cause it to leak.”

Violations of the EPA’s closed container regulations have historically resulted in companies being fined thousands of dollars per breach.

The guidance document focuses on both liquid and solid hazardous waste stores in two major accumulation areas: central accumulation areas (CAAs) and satellite accumulation areas (SAAs). It draws upon a number of state-issued guidance documents, as well as feedback from the public and several EPA regional offices.

Containers in CAAs

Hazardous waste can be stored in a facility’s CAA until the waste 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.

Facility owners are encouraged 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.

Containers in SAAs

Hazardous waste can be temporarily stored in locations other than a CAA, such an SAA [40 CFR 262.34(c)(1)].

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

Liquid Hazardous Wastes in SAAs

The EPA cites three potential risks when managing liquid hazardous waste in containers: inhalation, vapor buildup and accidental spills. Keeping containers closed can help protect against each of these problems.

Liquid hazardous waste storage containers 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:

• Drum funnels screw tightly into a bung opening on closed-head containers. They 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 prevents waste or emissions from exiting the container. Bung caps should be closed and capped except during fluid transfer.
• Latching drum lids completely and securely cover open-head containers. Eliminating the fuss of unscrewing nuts and bolts each time the container is open saves workers time and reduces closed container violations.

Solid and Semi-Solid Hazardous Wastes in SAAs

Spent absorbents, solvent-contaminated wipers, aerosol cans and batteries are examples of solid and semi-solid wastes that can 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 escaping vapors make collecting solvent-laden rags and spent sorbents faster and safer.

It’s important to keep in mind that containers’ seals in SAAs can erode over time and allow volatile organic compounds to escape. Seals should be checked periodically and replaced as necessary.

Preventing Spills at SAAs

Spills are likely in SAAs because they are near generation and processing areas, and because SAAs are areas where materials are being transferred. The following tips can help minimize spills:

• 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 and prevent the containers from tipping.
• Capture leaks and spills with secondary containment devices.
• Vent containers to help prevent pressure build-up. Vent options include metallic and non-metallic.
• Use level indicators or overflow prevention devices to minimize container overfills.

Keeping containers properly closed “is simply a matter of good operating practice,” according to the EPA. Complying with this standard keeps workplaces cleaner and safer and helps companies avoid fines.