Best management practices (BMPs ) for on-site container management is one of the foundations of RCRA compliance. If your firm or agency is a large quantity generator and/or generates hazardous waste on a regular basis, you need to be following certain regulations. And even if you generate on an occasional basis and thus are not required to follow all the regulations, why not incorporate them now, so that if you ever do become a large quantity generator or start to generate on a regular basis, you will already have your procedures in place?
EPA has found that the most common problem with generators of hazardous waste is the failure to meet the permit exemption requirements (for containers) as defined in 40 CFR 262.34(a)(1)(i). This regulation allows generators to temporarily store their hazardous wastes on-site, in containers, without a permit, provided that they meet certain container management requirements.
|Large Quantity Generators can store hazardous wastes in containers on-site for 90 days or less without a RCRA permit. The waste must be stored under certain conditions:
|Waste characterization, or identifying and understanding your waste, is really important. All generators are required to do the following:
Special methods and equipment are usually required to manage wastes that are Corrosive Combustible, Flammable, Oxidizer, Poison, Toxic, or Reactive §265.177.
And there are special requirements for incompatible wastes, which must not be placed in the same container, unless you have complied with 265.17 (b).
Managing Hazardous Waste in Containers
|WASTE CHARACTERIZATION and WASTE DETERMINATION: To safely manage hazardous waste in containers, you must know exactly what a waste is, how it will act, and what its properties are. Is the waste extremely toxic? Do workers need special protection? Is the waste corrosive? Will it corrode certain types of containers? Is the waste incompatible with other wastes? Will it react (explode, catch on fire) if it is mixed with other waste or water? Once a waste is generated, it should be characterized before you place it in a container.
Waste characterization can be done either by sampling and analyzing the waste or by identifying the waste based on process knowledge (i.e., you know the constituents in the process and therefore you can use that knowledge to determine if the resulting waste has characteristics that could make the waste hazardous).
AET can assist you in your waste determination and in your selection of container type. Our BMPs are based on the following trifecta:
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