Full Document:
RCRA Online Number: 14826
Title: CLOSED CONTAINER GUIDANCE: QUESTIONS AND ANSWERS
Document Date: 2011-11-03
To: RCRA Division Directors
From: Devlin
Description: For typical containers, such as 55 gallon drums, EPA recommends that a container cover be properly secured with snap rings tightly bolted, bungholes capped, and, where appropriate, pressure-vacuum relief valves to maintain the container's internal pressure to avoid explosions. EPA generally considers a container accumulating free liquids or liquid hazardous wastes to be closed when all openings or lids are properly and securely affixed to the container, except when wastes are actually being added to or removed from the container. Containers holding free liquids or liquid hazardous wastes in an SAA would meet the regulatory definition of closed using manually or spring closing lids or other similar devices for closed-head or closed-top drums (e.g., containers that have two bung holes with non-removable lids). Funnels used to add or remove liquid wastes would be screwed tightly to the bunghold and fitted with a gasket, if necessary, to seal the funnel lid firmly closed. Funnel lids for closed-head and closed-top drums may be fitted with a locking mechanism. Alternatively, the generator may use a funnel with a one-way valve that allows hazardous waste to enter the container but prohibits the waste or emissions from exiting the container. Liquid hazardous wastes also can be accumulated in open-head drums or open-top containers (e.g., where the entire lid is removable and typically secured with a ring and bolts or snap ring) and meet the definition of closed provided the rings are clamped or bolted to the container. The container could be considered closed if the lid covers the container top securely. For solid and semi-solid hazardous wastes, EPA considers the container closed as long as there is complete contact between the lid and the rim all around the top of the container. Containers continuously or intermittently receiving solid or semi-solid wastes (e.g., under a baghouse or filter press) should be capable of catching and retaining all of the material during transfer from a device to the container. Containers with covers opened by a foot pedal (e.g., flip-top or spring loaded lid) or with a self-closing swinging door may also be appropriate. For other types of containers, EPA considers them closed when they are sealed to the extent necessary to keep the hazardous waste and associated air emissions inside the container. Large roll-off containers are closed when indoors and the lids and shut and have a good seal around the rim. Large roll-off containers are closed when outdoors and the tarp is closed. EPA grants discretion to inspectors and enforcement staff to allow a container to remain open for extended periods of time if it is necessary to do so to make sure that all of the hazardous waste from the device is captured. Where the deposition of hazardous-waste into containers is a "batch process," a container of hazardous waste must be kept closed during times when the process is not depositing hazardous waste into the container. Strapping containers together should be strapped together only if this can be achieved without rendering any significant portion of the containers inaccessible for inspection.
Regulatory Citation(s): 265.173(a), 264.173(a)
Official ORCR Policy: Yes
Associated Topic(s):
Containers |
