In accordance with the rules of the Resource Conservation and Recovery Act (RCRA), each container used for on-site hazardous waste accumulation must be clearly labeled or marked with the words “Hazardous Waste”, an indication of the hazards of the contents and the date the accumulation began (sections 262, 16 (b) (y. The following list of regulatory requirements for hazardous waste in containers has been extracted from the supplementary information included in our RCRA training seminar brochures. While these points are a good summary, it's important to remember that you need to be vigilant to keep up to date with national and state regulations. If satellite accumulation requirements are carefully respected, additional requirements will be avoided.
Weekly inspections of container storage areas should be carried out, looking for leaks or other signs of actual or pending emissions. Containerized waste must be sent to off-site (commercial) hazardous waste management (HWM) facilities within 90 days of the start date of accumulation. The first time waste is added, the containers must be labeled with all of the above information, and the labels must be retained so that they are clearly legible. In addition, hazardous waste cannot be placed in an unwashed container that previously contained incompatible waste or materials.
Satellite accumulation is only allowed when waste is collected in containers (not tanks or stationary devices) and in volumes of 55 gallons or less. Satellite storage areas must be under the control of the generator or be secured at all times to prevent waste from accumulating improperly and to comply with all requirements related to containers and labeling. Containers containing hazardous waste must be managed in such a way that they do not break or damage, or cause the container to leak. Incompatible waste or incompatible waste and materials should not be placed in the same container for storage.
Containers should not be heavily rusted, dents, or other conditions that could result in leaks or other unsafe conditions. Depending on the type of generator, CaaS have specific requirements, such as storage requirements, storage time limits, and additional emergency response plans and training. Adequate aisle space must be maintained in the container storage area to allow unhindered movement in response to an emergency, as well as to carry out weekly inspections.