| Practical Disposal of Hazardous Containers and Waste Recycling Solutions.
Know about hazardous containers disposal & waste recycling solutions. A complete guide to hazardous waste management & practical disposal of containers.
Containers not meeting the empty requirements have to be managed as a hazardous waste, with the associated high costs. By Arthur J. Legros
In light of current regulations and the rising costs of hazardous waste management, the issue looms of how to manage the drums, pails and other containers left at a facility after they have served their intended purpose.
Proper management necessitates understanding of the regulations dictating the steps to render these containers non-hazardous or "empty", thus exempting them from hazardous waste management requirements. Regulations may be more stringent on a state-by-state basis, but in general fall in line with Federal EPA 40 CFR 261.7 regulations, or "Residues of hazardous waste in empty containers."
Attaining Empty Status
The decision flow diagram featured in this article is designed to be used as a guide which allows the users to quickly determine how their containers can be classified as empty. The regulations are defined by container size and by the classification of their contents:
- Non-hazardous waste containers are not regulated under the federal hazardous waste program.
- Compressed gas containers are considered "empty" when the internal pressure approaches atmospheric conditions, and no more gas is likely to escape.
- Acute hazardous waste containers are defined as any container used for hazardous materials listed in
§§ 261.31, 261.32, or 261.33(e). Such containers are considered empty when a non leaking liner is removed, or the container has been triple rinsed. Any liner removed from these containers must be managed per the regulations.
- Hazardous waste containers encompass all other categories, and are often the most confusing. Their contents are assumed to have been some form of wastes which are frequently removable to some degree by commonly used methods such as pouring, pumping, or aspirating. The amount of waste remaining in the containers, based on container size, is then used as a basis to determine its empty status.
Since all containers not meeting the empty requirements have to be managed as a hazardous waste - with the associated high costs, stringent management procedures and potential liabilities - it should be the intent of most users to do what they feasibly can to attain an exempt status.
In addition to the standard waste removal methods listed above, high pressure triple rinsing can most often be successfully used to remove sufficient amounts of the remaining wastes to render the container empty.
Triple-Rinsing
The triple-rinsing requirement is intended to remove as much of the contaminants as possible, in order to render the container non-hazardous. Effective triple-rinsing is achieved by a precision high pressure spray pattern of a solvent capable of removing the waste chemical. In many cases, waste materials in the container may have already started to cure and harden, and may require spray pressures in excess of 100 psi.
In dealing with such pressures, computer controlled systems are designed to ensure thorough cleaning efficiencies with maximum operator safety.
In Federal Register documents (45 FR 78258; November 11, 1980, and 47 FR 36095; August 18, 1982) triple-rinsing is not considered treatment, and therefore does not fall under RCRA permitting requirements. However, other environmental laws may be applicable, and should be verified through local agencies.
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Rinsate Handling Or Recycling
Both solvent and water based triple-rinse systems are in use today in a wide variety of applications. The rinsate is collected in a separate reservoir, where it can be managed per the applicable regulations, or preferably, recycled on site. The most frequently used recycling process involves distillation and recovery systems. With this technology, the solvent (or water) is recovered for reuse, while the hazardous material is left in a semi solid sludge, resulting in a large hazardous waste volume reduction. The sludge must be managed per the applicable regulations. |
Automatic solvent distillation system
Regulations concerning the recycling of hazardous waste materials are outlined in EPA 40 CFR 261.6. An important component in §261.6(c) is that while storage of a hazardous waste is regulated, the recycling process itself is exempt from RCRA regulations, which includes no permitting requirements. This fact is an incentive for recycling material as cited in §§261.6(b), (c), and §261.2(d).
Exceptions to the permitting may occur as air emission regulations, overseen by local Air Pollution Control Districts (APCD). While the recycling unit currently may not be regulated under RCRA, other environmental laws may be applicable.
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Disposing Of Exempt Containers
Once the containers have attained empty status, they can be appropriately disposed off-site or sent to a recycler for reuse or other purposes. If the containers can be reused or refurbished for reuse, the recycler can take them in their current form.
If the containers are not to be reused, because of damage or for other reasons, the user has the option to crush the containers to reduce the cost of shipping and storage. Drum crushers can reduce the container volume, and its associated storage and disposal cost by as much as 80%.
SRS Engineering Corp. designs, builds and installs systems to clean a recycle containers used with hazardous materials. Applications range from the thorough cleaning of totes, tanks and other containers for reuse in process lines, to the cleaning and crushing of used drums, pails and lids for non-hazardous disposal or recycling.
Reduce Costs...Health & Safety Risks...VOC Emissions
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