Hazardous Waste Containers€¦ · Best Management Practices Handbook for Hazardous Waste...

HAZARDOUS WASTEA C C U M U L A T I O NS T A R T D A T EC O N T E N T S

H A N D L E W I T H C A R E !CONTAINS HAZARDOUS OR TOXIC WASTES




H A N D L E W I T H C A R E !CONTAINS HAZARDOUS OR TOXIC WASTESHAZARDOUS WASTE

A C C U M U L A T I O NS T A R T D A T EC O N T E N T S




HAZARDOUS WASTEHAZARDOUS WASTE

Best Management Practices

Handbook for

Hazardous WasteContainers

U.S. EPA Region 6, 1997

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FOREWORD

This handbook was produced by A.T. Kearney, Inc., under contract to theEnvironmental Protection Agency (EPA) Region 6, for the Compliance Assurance andEnforcement Division of EPA Region 6. The idea to construct the handbook came froma RCRA workgroup composed of members of several oil and gas companies, theAmerican Petroleum Institute (API), the Texas Mid Continent Oil and Gas Association(TMOGA), EPA, and environmental consulting firms. The RCRA workgroup is one ofseveral workgroups making up the “Refinery Roundtable.” The overall mission of theRefinery Roundtable is to develop methods by which petroleum refineries can achievebetter compliance with the environmental regulations.

This handbook is to be used solely as guidance and cannot be relied upon to createany rights, substantive or procedural enforceable by any party in litigation with theUnited States. EPA reserves the right to act at variance with the policies andprocedures herein, and to change them at any time without public notice.

Table of Contents

1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2. Best Management Practices for Containers . . . . . . . . . . . . . . . . . . . . . . 4

A. Waste Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

B. Container Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

C. Managing Containers at 90-Day Areas . . . . . . . . . . . . . . . . . . . . 11

3. Inspecting Containers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

4. Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

5. Generic Inspection Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

6. Federal and State Contacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

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1. INTRODUCTION

Who will the Best ManagementPractices Handbook Help?

This handbook was written for anyone who,manages, or supervises the management ofhazardous waste containers.

Why did EPA develop thehandbook?

This handbook is a user-friendly training tool orreference that identifies and explains the regulationsfor managing hazardous waste containers safely inlay terms. The handbook also provides “BestManagement Practices” (BMP) -- real worldmethods, examples, and tips for meeting andexceeding regulatory requirements. When workersunderstand what regulations mean and how tocomply, environmental performance will improve.

The U.S. Environmental Protection Agency (EPA),Region 6, is working with the regulated communityto ensure compliance with the regulations under theResource Conservation and Recovery Act (RCRA). RCRA is the Federal government’s regulatoryprogram for managing hazardous wastes in order toprotect human health and the environment.

EPA has found that the most common problem withgenerators of hazardous waste is the failure to meetthe permit exemption requirements (for containers)as defined in 40 CFR 262.34(a)(1)(i). Thisregulation allows generators to temporarily storetheir hazardous wastes onsite, in containers, withouta permit, provided that they meet certain containermanagement requirements. A review of the findingsfrom all the inspections conducted at petroleumrefineries in Region 6 showed violations related tocontainer management occur twice as often as anyother type of RCRA violation.

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§262.34(a)(1)(i) -- Except as provided inparagraphs (d), (e), and (f) of this section,a generator may accumulate hazardouswaste on-site for 90 days or less without apermit or without having interim status,provided that:

(1) The waste is placed:(i) In containers and the generatorcomplies with subpart I, AA, BB and CCof 40 CFR Part 265.

How is the handbookorganized?

Generators can store hazardous wastes incontainers on-site for 90 days or less without aRCRA permit. The waste must be stored undercertain conditions:

1) The waste must be stored in containerswhich meet the definition of a portabledevice (e.g., 55-gallon drums). Permanently-mounted tanks, surface impoundments, andwaste piles would not be consideredcontainers.

2) the waste must be stored according to thefull set of regulatory requirements outlined in40 CFR 265, Subpart I.

Requirements of 40 CFR 265, Subpart I will bediscussed throughout this handbook.

The handbook is organized around the containermanagement process -- from the time a waste isgenerated and placed in a container, to the time thewaste-filled container is shipped off site for disposal.

A flow diagram of the container managementprocess is shown first, followed by a discussion ofthe process. The discussion explains real worldcontainer management requirements and operationsand fits the regulations into those operations.

Management of containers in less than 90 daystorage areas are also discussed in detail providingadditional tips for compliance.

A listing of Federal and state contacts who can helpyou comply with the regulations is also provided.

Finally, two compliance tools are included at theback of the handbook. The first tool is a genericcontainer inspection checklist (see page 16) thatmay be tailored for use at your facility. The secondtool is a poster (see page 18) that uses simple, clearpictures to show best management practices forcontainer management. You can tear the poster outof the handbook and display it for quick referencingat your facility.

BMPHWC 3

CONTAINERMANAGEMENTPROCESS

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Best Management Practice

2. BEST MANAGEMENTPRACTICES FOR CONTAINERS

The following sections will explain how tosuccessfully manage hazardous wastes incontainers. All relevant regulations are identifiedand explained. From these sections, you will...

A. Learn why waste characterization, oridentifying and understanding your wastes, isimportant.

B. Learn how to select and label containers. C. Learn methods to safely manage containers

of hazardous waste.

A. WASTE CHARACTERIZATION

To safely manage hazardous waste, you must knowexactly what a waste is, how it will act, and what itsproperties are. Is the waste extremely toxic? Doworkers need special protection? Is the wastecorrosive, will it corrode certain types of containers? Is the waste incompatible with other wastes -- will itreact (explode, catch on fire) if it is mixed withanother waste or water?

Once a waste is generated, it should becharacterized, before you place the waste in acontainer. Waste characterization can be done byeither:

1) sampling and analyzing the waste, or2) identify the waste based on process

knowledge (you know the constituents in theprocess and therefore you can use thatknowledge to determine if the resulting wastehas characteristics that could make thewaste hazardous).

Tips for Waste Characterization

1) Look at a material safety data sheet (MSDS)if it is available. Some information areas onthe MSDS to look for are physical property,reactivity, fire and explosion hazard, andspecial protection information.

2) If a product being used in a process meetsone or more hazardous characteristics, thewaste generated may exhibit some of thesame characteristics.

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CORROSIVE


3) Be aware of any changes in a productionprocess which could alter the composition ofthe waste generated.

Tips for Waste Characterization ofContainerized Waste

1) Pay attention to marking/labeling which mayindicate that a material is flammable,corrosive, etc.

2) Always check with your supervisor beforehandling unknown drums, or drums whichyou feel are labeled or marked incorrectly.

3) Look at a material safety data sheet (MSDS)if it is available.

4) If waste is in a plastic drum it is a goodindication the waste may be corrosive.

Special methods and equipment may be required tomanage wastes which are:

1) Corrosive2) Combustible3) Flammable4) Oxidizer5) Poison6) Toxic 7) Reactive

§265.177 -- Special requirements forincompatible wastes

(a) Incompatible wastes, or incompatiblewastes and materials (see appendix V forexamples), must not be placed in the samecontainer, unless 265.17 (b) is compliedwith.

Putting Wastes in Containers -Reactive or Incompatible Wastes

Through waste characterization, you learn if a wasteis reactive or incompatible with other wastes. Before putting wastes into a container it isnecessary to identify and segregate wastes if theyare incompatible and/or reactive. This isimportant!! Incompatible and/or reactivehazardous wastes must be stored in a manner toprevent fires or explosions.

The regulations state that incompatible wastescannot be placed in the same container, unless youcomply with other requirements found in §265.17(b). This prevents the wastes from reacting witheach other (e.g., exploding, catching on fire).

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The best managementpractice for incompatiblewastes is to store themseparately. It is safer andeasier to simply putincompatible wastes inseparate containers andseparate storage areas.

§265.17(b) ...the mixture or comminglingof incompatible wastes, or incompatiblewastes and materials, must be conductedso that it does not:(1) Generate extreme heat or pressure,fire or explosion, or violent reaction;(2) Produce uncontrolled toxic mists,fumes, dusts, or gases in sufficientquantities to threaten human health;(3) Produce uncontrolled flammablefumes or gases in sufficient quantities topose a risk of fire or explosions;(4) Damage the structural integrity of thedevice or facility containing the waste; or(5) Through other like means threatenhuman health or the environment.

The regulations allow you to put incompatiblewastes in the same container, under the conditionsfound in §265.17(b) (Warning: “Always talk toyour supervisor or environmental coordinatorbefore mixing any materials or wastes”). If youhave to mix incompatible wastes in the samecontainer you must make sure that the wastes won’treact. This means that you must:

1) keep the waste from becoming too hot (thiswill prevent fire or explosions);

2) keep the wastes from producing toxic and/orflammable mists, gases, fumes, or dust (thiswill prevent workers from being exposed tothe waste and will prevent fire or explosions);

3) make sure that mixing the incompatiblewastes won’t damage the container -- thecontainer won’t rupture or bulge; and

4) demonstrate that mixing the wastes won’t threaten workers, or the environment in anyway.

B. CONTAINER SELECTION

Once the waste has been characterized and youknow if the wastes are incompatible or reactive, youthen can select an appropriate container.

When selecting a container consider the amount ofwaste and type (characteristic) of waste.

First, you should consider the amount of waste youhave -- it makes more sense to put 20 to 25 gallonsof waste into a 30-gallon drum rather than a 55-gallon drum. On the other hand, a 55-gallon drum isbetter for storing contaminated gloves/coveralls.

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§265.172 Compatibility of Waste withContainer

The owner or operator must use acontainer made of or lined with materialswhich will not react with, and areotherwise compatible with, the hazardouswaste to be stored, so that the ability ofthe container to contain the waste is notimpaired.


When selecting the container you must make surethat a waste won’t react with the container itself. For example, highly corrosive wastes will react witha steel drum -- the drum may fail and waste may bereleased. How can you safely store corrosivewastes? Use plastic, or plastic-lined, steel drums tosafely store corrosive wastes. To prevent drumfailure, carefully “match” the right waste with theright container.

Tip for Container Selection

Consult a corrosion resistance guide to determine ifthe container and waste are compatible.

Match the waste withthe correct type ofcontainer.

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§265.177 Special requirements forincompatible wastes

(b) Hazardous waste must not be placed inan unwashed container that previouslyheld an incompatible waste or material(see appendix V for example), unless265.177 (b) is complied with.


There’s one more thing to think about whenselecting a container. You can put wastes intounwashed containers that have held incompatiblewastes, under regulation §265.177(b). But, youmust make sure that you meet the conditionsspecified in §265.17 (b) (See page 6).

If a container has been used to store waste or othermaterials, you are required to make sure that:

1) the waste/material previously held in thecontainer is compatible with the waste youare going to put in the container.

TIPS for Safely Putting Wastes in Containers

1) Make sure you know which wastes arereactive and/or incompatible. Keep thesewastes away from each other. Put them inseparate containers.

2) Make sure the container cannot be harmedby the waste.

3) If you rinse out containers onsite, be awarethat rinse water generated from drumwashing must be contained andcharacterized prior to disposal.

4) If you frequently reuse containers, consider“assigning” wastes to certain containers. This will allow you to reuse the containerwithout washing.

5) Use a funnel to prevent spills, and do notuse the same funnel for all wastes.

6) Certain chemicals may need room forexpansion, or they may require zeroheadspace depending on the characteristicsof the waste and storage conditions (e.g.,temperature fluctuations)

Marking & Labeling Containers

Hazardous waste generators can only accumulateor store waste on-site for less than 90 days withouta permit. The 90-day limit starts the moment thecontainer is full. If your facility is a small quantitygenerator shipping wastes over 200 miles you canstore wastes up to 270 days. If less than 200 miles,you can store waste up to 180 days.

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HAZARDOUS WASTEACCUMULATIONSTART DATECONTENTS

HANDLE WITH CARE!CONTAINS HAZARDOUS OR TOXIC WASTES

§262.34(a)(2) The date upon which eachperiod of accumulation began is clearlymarked and visible for inspection on eachcontainer.

§262.34(a)(3) While being accumulatedon-site, each container and tank islabeled or marked clearly with the words,“Hazardous Waste”...


You must be able to prove to inspectors that youhave not exceeded the time limit for accumulation.

The regulations require that you clearly mark on thecontainer the date hazardous waste completely filledthe container. In addition, you must clearly mark allcontainers holding hazardous waste with the words“HAZARDOUS WASTE”.

Besides the required markings, you will have tocomply with all Department of Transportation (DOT)labeling requirements on the container before thewaste can be shipped off site. The DOT labelexactly identifies the waste, including name,characteristics, and handling requirements.

(More specific information on DOT labeling can be foundin 49 CFR Part 172)

Tips for Marking/Labeling Containers

1) Have all personnel use the same method(e.g., handwritten, prepared labels) to labelcontainers. Make sure all handlers knowwhat the markings mean.

2) Besides the start date and the words“Hazardous Waste,” include informationabout contents (e.g., toxic, reactive,incompatible).

3) Apply DOT labels to the container whenwaste is first placed in the container. Thelabel will be in place for shipment andprovides information about the waste to drumhandlers.

4) Before reusing containers, make sure all oldmarkings/labels are washed off or blackedout.

Satellite Accumulation Points

It is important to mention satellite accumulationpoints (SAP) before discussing the requirements formanaging hazardous waste at less than 90-dayareas.

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262.34(c)(1) A generator may accumulateas much as 55 gallons of hazardous wasteor one quart of acutely hazardous wastelisted in 261.33(e) in containers at ornear any point of generation where wastesinitially accumulate, which is under thecontrol of the operator of the processgenerating the waste, without a permit orinterim status and without complying withparagraph (a) of this section provided he:

(i) Complies with 265.171, 265.172, and265.173(a) of this chapter; and (ii) Marks his containers either with thewords “Hazardous Waste” or with otherwords that identify the contents of thecontainers.(2) A generator who accumulates eitherhazardous waste or acutely hazardouswaste listed in 261.33(e) in excess of theamounts listed in paragraph (c)(1) of thissection at or near any point of generationmust, with respect to that amount ofexcess waste, comply within three dayswith paragraph (a ) of this section orother applicable provisions of thischapter. During the three day period thegenerator must continue to comply withparagraphs (c)(1)(i) through (ii) of thissection. The generator must mark thecontainer holding the excessaccumulation of hazardous waste with thedate the excess amount beganaccumulating.

You can store up to 55 gallons of hazardous waste(or up to 1 quart of acutely hazardous waste) at aSAP for an unlimited amount of time and followingonly some of the requirements for 90-day areas. Tostore waste at a SAP you must simply:

1) keep the containers in good condition;2) make sure the waste is compatible with the

container; and3) keep containers closed when not adding or

removing waste. Make sure you handle thecontainers to prevent leaks or spills.

4) Mark container with words “HazardousWaste” or words which identify the contents.

Because of fewer requirements, facilities like todesignate storage areas as SAPs. This can be aproblem. The definition of a SAP is specific. SAPscan only be located at or near the point of wastegeneration (where the waste is generated) AND theSAP has to be under the control of the persongenerating the waste. To be a SAP a storage areamust:

1) only accumulate waste generated at the SAP-- SAPs can’t be used as temporary stagingareas for wastes collected from other areas;and

2) be located as near the point of generation assafety allows. For example, lab wastes maybe accumulated in safety cans in the lab.

If you accumulate in excess of 55 gallons ofhazardous waste or one quart of acutely hazardouswaste at a SAP you must:

1) mark the container holding the excessaccumulation of hazardous waste with thedate the excess amount beganaccumulating.

2) move the container holding the excessaccumulation to a container storage areawithin 3 days.

If your company incorrectly manages a 90-daystorage area as a SAP, your company will be inviolation of the regulations.

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C. MANAGING CONTAINERS AT 90-DAY AREAS

The moment that waste is placed in the container,containers holding hazardous waste must bemanaged to prevent spills of hazardous waste.

Keeping Containers in Good Condition

§265.171 Condition of containers

If a container holding hazardous waste isnot in good condition, or if it begins toleak, the owner or operator must transferthe hazardous waste from this containerto a container that is in good condition,or manage the waste in some other waythat complies with the requirements ofthis part.

One of the easiest ways to prevent spills is to makesure that containers are kept in good condition --both before the waste is put in the container andwhile you are managing the container. What doesgood condition mean?

1) Containers must be free of dents andcorrosion -- these weaken the container.

2) Containers must not leak -- the containermust be structurally sound.

3) Containers must not bulge.

If you find any of these problems, you must transferthe waste from the “problem” container to a soundcontainer.

Managing Filled Containers

§265.173 Management of containers

(a) A container holding hazardous wastemust always be closed during storage,except when it is necessary to add orremove waste.

(b) A container holding hazardous wastemust not be opened, handled, or stored ina manner which may rupture thecontainer or cause it to leak.

How can you keep containers in good condition? Your company should have written procedures formanaging containers. All employees should betrained in these procedures. At a minimum, youmust:

1) keep containers closed at all times, exceptwhen you are adding or removing waste fromthe container;

2) be careful when you are handling thecontainers. You must open, handle, andstore containers to prevent ruptures or leaks. For example, use drum grapplers to lift andmove drums -- don’t hand-roll the drums fromone area to another; and

3) if the container begins to leak, or you noticedents or bulges, transfer the waste toanother container.

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H A Z A R D O U S W A S T EACCUMULATIONSTART DATECONTENTSHANDLE WITH CARE!

CONTAINS HAZARDOUS OR TOXIC WASTES




CONTAINS HAZARDOUS OR TOXIC WASTESH A Z A R D O U S W A S T EACCUMULATIONSTART DATECONTENTSHANDLE WITH CARE!


H A Z A R D O U S W A S T EACCUMULATIONSTART DATECONTENTS

HANDLE WITH CARE!CONTAINS HAZARDOUS OR TOXIC WASTES

H A Z A R D O U S W A S T EH A Z A R D O U S W A S T E

You must also prevent reactions of ignitable and/orincompatible wastes. EPA developed three specialmanagement requirements for these wastes:

1) incompatible wastes must be physicallyseparated

2) store ignitible and/or reactive wastes at least50 feet from your property line

3) manage ignitable and/or reactive wastes toprevent fire and/or explosions.

Managing Incompatible, Ignitable and/orReactive Wastes

§265.177 A storage container holding ahazardous waste that is incompatible withany waste or other materials storednearby in other containers, piles, opentanks, or surface impoundments must beseparated from the other materials orprotected from them by means of a dike,berm, wall, or other device.

Physically separate containers holdingincompatible wastes from other wastes or materials. Store the containers in an area surrounded by aberm, dike, wall, or other physical structure.

Keep incompatible wastes from contacting/reactingwith other wastes and materials.

§265.176 Special requirements forignitible or reactive waste

Containers holding ignitable or reactivewaste must be located at least 15 meters(50 feet) from the facility’s property line.

Keep incompatible wastes fromcontacting/reacting with otherwastes and materials

Store ignitible and/or reactive wastes at least 50feet from the property line of your facility. Manyfacilities stack drums along fence lines for storagespace -- this may be a convenient storage area thatmaximizes use of facility space, however, ignitableand/or reactive wastes CANNOT be stored this way. Locating these wastes well within the propertyboundaries provides two safeguards:

1) reduces the risk of the general publicreaching/contacting the waste or beingharmed in an explosion; and

2) if a release of hazardous waste does occur,this will help prevent the waste frommigrating offsite.

BMPHWC 13

§265.17(a) The owner or operator musttake precautions to prevent accidentalignition or reaction of ignitable orreactive waste. This waste must beseparated and protected from sources ofignition or reaction including but notlimited to: Open flames, smoking, cuttingand welding, hot surfaces, frictional heat,sparks (static, electrical, or mechanical),spontaneous ignition (e.g., from heat-producing chemical reactions), andradiant heat. While ignitible or reactivewaste is being handled, the owner oroperator must confine smoking and openflame to specially designated locations. “No Smoking” signs must beconspicuously placed wherever there is ahazard from ignitable or reactive waste.

Best Management Practices

Manage ignitable and/or reactive wastes toprevent fire and/or explosions. At a minimum youmust keep ignitable and/or reactive wastes awayfrom:

1) fire;2) hot surfaces like operating machinery,

engines;3) radiant heat or sunlight;4) cutting and welding operations;5) frictional heat -- keep drums stationary, don’t

pull drums along on the ground;6) sparks from static electricity, electrical

operations, or friction; and7) some reactive wastes must be kept away

from water.

Finally, you must ban smoking in all areas thatmanage ignitible or reactive wastes, especially whenwastes are being transferred/placed into containers.

“NO SMOKING” signs must be posted at all areasnear ignitible or reactive wastes.

Tips for Safely Managing Containers

1) Use a funnel or hose to add or transferwastes to drums. This will prevent spills. Remember to rinse the funnel andcharacterize the rinse water (a dedicatedfunnel would not have to be rinsed).

2) If you notice a leak, or a container is in poorcondition, transfer the waste to a newcontainer immediately.

3) Keep containers cool and dry.4) Make sure all container storage areas are

clearly marked -- keep ignitible/reactivewastes in their own area.

5) Don’t stack ignitible/ reactive wastes.6) Make sure to open and close steel drums

with a spark proof bung wrench.

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Best Management Practices Tips continued

7) Don’t push, roll, or drag containers. Use theright equipment to move the drums.

8) Make sure the drums are easy to reach --keep an open aisle space so that people andequipment can move freely.

9) Don’t drive equipment (trucks, forklifts) intocontainer storage areas unless you aremoving containers.

10) Keep the containers in a “containment area”to hold spills. Containment can be providedby dikes, berms, or walls.

Use a funnel to add or transfer wastes todrums. Remember when not in use to keepfunnel covered or closed

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§265.174 Inspections

The owner or operator must inspect areaswhere containers are stored, at leastweekly, looking for leaks and fordeterioration caused by corrosion orother factors.


3. INSPECTING CONTAINERS

Container storage areas must be inspected weekly. Inspections protect you, your company, and thepublic -- through inspections, you can stop spillsbefore they happen.

Your company should develop and maintain astandard inspection checklist to be used duringevery weekly inspection. The checklist should bedetailed and address the labeling and managementprocedures followed at your facility. An example ofa checklist that can be modified to fit your facility isattached to the back of this booklet.

At a minimum, the inspection checklist should cover:

1) leaks or staining from containers;2) container condition, including dents, bulging,

and/or corrosion;3) labeling -- start date, the words “Hazardous

Waste” and other information; and4) management practices -- such as aisle

space, drum stacking.

Inspections should be detailed and methodical. Anyone doing inspections should be trained.

Tips for Conducting Inspections

1) Follow the inspection checklist -- makedetailed notes if you find something wrong.

2) Be thorough. Check the tops of drums tolook for waste residue or corrosion.

3) Walk all the way around containers -- checkentire storage area.

4) Check containment area for stains.5) Note anything unusual in containment area --

even if it might not be a problem.6) If problems are found, get the problem taken

care of immediately. 7) Keep a logbook of the facility’s inspection

checklist.

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Summary

The Best Management Practices Handbook for Hazardous Waste Containers was published withthe intent of helping to interpret the regulations pertaining to the handling and management ofhazardous waste containers. The Handbook is not meant to act as a replacement for theregulations, but simply to give some practical examples of how to comply with them. Generatorsof hazardous waste should be aware that they must adhere to all the applicable regulations foundin Title 40 of the Code of Federal Regulations.

The Handbook is structured so that it follows the typical path a hazardous waste might take fromthe time it is generated, until the container is ready to be sent offsite for disposal. The first, andmost important task is for the generator to determine the composition and characteristics of thehazardous waste. The next step is to use that knowledge regarding the characteristics of thewaste, to choose a container which will be compatible with the waste. After the waste iscontainerized, it should be marked or labeled appropriately, and moved into a container storagearea. Once the container is transferred to a container storage area, it must be inspected weeklyand kept in good condition until it leaves the site. Generators must consult the appropriateDepartment of Transportation regulations found in Title 49 of the Code of Federal Regulations prior to shipping hazardous waste containers offsite for disposal.

Page 18 contains a list of phone numbers for both the EPA Region 6 office, as well as the variousstate agencies located in Region 6. If you have any questions regarding the handling andmanagement of hazardous waste containers, please contact your appropriate state agency, or theEPA Region 6 office.

BMPHWC 17

4. HAZARDOUS WASTE CONTAINER STORAGE AREAINSPECTION CHECKLIST

Month: Year:

Instructions: Weekly, place a “Yes” next to all inspection items that meet facility rules. Place a “No” next to all inspection items that do not meet the rules. Please provide specific comments on all “No-marked”items. When weekly inspection is completed, inspector must initial at the bottom of the table. Report all No-marked items to appropriate supervisor.

Four-Week Inspection Period Comments onInspection Items

Inspection Item Date:_____

Date:_____

Date:____

Date:_____

Number of Containers in Unit

Containers Marked/LabeledProperly

Containers Dated Properly

Containers Stored 90 Days or Less

Containers Observed to be free ofLeaks/Staining

Containers Observed with ClosedTops or Bungs

Containers Observed withoutDents or Corrosion

Appropriate Aisle SpaceMaintained

Containment System free of Wateror Other Liquids

Inspectors Initials

Overall Comments:

Reviewed by: Date:

Note: State and Federal regulations require that this inspection be performed weekly.

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5. FEDERAL AND STATE CONTACTS

1) National Spill Response Center - (800) 424-8802

2) EPA Region 6 Emergency Response - (214) 665-2770

3) EPA Region 6 1445 Ross AvenueDallas, Texas 75202(214) 665-6444

4) RCRA/Superfund HotlineWashington, DC(800) 424-9346

5) State Agency Numbers:

Arkansas Department of Pollution Control & Ecology (ADPC&E) - 8001 National DriveLittle Rock, Arkansas 72209(501) 682-0744

Louisiana Department of Environmental Quality (LDEQ) - 7290 Bluebonnet RoadBaton Rouge, Louisiana 70810(504) 765-0647

New Mexico Environmental Department (NMED) - 1190 St. Francis DriveRoom North 4050Santa Fe, New Mexico 87505(505) 827-6055

Oklahoma Department of Environmental Quality (ODEQ) - 1000 NE 10th StreetOklahoma City, Oklahoma 73117(405) 271-7363

Texas Natural Resources Conservation Commission (TNRCC) - Austin Regional Office1921 Cedar Bend Dr.Suite 150Austin, Texas 78758(512) 339-2929

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