DRAFT
        FACILITIES STORING HAZARDOUS WASTE IN CONTAINERS


        A Technical Resource Document for- Permit Writers
     This document  (SW-XXX) was prepared by Fred C. Hart,  Inc.,
under contract to EPA's Office of Solid Waste, and Karen A.  Walker
of the Hazardous and Industrial Waste Division, Office of  Solid
Waste.
        This document has not been peer  and administratively
        reviewed  within EPA and is for internal Agency use/
        distribution only.
              U.S. ENVIRONMENTAL PROTECTION AGENCY/1982

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                              PREFACE
     This is one of a series of technical resource documents that
provides information on standards for facilities that treat, store,
or dispose of hazardous waste.

     The documents are being developed to assist permit writers in
evaluating facilities against standards  (40 Code of Federal Regu-
1 at t ions, Part 264) issued under Subtitle C of the Resource Conserva-
tion and Recovery Act (RCRA) of 1976, as amended.  Included"in these
documents is detailed information about design, equipment, and
specific procedures for evaluating data submitted by the permit
applicant, as well as bibliographies that can be used to locate
additional information.

     The series, which is being produced by the Technology Branch
of EPA's Office of Solid Waste, includes guidance on:
      0     containers
      0     tanks
      8     compatibility of wastes
           incineration

     Permit writers  should keep  in mind when  using  this material
that the regulations are subject to change  through  amendments
and modifications  and should  incorporate  any  changes  into  their
evaluations of  facilities.
     The "material contained herein i.s; for guidance purposes only
and' is. nof enforceable;'' The technical'resoarce documents; are not
tp-be interpreted as'amending the'facility standards in .40 C.FR
Part:264."
                                 ii

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                             CONTENTS

                                                       Page

INTRODUCTION                                           1-1

QUESTIONS TO BE CONSIDERED BY THE PERiMIT WRITER        2-1

     Checklist for Permit Writers                      2-1
     Questions to Be Answered
       by the Permit Writer

TYPES OF .CONTAINERS                                    3-1

     Steel Containers                                  3-2
     Plastic Containers                                3-16
     Fiber Containers                                  3-16
     Barrels and Kegs                                  3-20
     Bags and Sacks                                    3-21
     Carboys                                           3-23
     Containers for Storing Ignitable
       and Combustible Liquids                         3-24

MANAGEMENT OF CONTAINERS                               4-1

     Introduction                                      4-1
     Current Storage Practices                         4-1
     Condition of Containers                           4-8
     Compatibility of Waste with
       Containers                                      4—11
     Incompatible Wastes                               4-11
     Storage of Ignitable
       or Reactive Waste                               4-12
     Containment                                       4-12

INSPECTION OF CONTAINER FACILITIES                     5-1

     Containers                                        5-1
     Container Storage Areas  and
       the Containment System                         5-5
     Evaluation of an Inspection Plan                  5-6

HAZARDOUS WASTE CONTAINER COSTS                      .  6-1

     Introduction                                      6-1
     Container Costs                                   6-1
     Containment System Costs                          6-4

REFERENCES                                             7-1
                               ill

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                              TABLES
3-1  Types of Containers                                  3-4
3-2  Properties of Principal Coating Resin                3-9
3-3  Typical Steel-Drum Specifications  for
       Hazardous Materials                                3-13
3-4  Advantages and Disadvantages
       of Different Types of Containers                   3-15
3-5  Chemical Resistance of Important  Plastics             3-17
3-6  Materials and Closures of Fiber Containers           3-19
4-1  Outdoor Liquid Storage in Containers                  4-6
5-1  Container Storage Facility
       Inspection Points                                  5-8
6—1  Prices of New Containers                             6-2
6-2  Prices of New and Reconditioned
       Containers (TABADA survey)                          6-3

                             FIGURES
Automatic  Container Palleting                             4-4
Types  of Corrosion                                        5-1
                                IV

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                           INTRODUCTION

     This manual provides the permit writer with a systematic
approach to evaluating permit applications from facilities that
store hazardous waste in containers.
     Owners and operators of facilities that  use containers to
store hazardous waste are regulated under authority of Section 3004
of the Resource Conservation and Recovery Act (RCRA).  Regulations
promulgated under RCRA on the use and management of containers
are  found in Sections 264.170-264.178, Subpart I, Title 40, of
the  Code of Federal Regulations (CFR).  The procedural requirements
for  obtaining a hazardous waste facility permit are in 40 CFR
122  and 124.
     EPA's regulations provide for  issuing hazardous waste facility
permits in two phrases:  Part A of  the permit application (interim
status) and Part 3 of the permit application  (permanent status—
the  final permit).  Interim status  allows facilities that are in
existence to continue operations while administrative action on
the  final permit is under way.  These facilities must submit Part
B of the permit application 180 days prior to beginning physical
construction.
     Part B of the permit application requires information on the
equipment,  structures, and procedures used for managing hazardous
waste at the facility.  The application must  also provide data on
the physical and chemical characteristics of  the wastes to be handled,
(See 40 CFR §122.25 of the Consolidated Permit Regulations for
the contents of Part B.)
                               1-1

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     The permit writer evaluates the information provided in Part
B of the application to determine whether the facility meets the
administrative and  technical standards (40 CFR 264) and the
procedural requirements for obtaining a permit  (40 CFR 122 and
124).  The permit writers' manuals provide background information
and procedures for evaluating the data provided by the applicant.
     The administrative procedures permit manual (prepared  by EPA's
Office of Enforcement)1 provides information on procedures  to
follow  from  the  initial contact  with an  applicant  through review,
public hearing, and any administrative appeals of  permit decisions.
The manual  also  contains  guidance  for  conducting  technical  reviews.
     Various  sections  of  the final regulations  for storage  reflect
 the use of  best  engineering  judgment (BEJ).  This  concept entails
 the. application  of  case-by-case  judgment, based on site-specific
 circumstances, in evaluating facilities for issuing  permits.   In
 those  sections of the regulations  that have been  written from  a
 BEJ standpoint,  some flexibility is allowed on the part of  the
 owner  or operator in meeting permit  requirements.   The  Agency
 feels  that evaluating facilities individually  will ensure  the
 protection  of human health and the environment and,  at  the  same
 time,  avoid overly restrictive requirements that might result
 from application of specific uniform rules  for all facilities.
      BEJ provides for tailoring of permit requirements to the
 specific wastes,  facility design,  and  environmental  conditions of
 the storage area, based on the best engineering judgment of the
 permit writer.  In order to make these  judgments,  the permit
                                1-2

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writer must have access to information on current technologies and
the specific site.
     The storage regulation for containers requires complete contain-
ment of the waste.  No discharge into the land, surface water, or
ground water is permitted.  Three lines of defense against potential
discharge are built into the regulation:  (1) a primary containment
device (the container  itself); (2) regular inspections to verify
condition of containers and to ensure that leaks or other problems
do  not go unnoticed; and  (3) a secondary containment system
capable of holding any discharges that should occur.
     The regulatory definition of "containers"  is "any portable
device  in which a  material  is stored, transported, treated, disposed
of, or otherwise handled" (40 CFR Section 260.10).  Specific  stand-
ards for managing  hazardous waste stored in  containers are  in
Subpart I,  40  CFR S §264.170-177.  These standards  cover  the following
general  areas:
         condition of containers
         compatibility of wastes with container material  and of
         wastes with wastes
      -  management of containers
         inspections
         containment
      -  special requirements for ignitable or reactive wastes
         special requirements for incompatible wastes
         closure
                                1-3

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                            CHAPTER 2


         QUESTIONS TO BE CONSIDERED BY THE PERMIT WRITER


     These questions will aid permit writers in evaluating

applications of owners or operators of facilities that use con-

tainers for storage of hazardous waste.  The first section is a

checklist of questions designed to assess the completeness of

the application.  The second section consists of general design

and operating questions-

A.  Checklist for Permit Writers

     The following outline will assist permit writers in assessing

the completeness and adequacy of a permit application.

     1.  General Facility Description

         .- aumber of containers

         - location of containers

         - buffer zone for ignitable/reactive
           waste in containers  (§264.176)

     2.  Chemical and Physical Analyses of Wastes

         - information necessary to determine waste-to-waste
           compatibility, waste-to-container compatibility,
           and  ignitability or reactivity

     3.  Waste Analysis Plan

         — analyses or trial tests used to determine waste-to-
           waste and waste-to-container compatibilities

         - analyses for determination of ignitability and reactivity

         - methods for selecting representative samples

         - frequency with which-original analysis will be reviewed
           or repeated

         - source of other information on composition and
                               2-1

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      characteristics of waste for off-site facilities
    - inspection of shipments received at the facility
4.-  Description of Security
5.  Inspection Schedule
    - schedule for inspecting container storage areas and
      containment systems, as specified in §264.174
    - list of items to be inspected for corrosion or rusting
      of containers, cracking of containment base, etc.
6.  Justification for Waiver of Preparedness and Prevention
    Requirements
7.  Contingency Plan
    - actions to be taken in response to fires, explosions,
      or unplanned releases of hazardous waste
    — arrangements with police department, fire department,
      hospitals, contractors, and State and  local emergency
      response  teams
    - list o£ emergency coordiriators
    - list and  location of emergency  equipment
    - evacuation plan,  if necessary
8*  Description of Procedures to:
    - prevent hazards  in  unloading
    - prevent runoff from handling areas
    - prevent contamination of water  supplies
    - mitigate  effects  of equipment failure  and power  outages
    - prevent exposure  of personnel to hazardous waste
9.  Description of Precautions to Prevent  Accidental  Ignition
    or Reaction
    - precautions  to prevent  ignition or reaction -of
      ignitable, reactive, or incompatible waste
    - documentation demonstrating compliance with  §264.17(a)
      (see item 20 of  this checklist)
                           2-2

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    10.  Traffic Pattern and Volume

    11.  Facility Location

         - political jurisdiction  in which facility lies

         - if facility is in an area listed in Appendix VI. of
           Part 264, demonstration of compliance with the seismic
           standard  (see §§264.18 and 122.25(a) (11) (ii) for details)

         - identification of whether facility  is located in 100-
           year floodplain

         - if  facility  is in a 100-year  floodplain, engineering
           analyses  showing design of operational units and
           flood-protection devices and  their  ability to withstand
           forces of a 100-year flood, or procedures for removing
           hazardous waste prior to a flood (see §§264.18(b) and
           122..25(a) (11) (lv) for details)

         - if  existing  facility  is not  in  compliance with
           §264.13(b),  a  plan and  schedule for bringing facility
           into compliance

     12.  Outline  of Training Program

     13.  Closure Plan (see  §264.112 for details)

     !£•.  Closure Cost Estimate  and Financial  Assurance  Mechanism
          (see §§264.142 and 264.143 for details)

     15.  Documentation of Compliance  with §264.147,  Liability
          Requirements, if Applicable

     16.  Proof of Coverage  by  State Financial Mechanism, Where
          Appropriate (see §§264.149 or  264.150)

     17.  Topographic Map (see  §122.2 5(a) (19)  for details)

     18.  Design Information When a Containment System  is Required*

          - design parameters, dimensions,  and  materials of
           construction

          - how containers will be managed so  that  they  are not
           stored in accumulated  liquids
*  A containment svstem is not required in storage- areas, where
containers hold only wastes that do not contain free  liquids,  IE
the conditions in 40 CFR 264.175(0 (46 FR 55112,  November 6,  1981)
are me t.
                               2-3

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          -  description of  methods  to  prevent  run-on

          -  capacity of the containment  system

          -  procedures for  analyzing and removing  accumulated  liquids

     19.   Justification for Waiver  of .Containment  System Requirements

     20.   Procedures for Handling Incompatible,  Ignitable,  or
          Reactive Waste

          - for offsite facilities, procedures for inspecting
            each shipment of waste  received at the facility (part
            of the waste analysis plan)

          - procedures for treating waste prior to placement in
            containers, where applicable

          - procedures used to prevent a waste from being placed
            in an unwashed tank, that previously held an incompatible
            waste

          — procedures used to prevent incompatible wastes from
            being placed in the sane container

          - documentation of compliance with buffer zone requirement

B.  Questions to Be Answered by the Permit Writer

     The following questions can be used by the permit writer

in evaluating the information in the permit application and in

preparing a facility permit.  The  text of this manual provides

the permit writer with information as to how these questions can

be answered.

     1.  Type of Container and Condition

         Is the vessel portable  (i.e., is it a container)?

         Is the container  in "good condition" (free of leaks,
         excessive rusts and dents, corrosion, etc.)?

         Is the container marked in accordance with Department
         of Transportation (DOT) specifications?

         Are there procedures to ensure that should the condition
         of a container deteriorate to the point  that it can no
         longer be used, will its  contents be transferred to a
                               2-4

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    container that is in good condition (e.g.,  does the
    permit applicant have an adequate supply of empty drums
    that can be used in this type of situation, etc.)?

2.  Compatibility of Waste with Container

    Does the waste analysis plan specify adequate procedures
    for determining whether the waste is compatible with the
    container construction or lining material?

3.  Management of Containers

    Are containers handled, in such a way as to ensure that
    ruptures, leaks, or other damage do not occur?

    Are containers always kept closed except when emptying
    and filling?

    How are leaking and otherwise damaged containers handled?
    Are they discarded or sent to a reconditioner?

4.  Inspection

    Does the inspection schedule contain the items required
    by §264.L74?

    Are the inspection procedures adequate to detect .".eaking
    and otherwise damaged containers and deterioration of
    the containment system components?

5.  Containment

    Is the containment system, jbase free of cracks and gaps
    and sufficiently impervious to hold spilled or leaked
    waste or precipitation until it is detected and removed?

    Does the design of the containment system provide a
    means to prevent containers from prolonged contact with
    accumulated waste (e.g., drainage designs, elevation of
    the containers on racks or pallets)?

    Is the capacity of the system 10 percent of the total
    volume of the containers or of the largest container
    (whichever is greater)?

    Does the design of the containment system include measures
    to prevent run-on?

    Are plans or procedures for removal of waste from the
    containment area adequate to prevent overflow?
                          2-5

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Ignitable, Reactive, and Incompatible Waste
Are containers of ignitable and/or reactive waste located
at least 50 feet from the property line of the facility?
Are procedures for management of incompatible wastes
adequate to satisfy the requirements of §264.177?
Closure
Has waste been charaterized  (chemical composition,
physical state, etc-)?
Has maximum inventory at closure been estimated?-
Are expected year of closure and schedule of closure
procedures  itemized?
3ow will wastes and residue  be  removed  from the  containers?
Will  the waste be treated, stored, or disposed of onsite
or offsite?
How will  the containment system components be
decontaminated or cleaned?   If  not possible, does the
plan-  specify an option  for removal and  disposal?
How will  contaminated soils, cleaning.products,  equipment,
residues,  etc-, be  disposed  of?
                       2-6

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                            CHAPTER 3
                       TYPES OF CONTAINERS
     At present, there are no containers of which the Agency is
aware that are manufactured specifically for the storage of
hazardous waste, with the exception of those used for high-level
radioactive waste.  Therefore, drums made for other purposes have
been adopted for containerizing hazardous waste.  Specific designs
appropriate for the contraction of containers for various types
of hazardous waste would-likely be more protective.  These would
be developed by analyzing many of the considerations pertinent to
hazardous waste storage  (for example, corrosivity, longevity of
storage, etc.).  Currently, EPA is reviewing drum design standards
developed by various organizations in an attempt to  resolve this
issue.  Because no current design standards exist, however,
containers  that are commonly used  in the  storage of  hazardous
waste  will  be  discussed  in  this chapter.
     This chapter emphasizes factors relevant to the evaluation
of the  appropriateness and effectiveness of each type of container,
Compatibility  and corrosion  factors  for each kind of container
are  also highlighted since  these components are  inseparably linked
to safety and  to  the prevention of discharge of  hazardous wastes.
     Steel  drums of 55-gallon  capacity  and plastic containers  are
most frequently used to  containerize and  store  hazardous waste.
The  useful  life of a container is dependent on  its resistance  to
corrosion and  to  chemical deterioration.  Steel  drums,  often with
appropriate protective lining  or coating material, are  suitable
                                3-1

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for the storage of corrosive, reactive, ignitable, or toxic waste.
Plastic containers are also well adapted for holding corrosive
wastes since they are generally resistant to chemicals-
     Since compatibility of the waste with the structural material
of the container is  important to prevention of failure of the
container, this compatibility must be determined prior to storage.
To ascertain the compatibility of  a  specific waste with  a-specific
container, the following information is needed:   (1) characteristics
of the waste, (2) intended  use of  the  container  and  its  structural
characteristics, (3) Length of storage, and  (4) storage conditions
(e.g., temperature and  humidity).  This determination  is so
critical  that a container that has been specifically designed for
a particular substance  may  not  be  suitable  for an off-specification
batch of  that same substance.   Ear example, a chemical compound
contaminated with only  a few  parts per million (ppm) of  chloride
may begin to deteriorate rapidly an  unprotected steel container.
For more  information on compatibility,  see EPA's  permit  writers
guide on  compatibility  of hazardous  wastes.2
     In addition, this  chapiter addresses.the advantages  and
disadvantages of various containers  that may be  used for the
storage of hazardous waste.   Special considerations for  selecting
appropriate  containers  for  the  storage of  flammable  and  combustible
wastes are also discussed.
A.  Steel Containers
     Steel containers vary  in capacity from 1- to 12-gallon
metal pails to the standard-size 55-gallon drum.  Other  standard

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sizes are presented in Table 3-1.  This section deals primarily
with the 55-gallon drun because of its overwhelming popularity
in storage.
     The metal pail is defined by  the U.S. Department of Commerce
as a single-rolled shipping container with a volume of from 1 to
12 gallons.  Pails are generally  constructed of minimum 28-gauge
mild steel.  This gauge is often  specified for pails that are
designed to hold dry  bulk materials.  Standard markings  include
the steel gauge, capacity, and date of manufacture.  For example,
the marking 28-5-77 denotes  a 28-gauge pail  of 5-gallon  capacity
made in 1977.  Pallets should be  provided when pails are used  to
store  hazardous  waste.
     1.  Compatibility  and Corrosion
     As  already  mentioned, compatibility of  waste with  the
container  is  integral to  prevention of discharge  of  the  waste  and
subsequent contamination of  the environment.   Storage  conditions
such as  humidity,  pH, and temperature can significantly  affect
 the corrosion resistance of a particular container.   (See Chapter
 4,  "Management of Containers,"  for a  further discussion.)   when
 assessing the suitability of a container for a particular waste,
 the permit writer must rely on the best  available data.
      Steel drums are usually fabricated from mild steel or  low-
 alloy  steels  and have a low resistance to corrosion.  Noncoated
 steel drums are well suited  for  wastes that are  not highly
 corrosive such as mild alkaies, mild acids,  and nonhalogenated
 organics.  They are  generally not compatible, however,  with strong
                                 3-3

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                                    TABLE  3-1
                                 Container size, description
j  Usable ;
i  volume, i
I  eu. ft. !
 Metal
 53 gaL. steel std. IS-gagc plate. DOTM7E, new	   7.33
 53 gal. steel, std.' 16-$age plate. DOT-17C. new	   733
 55 gaL. steel, removable head. 18-gage. Rule 40. new	v  .	  7.33
 55 gaL. steel removable head, '?„ gage. DOT-17H. new   	|  7.35   |
 55 gaL. steei. removable head, 18 gage. used, reconditioned	   7.35
 55 gaL. steei. std. 18 gage. used, inspected, cleaned	' .  -  -   "35
 55 gaLraluramum. std. 0.102-m. plat*	   '35
 55 gaL. type 304 stainless steei.  std. 16 gage. DOT-SC	j  '35   \
 30 gaL, steal, std. 20 gage. DOT-17E	.-	   4.00   \
 30 gaL, steei. removable head, 20-gage, Rule 40	   4.00   |
 18 gal, steel, removable lug  cover. 22 gage •	   2J4   I
 55 gal. steei-anil galvanized, std. IS gage. DOT-tTE	   7.35   j
 53 gaL. steel removable head. 40-mil polyethylene liner, external fittings, 20/18 gage.
   53-S-gaL  unhie volume. DOT-37M	   "3D

 Fiber draaw*
 81 gaL. 9 ply. 400-lb. load limit, dry products only. Rule 40   	   8.1?
 55 gaL, 9 ply. 400-lb. load limit, dry products only. Rule 40   	   7J5   I
 47 gaL, 9 ply. 400-lb. load limit, dry products only. Rule 40   	   9.23
 41 gaL, 9 ply. 400-lb. load limit dry products only. Rule 40	   5.43
 30 gaL. 9 ply. 400-tb. load limit, dry products only. Rule 40	   4.00   i
 30 gaL. 7 ply. 223-lb. load limit, dry products only. Rule 40	   4.00   I
 IS gaL. 8 ply. 150-lb. load limit, dry product! only. Rule 40	   2.00   j
 55 jaL. 9 ply, polyethylene barrier. 400-lb. load limit. Rule 4O	   7.35   !
 55 gaL. 9 ply. polyethylene-aluminum foil liner. 400-lb. load limit.. Rule 40   	   735   \
 55 gaL. 10  ply, blow-molded 15-mil polyethylene liquid-tight liner, tight head, sted cover              j
   with 2- and.y«-in. NTT  openings. SOO-lb. load limit. DOT-21C21CP liquid products  . .  .  .   7.35   {
 30 gaL. 9 ply. same as preceding except 430-lb. load limit	   4.00
 30 gaL. 8 ply. 300-lb. load limit, removable fiber cover, no barrier	   4.00
 13 gaL. 8 ply. same u preceding except 150-lb. load limit	   2.00
   1 gaL. 5 ply. same as preceding except 150-lb. load limit	   0.1333
 53 gaL. 9 ply, 400-lb. load limit, semisquare removable nber cover. "Rocon" style	   7.35
 45 gaL. same as. preceding	   8X31

 Bags, mvitrwaO paper. paivethylesw(fE) Slav
. Pasted-valve bag. 20"t x 22-ia. face. SV.-in. top and bottom with l-iml free Mm. 2/50. 1/60
    kraft. plain, no printing. PE internal sleeve	   	'  1.33
 Sawn-valve bag. 15  x 5V, x 301/, in. S'/.-m. PE internal sleeve  with  1-nul free Sim. 2/50.     j
    I/CO- KaUX^ f"MH, ftaT p^^lflltgt                                                           r
                                                                                          I

 Pasted-valve bag, 18% X 22% in. 3Vfia. top  and bottom.  PE internal sleeve. 3/50 kraft.      j
    plain, no prating	{  0.84
 Sewa open-mouth bag, 20 x 4 x 30*. in. 3/50. 1/80  kraft plain	   2.00
 Sewn-vmive bag. 19 X 5 X 33% in. 5y,-in. tuck-in  sleeve. 3/50. 1/60 kraft. plain	   iOO
 Pasted-valve bag, 24 x 25% m. SVj-in. top and bottom, tuck-in  sifcve. 3/50. 1/60 kraft,
    plain	   2.00
 Pasted open-mouth baler bags. 22 x 24 id. 6-in. bottom. 1/130  kraft (or 2/70). plain	
 Hat-robe, open-mouth bag. 10-mil  PE film, plain. 20V. x 34'.', in.	   133
 Square-end valve bag, 20% x 23-in. face. 5%-in. top and bottom. 10-mil PE Sim, plain	  1.33

 Small baas, pouches, folding boxet
 Poucn, Sf, X  16* in. 2-pty PE film. 2-mil thickness/ply	I  0.12
 Bag. sugar-pocket style. 6 x 2% X 16V,  in. 2- to 40-lb. baas weight, natural kraft paper     .1  0.12
 Bag. pioca style. 8% x 3 X  21  uu 2- to 40-lb, basis weight, natural kraft	:  0.12
 Folding box. 5 x 1 X 8  in. ravene-cuck design. 12-pomt krah board  with bleached white     |
    exrenor	j  (1028
 Folding box, 9V, x 4% x 13 in. full overlap top and bottom. 30-point chip board with        i
    bleached white exterior	I  0 3~

 Corrucated cartons, bulk bases                                                        •   1
 Regular slotted carton (RSQ. 24 X 16 x 8 in. 275-lb. test double wall, stapled (stitched)
    joint	
 RSC. 18 x 6 x 24 in. 275-lb. test double  walL stitched joint, end-opening style	
 Bag-in-box, RSC 15 x 15  X 22 in. 275-lb. test double wall, stitched  liner. SOO-lb. test.
    double wall	
 Bulk box. 600/900 'test  in Ib. for both pieces), laminated inner lining approximately
    41 x 34  x 38 in. less PE  liner and pallet	|  3.00

 Carbovs, plastic drams, jars, bottles                                                       I
 Carboy. 13% gaL. poivethvlene. Wow-molded	j  1.35
 Drum, polyethylene. 15  gaL, blow-molded. tCC-34 (DOT-341	]  ISO
 Carboy. 13 gaL, glass, nitric  acid service, wooden crate	   2.00
 Jug.  I f1  glass, with Snger handle, piasnc cap	_...-..]  0.1335
 Bottle. 1  qc. glass. "Boston" round, plastic cap	I  0.034
 Jar. 1 qu  glass, wide mouth, plastic cap	:  0.034
                                                                                      (cant.)

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                      TABLE 3-1

                     of_ Containers

Connin*r sixe. decription '
Carbo»t, piaidc dram. jus. bo(d« icotAiuurf)



Cam.pwb





WnpoMttriaii
CZndcJ ltd rnrfcacioc* - 	
FUm. poiy«thyiW. shctiabU 70% tntchio* dirKttock. 30% CIQH ottchiot diractioo.
*imi*i hmfnrm chntita** w V» (Ylfl «n in VMS t/miD I'Tftwfol S-2D31*
Tilra. peiypropylMM; ihnakafalc. yield bcror* liuuikaf* * 31.100 iq. ia./(lb.KmiO. Cdei LTS"
paper, knfc vmppun quality. -50 lb./mm bans ««iht. vmld « 1.000 sq. fe/r-un 	


Uable
voJltJIM.
CTX ft
0.133S
0.1333
0.034
0.017
067
087
01355
0.034
n i.'n?
O.UG3

.^

•••















1
1

Sources.  Perry and Chilton,. Chemical Engineer's  Handbook,
         McGraw-Hill, 5th Ed., 1973, Ch. 7

-------
acids, strong alkalies, or halogenated chemicals (both organic
and inorganic) because these compounds tend to corrode steel
drums fairly rapidly.
     2.  Coatings and Linings
     Protective coatings and linings are  layers of materials that
are impermeable to specific chemical compounds in which they are
applied and are used to prevent or  retard significantly the
corrosion of the containers.  Useful life is  thereby  increased.
Coatings are also used for abrasion resistance and  to facilitate
cleaning.  The same or different  coatings may be applied  to  the
inside and outside of  the container.
      Coatings and linings are  usually  applied to containers  using
spray equipment  followed by curing  in  baking  ovens.   The  function,
degradation, performance, and  types of coatings  and linings  are
discussed below.
      a)  Functions.   A coating or lining serves  two principal
functions:   (1)  it  protects  the substrate (metal)  from attack by
a corrosive  waste?  and (2)  it prevents the formation of hazardous
products arising from any  chemical reaction between waste and
structural  material.   Sometimes a toxic gas inside the coating is
produced,  and the pressure  from this gas may, in some instances,
rupture  the container or cause bulges.  Lined containers are
easier to  clean.
      The type of waste to be stored may dictate that it is prudent
 for an owner or operator to choose a coated container.  For example
 acidic or chloride-containing wastes should not be stored in steel
                                3-6

-------
containers unless they are coated.  Polyvinyl chloride or
polyester coatings exhibit good resistance to inorganic acids and
alkalies.  If organic solvents are to be stored, a coated container
would not be used.  Other factors, in addition to the materials
being stored, should be considered in the decision as to whether
to use a lined container.  For instance, some coatings, such as
chlorinated rubbers, are degraded by heat and ultraviolet light,
while others, such as epoxies, are degraded  by cold temperatures.
     b)  Degradation.  Degradation of a  coating  is evidenced by
changes  in coating color, blistering, and, ultimately, peeling.
     c)  Performance*  The performance of a  coating depends upon
its application and  is influenced by the following factors:
(1) nature of waste;  (2) pH,  (3)  ambient temperature;  (4) storage
conditions  e.g.  exposure to weatheV; and  (5)  thickness of the
coating.  These factors  affect  the stability of  the coating and,
therefore, its resistance  to  chemical attack.
     One of  the most important  properties associated  with the
chemical resistance  of a coating  is  its  permeability.  This  is  an
inherent property determined  by the  nature  of the  resin  or  resins
used,  the formulation, the  film ^thickness,  the  nature of  the
environment,  and  the temperature*  The extent of permeation  is
determined by the actual conditions  of use.   Some  chemicals  are
more  highly  permeating  than  others.   Permeability  increases
rapidly  with increasing  temperature  and  decreases  with increasing
film  thickness.   Solvation and  absorption  are other  physical
phenomena  that can  be detrimental to a  coating.

-------
     d)   Types of Coating and Lining
     The general characteristics of commonly used industrial
coating of each type of material are categorized in Table 3-2
by the general nature of the binder.  It is important to recognize
that differences in manufacturing processes and additives used to
make coatings may result in considerable differences in lifetime
and performance of coatings of the  same generic type.
     Furthermore, combinations of one or more generic types of
coatings may provide protective systems with a resistance different
and even superior to the separate components.  An example is th-3
addition of silicone to alkyds, or  vinyls  to other  types of
coatings to improve not only water  and temperature  resistance,
but ease of application.  Another instance is  the copolymerization
of epoxy with phenolics that, makes  an air-dry epoxyphenolic with
superior chemical resistance superior to eithfer the phenolic or
epoxy alone.
     The most widely used lining materials today are ployethylene,
chlorinated polyethylene, and  polypropylene.   These materials
have an excellent chemical  resistance to strong acids and- strong
alkalies in concentrated and dilute form,  but  exhibit a poor
resistance to certain  organic  solvents.  They  also  feature
excellent weatherability and durability.
     Phenolics,  vinyls, epoxies,  and polyesters are among the
many organic  coatings  applied  to  metal containers.   The following
are  some of  the most  common materials used:
                                3-3

-------
                                                  TABLE  3-2
                             Properties of Principal  Coating Resins
                     Description
Alkyds         Esterification   of   poly*
               hydric alcohol (glycerol)
               and  a   polybasic   acid
               (phthalic  acid),  modified
               with a drying oil. Hardens
               by  solvent  evaporation
               and oxidation
                                Performance
                          Good  resistance  to at-
                          mosphere    weathering
                          and  moderate  chemical
                          fumes:  not  resistant  to
                          chemical splash and spill-
                          age. Long oil alkyds have
                          good penetration although
                          are slow drying. Short oil
                          alKyds  are  fast  drying.
                          Temperature resistant to
                          225 F.
                                Limitation*
                          Mot chemically  resistant:
                          not  suitable  for  appli-
                          cation over alkaline sur-
                          faces such as fresh con-
                          crete.
                               Comments
                        Long oil alKyds make ex-
                        cellent primers for rusted
                        and  pined   steel  and
                        wooden  surfades. Corro-
                        sion  resistance  is  ade-
                        quate (or  mild  chemical
                        fumes that predominate in
                        many  industrial  areas.
                        Used as interior and exte-
                        rior industrial  and marine
                        finishes.
Vinyl*          Potyvinyt  chloride—poly-
               vinyl  acetate  copolymer
               dissolved in strong polar
               solvent generally a  ke-
               tone. Coating hardens by
               solvent evaporation.
Chlorinated     Formed  by adding  chic-
  rubbers      rine to  unsaturated. iso-
               prene  units.   Resin  is
               dissolved   in  aromatic
               hydrocarbons, esters and
               ketbnes. Haroens by sol-
               vent evaporation.
                          Insoluble in oils, greases.
                          aliphatic,   hydrocarbons
                          and alcohols. Resistant to
                          water and  salt solutions.
                          Not attacked at room tem-
                          perature   by   inorganic
                          acids and alkalis. Fire re-
                          sistant: good abrasion re-
                          sistance.
                          Low moisture permeability
                          and  excellent  resistance
                          to   water.  Resistant  to
                          strong   acids,  alkalis.
                          bleaches, soaps and de-
                          tergents,   mineral   oils.
                          mold  and  mildew.  Good
                          abrasion resistance.
                          Strong polar solvents re-
                          dissolve the vinyl. Initial
                          adhesion poor. Relatively
                          low  thickness  per  cost
                          (1.5-2.0 mils). Some types
                          will not adhere to  bare
                          steel without primer.  Pin-
                          holes in dried film more
                          prevalent than other types.
                          Redissolved in strong sol-
                          vents. Oegarded by  heat
                          (200 F. dry and 140 F.  wet)
                          and  ultraviolet  light,  but
                          can  be stabi zed  to im-
                          prove  these  properties.
                          May be difficult to spray.
                          especially in hot weather.
                         Tough  and flexible:  low
                         toxicity: tasteless:  color-
                         less: fire resistant. Used in
                         potable water  tanks  and
                         sanitary equipment: widely
                         used  industrial  coating.
                         Fire  resistant: 'odorless:
                         tasteless and  non-toxic.
                         Qu;ck crying and excel-
                         lent adhesion to concrete
                         and  steel.. Used in  con-
                         crete and masonry paints,
                         swimming pool coatings.
                         industrial coatings, marine
                         finishes.
Eooxv, amine
  cured
 Epoxy,
  polyamide
  cured
 Epoxy ester
Reaction of active hydro-
gens of aliphatic amines
with epoxy groups of bis-
phenoi-A   epicnlorhydrin
resin. Coating hardens by
solvent  evaporation  and
cures  by  cross linking.
Amine  adduct  eooxies
consist  of  partially  pre-
polymerized  coatings to
which  the  remainder of
the amine is added pnor
to application to complete
the cross linking.
Reactive poiyamide resins
(condensation products of
dimerized fatty acids with
polyamines)   combined
with epoxide groups in the
epoxy   resin.   Coating
hardens by solvent evap-
oration but cures by cross
linking.
 Formed  by  reaction  be-
 tween epoxy resm and un-
 saturated fatty acr.ds (com-
 monly linseed and soya
 oils). Coating hardens by
 solvent  evaporation  and
 oxidation.
Excellent   resistance  to
alkalis, most organic and
inorganic acids, water and
aqueous  salt  solutions.
Solvent  resistance   and
resistance   to   oxidizing
agents is good as long as
not  continually  wetted.
Amine   adducts   have
slightly less chemical and
moisture resistance.
Superior to straight epox-
ies for water resistance.
Excellent adhesion, gloss.
hardness impact and abra-
sion resistance. More flex-
ible and tough than amine
epoxies. Chemical resist-
ance  slightly  less  than
straight epoxies. Temper-
ature  resistance. 225  F.
dry: 150 F. wet.

Least  resistant  of epoxy
family.  Good weather re-
sistance: cr.emical resist-
ance  bener  than  alkycs
and usually  sufficient  to
resist normal atmospnenc
corrosive attack.
Harder  and less  flexible
than other  epoxies  and
intolerant of moisture dur-
ing application. Coating
will chalk on exposure to
ultraviolet  light.  Strong
solvents may lift coatings.
Temperature  resistance:
225 F. dry. 190 F. wet. Will
not cure   below  40 F.;
should   be   topcoated
within 72 hr. to avoid in-
tercoat      delamination.
Maximum   properties re-
quire  about seven  days
cure.
Cross  linking  does  not
occur below 40 F. Maxi-
mum  resistances  gener-
ally require  seven  days
cure at  70  F.
Not  resistant to  strong
chemical fumes, splash or
spillage.  Temoerature re-
sistance  225  F dry.
Good   chemical    and
weather resistance. Best
chemical  resistance   of
epoxy  family.  Excellent
adhesion  to  stesi  and
concrete.  Widely used in
maintenance coatings and
tank linings.
Easier to apply and too-
coat. more flexible and
Dener moisture resistance
than straight apoxies. Ex-
cellent   adhesion   over
steel and  concrete.  A
wioely used industrial and
marine maintenance coat-
ing.  Some formulations
can Be  aooiied to- wet  or
underwater    surfaces.


A  high  quality oil  sase
coating, good compatibil-
ity with most other coating
types. Sasy to aooly. Used
widely 'or atmospheric re-
sistance in chemical envi-
ronments  on  structural
steel, tank exteriors, etc.

-------
                                                   TABLE  3-2
                         Properties of Principal  Coating  Resins
 Epoxy, coal
    tar
  Silicon*
  Zinc rich
  Rre
    retardarrt
       Description
Coal tar mixed with epoxy
mm and cured using ei-
ther an amine  or a poiy-
amide.  Coating hardens
and cures by cross  link-
ing.
Latex  resins  (generally
styrene-butadiene.  poly-
vinyl acetate,  acrylic  or
Wends) are emulsified in a
water vehicle. After appli-
cation  the water  evapo-
rates and the resin parti-
cles coalesce and sinter
to form trie coating.
An unsaturated polyester
(resulting  from •sterifica-
Uon   reaction   between
pofynydric alcohol  and
polybasic acid) is furtn*'-
reacted with diallyl phtha-
late  to  cross  link and
harden.


Composed of the siioxane
bond with various organic
side chains.
      Performance
Excellent  resistance  to
salt and fresh water immer-
sion. Very good acid and
alkali resistance. Solvent
resistance  is  good,  al-
though   immersion   in
strong solvents may leech
the coal tar.
                                         Resistant  to  water,  mild
                                         chemical   fumes   and
                                         weathering.  Good  alkali
                                         resistance.  Latexes  are
                                         compatible   with   most
                                         generic coating types, ei-
                                         ther  as an undercoat  or
                                         topcoat.

                                         Excellent  resistance  to
                                         acids,  organic  solvents
                                         and water, as well as ab-
                                         rasion  and abuse resist-
                                         ance.
Inorganic type consists of
zinc dust in  binder such
as a silicate.  Can be post
or  self  cure,  and  can
he/den either  by curing
compound, water evapora-
tion or hydrolyzation. Or-
ganic  form used vehicles
such  as  epoxies. phen-
oxies or chlorinated rub-
ber. Hardens by chemical
cross  linking or solvent
evaporation.
Ram* retardant use non-
flammable resins and plas-
tieizers with  compounds
(sucn  as bromates) mat
generate   non-flammable
gases, intumescent coat-
ings  bubble  and  swell
upon  heating,  thus in-
sulating   substrate  from
the fire.
As heat resistant coating.
requires catalyzation  and
baking.  With  aluminum
pigments can withstand
1.000 P.; with ceramic frits
up to 1.400 F. As a water
repellant  resinous  sili-
cones in hydrocarbon sol-
vents  are  used  on mas-
onry.    Water   soluble
alkaline  silicone  in water
are used on limestone and
concrete.
Resistant  to  weathering
and mild chemical fume
environments. Zinc in the
coating is  attacked when
pH is  betow 6 or  above
10.5.  Inorganic  type  is
resistant to abrasion  and
temperatures up  to  700 F.
 Can reduce surface flam-
 mability   or  initial  heat
 effects of fire but should
 be used only with conven-
 tional    fire    protection
 methods. Properties are
 generally better the thicker
 the coating.
                                                                         Limitations
Embrittles on exposure to
cold or  ultraviolet  light.
Cold weather abrasion re-
sistance  is poor.  Should
be topcoated within 43 hr.
to avoid intercoat adhe-
sion problems. Will not
cure below 50  F. Black or
dark colors only. Temper-
ature resistance  225 F.
dry, 150 F.  wet.
Must  be  stored   above
freezing. Does not pene-
trate chalky surfaces. Ex-
terior weather and chemi-
cal resistance not as good
as  solvent  or oil  base
coatings.
                          Hard and inflexible. Very
                          short pot life. Swelled and
                          softened by strong alkalis.
                          Minimum thickness  of  S
                          mil required fcr cure.
Heat  resistant silicones
have  moderate cnemicai
      Comments
Good water  resistance.
Thicknesses to 10 mils per
coat  Can 3e applied to
bare  steel or  concrete
without a primer. Low cost
per unit coverage.
Ease  of  application and
cleanup.  No  toxic sol-
vents. Good concrete and
masonry  sealers because
breaking film allows pas-
sage of water vapor. Used
as  interior and  exterior
coatings.


Inert, tile-like appearance.
Good adhesive and cohe-
sive strength.  Hign film
build  pv coat (10 mils).
Used   in  maintenance
coatings  and  linings for
tanks and process equip-
ment

Can be  combined with
other coating types to im-
                                                                   fume resistance- at, lower  prove properties such as
                                                                   temperatures.
Requires clean steel sur-
faces.  More difficult to
apply  than  conventional
coatings. Topcoating may
be difficult especially with
inorganics. Must  be top-
coated in  severs, corro-
sion environments.
                                                                           heat and moisture resist-
                                                                           ance. Water repaiiants are
                                                                           dear, breathing and dura-
                                                                           ble. Used as stack coat-
                                                                           ings  and  above  grade
                                                                           water   repellams.
Eliminates  pitting  corro-
sion.  Despite  limitations.
widely used as industrial
and marine primer. In mild
environments can be used
as one coat system.
May not be-as chemically  Used   to  reduce-- name
resistant as  same type  spread  on  combustible
non-fire retardant coating,  materials and  to  initially
Generally provide only a  insulate  structural  steel
few minutes delay. Some  from heat of  fire.
intumescent coatings are
water  sensitive  and will
not retain  full properties
after prolonged exposure
to weather.
Source:   K.  3.  Tatar,  "Engineers  Guide  to  Protective Coatings",  Chemical Encineerint
            Vol. 79,  No.  27,  Dec.  4,  1972.

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     1.   Amine—cured epoxy coatings are widely used on tan} 3
         and  containers.   They exhibit excellent resistance to
         alkalies,  most organic and inorganic acids, water and
         aqueous salt solutions, and organic solvents.  Their
         main disadvantage is that they tend to chalk and
         deteriorate with prolonged exposure to ultraviolet
         light (i.e., sunlight).

     2.   Polyamide-cured epoxy coatings are superior to ordinary
         epoxies for their water resistance, hardness, impact.and
         abrasion resistance, and adhesive strength.  Their
         chemical resistance is comparable to that of ordinary
         epoxies, and their temperature resistance is higher.

     3.   Epoxy esters are the least resistant of the epoxy
         family.  However, they have good weather and chemical
         resistance and are usually able to resist normal atmos-
         pherics corrosive attacks.  They are not resistant to  strong
         chemical fumes.

     4.   Polyesters are commonly used as maintenance coatings  and
         linings for tanks and process equipment.  They also may
         be used to coat steel containers. They exhibit excellent
         resistance to acids, organic solvents, water, abrasion,
         and improper handling.  They tend, however,  to swell  and
         soften in the presence o£ strong alkalies.

     In evaluating the compatibility of a coating or  lining

material with a specific waste, the permit writer may need to

consult with its manufacturer.  The characteristics of the wiste

must, however, be known, particularly pH and concentration of

reactive chemical constituents, before contacting a coating or

lining manufacturer.

     Some examples of deterioration of liners by  incompatible

wastes include:  polyvinyl chloride by strong polar solvents;

chlorinated rubbers  by strong solvents; polypropylene, polyethylene

and ABS  (acrylonitrile-butadiene-styrene) polymers  by benzene,

carbon tetrachloride, or acetone.

     4.  Specifications

     The hazardous waste  storage  regulations do  not  include a
                                3-11

-------
design standard for containers that prescribes strength, corrosion
resistance, and other factors related to the structure of
containers.  Such a design standard may, however, be instituted
in the future.  Although design standards are not a matter of
regulations, the permit writer is urged to review the corrosion
and compatibility characteristics of proposed waste and container
systems, recommend changes, and make suggestions for improvements.
     The Department of Transportation's (DOT) hazardous materials
regulations (49 CFR 173, 178, and 179) require that all hazardous
materials  (including waste) be transported in containers that
have been designed according to DOT specifications and have been
approved by DOT.  At some future date, EPA may decide to require
that containers used for onsite storage of hazardous waste also
be DOT approved.
     Standard DOT specifications for steel drums are given in
Table 3-3.  Heavier gauge drums are used to store and transport
liquids, whereas lighter (22- to 26-gauge) steel drums are normally
reserved for handling dry bulk materials.  Drums used to store
liquids are generally specified by volume while  those used to
store bulk solids are usually specified by dimensions.
     Containers certified by DOT as returnable are generally
constructed of 18 or lower gauge metal.  Steel drums must also
bear a code indicating  the metal gauge, volume capacity,
manufacturer's name, and date of manufacture.  In general, drums
that are designed to contain liquids are usually of a closed-head
tyoe, with a  2-inch-pipe-thread opening for filling and emptying,
                                3-12

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                                                    TABLE 3-3

                            TYPICAL STEEL-DRUM SPECIFICATIONS FOR HAZARDOUS MATERIALS
Capacity
gal
55
55
30
Inside
diameter
22 1/2
22 1/2
18 1/4
Inside
height
32 11/16
32 11/16
27 5/16
Outside
diameter
23 27/32
23 27/32
19 19/32
Overall
height
34 13/16
34 13/16
29
Steel
gaug.e,
body
16
8
18
Steel
gauge,
cover
16
16
18
Steel
gauge ,
bottom
16
18
18
Steel
gauge ,
ring
12
12
12
Tare
weight
(approx. )
64.5
55.5
37.5
DOT
spec.
17C
17H
17C «.
17H .
Notes*

1.  All dimensions given in inches.  Dimensions are within normal manufacturing tolerances of _+ 1/16 in.
    (^ 1/8 in. on height).

2.  Container weights shown are approximate and may1 vary within the allowable limits Cor manufacturers'
    standard gauge.

3.  On the 55-gal drumr a third rolling hoop, directly below the top rim, gives strength and rigidity to
    meet specifications.

4.  These drums meet Department of Transportation Specifications DOT 17H and DOT 17C for storage and
    shipment of hazardous materials.  They also me'et Rule 40 of the Uni.form Freight Classification, and
    Rule 260 of the National Freight Classification.  DOT 17H drums also comply with ANSI standards.

5»  Table and notes from inland Steel Container Co.

Sources  -Schultz, G.A., "In-Plant Handling of Bulk Material in Packages and Containers", Chemical Engine
         ing Deskbook, Vol» 85, No. ?4, Oct. 30, 1978.
                                                          3-13

-------
and a 3/4-inch-pipe-thread opening for venting.  Dry products are
packed in removable head drums.  The removable cover is fastened
in place with a locking ring tightened by a bolt or toggle lever.
Variations include a friction plug in the head or bug-type cover
with approximately 20 tabs on the cover that can be bent under
the rim of the drum.3
     5.  Advantages and Disadvantages
     See Table 3-4 for a brief overview of the advantages and
disadvantages of using drums for storage of hazardous waste.
                                3-14

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                                   TABLE 3-4
                   ADVANTAGES AND DISADVANTAGES OF DIFFERENT
                              TYPES OF CONTAINERS
                         ADVANTAGES
                                           DISADVANTAGES
STEEL
 1.  Versatile  -  heavy  and  light-
    weight  gauges  available
 2.  Widely  available
 3.  Durable
 4.  Structurally superior  to
    all  other  materials
 5.  Reusable in  some  cases
 6.  If lined,  highly  resistant
	to many wastes	
3."
                                                           If unlined, not for
                                                           corrosive wastes
                                                           Expensive  (coated
                                                           drums mere so)
                                                           Heavier
PLASTICS
 1.   Durable
 2.   Widely available
 3-   Easy to clean
 4.   Reusable in some cases
 5,   For wide range wastes
1.  Not for concentrate1
    organics
2.  Not amendable to ro
    handling
V 1ER
                  1.  Light weight
                  2.  Low cost
                                                        3.
                                                        4.
                                                        5.
                                          Only for dry solids
                                          unless coated
                                          Structurally inferi
                                          to steel/plastic
                                          Le-ss durable
                                          Damage by weather
                                          Not reusable _
IOOD BARRELS/
 KEGS
 1.  -Low cost
1.  Unlined barrels not
    for liquids
2.  Damaged by weather
3.  Not reusable	
BAGS/SACKS
 1.   Lightweight
 2.   Low cost
Questionable for hazard
waste storage:
1.  Low durability
2.  Large volumes bulky
    difficult to handle
3.  Not for liquids,  ig
    able, reactive wast
4.  Not for handling  wi
    mechanical equipmer
5.  Not reusable    	
CARBOYS
 1-  Efficient for small amounts
Glas-s/earthenware  not
recommended for hazardc
waste storage:
1.  Fragility
2.  Not for handling w:
    mechanical equipmer
                                      3-15

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B.  Plastic Containers
     1.  Compatibility
     Plastics are highly resistant to inorganic acids and caustic
materials at various concentrations.  They are, however, degraded
relatively rapidly by organic solvents.  Polythylene and
polypropylene tolerate dilute organic acids, but are not resistant
to concentrated organic acids..  The chemical resistance of some
important plastics is shown in Table 3-5.
     2.  Specifications
     Plastic containers are manufactured in the same sizes and
capacities as steel containers.  Refer to Table 3-3 for these
specifications.
     3.  Advantages and Disadvantages
         See Table 3-4.
C.  Fiber Containers
  •  «^BBBMM*«^^BH-™«^«—•••—H™^»«—^—
     Fiber drums  are  rigid containers commonly used for storing
noncorrosive dry  bulk solids.  The  sidewalls are usually made of
  raft  piles bonded by an  adhesive.  The  top and bottom ends  are
  ade of  fiberboard or steel,  fitted to the cylindrical shell and
  apped or  latched into  place.  Sometimes the walls are lined or
  aated.
     The strength of  a  fiber  drum  is directly  related  to  the
  umber of  plies  in the  walls.  The  strength is measured and  drums
  a'ted  by the burst-strength  test.   Strength rating for the sidewalls
  ange  from 250  to 900 Ib/in.   The  bulk capacity of fiber  drums
  aries from 30  to 400  Ibs.  Various construction  techniques  are
                                3-15

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                         CHEMICAL RESISTANCE OF IMPORTANT PIASTICS
^ ._
1
1
1
1 . J ....'...
1 '
T ioT »2 so4~
1 50% H2 804
1 10% IIC1
I Acids 10% HN03
1 10% Acetic
i ... . .
1
1 ToTlteOif
I Alkalies 50% NaOH
	 NH4 OH
NaCl
FeClj
Salts CuS04
	 NH4 N03 - - - -
Wer \\2~S
JGases Wet C12
Wet'SO^
Gasoline
I Benzene
(Organics CC14
j Acetone
1 	 Jkl X~-.U-.1 ....
r n
Poly-
propylene
poly-
• 'ethylene
'
1
1
... ......
1
............
1
4
1. ....
	
4
CAB*
2
4
1
4
2
•7"
4
4.
1
....
1
4
i .
4
1
4
4
4
. A . .
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Saran (Polyester | ttpoxy
(glass (cjlasn
, 	 L .;„ •___ •_-.!_....
l
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r 	 - r 	 r — rn
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Phenol ic j Fluoro- 1 nated | Poly-
ashestos | carbons | polyether | cartonate
I |Penton (
r i
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             Ratings are £or long-term exposure at antoient temperatures (<100"F)

             1 » Excellent                      * Cellulose acetate butyrate

             2 «» Good                           •*• Acrylonitrile butadiene styrene polymer

             3 » Fair                           o Polyvinyl chloride,  type I

             4 « Poor
After Perry and Chilton's,
Chemical • Engineers ^Handbook.
 Chemical resistance of Saran-lined pipe
   superior to extruded Saran in some
   environments

Refers to general-purpose polyesters.  Special
polyesters have superior resistance, especially
alkalies.

-------
used for specific bulk-handling and liquid-handling requirements
(Table 3-6).
     1.  Compatibility
     As previously stated, fiber containers are normally used for
solids.  If, however, a coating which is liquid resistant is
applied to  the inside of a fiber drum, it can be used to store
liquids.  Liquid-resistant coatings are commonly made from plastics
such as polyethylene.  The compatibilities for plastic-coated
fiber drums would then be determined in the same way as for
plastic containers.
     2-  Coating and Linings
     In order to resist moisture, linings and coatings are often
applied to  fiber drums that are to be used to store hygroscopic
material..   In addition, chemical attack or deterioration due to
weather- can be guarded against by a lining that is non-reactive
with the waste or is durable to the climatic conditions.
     3.  Specifications
     In the discussion of specifications for steel containers, it
was noted that containers for shipping purposes must comply with
DOT standards.  This is true for any type of containers used to
transport hazardous materials.
     DOT fiber drums usually are specified according to inside
diameter, wall thickness, and overall outside height.  Wall con-
struction,  type of ends and any special barrier treatment are also
directed by DOT.  The capacity and construction of s.tandard fiber
drums made  in accordance with DOT specifications are listed in
                               3-18

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                            TABLE  3-6
              Materials and Closures of Fiber Drums
             Basic construction

                 All fiber
                 Fiber sidewalls, wooden heads
                 Fiber sidewalls, metal heads

             Typical top and bottom construction

                 Wood top and bottom with metal seal
                 Metal top and bottom
                 Metal cover with locking bands
                 Recessed fiber ends
                 Metal top. and bottom with friction covers

             General types of closures

                 Held by tape
                 Lever-actuated bands
                 Crimped lids
                 Nails
                 Metal clips
Source:  Schultz, G.A., "In-Plant Handling of Bulk Material in
         Packages and Containers," Chemical Engineering Deskbook,
         Volume 85, No. 24, Oct. 30, 1978.
                               3-19

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Table 3-1.
     4.  Advantages and Disadvantages
         See Table 3-4
D.  Barrels and Kegs
     Barrels are bilged  (bulging) cylindrical containers with
flat heads of equal diameters.  Their rated capacity usually
exceeds  30 gallons and their materials of construction may be low-
carbon steel, stainless  steel, or a variety of woods, depending
on  their use.
     They are generally  divided  into  two classes:   (1) non-
watertight slack barrels with  paper  liners  to prevent sifting,
which  are usually used  for dry materials and  (2)  tight barrels
used to  ship liquids.
      1.   Compatibility
      If  barrels are made of wood and are  unlined, hazardous
 liquids  should not be stored in them.  This is  due to the fact
 that wood is relatively pervious to most liquids.  For the sane
 reason,  dry materials that must remain dry should not be stored
 outdoors  in wooden barrels.  Barrels and kegs,  however,  are not
 often use for the storage of hazardous waste.
      2.   Coatings and Linings
      Barrels are  frequently coated with paraffin  in order to make
  them watertight.  Noncorrosive or mildly corrosive liquids can
  then  be stored  in barrels with  such  a coating.   Other lining
  materials,  such as  blends of  wax and polyethylene, also  provide
  greater resistance  to  corrosive materials.
                                 3-20

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     3.  Specifications
     For barrels constructed of stainless steel, the type of
steel used in the shell and head sheets is identified by an
American Iron and Steel Institute (AISI) type number.  The AISI
sets design specifications and standards for iron and steel
storage vessels including tanks and containers.  AISI designations
are related in a limited way to DOT specifications;  For example,
the type of manufacture of a stainless steel container is shown
by an AISI number, and may be included as a part of the DOT
specifications.  The letters HT (heat treatment) following the
steel designation indicate the containers that have been subjected
to stress relieving or heat treatment during manufacture.
     Barrels and kegs that are approved by DOT have been constructed
in accordance with standards related to:  (1) rated capacity;
(2) composition of materials; (3J construction of container; (4)
dimension of container; (5) closures; (6) markings; and (7) leakage
tests.
S.  Bags and Sacks**
     Frequently, paper bags are used for packaging pesticides,
and plastic bags are used as liners in rigid containers.  Bags
and sacks are also commonly manufactured from transparent films
such as cellophane/ polyethylene, polypropylene, woven paper and
plastic mesh; and from various textiles.  Custom paper bags are
also made with special barrier sheets (e.g., foil or polyethylene)
in almost any size desired to meet special requirements.  Completely
siftproof and moisture proof construction ara also available.  Two
                               3-21

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bag designs are commonly used:
     1)  Valve design - this has both ends closed during fabri-
         cation.  The filling is done through a small opening
         (valve) in one corner of the bag.
     2)  Open-mouth design - this has one end closed ^at the
         factory. The other end is closed after filling.
     Bags and sacks are sometimes used to store hazardous waste.
However, due  to their low durability and  lack of strength relative
to, for example, steel or plastic containers, the permit writer
should  carefully scrutinize  the design of any bag or  sack pro-
posed for use in storage of hazardous waste as well as  the handling
methods  proposed.  Judgment roust be  used  to consider  the situation
as a whole^
     1.  Compatibility
     Since  bags  and  sacks  are manufactured  in  a  wide  variety of
materials,  a  given waste is probably compatible with  some type of
bag  or sack in  most  cases.   Off-specification  chemical products
that become wastes may be  stored in  their original  paper or
plastic packing only  if  the  storage  conditions  are  compatible
with the packing.
     It should  be  noted  that plastic bags should be especially
guarded against high  ambient  tenperatures to prevent  rapid
deterioration.
      2.  Specifications
     Table 3-1  gives specifications of standard-size bags  in
accordance  with the Uniform Freight Classification Committee.
      DOT also gives specifications for bags and sacks  in 49 CFR 1/8
                                3-22

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F.  Carboys
     A carboy is a container made of glass, earthenware, plastic
or metal having a capacity of five to thirteen gallons.  They are
used principally for carrying corrosive liquids, chemicals,
distilled spirits, and similar materials.  Carboys are usually
encased in a rigid protective outer container.6
     Glass or earthenware carboys are generally not recommended
for the storage of hazardous waste because they may break.  When
faced with a proposal to use carboys, the permit writer is advised
to heed the same cautions as when confronted with a plan to store
hazardous waste in bags or sacks.
     1.  Compatibility
     Generally,, glass carboys may be used  to  store an  off-
specification batch of a substance.
     Carboys made of polyethylene are  incompatible with wastes
containing benzene, acetone, carbon tetrachloride, or  alcohol.
     2.  Specifications
     Carboys designed  in accordance with DOT  specifications
include the  following:   (1   name and year  of  manufacture marked
on  the  outside  of  the  container;  (2) acid-proof  stoppers or other
devices, with gaskets  securely  fastened;  (3)  venting devices,
when necessary,  to  prevent  internal pressures in excess of 3  psig
at  130F;  (4) wooden  boxes completely enclosing  the body of the
carboy, or wooden  boxes  completely  enclosing  the body  and  neck,
carrying  cleats;  (5)  specified  shock tests;  and  (6)  liquid-tight
cap of  suitable plastic  or  other material  or  liquid-tight  cap up
                                3-23

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to the venting pressure when such venting is prescribed.
G.  Containers for Storing Ignitable and Combustible Liquids
     Ignitable and combustible liquid wastes should 5e stored in
metal containers that meet the requirements of Chapter I,  Title 49,
of the Code of Federal Regulations (DOT regulations), or National
Fire Protection Association, NFPA-386, Standards for Portable
Shipping Tanks.  In order  to comply with these standards/ the
applicant must use containers with one or more devices installed
that have sufficient  emergency venting capacity to  lunit internal
pressure to 5 psig or 30 percent of the bursting pressure cf the
container, whichever  is greater under fire  exposure condi-.ions.3
At least one pressure-activated vent having a minimun capacity of
600 cubic feet  of  free air per hour  (14.7 atms and 6 OF ) must be
used.  ~It should be set to  open at not less than  5 psig.  If
fusible  vents  are  used,  they  should  be activated  by  elements that
operate  at a temperature not exceeding 3-0OF   When used for
paints,  drying  oils,  and  similar  materials, where the pressure-
activated vent  can become  plugged, fusible  vents  or vents that
soften to  failure  at a maximum of 300F under  fire exposure, may
be used  to meet the  emergency venting requirement.8
                                3-24

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                            CHAPTER 4
                     MANAGEMENT OF CONTAINERS
A.  Introduction
     This chapter deals with the management of containers and
specific relevant issues that, in most cases, have been addressed
in the regulations.  These areas of concern, along with the cited
regulations, are:  condition of containers (§264.171); compatibility
of waste with containers (S264.172); incompatible wastes (§264.177);
ignitable or reactive waste (§264.176); and secondary containment
(§264.175).
     In addition, container-handling techniques, current storage
practices, facility design considerations and operating procedures,
and information about liners is discussed.
B.  Current Storage Practices
     As described in Chapter 3, few containers are, in general,
designed specifically for the storage of hazardous waste.  Also,
management of hazardous waste storage sites  is not a well-developed
art.  Therefore, much of the content of this chapter borrows from
functions relevant to storage or various materials in containers
(e.g., warehousing techniques), where extrapolation of good
practices to hazardous waste management is considered desirable.
The applicability of several types of containers to hazardous
waste management was discussed in Chapter 3.
     Containers used to store hazardous waste can be efficiently
handled in a few different ways in order to minimize the possibility
of ruptures and leaks and make effective use of space.  These methods
                               4-1

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are described below.
     Storage practices discussed in this section pertain to both
indoor and outdoor facilities.  It should be noted that in addition
to the storage practices where combustible or flammable wastes
are stored, the standards set forth in NFPA 303 for storage of
flammable and combustible liquids should be complied with.  These
standards specify requirements for:  (1) quantities and freight
limits (2) separation and aisles, (3) building design factors
related to stacking drums, when containers are stored indoors,'and
(4) fire protection.
     1.  Stacking in Pallets and on Plywood Sheets
     Drums, kegs, and pails of various sizes are frequently stored
on pallets.  A pallet is a flat, portable platform properly
constructed to sustain loading and handling by mechanical equipment,
A standard pallet dimension is 40 by 45 inches, which allows for
sufficient loading and fits into trailers and freight cars.
Other sizes are also available.  Expendable pallets are made of
paperboard or foam plastic and can also be manufactured from foam
blocks glued to a corrugated fiber sheet.  Wood pallets are made
from a variety of woods; solid plastic pallets are also available.
The latter have the advantages of not splintering and of requiring
less maintenance.  The bearing load of the cheapest pallet is
about 500 Ibs., while the sturdier pallets can carry up to 10,000
Ibs.  The Material Handling Association issues specifications for
pallets.
     Depending upon the type of container used, the characteristics
                               4-2

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of the waste stored, and the amount of space available, the owner
or operator can place containers in single rows on a pallet or
stack them.  For example, if space is tight and containers amenable
to stacking are used, stacking on pallets can be an efficient
usage of space.  Another advantage of pallets is that they hold
containers a few inches off the base of the containment area and
may be effective in preventing standing liquids (accumulated
precipitation, leaked or spilled waste, or both) from coming into
direct contact with the containers, thereby accelerating corrosion.
Use of pallets between containers also facilitates later movement
of the containers.
     Figure 4-1 illustrates an automatic pallet dispenser.  Also
shown are standard  loading patterns that make efficient use of
pallet space.
     Plywood sheets are also frequently used instead of pallets.
Containers are stacked vertically in order to facilitate handling
and storage.
     It  is important both for purposes of safety and to prevent
possible rupture or weakening of bottom containers that the
containers not be stacked too high.  Factors to consider in
determining the maximum height of a stack include:   (1) type
of containers;  (2)  condition of containers;  (3) maximum lift of
fork-lift used to handle the containers;  (4) type of fork-truck
attachments available;  (5) use of pallets or plywood sheets.  All
of. these factors must  be judged together  in ascertaining a maximum
height  for stacked  containers or,  indeed, whether containers
                                4-3

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                                       FIGURE  4-1
                         Automatic Container Palletizing
                                                           Drum* (S5 gallon)   Drums 130 gallon)
      L Cotnpact automatic loadw and pallet d«p*n»r
                          ana pain
                                                          b. Standard loading patterns for drums,
                                                            and paili makt trfidmT UM of ssao
Source:   Perry and Chilton, Chemical Engineer's  Handbook,  McGraw-Hill,  5th Ed.,
          1973, Ch. 7.

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should be stacked at all.  This is an area where the permit
writer's judgment must be used, giving consideration to the
individual facility and  the wastes to be stored.  Some containers
may, for example, be too unwieldy to stack.  It may not be prudent
to stack drums of highly hazardous waste.  Regardless of the type
of container used or the degree of hazard of the waste, containers
of hazardous waste probably should not be stacked very high;
exactly how high is a matter of negotiation between the permit
writer and the permit applicant.
     For containers storing ignitable/flammable or combustible
materials, the NFPA standards  shown in Table 4—1 should be applied.
Classes IA, tB, and 1C apply to flammable  liquids.  Classes II
and III apply  to combustible liquids.  Flammable and combustible
liquids are defined in NFPA 30,8  the Flammable  and Combustible
Liquids Code.  Stack heights for  groups  of materials are given.
When  two or more classes of materials are  stored  in the same
stack, the most conservative figure should be observed to maximize
safety.
      2.  Racks
      Usually  built of  tubular  steel, racks are  structures on
which containers may be  stored either vertically or horizontally.
The racks may  be coated  with a variety of  corrosion-resistant
materials.
      Racks  can be used  to  store either a single row of containers
or  a  double row  (see  the NFPA  publication  number  231C, titled
 "Rack Storage  of Materials").9
                                4-5

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                            TABLE  4-1
               Outdoor Liquid Storage  in  Containers
Class

1A
IB
1C
II
III
Container ( <60 gal.)
Storage
Max per Pile
Gallons
1,100
2,200
4,400
3,800
22,000
Height
(ft)
10
12
12
12
18
Container (>60 gal.)
Storage
Max per Pile
Gallons
2,200
4,400
8,800
17,600
44,000
Height
(ft)
7
14
14
14
14
Distance
Between
Piles or
Racks
(ft)
5'
5
5
5
5
Source:  "Flammable and Combustible Liquids Code,  1981  ,  National
         Fire Protection Association, ANSI/NFPA 30,  Boston,  MA.
                               4-6

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     3.  Equipment



     Many types of equipment are used in container handling.



This includes fork-lift trucks and front-end loaders equipped



with drum-cradles or drum-grabbers.



     4.  Aisle Space



     Another area of concern in proper drum storage is adequate



aisle space.  The owner or operator of a facility must maintain



sufficient aisle space to allow the unobstructed movement of



personnel, fire protection equipment, spill control equipment,



and decontamination equipment to any area of facility operation



in an emergency unless it can be demonstrated to the Regional



Administrator that aisle space is not needed for any of these



purposes  (40 CFR 264.35, Subpart C-Preparedness and Prevention).



The exact amount of aisle space, how many aisles and their



placement in the storage area, is another judgment.  The amount



of aisle  space proposed by the permit applicant must be considered



and its adequacy evaluated based on the facility plan as a whole.



     Some guidance as to approximate aisle space can be taken



from NFFPA recommendations.  It should be noted, however, that,



with the  exception of the specific materials and/or situations



that NFPA is considering in each standard,- the information is to



be considered guidance only and should not necessarily be applied



to storage of other types of hazardous materials.  The purpose in



presenting "the NFPA data is to give examples.  The NFPA data is



based on  separation of materials in order to prevent hazardous



situations, as well as to allow access.  NFPA 30s specifies that
                               4-7

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palletized or stacked containers of flammable or combustible
materials should be arranged so that rows of drums are separated
from each other by a minimum aisle of 4 feet.  Aisles should be
provided so that no container is more than 12 feet from an aisle.
Where liquids are stored on racks, a minimum 4-foot aisle is to be
provided between adjacent rows or racks and adjacent storage of
liquids.  Main aisles should be a minimum of 8 feet wide,.
C.  Condition of Containers
     The regulation (§264.171) specifies that if a container
holding hazardous waste is not in good condition, or if it begins
to leak, the waste must be transferred to a container that is in
good condition or the waste must be managed in some other way that
complies with the requirements of Part 264.
     "Good condition" is a matter of judgment—a container not in
"good condition" would be evidenced by conditions such as severe
rusting, leaks, ruptures, and structural defects (such as excessive
bulges or dents).  The permit writer must use his own discretion
in evaluating types of containers and the conditions given by the
permit applicant.
     Design of containers is discussed in Chapter 3.  The design
affects a container's ability to withstand weathering, handling,
and containerization of wastes for a long period of time.  Hence,
design indirectly affects the container condition.
     Other factors to consider in assessing a permit applicant's
storage management plan with respect to the potential effect on
the integrity of containers are discussed below.
                               4-8

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     1.   Climatic Conditions
     The physical environment in which containers are stored
affects  their durability.
     Corrosion resistance and other physical aspects of a container
can be adversely affected by improper storage.  For instance,
high humidity may lead to reduced corrosion resistance, particularly
in the case of indoor storage.  High temperatures may also
accelerate the corrosion of steel drums.
     The ability of a coating to withstand deterioration is also
affected by the environmental conditions of the storage area.
Although many frequently used coatings are resistant to weathering,
problems can develop in cetain situations.  For example, some
kinds of chlorinated rubber are degraded by heat, particularly
when wet, and by ultraviolet light.  Coal-tar epoxies become brittle
when exposed either to cold or to ultraviolet light.  Anine-cured
epoxy coatings, widely used in tanks and containers, deteriorate
upon exposure to light-  Containers with any of these types of
coatings should, consequently, not be stored in sunlight.
     2.   Markings
     Containers that have been transported to the facility must
be marked according to DOT regulations.  Flammable and combustible
materials may be labelled according to NFPA specifications.
These markings often provide information that may facilitate safe
handling and prevent situations that could lead to premature
failure of the containers.
     Markings may be placed on labels or tags or stanciled on drums.

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Information such as  the type of hazardous waste stored and the
manifest identification number is generally given.  Caution
labels, placards, and/or warnings (e.g., ooison, explosives,
corrosives) may be attached as required by- DOT standards.
Flammable liquids may  also include the following marking in
accordance with NFPA 30: "FLAMMABLE - KEEP FIRE AWAY."8
     Palletized loads  of containers require the same mark-ings and
identifications as individual drums.
     3.  Dating of Containers
     A system of dating the age of drums, while not required,
would allow the owner/operator to anticipate when drums may need
to be replaced.  Drum  dating, coupled with knowledge of the
deteriorative effects  of the waste, can provide a more accurate
schedule of drum deterioration and subsequent  replacement.  The
dates may be marked  on the drum or placed on a schematic of the
drum storage area*
     4.  Steps to Take If  a Container Is Not in Good Condition
     The permit applicant  should have plans for removing containers
from service that are  no longer  in "good condition."  If a
container  is leaking,  if it  is suspected that  a failure may be
imminent due to rusting or structural defects, or  if  it  is at  the
end of  its useful storage  life,  the contents of the container
should  be  transferred  to a serviceable  container.  When  a leak  is
discovered and a suitable  replacement drum cannot  be  found
immediately, it may  be acceptable  for the leaky container to  be
placed  in  an overpack  (a recovered drum  that is large enough  to  hold
                                4-10

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the first container and its contents) .  The holes are then filled
with absorbent material.
     5.  Recovery and Reuse of Containers
     Containers constructed of metal are commonly reused, recycled,
or reconditioned.  This minimizes disposal of hazardous wastes
and maximizes resources.   For a detailed report on container
reconditioning/ consult "Barrel and Drum Reconditioning Industry
Status Profile.*10
     If  a permit  applicant wishes  to use reconditioned or recycled
drums, the permit writer  should make a careful review to ensure
that  the reconditioned, drums  will  be adequate  to  contain the waste.
D.  Compatibility of  Waste with Container  (§264.172)
     The container  and any linings  must  be compatible with  the
waste  stored  in  the container.   For a  discussion  of  compatibility
of waste see  EPA's  manual titled "Compatibility of Wastes  in Haz-
ardous Waste  Management Facilities."2
E.   Incompatible Wastes (§264.177)
      The facility standards for handling incompatible  wastes
require  that (a) incompatible wastes trust  not  be  stored  together
 in the same container, (b) hazardous waste must not be  placed  in
an unwashed container that previously held an  incompatible  waste
 or material,  and (c)  hazardous wastes stored in containers must
be separated from-other incompatible wastes or materials or
 protected from them  by a  dike, herm, wall, or other'device.
       The owner or operator can eliminate or at least minimize
 mistakes owing to incompatibility by conducting proper waste

                                4-11

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analyses, keeping accurate  records, and handling  the waste
carefully.
     Separate spill  and  run-off  collection  sunps  are also
advisable in storage areas  for incompatible wastes.  The wastes
discharged  from  collection  sumps should be  segregated  from other
wastes that are  incompatible.  Site or floor plans of  the facility
or piping and instrumentation  diagrams (P&IDs)  showing location
of collection sunps  should  be  furnished by  the  facility owner or
operator.
F-  Storage of Ignitable or Reactive  Waste  (§264.176)
     Containers  of ignitable or  reactive  wastes must be located
at least 15 meters (50  ft.) from the  facility  property line.
Facility owners  or operators should also  take  precautions to
prevent accidental  ignition or reaction of  these  wastes by
separating and protecting them from open  flames,  smoking, cutting
and welding, contact with hot  surfaces, frictional  heat, spontaneous
ignition sources (e.g.,  from heat-producing chemical reactions),
and radiant heat.  NFPA  standards for flammable and combustible
materials shoud  be applied  when  storing ignitable or reactive waste.
G.  Containment  (§264.175)
     In storage  areas  where a  secondary containment system is
required, the system must be sufficiently impervious that it
will hold collected  material until detection and  removal.  The
containment system must  also drain efficiently  so that  standing
liquid will not  remain  on the  base for extended periods of time
subsequent  to leakage or precipitation, and containers  mist be
protected from accumulated  liquids.   The  containment systam must
                               4-12

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be large enough to hold 10 percent of the volume of the containers
or the volume of the largest containers, whichever is greater.
Run-on must be prevented unless the containment system is large
enough to accommodate  it, and collected material must be removed
from the collection area as soon as necessary in order to prevent
overflow.
     Storage areas that store containers holding only wastes  that
do not contain free liquids are not required to have a secondary
containment system, provided that  (1) the storage araa is sloped or
is otherwise designed  and operated to drain and remove liquid
resulting from precipitation or  (2) the containers are elevated
or are otherwise protected from contact with accumulated liquid
(J254.t75(O).
     Some of the general factors to be considered in designing
and evaluating a containment system are discussed below:
     1.  Properties of the Waste Stored
     Some consideration should be  given to compatibility of the
type of wastes stored  with the liner or base to be used.  For
example, if highly corrosive wastes are to be stored, a very
durable, corrosion-resistant base  should be installed.
     2.  Number of Containers
     The maximum number of containers, volume of waste, stack
height, aisle space, and size of the storage aree within the
containment area should be considered.
     3.  Container Capacity
     The secondary containment system must be designed to allow
                                4-13

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for accumulation of precipitation.  Storm intensity in the araa
where the facility is located should be used to determine maximum
precipitation.  The flow velocity  in the drainage system (i.e.,
drainage channel or pipe) and the  bottom and side slopes of the
containment structure must also be considered.  The design
specifications of the facility will indicate if the capacity of
the containment system will equal  or exceed 10 percent of the
total capacity of the containers in the drainage area.
     Storm frequency and intensity (expressed in inches) data for
a given area are published by the  U.S. National Weather Service.
Data can also be obtained from the National Climatic Center in
Ashville, North Carolina.  Run-off volume is commonly calculated
as a fraction of rainfall, which is known as the run-off coefficient,
Capacity of the containment system can be calculated from these
sources.  (Refer to the Soil Conservation Service handbook for a
detailed discussion of these calculations.)11
     The storage area should be graded in a manner to divert
spills away from buildings or other enclosures or should be
surrounded by a curb to contain spills.  When curbs are used,

provisions must be made for draining accumulated ground or rain
water, or spills of liquids.  Drains must discharge at a safe
location and be accessible to operation under fire conditions.
     4.  Adequacy of the Containment System
     Section 264.175 requires that the containment system Dase
must be  "free of cracks or gaps and .  . . sufficiently impervious

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to contain leaks, spills,  and  accumulated rainfall until the
collected material is detected and removed."  since no -material
is totally impervious,  the permit writer must determine if the
material proposed for the  base by the permit applicant is adequate
to hold waste or precipitation until  it can be detected and removed.
     Waste migration through a base or liner material can be
calculated based on  the permeability  of the base material and the
hydraulic impact load of the waste.   formulas and a detailed
discussion of how to perform  the calculation can be found in EPA's
manual on Landfill and  Surface Impoundment Performance Evaluation. *2
     If the permit vvriter  can  be assured that the base of the
containment system will be dry most of the time, there would be a
negligible hydraulic impact load on the base and, therefore,
minimal waste migration through  the base.  If all of  the other
standards for containers in Subpart I are met, the base should
remain dry most of the  time.   For example, if the permit applicant
provides a design showing  that (a) spilled or leaked waste or
precipitation will remain  on  the base for short periods only (i.e.,
because the base is sloped  to provide drainage or accumulated
liquids are pumped out  of  the  containment area shortly after
being detected); (b) that  waste will  not contaminate the outside
of the containers and,  therefore, generate leachate after precip-
itation; or (c) that the storage area will be inspected weekly
and that  the inspector  will be able to visually assess the condition
of all containers and that any spills or leaks will be quickly
                                4-15

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cleaned up, then the thickness of the base should not be dependent
on waste migration..  It should, rather, be based on the ability
of the base to adequately support the weight of the drums.  In
order to make this type of assessment, the permit application
should provide the permit writer with the engineering data used
to contruet the base.
     The permit writer may decide,  however, that other storage
management plans or designs  in which accumulated liquids would
remain on the base for  longer periods of  time, or in which it
might not be possible to closely monitor  each container, might
be acceptable-  In these cases,  the permit applicant must
demonstrate that the waste will  be  contained by the base  for the
life of  the facility.  ,To do this,  the permit applicant needs  to
submit calculations  showing  time for waste to leak  through tne
base, as mentioned previously-
     5.  Auxiliary structures
     The design o'f  the  containment system may  include  curbs or
dikes  surrounding  the  storage area and  in areas between  incompatible
wastes.  Curbs  or  dikes may, in some  cases,  be  an  integral part
of  the  design  for  containment capacity  and  is one means  of
preventing run-on.   Ditches or trenches  surrounding the  perimeter
of  the  storage  area  may also be used  to  prevent run-on.
     The Subpart  I regulations do not require  that  these barriers
 be  impervious  to  the waste being stored;  however,  the permit
 writer will probably want to be assured that they  have been
 constructed of a reaonably impermeable material.   Curbs  may
                                4-16

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or the storage area may also be used to prevent run-on.
     The Subpart I regulations do hot require that these barriers
be impervious to the waste being  stored; however, the permit
writer will probably want to be assured that they have been
constructed of a reaonab-ly impermeable material.  Curbs may
typically be made of concrete and are sometimes coated with an
impermeable material such  as  epoxy.  Berms  and  ditches may be
lined with a synthetic membrance  or may be  made of a natural
liner material such as  clay.   (For more  information on  liners see
Lining of Waste Impoundment and Disposal Facilties.13)
     Generally, however, materials such as  concrete and asphalt
are  utilized  in storage areas for containers.   Liners may be used
in placed of, or in addition  to,  concrete and asphalt.
     The  height of curbs,  walls,  or dikes  is important  not only
for  containment of spilled or leaked waste  and  accumulated
precipitation, but  in  the  prevention of run-on  into  the storage
area.   Run-on can be diverted by  proper  grading.   In evaluating
 the height and  capacity of the containment structure,  the  permit
 writer  should take  into consideration  storm intensity  and  frequency
 data in the area  of  the facility and capacity of the leachate
 and  run-off collection system.  If a containment system is not
 capable of adequately  discharging run-off  from the containment
 area during a severe  storm,  the containment structure  must provide
 sufficient holding capacity to prevent overflow.  In addition,
 the containment system design should allow for  a reasonable
 safety factor beyond the minimum height of  the barrier.

                                4-17

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These include drains that lead  into a sump under the base; a
sloped base that directs liquids into a sump; elevation of
containers on pallets or racks  and a plan to pump accumulated
liquids out of the storage area; and a roof over the container
area.  The last design, it should be noted, would only protect
against contact of containers with precipitation.  Discharged
waste would have to be removed  in some other manner.
     Where a drainage sump is provided, the permit writer should
ascertain if the sump, pump, and discharge piping are of sufficient
capacity and if the materials of construction are compatible with
the wastewater.  The permit applicant should provide sump, pump,
and piping specifications and diagrams for review.
     7.  Ability to Clean Up and Remove Spills
     The permit writer must be  assured that the facility owner or
operator has adequate plans and equipment for cleaning up and/or
removing any spilled or leaked  waste in the containment area.  A
contingency plan should be included in the permit application for
this purpose.
                               4-18

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                            CHAPTER 5
               INSPECTIONS OF CONTAINER FACILITIES

     Regular inspections of container storage areas is a major
management tool for preventing discharge of hazardous waste into
the environment.  The  regulations require that containers, container
storage areas, and containment systems be inspected weekly (§264.174)
     In a container storage area/ inspections can only be expected
to reveal obvious problems and give the facility owner or operator
a general idea of the  type and rate of  long-term deterioration of
containers.  Because corrosion inside a container cannot be
detected by visual  inspection of  a container (external corrosion
would be evident) and  because sudden or accidental damages
occur  (e.g., ruptures  or  leaks),  the  facility owner or operator
should expect to find  failures when he make inspections.
Inspections must, of course, be  combined with remedial action.
     The permit writer should review  the inspection plan as well as
proposed emergency measures  in  the permit application.
     Ihis chapter discusses inspection techniques and evaluation
of  inspection plans.
A.  Containers
     Corrosion  of metal containers  is the major  cause of  leaks
at  container storage facilities.  To  some degree, corrosion of
metal  is  a  natural  phenomenon.   With  time,  all metals corrode to
a certain extent.   Since  it  is an aging process, the management
of  the site should  be  planned with  the idea that containers
susceptible  to  corrosion  will deteriorate over time and,  hence,

                                5-1

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require replacement.
     Corrosion may be accelerated when corrosive wastes are stored
or when containers are exposed to weather conditions.  (See
Chapter 4 for a discussion of the impact of climatic conditions
on containers.)
     The information presented in this chapter should be regarded
as a general overview of the subject of corrosion.  The permit
writer should refer to the guidance manual on hazardous wastes
compatibility2 for more information on corrosion.
     A visual maintenance check  is the simplest way to detect
any corroded, leaking, or structurally defective containers.
Since corroded or deteriorating  containers will eventually lead
to leakage, the detection and packing of faulty containers is
integral to spill and" leak prevention.
     Various forms of corrosion  produce different visual results.
Some of these corrosion types and signs to be alert  for are
outlined below.
     1.  Forms of Corrosion14
     Corrosion is most often confined to the metal surface of a
container.  The complete corrosion reaction is divided into an
anodic portion and a cathodic portion, occurring simultaneously
at discrete points on metallic surfaces.  Local cells created
either on a single metallic surface  (because of local point-to-
point differences on the surface) or between dissimilar metals
may generate the  flow of electricity from the anodic to the
cathodic areas.   Bimetallic cells derive their driving voltage
                                5-2

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from the interaction of  two different metals.  Bimetallic cells

are created by the connection of two dissimilar metals.

     Corrosion may be uniform or localized.  Its product may be

easily recognizable, as  the reddish-brown particles in the case of

iron oxide.  The various forms of  corrosion are identified below

and are illustrated in Figure 5-1.

     •  Uniform Corrosion,  aniform  attack over large  areas is
        the most common  form of corrosion.  Proper selection of
        containers and linings or  coatings can significantly
        reduce corrosive  action.   If corrosion causes discoloration
        in a particular  case, uniform corrosion may be more easily
        spotted than localized attacks on metal containers.

     0  Crevice Corrosion.  Various  changes in the area surrounding
        the crevices of  a container  (usually at the seams), such
        as a deficiency  of  oxygen  or changes in acidity, may cause
        corrosion*  Corrosion also commonly occurs in crevices
        that contain, for example, dirt  deposits, corrosion
        products,, or scratches in  the paint film.  Consequently,
        particular attention  should  be paid to seams when
        inspections are  carried out.

     0  pitting Corrosion.  Pitting  corrosion  is caused by the
        formation of holes  in an otherwise relatively  unattacked
        surface.  The holes can  have various shapes, with  the
        shape often being responsible for continued corrosion.
        Pitting is generally  a slow  process (taking  several months
        or years to become  visible).  The  small size of a pit and
        the small amount of metal  dissolved make detection
        difficult in the early stages.   Selection of containers
        known to be resistant to pitting in .a  given  environment
        is usually the best protection against this problem.

     0  Exfoliation and  Selective  Leaching.  Exfoliation  is
        corrosion that spreads below the surface.  It  differs
        from pitting  in  that  the attack  has a  laminated appearance.
        Whole layers of  material are eaten away and  the attack is
        usually marked  by a flaky  and sometimes  blistered  surface.
        Exfoliation and  selective  leaching occur mostly on steel-
        aluminum alloys. Consequently,'  special  attention  should
        be given to container bottoms.

     a  Intergranular  Corrosion.   In a  severe  case of  intergranular
        corrosion,  the  surface of  the metal container  will appear
                                5-3

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                                    FIGURE  5-1

                               TTPSS  OF CORROSION
 LOCALIZED corrosion is more aifficuit to control man uniform attack
Source:  M.  Hawthorne,  "Understanding Corrosion", Ch^lca! Engineering, Vol.  79,
         No. 27, Dec-  4, 1972.

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        rough and feel "sugary."

     0  Stress-corrosion Cracking.  Stress-corrosion cracking is
        often identified by the presence of crack branching.
        A metal container that fails because of stress-corrosion
        cracking will usually have visible corrosion products on
        the fracture surface.  Stacking containers may exacerbate
        this form of corrosion.  Therefore visual inspection
        should include checking of stack heights.

     *  Galvanic Corrosion.  Galvanic corrosion is the excess
        corrosion rate that is associated with electrons flowing
        from an anode to a cathode in the same environment.
        Galvanic corrosion is an important consequence of" coupling
        two metals widely separated in the galvanic series.   The
        result is an accelerated attack on the more active metal.
        Therefore visual inspection should include the checking
        of the types of containers stored next to each other, as
        well as how they are stored.

     Where corrosion or defects are anticipated and visual inspec-

tion confirms the expectation, the contents must be transferred to

a container that is in good condition.

     Although inspections of containers are required weekly, under

some circumstances certain containers should be inspected more.

frequently.  Reasons for additional inspections include: results

of previous inspections, contraction and potential for corrosion

of the container, properties and corrosion rates of the wastes,

potential risk of air or water pollution, and safety  to personnel.

In addition, containers holding new wastes that have  not previously

been stored at the facility may warrant more frequent inspections

until adequate data on the containers  performance have been

collected.

B.  Container Storage Areas and the Containment System

     1.  Visual Inspection

     Curbs or dikes can be examined for deterioration and container;
                               5-5

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can be moved from the  base periodically  in order to detect any
cracks or holes in the-base.   (Moving the containers probably
provides a better than usual  inspection  of the drums as well.)
Vegetation surrounding dikes should be examined for any changes
that may be caused by  leachate or  overflew of spilled waste; a
change might be either more luxuriant growth or dying vegetation.
Further/ the base should  be checked  to see that containers are
not standing in liquids or, if  the containment design includes a
sloped base or drains, that liquids  appear to run off or drain
properly.  Subsequent  to  a rainfall, leakage, or spillage, systems
designed to remove liquids should  be examined to determine if
they are functioning properly.  Drains should be checked, for
example, to see that they are  not  clogged.
     2,   Testing
     Auxiliary features such  as drainage systems, simps, and pumps
should be tested periodically.  Emergency response equipment such
as alarms and communication systems  should also be tested.
     As with containers,  certain situations or conditions may
warrant more frequent  inspection of  some areas.  Situations where
drums are subject to the  elements, such  as outdoor storage, and
sections of the containment area that are deteriorating more
rapidly than other parts  may  justify more frequent inspections.
C.  Evaluation of an Inspection Plan
     An inspection plan should  be comprised of a checklist of
equipment and items to be inspected, directions for the method of
inspection, and a separate schedule for  those areas to be inspected
                                5-6

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more frequently than  specified  in the regulations.  Unlike the design
evaluation of a facility, whi-ch  tends to be conceptual, the
inspection evaluation is necessary  to make certain that the
owner/operator performs all mechanical, visual, or other routine
or special inspections.  As long as  the containers are inspected
and judged to be in good condition,  the inspection plan may be
viewed as satisfactory.  The  inspection plan should specifically
note that the owner/operator  is  responsible for the detection of
corrosion, cracks, leaks, bulges, buckles, and other signs of
deterioration.  The inspection  plan  should also indicate that che
owner/operator will use industrially acceptable practices to
locate any faulty items and make necessary repairs as soon as
possible.  Remedial procedures  for  faulty containers, spills, and
leaks should be induced in the  plan.  The plan may also provide
for changes in operational procedures to ensure the safe operation
of the facility.
     The evaluation of an inspection plan should  include a review
of employees  qualifications  to  conduct inspections, procedures
for responding to improper operations observed during inspections,
recordkeeping procedures, the inspection log, and personnel
training plan.  Some  key items  to be inspected are listed in
Table 5-1.
                               5-7

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                            TABLE 5-1
           CONTAINER STORAGE FACILITY INSPECTION POINTS

I.   Containers
     1.  corrosion, leakage, or structural defects
     2.  proper placement
     3.  proper stacking (including required aisle space)
     4.  segregation of incompatible wastes
     5.  missing or improper labeling
     6.  properly closed containers
II.  Container Storage Area and Containment System
     1.  base for lacerations, cracks
     2.  berms/dikes for cracks,  structural stability, freeboard
     3.  collection sump and pumping systems for proper operation,
         periodic maintenance  (visual and physical tests)
     4.  emergency response equipment for alarms, communication
         systems, fire fighting capabilities
     5.  fences or barriers for controlling access to  the facility
     6.  clean-up procedures for  debris  and refuse
     7.  personnel safety  precautions
     8.  surrounding vegetation for  changes
     9.  base drainage system,  if used  (visual  and physical tests)
                                5-8

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                            CHAPTER 6
                 HAZARDOUS WASTE CONTAINER COSTS
     Data presented on costs of operating a container facility is
provided in this manual purely for informational purposes.  The
permit writer is not required to evaluate a permit applicant's
costs for maintaining a container storage facility*  However, he
should be cognizant of the economics of options available to the
permit applicant.  The costs provided here are brief, general, and
are not meant to substitute for current market figures.  They
should not be used for engineering design.
A.  Introduction
     The cost of constructing and operating a container storage
area can be broken down into three main components:
     (1)  cost of the containers,
     (2)  cost of constructing the containment system, and
     (3)  operating cost.
     Operating costs will not be addressed in this chapter,
because it is dependent on site-specific factors such as frequency
of moving or emptying containers.
B.  Container Costs
     The most widely used type of container is the 55-gallon
steel drum.  Table 6—1 presents the prices of new 55-gallon drums
obtained from the Bureau of Census report "Steel Shipping Drums
and Paints" (also known as the M 34K report).13  Table 6-2 presents
cost data on steel drums obtained in a survey by the .National
Barrel and Drum Association.
                               6-1

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                            TABLE 6-1
                       PRICES OF NEW CONTAINERS
                  (Bureau of the Census Survey)
                                   PRICE (in dollars)
                                   March      March
                                   1980       1979
Tight Head
18-gauge and heavier               18.07      17.26
19- and 20-gauge**                 18.39      16.86
Open Head
18-gauge and heavier               22.37      19.33
19- and 20-gauge**                 16.82      15.60
*  Container price  is  at  the point  of  production.  It includes the
   net sales price, f.o.b.  plant, after discounts and allowances,
   exclusive of  freight charges and  excise  taxes.
** Includes 20/18 gauge containers
Source:   "Steel  Shipping  Drum  and Paints,"  Report M34K, Bureau of
           Census.
                             TABLE 6-2
               PRICES  OF  NEW AND  RECONDITIONED DRUMS
                          (NAB ADA survey)
                            Mean          Standard           Range
 Drum Type                 Price ($)        Deviation      Min.      Max.
 New Tight  Head             17.47            2.66        13.50     27.00
 New Open Head              19.42            4.31        15.00     34.00
 Reconditioned Tight Head   11.74            1.33         9.00     15.19
 Reconditioned Open Head    11.89            1.79         9.75     15.50
 Laundry/Service Fee         5.78            1.18         4.00      9.80
 source. - Survev conducted  by National Barrel and Drum -Association
 Source.  ™*v**™". -Srrel and Drum Reconditioning:   Industry
          Status Profile," Solid and Hazardous Waste Research
          Division, Municipal Environmental Sesearch Laboratory
          Cincinnati, Ohio.10
                                6-2

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     Costs may be substantially higher for other types of con-
tainers and vary widely with size.  The cost of a painted steel
(liquidexpansion) container ranges from $58 for an 8-gallon
container to $120 for a 40-gallon container.  Steel ASME expansion
(painted) containers range from $240 for an 18-gallon container
to $1,925 for a 515-gallon container.
C.  Containment System Costs16
     The cost of a typical containment system for a container
storage area can be subdivided into  three major cost components:
     (1)  base,
     (2)  curb or' dike, and
     (3)  sump pump.
     T.he estimating costs  for model  containment systems designed
for the storage of 100, 200, and  500 55-gallon drums are presented
below.  The major assumptions in  estimating these costs have  been:
     (1)  containers  (2 1/2  diameter  x  4'  height)  are  stacked
          in two tiers;
     (2)  no special  foundation design (e.g., use of pilings)
          was  necessary; and
     (3)  the  base  is  surrounded  by  6-inch  curbs and drains to  a
          sump pump.
     1.  Area  of Containment System
         a.   100 containers  (stacked 7 in 7 rows, 2 tiers  high)
               3 ft./container
              »  450 sq.;  ft.  (211  x 21')
              +  50% for  access  and drainage
              *  1000  sq.  ft.  (32' x  32' )
         Area  *  111 sq.  yds.
                                6-3

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Perimeter * 42 yds.
     b.  200 containers (stacked 10 in 10 rows, 2 tiers high)
          =  900 sq. ft. (301 x 30')
          +  50% for access and drainage
          -  2025 sq. ft.  (45' x 45')
     Area »  225 sq. yds.
Perimeter » 60 .yds.
    c.  50 containers (stacked 16  in  16  rows, 2 tiers high)
          3 ft. container
          -  2250 sq. ft.  (471 x 47')
          +  50% for access and drainage
          »  5000 sq^ ft.  (71- x 71')
     Area »  556 sq. yds.
Perimeter »  94 yds.
     2.  Cost  Estimates
                                            Number of Containers
                                              100     200     500
         Base  - $10/sq. yd.                  $1,110  $2,250  $5,560
         Curb  - $ll/yd.*                        462      660   1,034
         Pump  » $2,000*                       2,000   2,000   2.,000
            Total                            $3,572  $4,910  S8,594
         Cost  per  container                    536      $25     $17
         Annualized cost  over
         a  20-year period                     $219     $300     $=26
      (aanualization factor » .0612)
                                6-4

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These storage areas can be compared by utilizing the following
tables


    Number         Storage        Total        Cost per      Annualized
of Containers    Space (ft.2)   Space (ft.2)   container       cost
100
200
500
450
900
2250
1000
2025
5000
S36
25
17
219
300
526
     Obviously, other container  arrangements are possible and may

be acceptable to the permit writer.   In every case cost, estimates

should be obtained for the specific  facility in question, utilizing

up-to-date data.
                                6-5

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                             REFERENCES
 1.   Administrative Procedures for Obtaining RCRA Permits (Washington,
     D.C.:  U.S.  EPA),  SW-934.
 2.   Theodore P.  Senger and Fred C. Hart Associates,  Inc. ,
     Compatibility of  Wastes in Hazardous Waste Management Facilities
     (Washington,  D. C.: U.S. EPA, Office of Solid Waste, July 1981).
 3.   John H.  Perry and Cecil H.  Clilton, Chemical Engineers' Handbook,
     5th ed», (New York:  McGraw Hill 1973).
 4.   R.B. Tator,  "Engineer Guide to Protective Coatings," Chemical
     Engineering,  (79) 27, 1972.
 5.   G.A. Schult~, "In-plant Handling of Bulk  Material in Packing
     and Containers,"  ibid.  (85) 24, 1978.
 6.   J. F. Hanlon,  Packaging- Marketplace, (Detroit,  Mich.:  Gale
     Research Co., 1978).
 7,   National Fire Protection Association, "Standards for Portable
     Shipping Tanks NFPA 385," 1979.
 8.   National Fire Protection Association, "Flammable and Combustible
     Liquids  Code NFPA 30   1981.
 9.   National Fire Protection Association, "Rack  Storage of  Materials
     NFPA 231," 1980.
10.   J.  Touhill,  "Barrel and Drum Reconditioning:  Industry  Status.
     Profile," EPA Solid and Hazardous Waste  Research Division
     (Cincinnati,  Ohio: Municipal and Environmental Research
     Laboratory, 1980).
11.   Soil Conservation Service, SCS National  Engineering Hydrology,
     (Washington,  D.C.: U.S. Department of Agriculture, 1972).
12   Charles Moore, Landfill, and Surface Impoundment Performance
     Evaluation,  (Washington D.C.: Office of  Solid Waste, U.S. EPA,
     1980) .
13.   Matrecon, Lining of Waste  Impoundment and Disposal Facilities,
     U.S. EPA Washington,  D.C.: Office of Solid  Waste, U.S..  EPA,  1980)
14.   M. Hawthone,  •rrnrioT-sf.andina Corrosion,"  Chemical Engineering,
     (79) 27, 1972.
15.   "Steel Shipping  Drums  and Paints," Report M34K, Bureau of Census.
16.   Pope-Seid Associates,  St.  Paul, Minnesota.   Prepared under  EPA
     Contract No. 68-01-6322.
                                 7-1

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