Best Management Practices
 Handbook for
Hazardous Waste
    Containers
 U.S. EPA Region 6, 1997

-------
                              FOREWORD
This handbook was produced by AT. Kearney, Inc., under contract to the
Environmental Protection Agency (EPA) Region 6, for the Compliance Assurance and
Enforcement Division of EPA Region 6. The idea to construct the handbook came from
a RCRA workgroup composed of members of several oil and gas companies, the
American Petroleum Institute (API), the Texas Mid Continent Oil and Gas Association
(TMOGA), EPA, and environmental consulting firms. The RCRA workgroup is one of
several workgroups making up the "Refinery Roundtable."  The overall mission of the
Refinery Roundtable is to develop methods by which petroleum refineries can achieve
better compliance with the environmental regulations.

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

-------
                            Table of Contents
1.     Introduction	      1



2.     Best Management Practices for Containers  	      4



      A.    Waste Characterization	      4



      B.    Container Selection	      6



      C.    Managing Containers at 90-Day Areas  	     11



3.     Inspecting Containers	     15



4.     Summary	     16



5.     Generic Inspection Checklist	     17



6.     Federal and State Contacts  	     18

-------
                                      1.  INTRODUCTION
Who will the Best Management
Practices Handbook Help?
This handbook was written for anyone who,
manages, or supervises the management of
hazardous waste containers.
                                    This handbook is a user-friendly training tool or
                                    reference that identifies and explains the regulations
                                    for managing hazardous waste containers safely in
                                    lay terms. The handbook also provides "Best
                                    Management Practices" (BMP) - real world
                                    methods, examples, and tips for meeting and
                                    exceeding regulatory requirements. When workers
                                    understand what regulations mean and how to
                                    comply, environmental performance will improve.
Why did EPA develop the
handbook?
The U.S. Environmental Protection Agency (EPA),
Region 6, is working with the regulated community
to ensure compliance with the regulations under the
Resource Conservation and Recovery Act (RCRA).
RCRA is the Federal government's regulatory
program for managing hazardous wastes in order to
protect human health and the environment.

EPA has found that the most common problem with
generators of hazardous waste is the failure to meet
the permit exemption requirements (for containers)
as defined in 40 CFR 262.34(a)(1)(i). This
regulation allows generators to temporarily store
their hazardous wastes onsite, in containers, without
a permit, provided that they meet certain container
management requirements. A review of the findings
from all the inspections conducted at petroleum
refineries in Region 6 showed violations related to
container management occur twice as often as any
other type of RCRA violation.
BMPHWC

-------
§262.34(a) (1) (i) — Except as provided in
paragraphs (d), (e), and (j) of this section,
a generator may accumulate hazardous
waste on-site for 90 days or less without a
permit or without having interim status,
provided that:

(1) The waste is placed:
(i) In containers and the generator
complies with subpart I, AA, BB and CC
of 40 CFR Part 265.
How is the handbook
organized?
Generators can store hazardous wastes in
containers on-site for 90 days or less without a
RCRA permit.  The waste must be stored under
certain conditions:

1)     The waste must be stored in containers
       which meet the definition of a portable
       device (e.g., 55-gallon drums).  Permanently-
       mounted tanks, surface impoundments, and
       waste piles would not be considered
       containers.
2)     the waste must be stored according to the
       full set of regulatory requirements outlined in
       40 CFR 265, Subpart I.

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


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

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

Management of containers in less  than 90 day
storage areas are also discussed in detail providing
additional tips for compliance.

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

Finally, two compliance tools are included at the
back of the handbook. The first tool is a generic
container inspection checklist (see page 16) that
may be tailored for use at your facility.  The second
tool is a poster (see page 18) that  uses simple, clear
pictures to show best management practices for
container management.  You can tear the poster out
of the handbook and display it for quick referencing
at your facility.
                                                                     BMPHWC

-------
CONTAINER
MANAGEMENT
PROCESS
                       Satellite
                   Accumulation
                        Point
      Waste
    Generation/
   Characterization
                    Container Storage Area
        Off-Site
        Shipment
              Condition
                 of
             Containers
  Weekly
Inspections
                     Container
                   Management
                Best Management
                    Practices
BMPHWC

-------
Best Management Practice
           a
                                    2.     BEST MANAGEMENT
                                           PRACTICES FOR CONTAINERS
I
                                    The following sections will explain how to
                                    successfully manage hazardous wastes in
                                    containers. All relevant regulations are identified
                                    and explained. From these sections, you will...

                                    A.     Learn why waste characterization, or
                                           identifying and understanding your wastes, is
                                           important.
                                    B.     Learn how to select and label containers.
                                    C.     Learn methods to safely manage containers
                                           of hazardous waste.

                                    A.    WASTE CHARACTERIZATION

                                    To safely manage hazardous waste, you must know
                                    exactly what a waste is, how it will act, and what its
                                    properties are.  Is the waste extremely toxic? Do
                                    workers need special protection? Is the waste
                                    corrosive,  will it corrode certain types of containers?
                                    Is the waste incompatible with other wastes - will it
                                    react (explode, catch on fire) if it is mixed with
                                    another waste or water?

                                    Once a waste is generated, it should be
                                    characterized, before you place the waste in a
                                    container.  Waste characterization can be done by
                                    either:

                                    1)     sampling and analyzing the waste, or
                                    2)     identify the waste based on process
                                           knowledge (you know the constituents in the
                                           process and therefore you can use that
                                           knowledge to determine if the resulting waste
                                           has characteristics that could make the
                                           waste hazardous).
                                            *  ,*,  * ^u    *  •  *•
                                            for Waste Characterization
                                     1)     Look at a material safety data sheet (MSDS)
                                           if it is available.  Some information areas on
                                           the MSDS to look for are physical property,
                                           reactivity, fire and explosion hazard, and
                                           special protection information.
                                     2)     If a product being used in a process meets
                                           one or more hazardous characteristics, the
                                           waste generated may exhibit some of the
                                           same characteristics.
                                                                  BMPHWC

-------
Best Management Practice
§265.177 — Special requirements for
incompatible wastes


(a) Incompatible wastes, or incompatible
wastes and materials (see appendix Vfor
examples), must not be placed in the same
container, unless 265.17 (b) is complied
with.
                                      3)     Be aware of any changes in a production
                                            process which could alter the composition of
                                            the waste generated.
                                             for Waste Characterization of
                                      Containerized Waste

                                      1)     Pay attention to marking/labeling which may
                                            indicate that a material is flammable,
                                            corrosive, etc.
                                      2)     Always check with your supervisor before
                                            handling unknown drums, or drums which
                                            you feel are labeled or marked incorrectly.
                                      3)     Look at a material safety data sheet (MSDS)
                                            if it is available.
                                      4)     If waste is in a plastic drum it is a good
                                            indication the waste may be corrosive.

                                      Special methods and equipment may be required to
                                      manage wastes which are:
                                      1)
                                      2)
                                      3)
                                      4)
                                      5)
                                      6)
                                      7)
       Corrosive
       Combustible
       Flammable
       Oxidizer
       Poison
       Toxic
       Reactive
Putting Wastes in Containers -
Reactive or Incompatible Wastes

Through waste characterization, you learn if a waste
is reactive or incompatible with other wastes.
Before putting wastes into a container it is
necessary to identify and segregate wastes if they
are incompatible and/or reactive. This is
important!! Incompatible and/or reactive
hazardous wastes must be stored in a manner to
prevent fires or explosions.

The regulations state that incompatible wastes
cannot be placed in the same container, unless you
comply with other requirements found in §265.17
(b). This prevents the wastes from  reacting with
each other (e.g., exploding, catching on fire).
BMPHWC

-------
   §265.17(b) ...the mixture or commingling
   of incompatible wastes, or incompatible
   wastes and materials, must be conducted
   so that it does not:
   (1) Generate extreme heat or pressure,
   fire or explosion, or violent reaction;
   (2) Produce uncontrolled toxic mists,
   fumes, dusts, or gases in sufficient
   quantities to threaten human health;
   (3) Produce uncontrolled flammable
   fumes or gases in sufficient quantities to
   pose a risk of fire or explosions;
   (4) Damage the structural integrity of the
   device or facility containing the waste; or
   (5) Through other like means threaten
   human health or the environment.
The best management
practice for incompatible
wastes is to store them
separately. It is safer and
easier to simply put
incompatible wastes in
separate containers and
separate storage areas.
The regulations allow you to put incompatible
wastes in the same container, under the conditions
found in §265.17(b) (Warning: "Always talk to
your supervisor or environmental coordinator
before mixing any materials or wastes").  If you
have to mix incompatible wastes in the same
container you must make sure that the wastes won't
react. This means that you must:

1)     keep the waste from becoming too hot (this
       will prevent fire or explosions);
2)     keep the wastes from producing toxic and/or
       flammable mists,  gases, fumes, or dust (this
       will prevent workers from being exposed to
       the waste and will prevent fire or explosions);
3)     make sure that mixing the incompatible
       wastes won't damage the container -- the
       container won't rupture or bulge; and
4)     demonstrate that mixing the wastes won't
       threaten workers, or the environment in any
       way.

B.     CONTAINER SELECTION

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

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

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

-------
§265.172 Compatibility of Waste with
Container

The owner or operator must use a
container made of or lined with materials
which will not react with, and are
otherwise compatible with, the hazardous
waste to be stored, so that the ability of
the container to contain the waste is not
impaired.
When selecting the container you must make sure
that a waste won't react with the container itself.
For example, highly corrosive wastes will react with
a steel drum -- the drum may fail and waste may be
released.  How can you safely store corrosive
wastes? Use plastic, or plastic-lined, steel drums to
safely store corrosive wastes.  To prevent drum
failure, carefully "match" the right waste with the
right container.
Best Management Practice         Tip for Container Selection
                                        Consult a corrosion resistance guide to determine if
                                        the container and waste are compatible.
                                                                   Match the waste with
                                                                   the correct type of
                                                                   container.
BMPHWC

-------
§265.177 Special requirements for
incompatible wastes

(b) Hazardous waste must not be placed in
an unwashed container that previously
held an incompatible waste or material
(see appendix Vfor example), unless
265.177 (b) is complied with.
Best Management Practice
There's one more thing to think about when
selecting a container. You can put wastes into
unwashed containers that have held incompatible
wastes, under regulation §265.177(b).  But, you
must make sure that you meet the conditions
specified in §265.17 (b) (See page 6).

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

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


TIPS for Safely Putting Wastes in  Containers

1)     Make sure you know which wastes are
       reactive and/or incompatible.  Keep these
       wastes away from each other.  Put them in
       separate containers.
2)     Make sure the container cannot be harmed
       by the waste.
3)     If  you rinse out containers onsite, be aware
       that rinse water generated from  drum
       washing must be contained and
       characterized prior to disposal.
4)     If  you frequently reuse containers, consider
       "assigning" wastes to certain containers.
       This will allow you to reuse the container
       without washing.
5)     Use a funnel to prevent spills, and do not
       use the same funnel for all wastes.
6)     Certain chemicals may need room for
       expansion, or they may  require zero
       headspace depending on the  characteristics
       of the waste and storage conditions (e.g.,
       temperature fluctuations)
                                      Marking & Labeling Containers

                                      Hazardous waste generators can only accumulate
                                      or store waste on-site for less than 90 days without
                                      a permit. The 90-day limit starts the moment the
                                      container is full.  If your facility is a small quantity
                                      generator shipping wastes over 200 miles you can
                                      store wastes up to 270 days.  If less than 200 miles,
                                      you can store waste up to 180 days.
                                                                     BMPHWC

-------
§262.34(a)(2) The date upon which each
period of accumulation began is clearly
marked and visible for inspection on each
container.

§262.34(a)(3) While being accumulated
on-site, each container and tank is
labeled or marked clearly with the words,
"Hazardous Waste"...
   HAZARDOUS WASTE
   ACCUMULATION
   START DATE	
   CONTENTS  	
         HANDLE WITH CARE!
    CONTAINS HAZARDOUS OR TOXIC WASTES
You must be able to prove to inspectors that you
have not exceeded the time limit for accumulation.

The regulations require that you clearly mark on the
container the date hazardous waste completely filled
the container.  In addition, you must clearly mark all
containers holding hazardous waste with the words
"HAZARDOUS WASTE".

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

(More specific information on DOT labeling can be found
in 49 CFR Part 172)
Best Management Practice         TIpS for Marking/Labeling Containers
                                       1)     Have all personnel use the same method
                                             (e.g., handwritten, prepared labels) to label
                                             containers. Make sure all handlers know
                                             what the markings mean.
                                       2)     Besides the start date and the words
                                             "Hazardous Waste," include information
                                             about contents (e.g., toxic, reactive,
                                             incompatible).
                                       3)     Apply DOT labels to the container when
                                             waste is first placed in the container. The
                                             label will be in place for shipment and
                                             provides information about the waste to drum
                                             handlers.
                                       4)     Before  reusing containers, make sure all old
                                             markings/labels are washed off or blacked
                                             out.
                                      Satellite Accumulation Points

                                      It is important to mention satellite accumulation
                                      points (SAP) before discussing the requirements for
                                      managing hazardous waste at less than 90-day
                                      areas.
BMPHWC

-------
262.34(c)(l) A generator may accumulate
as much as 55 gallons of hazardous waste
or one quart of acutely hazardous waste
listed in 261.33 (e) in containers at or
near any point of generation where wastes
initially accumulate, which is under the
control of the operator of the process
generating the waste, without a permit or
interim status and without complying with
paragraph (a) of this section provided he:

(i) Complies with 265.171, 265.172, and
265.173 (a)  of this chapter; and
(ii) Marks his containers either with the
words "Hazardous Waste " or with other
words that identify the contents of the
containers.
(2) A generator who accumulates either
hazardous waste or acutely hazardous
waste listed in 261.33(e) in excess of the
amounts listed in paragraph (c)(l) of this
section at or near any point of generation
must, with respect to that amount of
excess waste, comply within three days
with paragraph (a) of this section or
other applicable provisions of this
chapter. During the three day period the
generator must continue to comply with
paragraphs (c)(l)(i) through (ii) of this
section. The generator must mark the
container holding the excess
accumulation of hazardous waste with the
date the excess amount began
accumulating.
You can store up to 55 gallons of hazardous waste
(or up to 1 quart of acutely hazardous waste) at a
SAP for an unlimited amount of time and following
only some of the requirements for 90-day areas. To
store waste at a SAP you must simply:

1)     keep the containers in good condition;
2)     make sure the waste is compatible with the
       container; and
3)     keep containers closed when not adding or
       removing waste.  Make sure you handle the
       containers to prevent leaks or spills.
4)     Mark container with words "Hazardous
       Waste" or words which identify the contents.

Because of fewer  requirements, facilities like to
designate storage areas as SAPs.  This can be a
problem. The definition of a SAP is specific. SAPs
can only be located at or near the point of waste
generation (where the waste is generated) AND the
SAP has to be under the control  of the  person
generating the waste.  To be a SAP a storage area
must:

1)     only accumulate waste generated at the SAP
       -- SAPs can't be used  as  temporary staging
       areas for wastes collected from  other areas;
       and
2)     be located as near the point of generation as
       safety allows.  For example, lab wastes may
       be accumulated in safety  cans in the lab.

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

1)     mark the container holding the excess
       accumulation of hazardous waste with the
       date the excess amount began
       accumulating.
2)     move the container holding the excess
       accumulation to a container storage area
       within 3 days.

If your company incorrectly manages a 90-day
storage area as a  SAP, your company will be in
violation of the regulations.
10
                                BMPHWC

-------
§265.171 Condition of containers

If a container holding hazardous waste is
not in good condition, or if it begins to
leak, the owner or operator must transfer
the hazardous waste from this container
to a container that is in good condition,
or manage the waste in some other way
that complies with the requirements of
this part.
C.     MANAGING CONTAINERS AT
       90-DAY AREAS

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

Keeping Containers in Good Condition

One of the easiest ways to prevent spills is to make
sure that containers are kept in good condition -
both before the waste is put in the container and
while you are managing the container. What does
good condition mean?

1)     Containers must be free of dents and
       corrosion - these weaken the container.
2)     Containers must not leak - the container
       must be structurally sound.
3)     Containers must not bulge.

If you find any of these problems, you must transfer
the waste from the "problem" container to a sound
container.
§265.173 Management of containers

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

(b) A container holding hazardous waste
must not be opened, handled, or stored in
a manner which may rupture the
container or cause it to leak.
Managing Filled Containers

How can you keep containers in good condition?
Your company should have written procedures for
managing containers. All employees should be
trained in these procedures. At a minimum, you
must:

1)     keep containers closed at all times, except
       when you are adding or removing waste from
       the container;
2)     be careful when you are handling the
       containers.  You must open, handle, and
       store containers to prevent ruptures or leaks.
       For example,  use drum grapplers to lift and
       move drums -- don't hand-roll the drums from
       one area to another; and
3)     if the container begins to leak, or you notice
       dents or bulges, transfer the waste to
       another container.
BMPHWC
                                              11

-------
§265.177 A storage container holding a
hazardous waste that is incompatible with
any waste or other materials stored
nearby in other containers, piles, open
tanks, or surface impoundments must be
separated from the other materials or
protected from them by means of a dike,
berm, wall, or other device.


§265.176 Special requirements for
ignitible or reactive waste

Containers holding ignitable or reactive
waste must be located at least 15 meters
(50 feet) from  the facility's property line.
Keep incompatible wastes from
contacting/reacting with other
wastes and materials
You must also prevent reactions of ignitable and/or
incompatible wastes. EPA developed three special
management requirements for these wastes:

1)     incompatible wastes must be physically
       separated
2)     store ignitible and/or reactive wastes at least
       50 feet from your property line
3)     manage ignitable and/or reactive wastes to
       prevent fire and/or explosions.

Managing Incompatible, Ignitable and/or
Reactive Wastes

Physically separate containers holding
incompatible wastes from other wastes or materials.
Store the containers in an area surrounded by a
berm, dike, wall, or other physical structure.

Keep incompatible wastes from contacting/reacting
with other wastes and materials.

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

1)     reduces the risk of the general public
       reaching/contacting the waste or being
       harmed in an explosion; and
2)     if a release of hazardous waste does occur,
       this will help prevent the waste from
       migrating offsite.
12
                                BMPHWC

-------
§265.17(a) The owner or operator must
take precautions to prevent accidental
ignition or reaction ofignitable or
reactive waste. This waste must be
separated and protected from sources of
ignition or reaction including but not
limited to: Open flames, smoking, cutting
and welding, hot surfaces, frictional heat,
sparks (static, electrical, or mechanical),
spontaneous ignition (e.g., from heat-
producing chemical reactions), and
radiant heat.  While ignitible or reactive
waste is being handled, the owner or
operator must confine smoking and open
flame to specially designated locations.
"No Smoking" signs must be
conspicuously placed wherever there is a
hazard from ignitable or reactive waste.
Manage ignitable and/or reactive wastes to
prevent fire and/or explosions. At a minimum you
must keep ignitable and/or reactive wastes away
from:

1)     fire;
2)     hot surfaces like operating machinery,
       engines;
3)     radiant heat or sunlight;
4)     cutting and welding operations;
5)     frictional heat  -- keep drums stationary, don't
       pull drums along on the ground;
6)     sparks from static electricity,  electrical
       operations,  or friction; and
7)     some reactive wastes must be kept away
       from water.

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

"NO SMOKING" signs must be posted at all areas
near ignitible or reactive wastes.
Best Management Practices        TIpS for Safely Managing Containers
                                         1)     Use a funnel or hose to add or transfer
                                               wastes to drums.  This will prevent spills.
                                               Remember to rinse the funnel and
                                               characterize the rinse water (a dedicated
                                               funnel would not have to be rinsed).
                                         2)     If you  notice a leak, or a container is in poor
                                               condition, transfer the waste to a new
                                               container immediately.
                                         3)     Keep containers cool and dry.
                                         4)     Make  sure all container storage areas are
                                               clearly marked - keep ignitible/reactive
                                               wastes in their own area.
                                         5)     Don't stack ignitible/ reactive wastes.
                                         6)     Make  sure to open and close steel drums
                                               with a spark proof bung wrench.
BMPHWC
                                                13

-------
Best Management Practices       Tips continued
                                    7)     Don't push, roll, or drag containers. Use the
                                          right equipment to move the drums.
                                    8)     Make sure the drums are easy to reach --
                                          keep an open aisle space so that people and
                                          equipment can move freely.
                                    9)     Don't drive equipment (trucks, forklifts) into
                                          container storage areas unless you are
                                          moving containers.
                                    10)    Keep the containers in a "containment area"
                                          to hold spills. Containment can be provided
                                          by dikes, berms, or walls.
                                          Use a funnel to add or transfer wastes to
                                          drums. Remember when not in use to keep
                                          funnel covered or closed
14
BMPHWC

-------
                                      3.    INSPECTING CONTAINERS
                                        J
§265.174 Inspections

The owner or operator must inspect areas
where containers are stored, at least
weekly, looking for leaks and for
deterioration caused by corrosion or
other factors.
Container storage areas must be inspected weekly.
Inspections protect you, your company, and the
public -- through inspections, you can stop spills
before they happen.

Your company should develop and maintain a
standard inspection checklist to be used during
every weekly inspection.  The checklist should be
detailed and address the labeling and management
procedures followed at your facility. An example of
a checklist that can be modified to fit your facility is
attached to the back of this booklet.

At a minimum,  the inspection checklist should cover:

1)     leaks or staining from containers;
2)     container condition, including dents, bulging,
       and/or corrosion;
3)     labeling - start date, the words "Hazardous
       Waste" and other information; and
4)     management practices -- such as aisle
       space, drum stacking.

Inspections should be detailed and methodical.
Anyone doing inspections should be trained.
Best Management Practice        Tips for Conducting inspections
                                      1)     Follow the inspection checklist -- make
                                            detailed notes if you find something wrong.
                                      2)     Be thorough.  Check the tops of drums to
                                            look for waste residue or corrosion.
                                      3)     Walk all the way around containers - check
                                            entire storage area.
                                      4)     Check containment area for stains.
                                      5)     Note anything unusual in containment area -
                                            even if it might not be a problem.
                                      6)     If problems are found, get the problem taken
                                            care of immediately.
                                      7)     Keep a logbook of the facility's inspection
                                            checklist.
BMPHWC
                                             15

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

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

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

-------
                    4.
                         HAZARDOUS WASTE CONTAINER STORAGE AREA
                                    INSPECTION CHECKLIST
                                 Month:
                                                        Year:
Instructions:   Weekly, place a "Yes" next to all inspection items that meet facility rules. Place a
              "No" next to all inspection items that do not meet the rules. Please provide specific comments
              on all "No-marked"items. When weekly inspection is completed, inspector must initial at the
              bottom of the table. Report all No-marked items to appropriate supervisor.

Inspection Item
Number of Containers in Unit
Containers Marked/Labeled
Properly
Containers Dated Properly
Containers Stored 90 Days or Less
Containers Observed to be free of
Leaks/Staining
Containers Observed with Closed
Tops or Bungs
Containers Observed without
Dents or Corrosion
Appropriate Aisle Space
Maintained
Containment System free of Water
or Other Liquids
Inspectors Initials
Four-Week Inspection Period
Date:










Date:










Date:










Date:










Comments on
Inspection Items










Overall Comments:
                                                        Date:
Reviewed by:	
Note:  State and Federal regulations require that this inspection be performed weekly.
       BMPHWC
                                                                                           17

-------
            5. FEDERAL AND STATE CONTACTS
1)     National Spill Response Center - (800) 424-8802

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

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

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

5)     State Agency Numbers:

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

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

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

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

      Texas Natural Resources Conservation Commission (TNRCC) -
      Austin Regional Office
      1921 Cedar Bend Dr.
      Suite 150
      Austin, Texas 78758
      (512) 339-2929
      18                                                          BMPHWC

-------

-------