Proper hazardous waste storage is one of the most important methods for protecting your facility and maintaining normal operations. Additionally, upholding best practices for waste management is crucial for ensuring proper storage techniques, along with the wellbeing of the surrounding environment and the safety of all visitors and employees.
Beyond the safety and operational concerns, failure to comply with all the legal requirements can lead to significant sanctions and other penalties.
Just recently, the Los Alamos National Laboratory was fined up to $10,000 per day for each violation when it was discovered that storage containers had been mislabeled, leading to them being stored on-site beyond the allowed timespan. Compliance failures can also spur a hefty response from state and local authorities, as in the case of Home Depot, which was slapped with a nearly $30 million penalty from the State of California for improper waste storage and disposal, including non-compliant labeling practices.
Clearly, the consequences for failing to comply with all regulations are stark, but how can your facility meet its legal obligations for storing hazardous waste without disrupting operations? Partnering with a knowledgeable and fully certified waste management provider is the best way to keep your facility compliant and up to code.
Here are some additional tips to help create and administer an effective, legally sound hazardous waste storage program.
Identify a Temporary Storage Location
A key component of a compliant hazardous waste stream is the temporary storage location, otherwise known as Satellite Accumulation Areas (SAA). Along with minimizing operational disruptions caused by constantly hauling hazardous waste to central storage areas, an SAA lets you immediately transfer waste to a compliant container and more closely monitor individual waste streams.
Once you’ve accumulated either 55 gallons of general hazardous waste, or either one quart or one kilogram of acute liquid or solid hazardous waste, you must transfer the relevant containers out of the SAA and into central storage areas for your facility.
Build a Containment System
Containment areas for your stored hazardous waste must comply with a variety of guidelines intended to keep the waste safely contained in the event of a spill or mishap.
In any situation where liquid waste is present, containment areas are required to include a structurally solid base (such as thick concrete) that’s free of cracks or gaps and is impervious to liquid penetration. The base must be sloped or designed to immediately drain liquid into safe containment areas, unless the storage containers are raised high enough to prevent spill contamination. Environmental runoff or other liquid sources must be able to be properly drained and collected in a timely manner.
Containment areas for solid waste have similar restrictions, but don’t require liquid management except to ensure waste containers aren’t damaged by liquid accumulating from other sources.
Separate Hazardous Waste Types
Managing individual waste streams is a central component of your hazardous waste regime, so storage regulations are heavily focused on ensuring your various streams don’t mix, leading to incompatible or even dangerous waste interactions.
In general, incompatible waste types must never be mixed, even including trace amounts of leftover waste in previously used containers. Additionally, any waste with ignitable or reactive characteristics must be located at least 50 feet from your facility’s property line to protect bystanders and neighbors.
It’s always best to work closely with your waste management provider to properly identify and segregate waste streams when creating a storage regime.
Use Proper, Sealed Containers
Regulations closely define the allowable characteristics for your hazardous waste storage containers, so you should always ensure every container on-site meets those requirements.
In brief, every container must be in good condition, without significant rusting or corrosion, and with no breakage, gaps, cracks or other leaks that might lead to spills or overflows. Transferring hazardous waste to a container in poor condition is automatically a violation that can be penalized.
You’re also required to ensure each container is appropriate for the hazardous waste it will hold, including being lined with protective or non-reactive materials when necessary.
Finally, storage containers must be kept closed during storage—except when in active use to add or remove the waste—and must never be handled in a way that imparts any risk of spills, leaks or other damage.
Label Containers Correctly
Compliant hazardous waste labeling serves two key functions: it notifies all observers of the container’s contents and hazardous characteristics, and provides at-a-glance verification for storage times and other regulatory monitoring.
Every container label must contain language specified by the EPA, and may also require additional tightly regulated language depending on the specific contents. Work with your waste management provider to properly identify every category of waste in your facility, then incorporate proper labeling practices into your staff training and daily operations.
Follow Storage Volume and Time Limits
Regulations define three categories of hazardous waste generators that are used to determine the relevant stipulations for how much hazardous waste your facility can store, and for how long.
Very Small Quantity Generators
VSQGs produce 100 kg or less of hazardous waste each month, or 1 kg or less of acutely hazardous waste. VSQGs have no time limit for storage, but must not accumulate more than 1,000 kg or 100 kg of hazardous or acutely hazardous waste, respectively.
Small Quantity Generators
SQGs generate less than 1,000 kg or 100 kg of hazardous or acutely hazardous waste each month, respectively. SQGs may store waste for up to 180 days, unless the disposal facility is 270 or more miles away, in which case they may store waste for up to 270 days.
SQGs may accumulate no more than 6,000 kg of waste on-site.
Large Quantity Generators
LQGs generate more than 1,000 kg or 1 kg of hazardous or acutely hazardous waste per month, respectively. There is no accumulation limit for LQGs, but they may only store waste on-site for 90 days unless they receive a permit exemption.
Inspect Storage Containers
You must inspect all storage containers at least once per week to verify they’re in safe, compliant condition.
Have a Contingency Plan
While LQGs are the only type of generator required to have a disaster contingency plan, they remain a best practice for all facilities, regardless of size or waste activity.
Disaster contingency plans are used to formulate and specify response procedures to any type of facility disaster.
Effective contingency plans contain:
- Full descriptions and accounting for all the hazardous waste on-site, including risks, quantities and locations
- Definitions for various likely disaster scenarios
- Assigned emergency coordinators and other staff responders
- A fully described containment and response plan for any emergency
- Plans to prevent hazmat exposure
- Locations of all safety and remediation supplies
Working with your waste management provider is the best way to create and administer a fully compliant hazardous waste management program. With the tips above, you can ensure your facility remains safe and compliant, both now and in the future.