The management of containerized wastes that are reactive, ignitable, or incompatible has to follow strict regulations under the Code of Federal Regulations 265.177 (found under Title 40 of the Environmental Protection Agency Rules.) According to this regulation:
– Storage containers that contain hazardous waste that is not compatible with any other waste stored near it in other containers, open tanks, piles, or surface impoundments are required to be separated from these other materials and protected from them by means such as a berm, wall, dike, or other devices.
If you are a generator with containers that contain wastes incompatible with other waste materials, you are responsible for physically separating the two types of waste so that there is no contact or potential for them to react.
There are additional special requirements you are responsible to follow for your reactive and ignitable wastes.
Regulation for Managing Ignitable and Reactive Materials
These classifications of wastes are required to be stored at least fifty feet from your facility’s property line. Some companies stack their drums along a fence bordering their property to maximize storage space. This method may work for your chemical waste management, but it will not work for reactive or ignitable waste materials.
You cannot keep reactive or ignitable materials within the boundaries of your facility for two reasons:
– To reduce the risk of the general public being able to come into contact with the waste
– If there should be any type of release involving these wastes, distance will prevent the waste from trekking offsite
Distance from the waste is one regulation. These are others involving reactive and ignitable materials:
You are required to take precautions that will prevent accidental reactions of ignitable or reactive waste
You must separate and protect the waste from any source of reaction or ignition including, but not limited to:
– Welding and cutting
– Open fires or flames
– Sparks from electricity, static, or mechanical
– Surfaces that can become hot
– Spontaneous ignitions such as heat-producing chemicals
– Radiant heat
– When handling the waste, your operator has to confine open flames and smoking
– You are required to post ‘No Smoking’ signs in conspicuous places wherever you have reactive or ignitable waste materials
Breakdown of Chemical Waste Management for Reactive and Ignitable Materials
Wastes classified as reactive or ignitable have to be managed specially in order to prevent explosions or fires. These are some of the materials you have to keep those wastes away from:
– Machinery engines or other hot surfaces
– Frictional heat, which means your drums have to remain stationary, and never be pulled or dragged along the ground
– Electrical operations and sparks from static electricity
– Radiant heat or sunlight
– Welding and cutting operations
– Some cases of reactive wastes require them to be kept away from water
– Smoking- as mentioned above- signs must be posted for ‘No Smoking’ in any area where you have an ignitable or reactive waste
EPA Chemical Waste Management for Reactive and Ignitable Materials
Following the EPA’s regulations for reactive and ignitable materials includes:
– If a container has a leak or is in poor condition, the waste inside must be transferred to a new container immediately
– All container storage areas need to be clearly marked- all ignitable and reactive waste materials should have their own storage area
– When opening or closing the steel storage drums, you must use a spark-proof wrench
– Keep storage drums in an area that is easily accessible so that both equipment and people can move around them freely
– Storage containers with these materials should be kept in a ‘containment area’ in case of spills, and so there can be walls, berms, or dikes created in case of such spills
– When transferring waste to the drum, you should use a hose or funnel to prevent spills. The item used during transfer should be rinsed after use, or use a dedicated hose or funnel for each use which would not have to be rinsed
– The storage area should be dry and cool
– Do not stack drums containing ignitable or reactive waste materials
– Use the proper equipment when moving the storage drums- never drag, roll, or push them
– There should never be equipment driven into the storage area except for those times when you are moving the containers
Definition of Ignitable, Corrosive, and Reactive Materials by the RCRA 40 CFR Parts 261
Proper identification of hazardous materials is sometimes difficult. If you are unsure how your waste materials should be classified and handled, talk to the experts at Environmental Marketing Services. These are some definitions that may also help you with identifying or characterizing your materials.
Wastes that are alkaline or acidic or those that can readily dissolve or corrode metal, flesh, or other materials are considered corrosive. Automobile batteries are a good example of a corrosive material as they contain sulfuric acid. Environmental Marketing Services is a good source to question if you are unsure whether your waste would fall under the corrosive identification rules.
Wastes that are able to catch fire and sustain combustion are considered ignitable. A lot of the industrial wastes such as paints and cleaners pose such a fire hazard. Typically ignitable materials are in liquid form. A non-liquid waste is hazardous due to how it can spontaneously catch fire under normal handling and is able to burn so hard that it becomes a hazard. An ignitable waste is one of the most common hazardous wastes.
A material that can readily undergo violent reactions or explode is classified as reactive. A good example of reactive waste is discarded explosives or munitions. The EPA’s narrative criteria for defining a reactive waste is:
– Material that is able to react violently or explode when it becomes exposed to water, is heated, or when handled under normal conditions
– Material that can create toxic gases or fumes when it becomes exposed to water or under normal handling conditions
– Material the meets the DOT’s classification rules
– Material that generates toxic levels of cyanide gas or sulfide when it becomes exposed to a pH range of 2 through 12.5
Where to Learn More About Chemical Waste Management
The professionals at Environmental Marketing Services are here to help with your facility’s chemical waste management. We have more than ninety years of experience in the waste disposal industry and will help you protect the environment, your employees, and the community through proper chemical waste management services.