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Q&A: Can I store drums of hazardous waste with non-hazardous waste?

Q&A: Can I store drums of hazardous waste with non-hazardous waste?

An assumption, some research and a question (02.21.17):

Hi Daniel,

I always thought that RCRA Hazardous waste regulations require hazardous waste drums not be stored with non-hazardous waste drums.  However, I scanned through 40 CFR and don’t see where it specifically says this.

I ask because I am working on reclassifying some of our solvent waste as Hazardous Secondary Materials (HSM) since they are legitimately recycled.  Indiana adopted the Federal HSM regulation in November of 2016. I’d prefer to keep my drum storage as is, and leave the HSM drums with the other “hazardous waste” drums and not have to find a different storage location.

Can you please let me know if I’m missing the regulation that would prohibit this?55-gallon drums of Non-Hazardous Waste

My reply the same day:

There is no regulations – state or Federal – I am aware of that forbids storage of hazardous and non-hazardous waste in proximity to each other.  Some accumulation requirements to note:

  • Regulations applicable to a small quantity generator (SQG) and large quantity generator (LQG) of hazardous waste require them to segregate all incompatibles whether they be hazardous, non-hazardous, or not a waste at all, i.e. material.  Read:  Examples of Potentially Incompatible Wastes
  • An LQG must maintain Ignitable (D001) and Reactive (D003) Haz Waste >15 m (50 feet) from its property line.  The Generator Improvements Rule has created a waiver to this rule.
  • On-site accumulation of HSM subject to new requirements for speculative accumulation.

I hope this helps.  Please let me know if you have any other questions.

Conclusion:

The question is a simple one with a simple answer but a much deeper meaning.  Notice how the questioner had a long-standing incorrect assumption (harmless as it turned out) regarding the regulations.  Also, how a ‘scan’ of the regulations didn’t return an answer.  A great error of many in the regulated industry – and one I have to be on guard for – is the assumption of how the regulations work without an understanding of their exact meaning as written and any interpretations.  Don’t let an assumption of the USEPA RCRA regulations for the management of hazardous waste determine your compliance with them; it may lead to a violation.

So what can you do besides spend hours every day researching the regulations?  Do what this person did and contact me with your questions about the cradle-to-grave management of hazardous waste.

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