Drum Compaction Case Study
Management is tired of paying shipping costs for half-empty steel drums of solvent-contaminated debris (an ignitable hazardous waste), so they approach you about purchasing a hydraulic drum compactor. Less drums and an overall reduction in costs; what could go wrong? As an LQG, you know that your facility is commonly under scrutiny, so you need to make sure everything is considered.
Regulatory Considerations
Practical Considerations
f Compacting hazardous waste meets the definition of treatment as there is a physical change to the hazardous waste and an intent to reduce the volume f Hazardous waste treatment of this nature is only allowed in accumulation containers, meaning that drum compaction is not allowed in satellite accumulation containers (the typical type of container accumulating solvent-contaminated debris) f Drum accumulation containers must comply with the container management requirements of 40 CFR 262.17(a) (1) , which notably includes: • Keeping the container closed except when adding or removing waste • Inspecting the container at least weekly for leaks and deterioration • Shipping the container off-site within 90 days of accumulating hazardous waste within the container f Update the facility’s RCRA Contingency Plan and associated Quick Reference Guide to incorporate these new accumulation containers f Confirm the State agency’s interpretation of the 40 CFR 268.7(a)(5) treatment exclusion, and ensure no additional state-specific requirements apply
f As the drum compaction must occur in accumulation containers that are subject to a 90-day time limit, will the facility be able to fill these drums and ship them off-site within 90 days? How long does it take to fill the drum without compaction? Converting the satellite accumulation drum to an accumulation drum may not make sense if the satellite drum takes a significant amount of time to fill. f What is the weight limit of the steel drums? Will the compaction create drums that are too heavy to move or ship? f How will the facility ensure the drums remain closed when not actively adding waste to the drum? Does the compaction device maintain a seal when engaged with the drum? If not, how much time will it take to move the drums in and-out of the compactor, adding/removing lids, etc.? Should the facility compact the drums daily, weekly, or some other frequency? f Who will complete the required weekly inspections of the drums being compacted? Do they have adequate RCRA training to complete these inspections? f Are there any new safety concerns associated with compacting the ignitable debris? f Likely need to develop a Standard Operating Procedure for the drum compaction operation as a tool to ensure regulatory compliance.
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