Fact Sheet: Managing Empty Containers

Virginia Waste Minimization Program
Vol. 1 Issue I

A Fact Sheet from the Virginia Waste Minimization Program on managing empty containers.

Managing Empty Containers

As concerns, about ground water contamination increase in Virginia, the disposal of empty containers that held hazardous materials becomes increasingly more difficult. Landfill operators are concerned about the effects of even small amounts of residues. Therefore, businesses must take measures to assure that they have options for their empty containers.

Remember: virgin materials not removed from drums are materials that your company purchased. Employees should be trained not only to empty drums and containers completely but also should be shown why this practice is important. For example: waste from ten drums, each with 1/2 inch residue, represents a loss to your company of 10 gallons of product. At a cost of $5.00/gal, the residue represents a $50.00 loss to your company.

Options for Handling Empty Containers and Drums:

Options for handling empty containers may be affected by the decisions you make in purchasing chemicals. Careful consideration of the kinds of containers in which you receive chemicals should minimize your difficulty in disposing of empty drums and containers. The range of alternatives noted below will be affected by your company's purchasing and handling practices.

Return Drums to Your Supplier

Requesting your chemical supplier to provide materials to you in drums that can be returned makes this option viable. This option will work only if you have made the use of returnable containers a part of the purchase agreement with your chemical suppliers. Returnable drums often require drum deposits and must be maintained in good condition in order for deposits to be refunded. They must be returned with all bungs. rings and closures in place.

Contract with a Barrel Conditioner

Requesting that chemicals be supplied in drums made of heavy gauge steel means that the drums may be reconditioned; 18-20 gauge steel drums are heavy enough for repeated trips with chemicals. If your chemical suppliers will not provide returnable drums or containers, you should require heavy gauge steel drums. 18-20 gauge drums will cost you more money to buy, but when they are empty, a good outlet exists for them at minimal or no cost to your company by way of a reputable barrel conditioner.

Use Scrap Processors or Landfills for Drum Disposal

Scrap processors or landfills may take empty drums and containers under certain conditions. Depending on the processor or landfill, some or all of the following requirements must be met for containers that once held hazardous substances:

• Containers must be drained thoroughly.
  
• Residues must be removed by rinsing the drums.
  
• Certification forms stating that the drums contain no hazardous waste must be signed.
  
• Drums must have one end or both ends removed. Drums and containers must be crushed.
  
• A charge may exist for disposal.
  

Hazardous Waste Containers

It is important to note that containers that have held hazardous waste are subject to very strict definitions of "empty". The following is a list of conditions.

1. A container that has held any hazardous waste. except a waste that is a compressed gas or that is identified as an acute hazardous waste, is empty if.
   
   1. AU wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container (e.g., pouring pumping, and aspirating): and
      
   2. No more than 2.5 centimeters (one inch) of residue remain on the bottom of the containers or inner liner; or
      
   3. (1) No more than 3% by weight of the total capacity of the container remains in the container or the inner liner if the container is less than or equal to 1 1 0 gallons in size; or (2) No more than 0.3% by weight of the total capacity of the container remain in the container or inner liner if the container is greater than 110 gallons in size.

2. A container that has held a hazardous waste that is a compressed gas is empty when the pressure in the container approaches atmospheric.

3. A container that had held an acute hazardous waste is empty if.
   
   1. The container has been triple rinsed using a solvent capable of removing the commercial chemical product or manufacturing chemical intermediate: and
      
   2. The container has been cleaned by another method that has been shown in the scientific literature, or by tests conducted by the generator, to achieve equivalent removal; or
      
   3. The inner liner that prevented contact of the conunercial chemical product or manufacturing chemical intermediate with the container has been removed.

Editor's note: Under the Superfund Amendments of 1986, hazardous residue left in empty containers may subject a company to liability for the clean-up of property where such containers are found. Therefore, while a drum may be empty under hazardous waste rules, caution should be used in the handling of empty drums containing residues of hazardous substances.

(This article is reprinted with permission from the Minnesota Technical Assistance Program (MnTAP). Modifications have been made to tailor this fact sheet for use in Virginia.)

This Waste Reduction Fact Sheet is provided as a service of the Virginia Waste Minimization Program, a technical assistance program of the Virginia Department of Waste Management.

For more information on opportunities to reduce waste contact:

Virginia Waste Minimazation Program
llth Floor Monroe Building, 101 North 14th Street
Richmond, Virginia 23219
804-371-8716 or 1-800-552-2075
TDD 804-371-8737