Tank or Container?
by Jeff Mayhugh
The hazardous waste management requirements for containers differ significantly from the requirements for tanks. To be in compliance, you must properly determine whether your hazard- ous waste management unit is a container or a tank. Both “container” and “tank” are defined in Ohio Administrative Code (OAC) rule 3745-51-10 [paragraphs (A)(17) and (A)(114)].
What is a container?
A container is any portable device in which a material is stored, transported, treated, disposed of or otherwise handled.
What is a tank?
A tank is a stationary device, designed to contain an accumulation of hazardous waste, which is constructed primarily of non-earthen materials (for example, wood, concrete, steel, plastic) that provides structural support and “Tank system” means a hazardous waste storage or treatment tank and its associated ancillary equipment and containment system.
The key to properly identifying whether you have a tank or a container hinges on the characteristics of the unit (portable or stationary) and how the unit is used at your facility. If you do not use it to move the hazardous waste, it is most likely a tank. If the unit is used to collect the material in one location and it is then moved to another location, it is a container.
If you accumulate hazardous waste in a reinforced fiberglass, 500-gallon vessel that is never moved, the vessel is a tank.
If you accumulate your hazardous waste in the same vessel but you periodically move it with a forklift to another part of the facility to pump the waste into a tank truck, the vessel is a container.
What are the differences between the hazardous waste requirements for tanks and containers?
Containers must be in good condition, compatible with the hazardous waste they store, and kept closed except when adding or removing waste. The area where containers are stored must be inspected at least weekly.
For tanks, you must provide secondary containment that meets the requirements in OAC rule 3745-66-93. All tank systems, until such time as secondary containment meeting these requirements is provided, must have performed an integrity assessment and must complete a leak test on it annually. The tank must have a leak detection system that is capable of detecting releases within 24 hours. All above-ground portions of the tank system must be inspected daily.