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Proper Satellite Drum Storage

Q. I am a large quantity generator following the 90 day rules. We have drums for sattelite collection of spent filters from our plating line. RCRA rules say these drums should be closed except when adding materials. The drums are open top style with a bolt ring.

We add filters to these drums at least twice a day. There is no residual liquid, we let them drain before we put them into the waste drum.

I am looking for clarification of what constitutes a "closed" drum in my case. Specifically, is it enough to just put the top on during the collection period without the bolt ring? If I were required to use the bolt ring it would take a lot more labor.

Please give me some guidance on this as I was cited for not having a cover on these in the past.

Joel Tomasetti
- Petersburg, Virginia

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