From: "Noce, Anthony" <ANoce**At_Symbol_Here**HALEYALDRICH.COM>
Subject: Re: [DCHAS-L] Question about salvage IBC units
Date: Thu, 16 Jun 2016 22:45:17 +0000
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 376CFBB5-F95C-4186-A2C7-7F7F2180C2A4**At_Symbol_Here**
In-Reply-To <523B38AD-9C80-4444-8540-AD683F71510D**At_Symbol_Here**>

There's a lot of places I could go with this, but I'll keep it simple: If you could pour the stuff out of it, it was not RCRA empty. Check the definition again. 

That's not to say there aren't issues...

Sent from my iPhone - please excuse any typos
(518) 466-5608

On Jun 16, 2016, at 14:38, ILPI Support <info**At_Symbol_Here**ILPI.COM> wrote:

I figure that some of you with the EPA and RCRA experience might find this an interesting situation.

A colleague of mine here in New Jersey decided to go green and purchase a used IBC container to make his own mega rain barrel. For those not familiar with these, they are the industry standard big brother to a 55-gallon drum, and are usually in the ballpark of 1000 liters (275 gallons).  See  These are used for everything from food syrup, to firefighting foam concentrate, to hazmats and more.

He picked up one of the several dozen of these available at a local industrial surplus place. They cautioned him him that they couldn't be used for drinking water and that he should rinse them out before using them. Key point - all of the label information on these had been removed.  He just assumed that it had been properly emptied.

His surprise came when he got his home. There was at pretty good amount of residue in the tank, maybe a gallon, of a white fairly viscous material that was not water soluble (suspect some sort of polymer resin component) and a few quick home chemistry experiments indicate it won't harden with say, some free radical initiator..  So probably something that has to undergo an condensation polymerization, I would imagine.

Regardless of whatever it is, he's now rather reasonably upset that the seller has expected him to basically dispose of a gallon of unknown waste into his sewer, yard, water system, whatever.

As I read the RCRA (which I never have until today; not my area), I see that containers this size are indeed "empty": and by that definition the container with its gallon of unknown substance is now considered to be a nonhazardous solid waste under Federal regs (assuming the material did not fall into the category of acute hazardous waste).  But if you manage to pour the stuff out of it, then wouldn't that material be regulated? And so here we have a consumer stuck with an unknown hazmat?

We'd be interested in your thoughts on this, particularly as to whether resale of the RCRA-clean-but-not-truly-clean unlabeled containers is even legal (is selling waste to consumers legal?) and what steps my colleague might take if he finds himself with too much time on his hands…

Thanks all,

Rob Toreki

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