Rob – that issue is more common than a lot of people realize. I suspect he did not buy this from a reconditioner; he most likely got it from an end user. Responsible resellers of drums and 275 gallon totes go through a thorough reconditioning process and remove all residues. Those facilities have wastewater treatment permits to handle the rinseates, including detergents, used in the cleaning process, and you will always get a sparkling clean container. Your colleague should have carefully inspected the container before taking it (I know, too late now).
As to the legality, the container certainly meets the <1 inch or 3% capacity RCRA rule. It is unlikely that what you describe would be listed or have a characteristic, but some quick & dirty tests should help him decide if the gallon of waste is safe to solidify and dispose of in household trash. The best way to clean it out is to loosen the resin with a pressure hose, and then pump the liquid out through a filter to catch anything that hasn’t emulsified.
He can be greener than the company that sold him this bill of goods. Caveat Emptor.
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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 https://en.wikipedia.org/wiki/Intermediate_bulk_container 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": https://www.law.cornell.edu/cfr/text/40/261.7 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…
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