ALL DRUMS MUST BE RCRA EMPTY BEFORE TCC WILL ACCEPT THEM FOR PROCESSING

Twin City Container, Inc. receives metal and poly containers only under the following National Environmental Protection Agency Regulations (NEPAR) 40 CFR 173.29:

With regards to most regulated residues, EPA’s 40 CFR 261.7 says “ A container is empty if:

1) All waste has 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. 

2) No more than 2.5 centimeters (one inch) of residue remain on the bottom of the container.”

EPA has explained this rule, saying “one inch of waste material is an overriding constraint and may remain in an empty container only if it cannot be removed by normal means. The rationale for this provision is that there are certain tars and other extremely viscous materials that will remain in the container even after the container is emptied by normal means.”

For residues of products specifically listed by name in 40 CFR 261.33, EPA says the container is empty only if the container has been tripled-rinsed using a solvent capable of “removing” the product, or has been cleaned by another method shown to achieve equivalent removal.

DOT’s 49 CFR 173.29 says that all openings on the empty container must be closed, and that all markings and labels must be in place as if the drum were full of its original contents. A DOT shipping paper is not required for transportation of a drum for reconditioning via contract or private motor carrier. DOT placarding is not required for vehicles carrying empty containers.