Date: Sun, 5 Apr 2009 16:30:44 -0700
Reply-To: David Bunzow <davidbunzow**At_Symbol_Here**COMCAST.NET>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: David Bunzow <davidbunzow**At_Symbol_Here**COMCAST.NET>
Subject: Use of Vented Caps on Liquid Waste SAA Containers


In reviewing published accidental explosion descriptions involving either aqua regia or sulphuric acid + hydrogen peroxide, there appear to be several common (not terribly surprising) themes. These are:

[1] pressure build-up inside tightly capped glass containers from ongoing decomposition reactions, and;

[2] improper addition of aliphatic organics into these containers resulting in overpressure, explosion and sometimes fire.

My question of list participants and colleagues is their perspective/experience on using vented caps to prevent build-up on waste containers in SAAs. Specifically,

[A}  In your experience, is the use of vented caps a permitted practice under RCRA or your state EPA agency?

[B}  Does EPA or your state regulatory agency have either regulations or interpretations that define or interpret “container closure” as requiring it be tightly in place on the container as opposed to loosely in place to prevent pressure build-up?

BTW, I am in California but am interested in your response no matter where you are located.

TIA and make it a great day!!


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