Date: Sun, 5 Apr 2009 21:57:30 -0700
Reply-To: Paul Sonnenfeld <p_sonnenfeld**At_Symbol_Here**HOTMAIL.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Paul Sonnenfeld <p_sonnenfeld**At_Symbol_Here**HOTMAIL.COM>
Subject: Re: Use of Vented Caps on Liquid Waste SAA Containers
Comments: To: davidbunzow**At_Symbol_Here**
In-Reply-To: <000001c9b646$8adaf0a0$a090d1e0$**At_Symbol_Here**net>

Last year I conducted a compliance audit at a federal lab in Alameda. The H PLC equipment that they used had a fairly constant discharge which w as captured in a 4-liter glass jar with teflon stopper with two holes.  ; One hole was for the discharge tubing, the other was for a ver y small diameter "breather" tube (capillary tube).  The 4-liter jar was in a secondary containment tray which was labeled as a satellite accumu lation area in accordance with the state's HW rules.  The local CUPA seemed to accept this practice due to the presence of the secondary contai nment unit and the fact that the 4-liter bottle was under the watchful eye( s) of the "operator" when the HPLC was functioning.  I'd suggest con tacting your CUPA for some "guidance".
Respectfully yours,

Paul Sonnenfeld, CPEA


Date: Sun, 5 Apr 2009 16:30:44 -0700
From: davidbunzow**At_Symbol_Here**COMCAST.NET
Subject: [DCHAS-L] Use of Vented Caps on Liquid Waste SAA Containers
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU



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


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

[2] improper addition of aliphatic organics into th ese 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 wa ste containers in SAAs. Specifically,


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


[B}  Does EPA or your state regulatory agenc y have either regulations or interpretations that define or interpret =93co ntainer closure=94 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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