From: "Russ Phifer"
Date: April 6, 2009 8:28:00 AM EDT (CA) Subject: RE: [DCHAS-L] Use of Vented Caps on Liquid Waste SAA Containers I can=92t speak to California requirements, but the intent of the requirement to maintain a closed container, as explained in the preamble to the May 19, 1980 Hazardous Waste Regulations is =93to minimize emissions of volatile wastes, to help protect ignitable or reactive wastes from sources of ignition or reaction, to help prevent spills and to reduce the potential for mixing incompatible wastes and direct contact of facility personnel with waste.=94 This has generally been interpreted to mean containers of hazardous waste being stored must have all container opening covers tightly affixed to the container when waste is not actually being added or removed from the container. However, since the HPLC discharge is described as fairly constant, many states may interpret this as =93waste being added to the container=94, meaning there is would be no regulatory objection to the discharge as described. Russ Phifer Russ Phifer WC Environmental, LLC 1085C Andrew Drive West Chester, PA 19380 610-696-9220x12/ fax 610-344-7519 rphifer**At_Symbol_Here**wcenvironmental.com
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