Date: Mon, 6 Apr 2009 08:30:45 -0400
Reply-To: List Moderator <ecgrants**At_Symbol_Here**UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: List Moderator <ecgrants**At_Symbol_Here**UVM.EDU>
Subject: Re: Use of Vented Caps on Liquid Waste SAA Containers

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

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