Date: Tue, 7 Apr 2009 10:00:25 -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: "Long, Don" 
Date: April 7, 2009 9:36:48 AM EDT (CA)
Subject: RE: [DCHAS-L] Use of Vented Caps on Liquid Waste SAA Containers

All -

I'm sure the EPA stuff I've posted below is info everyone has already  

seen, however, for what it's worth;

- if a container is venting, it is "leaking".
- for the most part, incompatibles shouldn't be "wasted" together  
(there are exceptions).
- I'm not sure if an HPLC direct discharge container is classified as  

a SAA, so it might not be a good example.

- the comment below 265.177 seems to answer some of the questions.

=A7 265.173   Management of containers.
  (a) A container holding hazardous waste must always be closed during  

storage, except when it is necessary to add or remove waste.
(b) A container holding hazardous waste must not be opened, handled,  
or stored in a manner which may rupture the container or cause it to  
[ Comment: Re-use of containers in transportation is governed by U.S.  

Department of Transportation regulations, including those set forth in  

49 CFR 173.28.]
[45 FR 33232, May 19, 1980, as amended at 45 FR 78529, Nov. 25, 1980]
=A7 265.176   Special requirements for ignitable or reactive waste.
Containers holding ignitable or reactive waste must be located at  
least 15 meters (50 feet) from the facility's property line.

[ Comment: See =A7265.17(a) for additional requirements.]

=A7 265.177   Special requirements for incompatible wastes.
(a) Incompatible wastes, or incompatible wastes and materials, (see  
appendix V for examples) must not be placed in the same container,  
unless =A7265.17(b) is complied with.

(b) Hazardous waste must not be placed in an unwashed container that  
previously held an incompatible waste or material (see appendix V for  

examples), unless =A7265.17(b) is complied with.

(c) A storage container holding a hazardous waste that is incompatible  

with any waste or other materials stored nearby in other containers,  
piles, open tanks, or surface impoundments must be separated from the  

other materials or protected from them by means of a dike, berm, wall,  

or other device.

[ Comment: The purpose of this is to prevent fires, explosions,  
gaseous emissions, leaching, or other discharge of hazardous waste or  

hazardous waste constituents which could result from the mixing of  
incompatible wastes or materials if containers break or leak.]

Don A. Long
Southwest Research Institute Laboratory
Pine Bluff Chemical Agent Disposal Facility
PO Box 20130
White Hall, AR  71612

Previous post   |  Top of Page   |   Next post

The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.