Date: Thu, 18 Mar 2010 15:52:11 -0400
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.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: Evaporating HW

From: John Burnham <burnhamj**At_Symbol_Here**>
Date: March 18, 2010 3:01:05 PM EDT

Intentional evaporation of a flammable solvent waste is not permitted under RCRA Subtitle D. 

From: "Halim A. Hasan" <HALI**At_Symbol_Here**>
Date: March 18, 2010 2:59:38 PM EDT

No. Waste is hazardous once generated. You are able to treat in the waste container while it's being generated, but dilution is a form of treatment that is regulated. This is considered a release, which is not allowed.

Halim A. Hasan, CHMM 
Environmental Health & Safety Officer 
Radiation Safety Officer 
Lundbeck Research USA 
201.350.0119 Office 
201.315.4842 Mobile 

From: "Subramanian, Venkatraman" <Venkatraman.Subramanian**At_Symbol_Here**aa. com>
Date: March 18, 2010 3:13:39 PM EDT

This circumvents EPA's RCRA Rule of properly managing hazardous waste and also may violate CAA Section 112 as I believe acetone is a HAP.

Also, "small amounts" (how much) can trigger other compliance requirements if your facility is classified as CESQG, SQG or LQG.

Finally disposing them in a compliant manner may be a bit expensive (proper storage, signage, shipping, manifesting to TSDF etc.) but in the long run could avoid hefty fines.

Venkat Subramanian, Ph.D,
Regional Environmental Manager
American Airlines
4333, Amon Carter Blvd, MD 5285
Ft Worth, Texas 76155
venkatraman.subramanian**At_Symbol_Here**aa. com

From: "Eric Clark" <erclark**At_Symbol_Here**>
Date: March 18, 2010 3:14:58 PM EDT
Subject: Re: Evaporating HW 

The short answer is no.  You cannot intentionally evaporate away hazardous waste.  Here's the problem with that idea:  1. Failure to count number of pounds of HW per month,  2. Open Hazardous Waste Container inside the fume hood, 3. Illegal disposal of F003 Hazardous Waste.  
The same goes for allowing HW from the ICP/AA/HPLC/etc. to discharge directly into an open waste bottle beneath the instrument and allowing the waste to continuously evaporate away.  
There are other ways to manage that waste - but that would be a longer answer.   


Eric Clark, MS, CCHO, CHMM 
Safety & Compliance Officer 
Los Angeles County Public Health Lab

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