Date: March 18, 2010 2:59:38 PM EDT
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
Halim A. Hasan, CHMM
Environmental Health & Safety Officer
Radiation Safety Officer
Lundbeck Research USA
Date: March 18, 2010 3:13:39
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
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
Amon Carter Blvd, MD 5285
Date: March 18, 2010 3:14:58
Subject: Re: Evaporating
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.
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.
Clark, MS, CCHO, CHMM
Safety & Compliance Officer
Los Angeles County Public Health Lab
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