Date: Thu, 18 Mar 2010 15:15:16 -0700
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: Paul Sonnenfeld <p_sonnenfeld**At_Symbol_Here**HOTMAIL.COM>
Subject: Re: Evaporating HW
In-Reply-To: <2DCB7D06-8BB3-45D8-955E-E9D71CAF7B43**At_Symbol_Here**>

Time out folks!  Please read the land-disposal restrictions (40 CFR 268) very carefully.  While it is clearly prohibited to dilute a lis ted waste (F, K, U, P) it may be acceptable to dilute a characteristi c waste (D-code) so that it no longer meets the characteristic.

I wo uld recommend contacting the POTW that receives the waste from lab sinks an d specifically (not hypothetically) ask if the POTW, as a permit-by-rule facility can receive de minimis quantities of the flammable solvent.  ; I know of a federal research lab in Georgia that has written permission from the POTW to discharge up to 2 liters per day of F003 waste.

Pa ul Sonnenfeld, CPEA

Date: Thu, 18 Mar 2010 15:52:11 - 0400
From: ecgrants**At_Symbol_Here**UVM.EDU
Subject: Re: [DCHAS-L] Evaporating HW
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU

From: John Burnham <burnhamj**At_Symbol_Here**>
Date: March 18, 2010 3:0 1:05 PM EDT

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

= ==
From: "Halim A. Hasan" <HALI**At_Symbol_Here**>
Date: March 18, 2010 2:59:3 8 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 treatmen t that is regulated. This is considered a release, which is not allowed.< /font>

Halim A. Hasan, CHMM 
Environmental Health & Safety Officer 
Radiation Safety Officer 
Lundbeck Researc h USA 
< div style="margin-right: 0px; margin-bottom: 0px; margin-left: 0px; ">201 .350.0119 Office 
201.315.4842 Mobile  ;

< /div>

From: "Subramanian, Venkatraman" <Venkatraman.Subramanian**At_Symbol_Here**>
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 r equirements if your facility is classified as CESQG, SQG or LQG.

Finally disposin g them in a compliant manner may be a bit expensive (proper storage, sign age, shipping, manifesting to TSDF etc.) but in the long run could avoi d hefty fines.
< br>

Venkat Subr amanian, Ph.D,
Regional Environmental Manager
Ameri can Airlines
4333, Amon Carter Blvd, MD 5285
< font style="font: 12px Helvetica;" face="Helvetica" size="3">Ft Wor th, Texas 76155

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.  
< div style="margin-right: 0px; margin-bottom: 0px; margin-left: 0px; ">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 man age that waste - but that would be a longer answer.   


Eric Clark, MS, CCHO, CHMM< span class="ecxApple-converted-space"> 
Safety &a mp; Compliance Officer 
Los Angeles County Public Health Lab

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