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Subject: Bretherick Online
Date: Thu, 18 Mar 2010 15:15:56 -0700
Author: NEAL LANGERMAN
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Subject: Re: Evaporating HW
Date: Thu, 18 Mar 2010 19:13:42 -0400
Author: List Moderator
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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**uvm.edu>
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
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.
=
==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>
===
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
===
Date: March 18, 2010 3:14:58 PM EDT
Subject: Re:
Evaporating HW
Alan,
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
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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