Here’s a follow-up on the regulator’s perspective (being a former HW inspector) on why volatile characteristic HW (e.g. D001) cannot be allowed to simply evaporate away: It’s illegal disposal of hazardous waste. Letting volatiles continuously evaporate out of an un-stoppered bottle in the fume hood is no different than pouring the bottle in a large tub in the parking lot and letting it evaporate there (I’ve seen that, too). There’s a reason why being able to fit 10s or 100s of liters of waste into a 1L bottle and never emptying it and saving all that money on HW disposal just seems too good to be true.
Eric Clark, MS, CCHO, CHMM
Los Angeles Trade Technical College
Los Angeles CA 90015
I am assuming that the laboratory waste generated would be meet the classification criteria as defined by EPA, (federal or state, whichever is applicable) as a hazardous waste (HW). With that assumption and knowing that you are generating very volatile waste, I would focus upon the intent of the HW rules for a Satellite Accumulation Point, specifically to “keep the container closed.” The intent is to insure the contents will not create additional hazards if knocked over or spilled. You cannot simply leave the lid off, I think that would be a violation from any regulators perspective. I would require the installation and use of an appropriate filtering device to allow the pressurized vapors to be collected on an appropriate absorption/adsorption media. (Possibly activated charcoal if the volatile liquids are organics.) This would prevent the pressure build-up within the container(s) and possibly prevent the container from being over-pressurized. If considering a pressure relief valve, I would verify the designed/tested pressure rating of the waste collection container and ensure the selection of a pressure release device under that limitation. A closed, but filtered container will not release the contents when spilled. Personally, I would focus on meeting the HW rules regarding satellite accumulation, filtering the volatile aspects through an appropriate filter. I would absolutely simply allow the lab to leave the waste container open.
A colleague asked me if there were ever requirements for pressure release valves on lab waste collection containers particularly for very volatile liquids.
In absence of a pressure release valve, some wonder if one can simply “leave the lid off” which seems to be a problem from many perspectives.
If there are any best practices that can be sited or regulations, I would be interested.
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