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Subject:
Re: [DCHAS-L] Haz Waste Storage
Date:
Sep 29, 2022 12:36 UTC
Author:
Richard Palluzi <000006c59248530b-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
From:
Jeffrey Lewin <jclewin**At_Symbol_Here**MTU.EDU>
Subject:
Re: [DCHAS-L] Haz Waste Storage
Date:
Sep 29, 2022 12:39 UTC
Reply-To:
ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID:
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In-Reply-To:
<CA+KeQVv8b0cGmetmADCn-YJ07tE8xPeYFgthWyEd=4EnxCt2gA**At_Symbol_Here**mail.gmail.com>
Monique,
I'll qualify this in that we are an SQG so I don't follow LQG rules in detail. That said, I've not seen any guidance from EGLE (for other on the list, that is our state regulator for hazardous waste) that 1) requires secondary containment IN A SATELLITE ACCUMULATION AREA (aka the lab); of course, it is a "best practice and isn't prohibited) or 2) prohibits storage of satellite accumulation containers (or their secondary containers) from being on the floor.
Note, there are secondary accumulation requirements for SQGs (more than 1000kg of liquid waste; LQGs it looks like any liquid waste) in the waste accumulation area.
I'll add that during our inspection (4 years ago so pre-adoption of the Generator Improvement Rules, aka GIR) our waste inspector did not comment about containers placed on the floor.
Some references that might be helpful:
Jeff
Hi Everyone,
Can hazardous waste be stored in a secondary container on the floor in a lab? If not, which reg is it: EPA or OSHA?
Thank you,
Monique
--
Jeff Lewin
Director of Chemical Laboratory Operations
Research Integrity Office
Laboratory Operations
205 Lakeshore Center
Michigan Technological University
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