David: Listers=85 In reviewing published accidental explosion descrip
tions involving either aqua regia or sulphuric acid + hydrogen peroxide,
there appear to be several common (not terribly surprising) themes. These a
re: [1] pressure build-up inside tightly capped glass c
ontainers from ongoing decomposition reactions, and; [2] improper addition of aliphatic organics into th
ese containers resulting in overpressure, explosion and sometimes fire.
P>
My question of list participants and colleagues is
their perspective/experience on using vented caps to prevent build-up on wa
ste containers in SAAs. Specifically, [A} In your experience, is the use of ven
ted caps a permitted practice under RCRA or your state EPA agency? [B} Does EPA or your state regulatory agenc
y have either regulations or interpretations that define or interpret =93co
ntainer closure=94 as requiring it be tightly in place on the container as
opposed to loosely in place to prevent pressure build-up? BTW, I am in California but am interested in your
response no matter where you are located. TIA and make it a great day!! David
Last year I conducted a compliance audit at a federal lab in Alameda. The H
PLC equipment that they used had a fairly constant discharge which w
as captured in a 4-liter glass jar with teflon stopper with two holes. 
; One hole was for the discharge tubing, the other was for a ver
y small diameter "breather" tube (capillary tube). The 4-liter jar
was in a secondary containment tray which was labeled as a satellite accumu
lation area in accordance with the state's HW rules. The local CUPA
seemed to accept this practice due to the presence of the secondary contai
nment unit and the fact that the 4-liter bottle was under the watchful eye(
s) of the "operator" when the HPLC was functioning. I'd suggest con
tacting your CUPA for some "guidance".
Respectfully yours,
Paul Sonnenfeld, CPEA
Date: Sun, 5 Apr 2009 16:30:44 -0700
From: davidbunzow**At_Symbol_Here**COMCAST.NET
Subject: [DCHAS-L] Use of Vented Caps on Liquid Waste SAA Containers
To:
DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
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