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Date: Mon, 6 Apr 2009 08:30:45 -0400
Reply-To: List Moderator <ecgrants**At_Symbol_Here**UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: List Moderator <ecgrants**At_Symbol_Here**UVM.EDU>
Subject: Re: Use of Vented Caps on Liquid Waste SAA Containers
From: "Russ Phifer"
Date: April 6, 2009 8:28:00 AM EDT (CA)
Subject: RE: [DCHAS-L] Use of Vented Caps on Liquid Waste SAA Containers
I can=92t speak to California requirements, but the intent of the
requirement to maintain a closed container, as explained in the
preamble to the May 19, 1980 Hazardous Waste Regulations is =93to
minimize emissions of volatile wastes, to help protect ignitable or
reactive wastes from sources of ignition or reaction, to help prevent
spills and to reduce the potential for mixing incompatible wastes and
direct contact of facility personnel with waste.=94 This has generally
been interpreted to mean containers of hazardous waste being stored
must have all container opening covers tightly affixed to the
container when waste is not actually being added or removed from the
container. However, since the HPLC discharge is described as fairly
constant, many states may interpret this as =93waste being added to the
container=94, meaning there is would be no regulatory objection to the
discharge as described.
Russ Phifer
Russ Phifer
WC Environmental, LLC
1085C Andrew Drive
West Chester, PA 19380
610-696-9220x12/ fax 610-344-7519
rphifer**At_Symbol_Here**wcenvironmental.com
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