From: "Long, Don"Date: April 7, 2009 9:36:48 AM EDT (CA) Subject: RE: [DCHAS-L] Use of Vented Caps on Liquid Waste SAA Containers All - I'm sure the EPA stuff I've posted below is info everyone has already seen, however, for what it's worth; - if a container is venting, it is "leaking". - for the most part, incompatibles shouldn't be "wasted" together (there are exceptions). - I'm not sure if an HPLC direct discharge container is classified as a SAA, so it might not be a good example. - the comment below 265.177 seems to answer some of the questions. =A7 265.173 Management of containers. (a) A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste. (b) A container holding hazardous waste must not be opened, handled, or stored in a manner which may rupture the container or cause it to leak. [ Comment: Re-use of containers in transportation is governed by U.S. Department of Transportation regulations, including those set forth in 49 CFR 173.28.] [45 FR 33232, May 19, 1980, as amended at 45 FR 78529, Nov. 25, 1980] =A7 265.176 Special requirements for ignitable or reactive waste. Containers holding ignitable or reactive waste must be located at least 15 meters (50 feet) from the facility's property line. [ Comment: See =A7265.17(a) for additional requirements.] =A7 265.177 Special requirements for incompatible wastes. (a) Incompatible wastes, or incompatible wastes and materials, (see appendix V for examples) must not be placed in the same container, unless =A7265.17(b) is complied with. (b) Hazardous waste must not be placed in an unwashed container that previously held an incompatible waste or material (see appendix V for examples), unless =A7265.17(b) is complied with. (c) A storage container holding a hazardous waste that is incompatible with any waste or other materials stored nearby in other containers, piles, open tanks, or surface impoundments must be separated from the other materials or protected from them by means of a dike, berm, wall, or other device. [ Comment: The purpose of this is to prevent fires, explosions, gaseous emissions, leaching, or other discharge of hazardous waste or hazardous waste constituents which could result from the mixing of incompatible wastes or materials if containers break or leak.] Don A. Long CHO / STS Southwest Research Institute Laboratory Pine Bluff Chemical Agent Disposal Facility PO Box 20130 White Hall, AR 71612 870-541-4930
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