Laurie – I’d say you are accurate. The laboratory wastewater rule exempts toxic (T) wastewaters generated by laboratory operations from RCRA as long as the total percent of the laboratory wastewaters don’t exceed 1% of the facility’s total discharge. It may be that the student’s former institution was using that as a basis for legal disposal. However, the pH of that mixture can be expected to be about 1.8-2.0, which would mean the waste would carry the characteristic of corrosivity. The laboratory waste exclusion does not apply in this case as described. If the pH were adjusted, perhaps, but it doesn’t sound like they are doing that. The dilution should result in a flashpoint above 140F and the mixture is therefore not flammable, so corrosivity is the sticking point. No other listing or characteristic applies.

Proper disposal involves either acid-base neutralization and discharge, within the limits of the local sewer authority’s discharge parameters and ideally with their permission, or removal and disposal by your hazardous waste vendor.

Russ

Russ Phifer

WC Environmental, LLC

1085C Andrew Drive

West Chester, PA  19380

Fax 800-858-6273

Cell - 610-322-0657

rphifer**At_Symbol_Here**wcenvironmental.com

http://www.wcenvironmental.com

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From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Laurie Yoder
Sent: Tuesday, October 04, 2016 1:00 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] HPLC solvent disposal

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