Re: Crushing LSC Vials

["John DeLaHunt" <jdelahunt@cc.colorado.edu>]

> If the vials contain RCRA (Resource Recovery Conservation Act) regulated
> chemicals like toluene or xylene they must be disposed of properly.  It
> probably makes little sense from a safety and personnel standpoint to
> open them and pour them into a drum.  The term "process" has a very
> specific meaning under RCRA.  Crushing vials is probably not regarded as
> part of a "closed process".  Hence a permit is needed to do such a thing.
> Why don't you just collect the vials in drums and send them out to a
> place like QUADREX.

Even better, get your researchers or faculty to switch to a scintillating
fluid with a flash point above 140 F.

> You will find some help in 40 CFR parts 260 on all of this.  A "mixed
> waste" consists of RCRA regulated chemicals mixed with licensed
> radioactive materials in any concentration.

You may not find "help", per se, in 40 CFR 260-268, but you will find the
EPA's RCRA regulations.

Hope this helps.

John

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