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We at Reactives Management have been ACS members since 1981. We are also CHAS members and contributed to Handbook edited by Dr. Alaimo.
We work with peroxide-forming materials, nitrated aromatics, alkali metals, perchloric acid fume hoods and most other materials that meet the EPA definition of reactivity characteristic waste, code D003.
We have worked in 42 states. One confounding factor is the status of “treatment” as defined and interpreted by various state agencies. In some states, if the residues are manifested off-site as hazardous waste, no waste treatment permit is required. In other states, the federal definition of treatment is used (change in DOT hazard class; make a materials easier or safer to transport and dispose) and a permit is required. In some states, a permit application is one or two pages. In some states, a waste treatment permit application may be 15 to 20 pages. Our worst case situation was (i) EPA waste treatment permit, (ii) EPA air permit, and (iii) DOT permit to move the untreated material to a suitable waste treatment site. Those three permit applications were approximately 100 pages long. There will be a charge for permit application preparation.
Some generators (federal agencies, state agencies, industrial organizations) require us to list them on our insurance. Some other generators do not. These insurance requirements have ranged from $1,000,000 to $5,000,000. The higher limits, the higher the premiums. Some police departments (bomb squads) will post insurance, some will not.
Some states charge a fee for issuing a permit. The permit fees we have paid have ranged up to $2,400.
The bottom line of all this is cost is very difficult to predict without some site- and state- specific information.
George Walton
Reactives Management Corporation
Chesapeake, VA
757-436-1033
From:
DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of
Bell,Martin
Sent: Tuesday, September 21, 2010 10:08
AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L]
Peroxide Question
We utilized a company called Rapid Response, Inc which is now Environmental Waste Minimization, Inc. The specialist is Tom Gundlach.
Martin W. Bell, CSP CHMM
Drexel University
Department of Environmental Health and Safety
Environmental Health and Safety Manager
Telephone : 215-895-5892
Cell Number: 215-778-4278
Fax Number: 215-895-5926
From:
DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of
ACTSNYC**At_Symbol_Here**CS.COM
Sent: Tuesday, September 21, 2010 9:26
AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L]
Peroxide Question
Hmmm. These
people really sound useful in the art and theater shops where we find
ancient MEK-P and related resin catalysts. Where do we find these
high hazard deactivation specialists? Monona
In a message
dated 9/21/2010 9:10:55 AM Eastern Daylight Time, mwb32**At_Symbol_Here**DREXEL.EDU writes:
We
utilize a high hazard deactivation specialist to deactivate peroxide
containing materials. The specialist utilizes a hydraulic remote opening
device to open expired peroxide forming chemicals. Once the container is
open the material is deactivated using ferrous salts, amines, aqueous
sodium metabisulfite and stannous chloride, and sodium hydroxide. The
deactivation material will depend on the type of peroxide former. Our
hazardous waste hauler accepts the material once it is
deactivated.
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