Laurie,

I recommend separating the waste waters from the steel vs. stainless and having EACH of them tested for presence of hazardous waste components. Iron, copper, etc. may be present for the steel, but they may expect hex-chrome from the stainless plasma cutting.

The key questions are: if the contaminants are present above regulatory levels of hazardous wastes AND what employees could be exposed to during the process. They have two methods to determine waste disposal characterization, generator knowledge or analytical results. Occupational exposures during the process are a separate material issue that needs to be quantified before those questions can be answered.

They need to look at two aspects, employee exposure during generation v. disposal, which are completely different and need to be kept in their respective aspects.

BruceV

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Laurie Yoder
Sent: Sunday, September 23, 2018 2:17 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] hexavalent chromium

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas