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Hazardous material classification question

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#42950

Hazardous material classification question | 26 July, 2006

We're dealing with upcoming (Oct. 2008) requirements for secondary containment of hazardous material that are dependant upon volume. 20 gallons or 200 lbs. (dry).

Our washer has a 60 gallon wash sump and a 35 gallon rinse sump. The challeng is how to communicate to the authorities that a 60 gallon sump with 4 oz. of metal solids in it is not 60 gallons of hazmat? Are you guys dealing with this, and if so, how?

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#42978

Hazardous material classification question | 27 July, 2006

We think all you need to do is explain: * Which portion of the 60 gallons of water contains the hazmat * How you seperate and contain that portion from the non-contaminated portion when your washer leaks

We'd go for a waiver

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#43077

Hazardous material classification question | 30 July, 2006

We think you hit the nail on the head.

FWIW, I haven't heard back from them when I brought this up. I suspect it's going up the ladder. Not necessarily a good sign, but sumpin's brewin'.

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