LSPA October 2022 Practice Tip of the Month

The following LSPA practice tip was presented at the October 2022 Membership Meeting, which was held virtually through the Zoom webinar platform, on October 27, 2022.  

Practice Tip of the Month: 
Did you know MassDEP's position is that discarded carbon canisters, as a generated waste, are a sludge and subject to 310 CMR 30.302: Determination of Whether a Waste is Hazardous? Accordingly, per policy HW94‐007, a spent carbon canister that contains hazardous waste constituents from a listed hazardous waste source must be managed as a hazardous waste, regardless of whether the carbon canisters were used to treat groundwater or vapors from groundwater or soils.