The way it is usually explained is if it is part of the process, i.e. are you quenching the sodium in still as part of the "production" process?  Or, are you collecting a bunch of sodium metal chunks in a waste container then quenching (treating) the waste after the fact?

Essentially, once you've collected it as waste you can't treat it (corrosivity neutralization is a notable exception) without a permit.

This LION posting might help.

Do’s and Don’ts: Treating Hazardous Waste Without a RCRA Permit

Jeff

On Fri, May 12, 2023 at 9:52 AM Mary Beth Mulcahy <mulcahy.marybeth**At_Symbol_Here**gmail.com> wrote:

All, 

I was talking to a friend who formerly worked at the EPA about quenching sodium metal at the end of a reaction and his initial response was, "you aren't allowed to do that, EPA doesn't let you treat waste like that." LIke all good friends, he dug into the issue and sent me this link, https://rcrapublic.epa.gov/files/14618.pdf, highlighting this paragraph (he acknowledged that his initial response was incorrect):

'If the waste is being treated on-site and the treatment residue is destined to be land disposed, the generator still has responsibilities under the land disposal restrictions (LDR) program.  The LDRs require that hazardous waste must be treated by a specified method or to a specified constituent concentration level before it (or its residue) may be placed in the land.  The generator must know the treatment standard applicable to his/her waste and either treat to meet the treatment standard or send it to a treater to do so.  Generators who treat waste on-site to remove a hazardous characteristic must prepare a waste analysis plan if treatment occurs in units that do not require a RCRA permit (see 40 CFR 262.34(a)(4) for LQGs, and 40 CFR 262.34(d)(4) forSQGs).  In addition, there are some generator paperwork requirements associated with the LDRs(40 CFR268.7(a))."

 

As he said to me, "the devil is in the details," so whoever is doing the treatment must be treating it to a specified method and the person must know the treatment standard prior to treating the waste. This is probably why it is strongly discouraged (and he thought illegal).

My friend pointed out that this is only an issue if you are changing the haz waste profile of the material. If you say it is a metal and you treat it and still call it that same metal after treating, it gets disposed of the same way and it doesn't really matter. If you treat it and say it is now something else, then you can get into trouble. 

My thinking is that quenching the sodium is a safety issue first, that once dealt with, then renders the bi-products a waste issue, and that the sodium metal isn't yet waste until it is quenched. After quenching it (say using a procedure like the one described here, https://sites.chemengr.ucsb.edu/~ceweb/faculty/scott/Chemical%20SOPs/Sodium.pdf) you would then dispose of the by-products appropriately. 

So, I was curious what the DCHAS brain would say about this...when do you have to designate something (like sodium metal used in a distillation still) as waste? Do you define that point in time for your researchers? 

Mary Beth...not Koza, the other DCHAS Mary Beth ;)

 

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Jeff Lewin

Director of Chemical Laboratory Operations

Research Integrity Office

Laboratory Operations

205 Lakeshore Center 

Michigan Technological University

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