About This Archive | DCHAS-L 2023 Index | DCHAS-L Yearly Index | DCHAS-L Home Page
From: rphifer**At_Symbol_Here**WCENVIRONMENTAL.COM
Subject: Re: [DCHAS-L] When is a chemical defined as waste?
Date: May 12, 2023 23:15 UTC
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: <25cfc01d98527$ae8e7250$0bab56f0$@wcenvironmental.com>
In-Reply-To: <1866592279.858587.1683906793743**At_Symbol_Here**mail.yahoo.com>
An interesting perspective on lab treatment because of the assumption that the nature of the “waste” would be changed. Yes, the devil is in the details… EPA has NEVER been really clear about when a waste becomes a waste, particularly in a laboratory setting. The assumption is that once it meets the Subpart C criteria (as a solid waste) then there are limits regarding on-site treatment. However… EPA is also clear that treatment as part of a process BEFORE the material becomes a waste is fine. For example, in an academic laboratory where a class does an experiment that results in a by-product, it is perfectly legal to add an additional step to render the material non-hazardous or less hazardous – before it is formally declared or labeled a waste. If you transport a hazardous by-product to a central accumulation area and treat it, that’s illegal. If you put it in a waste accumulation container in the lab hood and label it a waste, then it is too late to then treat it legally without a permit.
Bottom line, I’m with Mary Beth on this. Don’t declare it a waste yet, quench it, and then characterize it. I don’t even see the specific need to follow a treatment standard UNTIL you declare it a waste.
Russ
Russ Phifer
WC Environmental, LLC
1085C Andrew Drive
West Chester, PA 19380
610-322-0657
rphifer**At_Symbol_Here**wcenvironmental.com
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Monona Rossol
Sent: Friday, May 12, 2023 11:53 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] When is a chemical defined as waste?
That is a small but very important difference. Thanks. I learned something today. Monona
-----Original Message-----
From: Mary Beth Mulcahy <mulcahy.marybeth**At_Symbol_Here**GMAIL.COM>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Thu, May 11, 2023 8:23 am
Subject: [DCHAS-L] When is a chemical defined as waste?
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 ;)
--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org
--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org
