Russ,
I am not sure that this is entirely correct Perhaps you are not taking the full regulation into context. While there may be instances where a SQG or LQG may treat
hazardous waste on-site the only way to get around having a Federal or State permit to do so is if "a facility which beneficially uses or reuses, or legitimately recycles or reclaims the waste, or treats the waste prior to reuse, recycling or reclamation.
At the time (1980's), EPA indicated that wastes often have little independent economic value, but are recycled to avoid disposal costs. Unless the wastes are
extremely valuable (as in the case of precious metal-containing wastes), there is little incentive to avoid leaks and spills. EPA saw no reason to reconsider the issue at that time.
The Agency disagrees that on-site treatment should be encouraged by exempting those generators of 100-1000 kg/mo from the RCRA permitting requirements. To the
extent that these generators are conducting the same treatment/storage or treatment/disposal as other permitted facilities, their on-site treatment activities pose a potential risk to human health and the environment. Therefore, reduced or eliminated permitting
requirements would be inappropriate.
Most times, a generators want to treat waste to remove the RCRA characteristics to avoid disposal costs. If an generator did want to treat hazardous waste and
were able to do so without a permit, there would need to be a building that meets the requirements, a treatment plan, and emergency response plan, and recordkeeping (this includes elementary neutralization). The savings of treatment may not be worth the extra
work, not to mention worst case scenarios. There is some burden to demonstrate that treatment is effective.
Further, once wastes are treated, they may not always be drain disposed. Waste discharged to a public sewer system that are exempted from RCRA are regulated under
the Clean Water Act.
I be interested in hearing more, so would Jo and Monique.
Be well,
James
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU]
On Behalf Of Monique Wilhelm
Sent: Friday, October 11, 2019 3:49 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Iodine clock reaction waste
Me too, especially because this is one area that people poorly understand.
_________________________________________________________
Monique Wilhelm, M.S., NRCC Certified CHO
ACS CHAS Secretary|2017 CERM E. Ann Nalley Award Recipient
Laboratory Manager|Adjunct Lecturer|Chemistry Club Advisor
Department of Chemistry & Biochemistry|University of Michigan-Flint
On Fri, Oct 11, 2019 at 2:36 PM Wagoner, Jo <jwagoner**At_Symbol_Here**butler.edu> wrote:
I would love to know the history, thanks! -Jo
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of "rphifer**At_Symbol_Here**WCENVIRONMENTAL.COM" <rphifer**At_Symbol_Here**WCENVIRONMENTAL.COM>
Organization: WC Environmental, LLC
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Date: Friday, October 11, 2019 at 2:21 PM
To: "DCHAS-L**At_Symbol_Here**PRINCETON.EDU" <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Subject: Re: [DCHAS-L] Iodine clock reaction waste
The responses I've seen to this question are technically correct; it is certainly best to make it part of the procedure if you're going to "treat" the by-product prior to declaring it a waste. However, treatment in an accumulation container is allowed under RCRA. The reference is 51FR 10168, March 24, 1986. There are two conditions - the container must be kept closed except when adding or subtracting waste, and accumulation standards apply for time limits and container management.
In other words, it may be legal to treat the hazardous byproducts from a lab experiment in a satellite accumulation area as part of the waste accumulation process. You would need to consider compatibility with any other substances being accumulated in the waste "container", which in this case might be a reaction vessel.
I'd be glad to go into the history of why this rule exists if anyone cares.
Russ
Russ Phifer
WC Environmental, LLC
1085C Andrew DriveWest 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 James Saccardo
Sent: Friday, October 11, 2019 2:02 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Iodine clock reaction waste
Ann,
Pam is right, if the material is declared a waste and then you add thiosulfate, it is considered treatment of hazardous waste (oxidizing - EPA D001) to remove the hazardous characteristic and you permit to perform such treatment. Thiosulfate is a reducing agent in this case.
However, if the students add the thiosulfate as part of the last step in the experiment and then add it to the waste container, the waste should not have any hazardous characteristics or EPA listed constituents and can be managed as non-hazardous waste (assuming the pH is between 5 and 9).
Of course you need to consider the volume, your municipal water regulations, municipal waste water treatment methods, and ultimate fate.
Perhaps setting up a profile with your TSDF and direct shipping the waste in large volume containers (5 to 16 gallon DOT rated drums) - the cost might be much less than you expect (vs. the cost of thiosulfate) and environmentally sound.
Be well,
James
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Wagoner, Jo
Sent: Friday, October 11, 2019 1:31 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Iodine clock reaction waste
Hi Pamela.
We looked into this process in the past, and found out that unless you have a license to treat waste, you cannot do this unless it is part of the lab experiment itself.
-Jo
Jo Wagoner
Stockroom Coordinator
Butler University
Department of Chemistry & Biochemistry
4600 Sunset Ave., GH300A
Indianapolis, IN 46208
Office 317-940-9972
NAOSMM Safety Committee Chair
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of "Klotz, Ann" <klotz**At_Symbol_Here**SIENA.EDU>
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Date: Friday, October 11, 2019 at 8:18 AM
To: "DCHAS-L**At_Symbol_Here**PRINCETON.EDU" <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Subject: Re: [DCHAS-L] Iodine clock reaction waste
Pamela,
Any drain disposal of chemicals should be evaluated by your local water authority.
Ann
On Thu, Oct 10, 2019 at 11:49 AM Pam Auburn <aubu**At_Symbol_Here**hotmail.com> wrote:
I was wondering if anyone here has experience with this reaction and the proper waste disposal
IO3- + 3 HSO3- --> I- + 3 SO4-2 + 3 H+
IO3- = 8 I- + 6 H+ --> 3 I3- + 3 H2O
I3- + HSO3- + H2O --> 3 I- + SO4-2 + 3 H+
2 I3- + starch --> starch-I5- complex (blue)
I saw from something published in 1996 "For disposal of waste products, combined all of the solutions used in this experiment with solid sodium thiosulfate until the mixture is no longer blue. The resulting clear mixture can then be discarded by flushing down the drain upon the addition of water."
Mitchell, R.S. Iodine Clock Reaction. J. Chem. Educ., 1996, 73 (8), 783.
Is this still acceptable?
Thanks
Pamela Auburn, PhD
2041 Branard
Houston TX 77098
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