May 6, 2016, a question from a past attendee of one of my Training Seminars (unfortunately, I don’t provide Training Seminars anymore. Check out my website for other training options: Onsite Training or Webinar Training).
I took a class with you a couple years ago.
I have another question for you. I figure if you don’t know the answer you might be able to direct me to where I’d find it.
We would like to do a lab test which requires sodium arsenite which is a hazardous waste. In the test, the sodium arsenite will be greatly diluted. Does the diluted solution then become hazardous waste?
I would greatly appreciate any direction you can give me.
My reply the next day (May 7, 2016):
I will try to answer your question.
- If the diluted solution of sodium arsenite is to be discarded, it must be managed as a solid waste. The term “solid waste” as used by USEPA and most states is not limited to wastes in a solid form. A “solid waste” could be a solid, liquid, semi-solid, or containerized gas.
- The generator of a solid waste must conduct a hazardous waste determination.
- Sodium arsenite and the process of generation you indicate does not appear to be a listed hazardous waste. It does not appear on any of the following codifications of listed hazardous waste:
- Hazardous waste from non-specific sources (F-codes).
- Hazardous waste from specific sources (K-codes).
- Discarded commercial chemical products, off-specification species, container residues, and spill residues thereof (P-codes for acutely toxic and U-codes for toxic).
- Sodium arsenite does not appear to display the characteristic of any of the following hazardous wastes:
- Ignitability (D001)
- Corrosivity (D002)
- Reactivity (D003)
- Arsenic is a toxin identified by the USEPA at 40 CFR 261.24. It is possible, therefore, that it displays the characteristic of toxicity (D004 – D043) for arsenic (D004).
- A waste containing arsenic may be a toxic hazardous waste (D004) if it contains a leachable concentration of arsenic above the regulatory threshold of 5.0 mg/L. In other words, if it displays the characteristic of toxicity.
- Analysis by the Toxicity Characteristic Leachate Procedure (TCLP) is one way to determine the concentration of a toxin in leachate derived from a waste in a solid form. If the waste is already in a liquid form, the total concentration of the toxin must be determined.
- Another – and less expensive – method to determine if your waste displays the characteristic of toxicity is the “Rule of 20”. Read more about TCLP and alternatives to it here.
- It is possible, if greatly diluted, that the waste you discard may not be a toxic hazardous waste.
Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste
Daniels Training Services