From: "Biersack, Mary" <Mary.Biersack**At_Symbol_Here**WESTPHARMA.COM>
Subject: Re: [DCHAS-L] Hydrofluoric acid solution neutralization...
Date: Thu, 31 Mar 2016 14:53:37 +0000
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: AA020255FC11BE4BA08B0AC8248D7B29767E2B1B**At_Symbol_Here**USVFMBX01.WestPharma.net
In-Reply-To


Hello,

My understanding is that you would not be able to treat this mixed waste by neutralizing because it contains a listed waste (HFl acid) that has a characteristic other than corrosivity (it is also toxic) and it doesn’t matter what the concentration of the HFl acid is. 

 

What if you could separate the HFl acid from the nitric acid into separate waste streams, would you then be able to neutralize the nitric acid and dispose of this down the sewer?  If the nitric acid waste is not a listed waste for any characteristic other than corrosivity than I would think yes you could treat it through neutralization and sewer if your water sewer rules allow.  I am in this situation now where I have a detergent that enters our sewer system at a pH of 10 which should be fine to sewer according to the RCRA corrosivity definitions however our local sewer plant does not allow a pH over 9 unless we get approval through them via sewer application or permit. 

 

I am interested in hearing how others interpret this treatment rule because I struggle with it. 

 

Thanks,

Mary

 

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu] On Behalf Of Cieslinski, Gerald B
Sent: Wednesday, March 30, 2016 6:54 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: [DCHAS-L] Hydrofluoric acid solution neutralization...

 

We have a new project that is generating around 10 gallons of an aqueous solution per week consisting of <1% of hydrofluoric acid and nitric acid that is being collected and disposed of as hazardous waste. The PI wants to know if he can neutralize this solution and dispose as wastewater. There are two issues at play:

 

·        Does this waste qualify under the exemption to treat hazardous waste without a permit? The waste is hazardous because of its corrosivity (D002), and is listed as U134. But does the toxicity of the hydrofluoric acid, even at these very low concentrations, disqualify it from the treatment exemption?

·        If it can be treated, is there a widely accepted methodology for neutralization? I have seen multiple procedures either using calcium chloride solutions to bind the fluorine then flocculate into a cake for later disposal, or using sodium bicarbonate solutions for pH neutralization.

 

Regards,

 

G. Benjamin Cieslinski, EH&S Specialist III

Tulane University, Office of Environmental Health & Safety (OEHS)

Mailing: 1430 Tulane Avenue $8480, New Orleans, LA 70112-2699

Office: 1440 Canal St. Suite 1156

Direct: (504) 988.3996

Cell: (504) 491.5122

 

For non-emergency OEHS assistance, please go to OEHS Help Desk

©Confidentiality Notice: The documents accompanying this transmission contain confidential privileged information. The information is the property of the sender and intended only for use by the individual or entity named above. The recipient of this information is prohibited from disclosing the contents of the information to another party. If you are neither the intended recipient or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that disclosure of contents in any manner is strictly prohibited. Please notify G. Benjamin Cieslinski at Tulane University by calling 504.988.3996 immediately if you received this information in error.

 

 

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