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.
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.
G. Benjamin Cieslinski, EH&S Specialist III
Tulane University, Office of Environmental Health & Safety (OEHS)
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