Once again U-listed waste refers to "DISCARDED COMMERCIAL CHEMICAL PRODUCTS, OFF-SPECIFICATION SPECIES, CONTAINER RESIDUES, AND SPILL RESIDUES THEREOF--TOXIC WASTES" - copied directly from your linked document. None of these categories apply to this "HF" waste. It is spent process waste containing dilute "HF."
Hydrofluoric acid is actually a U listed waste with two classifications (toxic and corrosive). The waste code is U134. You can review the code at https://www3.epa.gov/epawaste/inforesources/data/br91/na_apb-p.pdf.
Hydrofluoric acid in not considered as a RCRA Toxic ( e.g., it is not D-listed). Being a fluorine compound doesn't make it toxic (I brush my teeth with a fluoride compound). It can be neutralized under RCRA. As was pointed out, the issue would be then, what do you do with the liquid which has residual fluorine. Would need to meet your wastewater standard.
It is my understanding that this would not qualify since the hydrofluoric acid is classified as toxic and corrosive. Elementary neutralization can only be performed on wastes that exhibit the corrosivity characteristic.
A good source for treatment methodologies is Margaret-Ann Armour's book called "Hazardous Laboratory Chemical Disposal Guide".
Martin W. Bell, M.S. CIH CSP
Director, Environmental Compliance
Department of Environmental Health and Safety
400 North 31st Street
Philadelphia, PA 19104
Tel: 215.895.5892 | Fax: 215.895.5926
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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