I think there are at least 3 considerations in determining the treat ability of this waste.
- Federal RCRA
- State waste rules
- Local wastewater permits and rules
Federal RCRA would allow neutralization if:
- the waste is “spent” HF carrying the D002 waste code only.
- The waste is not D001 ignitable due to Oxidizing characteristics
It sounds like your dilute and used nitric/HF solution is a "spent waste" (used in some process or generated in the lab). So you have a D002 not a U listed waste. In addition this solution would not be considered oxidizing at this concentration. The EPA defers to the DOT to define oxidizers. Nitric acid mixtures must be greater than 50% concentration to be considered oxidizing (UN1796).
I cannot comment on your state or wastewater permit rules but this is likely allowable under the RCRA treatment exemption.
Here is the neutralization rule reference: 40 CFR 270.2(c)(2)(v)
And the D001 regulatory reference:
Title: Section 261.21 - Characteristic of ignitability.Context: Title 40 - Protection of Environment. CHAPTER I - ENVIRONMENTAL PROTECTION AGENCY (CONTINUED). SUBCHAPTER I - SOLID WASTES (CONTINUED). PART 261 - IDENTIFICATION AND LISTING OF HAZARDOUS WASTE. Subpart C - Characteristics of Hazardous Waste.
Michael D. Cimis, MA, CIH, CHMM
Senior Associate Director
Dartmouth College, EHS
37 Dewey Field Road
Hanover, NH 03755