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