Sulfuric Acid Spill Case Study
Spills of products contained in drums and totes onto soil are a common occurrence in an industrial setting. Whether accidentally puncturing containers with a forklift or losing material during a transfer operation, spills of material with a pH ≤2 or ≥12.5 has implications for generation of corrosive HW. The elementary neutralization treatment exemption affords the generator a unique opportunity for excavation and ex situ treatment on-site. Further, is it possible to treat the contaminated soil in situ? Consider the options available when a 275-gallon tote of 93% by weight sulfuric acid (roughly 3,900 lb of sulfuric acid) is punctured during unloading and completely drains into soil in an outdoor storage yard. We will assume the tote contents are characterized by only EPA Waste Code D002 when discarded.
Ex Situ Treatment
In Situ Treatment
f In Situ treatment within an Area of Contamination (AOC) is not subject to RCRA permitting requirements nor LDR considerations including treatment standards f If the material is not being excavated, the spill area is not considered a point of generation and therefore, in situ remediation is not considered land disposal f Mix and rototill soda ash into the contaminated soil f Document the following: • Sampling and testing of contaminated soil • Delineation made to determine the extent of the AOC • Remediation procedures such as mixing of high pH material to neutralize the acid • Verification sampling and testing to document the final pH of the soil f It is recommended to maintain in situ remediation records for the life of the facility f Confirm no additional state-specific requirements
f Sulfuric acid-contaminated media is excavated and placed into a lined roll-off and determined to be corrosive f Develop a brief waste analysis plan to describe how the soil will be treated and verification of treatment f The lined roll-off is considered an “elementary neutralization unit” and neutralization within the unit is exempt from RCRA permitting f Mix soda ash (sodium bicarbonate) into the roll-off to de-characterize the material as solid waste which is no longer corrosive f Dispose of the de-characterized soil in a RCRA Subtitle D landfill (additional requirements apply to redeposit on-site) • Include notice and certification of treatmen t with the initial shipment f If the material was treated immediately upon excavation, the mass does not count towards the facility’s monthly HW generator total f Maintain all notices and waste analysis data for at least 3 years f Confirm no additional state-specific requirements
EHS Quarterly / trinityconsultants.com 15
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