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Evaporating Hexavalent Chrome waste and sending remains off for treatment

We have always treated our hex-chrome wastes to form trivalent chrome, and precipitated this, caked and shipped off site as a haz-waste. Presently we are asking if we could use an evaporator, and not bother to treat, but instead ship a waste stream of solids (mostly salts) containing hex-chrome, as well as whatever else would be present (some ferricyanide, and lots of other typical finishing line stuff). Has anyone ever tried this approach? Know any good reasons why this couldn't be done?

Thanks!

David H. Duncan
- Ponderay, Idaho, USA
2003

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Let me forego technical considerations and rants, and just tell you that a good reason to not do it is that there is a regulator out there somewhere who doesn't want you to do it, and who will make your life miserable by asserting that you are operating an unlicensed treatment and disposal facility if you do it.

Ted Mooney, P.E.
Striving to live Aloha
finishing.com - Pine Beach, New Jersey
2003

Ted -- thank you for your reply -- I appreciate your thoughts on this. We have determined that the waste treating company we presently pay to take our wastes would be able to take a waste material containing hex chrome. They would treat and dispose. We presently are permitted to treat, to reduce to the trivalent state, precipitate and cake. I believe this new route would be legal, but would appreciate your further thoughts, and also any considerations on technical difficulties we now do not foresee.

David H. Duncan
- Ponderay, Idaho, USA
2003

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2003

I've been around too long and seen too much nonsense to be dispassionate about waste treatment issues, David :-)

Back in the early 70's when the development document was being drafted for the Department of the Interior, just about the only person in America who really knew anything in depth about the subject was my boss, Dr. Leslie Lancy, who had already designed and installed a thousand metal finishing waste treatment systems. He stridently warned that the whole premise of the development document was a faulty and foolish concentration on the harmless water instead of the harmful process solutions, because the beltway bandits commissioned to write it actually had so little actual experience in the subject. He said this document would doom us to decades of pollution, paperwork, frivolousness, and closed shops (which of course is just exactly what it did). In fact the "zero discharge" system the document writers espoused as a demonstration of the feasibility of their foolish paper study was soon put in a box and locked away in an arsenal, probably next to Indiana Jones' Arc of the Covenant :-)

One of the harmful consequences of this foolish bureaucratic mis-focus on water instead of waste was that eventually many regulators around the country became convinced that somehow the purpose of an industrial wastewater treatment system is to deal with water, not process waste--and that consequently any waste treatment operation other than precipitation and clarification of rinsewater would be a violation of the permit! It's very hard to stamp out a toxic meme like this once it is foolishly let out in the wild.

Although evaporation of rinsewater for return to the plating tank is perfectly accepted, as is sludge drying and the use of ion-exchange to remove contaminants from end-of-pipe, one plating shop operator I knew was charged with a felony for evaporating his cyanide rinse water end-of-pipe in the fashion you are describing for your chrome rinse water. Although the charge was later dropped, I would never take the chance of evaporating a waste product. Regulators have been encouraged by the politicians and the public to adopt a confrontational, "What is THIS?!" attitude towards waste treatment; it stopped progress in its tracks, and makes a proposition like yours too risky to even consider.

I would probably attempt to collect the chrome content on ion exchange resin, and ship the ion exchange canisters to your recycler, and continue to treat what escapes with conventional end-of-pipe precipitation.

Just one person's opinion.

Ted Mooney, P.E.
Striving to live Aloha
finishing.com - Pine Beach, New Jersey

Different regions of EPA interpret the CFR differently. Last I knew, the Minneapolis region is adamantly enforcing it the way that Ted Says, while the Dallas region agrees with your interpretation. The way the CFR is written, you cannot do anything! to your wastewater. IE, you need a waste treatment license. EPA said OOPS, that is not what we meant and published a "clarification" in the "record". Unfortunately, many of the EPA enforcers are not aware of this small entry in the congressional record. They do know that they can not mess with conventional wastewater treatment but do not know why, just that is the way we have always done it. Since what you want does not fit that description as they know it, you therefore cannot. For a small fee, Lion Technology -NJ- I think, will provide you with a copy of that critical piece of paper. Amazing- EPA/congress never changed the CFR to reflect the modification.

James Watts
- Navarre, Florida
2003

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Thanks James, but risking a felony charge because you might be in an EPA zone that interprets things differently than another zone is too big a risk for a sane person. Our federal government seems to be doing absolutely everything within it's power to raze The Arsenal of Democracy that won two world wars and replace it with The People's Arsenal of China :-(

Yike. I'm gonna watch American Idol or something; trying to figure out how to survive in the manufacturing sector these days, with the government and the public aligned against you, is nothing but depressing :-)

Regards,

Ted Mooney, P.E.
Striving to live Aloha
finishing.com - Pine Beach, New Jersey