vvEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9444.11(84)
TITLE: Clarification of K062 - Spent Pickle Liquor
• Listing
APPROVAL DATE: 7-27-84
EFFECTIVE DATE: 7-27-84
ORIGINATING OFFICE: Office of Solid Waste
0 FINAL
D DRAFT
STATUS:
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A- Pending OMB approval
B- Pending AA-OSWER approval. ....
[ ] C- For review &/or comment '
[ ] D- In development or circulating
REFERENCE (other documents):
headquarters
OSWER OSWER OSWER
/£ DIRECTIVE DIRECTIVE Di
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PART 261 SUBPART D - LISTS DOC: 9444.11(84)
Key Words: Pickle Liquor
Regulations: 40 CFR 260.20, 260.22, and 261.30
Subject: Clarification of K062 - Spent Pickle Liquor Listing
Addressee: Directors, Waste Management Divisions, Regions I-X
Originator: John H. Skinner, Director, Office of Solid Waste
Source Doc: #9444.11(84)
Date: 7-27-84
Summary:
OSW defines "steel finishing operations" as processes which impart de • (.red
mechanical and surface characteristics to steel. Although the background docu-
ment for K062 addresses only spent pickle liquor from the iron and steel industry,
the Agency intended the listing to cover all industries engaged in pickling
steel. These processes include: acid pickling, alkaline cleaning, cold
reduction, blast cleaning, cold drawing, cold rolling, galvanizing, coating
with organic and inorganic compounds, tempering, coating of steel with metals,
tin plating, and electropolishing.
Concentrations of hazardous constituents for which spent pickle liquor was
listed may differ among industries based on process variations. Wastes that do
not meet the criteria for which pickle liquor was originally listed may be
excluded from regulation on a site-specific basis (§260.20 and §260.22). Also,
lime stabilized waste pickle liquor sludge generated by the iron and steel
industry is excluded from the list.
The following wastes generated by pickling prior to electroplating are
F006 wastes: all acidic wastes from the electroplating process and sludge
generated from mixing acid wastes from pretreatment of metal using acidic baths
with spent plating bath solutions. If the pickle liquor is lime treated prior
to disposal, the sludge from this process is a hazardous waste by virtue of the
"residue rule."
Acidic wastes from electroplating that remain untreated or are segregated
from other process waste and treated separately are considered K062.
EPA intended that the K062 listing pertain to all acids used in the pickling
of steel.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
27 JUL 1984'
OC*«CE OF
SOLID WASTE AND 6MERGENCV
MEMORANDUM
Subject: Clarification of K062 - Spent Pickle Liquor Listing
From: John H. Skinner, Director V«f$
Office of Solid Waste M
To: Directors, Waste ManagemenVoivisions
EPA Regions I-X
Within the past year, several EPA Regional Offices have
requested clarification of EPA Hazardous Waste No. K062 -
Spent pickle liquor from steel finishing operations. This
interpretive memorandum addresses several questions and issues
which have been raised regarding the listing.
1) Which operations/processes are considered "steel finishing
operations" and thus are covered by the listing?
The Office of Solid' Waste (OSW) defines "steel finishing
operations".as processes which impart desired mechanical
and surface characteristics to steel. The following
processes are included in this description and are
intended to be covered by the K062 listing, provided
that spent pickle liquor is generated:
1) acid pickling
2) alkaline cleaning
3) cold reduction
4) blast cleaning
5) cold drawing
6) cold rolling
7) galvanizing
8) coating with organic and inorganic compounds
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9) tempering I/'
10) coating of steel with metals
11) tVn plating
12) electropolishing
Although the background document for K062 addresses "only
spent pickle liquor from the iron and steel industry, the
Agency intended the listing to cover all industries engaged
in the pickling of steel. Indeed, many persons who generate
spent pickle assumed that the listing was much broader then
indicated in the background document.2/ Furthermore, on
January 4, 1984, (see Notice of Availability of Data and
Request for Comments, 49 FR 427) the Agency stated that steel
finishing is practiced by a diverse group of manufacturers.
The large number of notifiers indicate that generators in
many industry categories are aware of this interpretation.
Recently, representatives from the porcelain industry
informally challenged OSW on its interpretation of the K062
listing. It is their position that the listing pertains
only to the iron and steel industry.V However, for reasons -
stated earlier, to the extent that facilities within this
industry category pickle steel prior to coating or enameling,
the spent pickle liquor (or any waste derived therefrom) is
considered the listed waste.
The Agency realizes that concentrations of the hazardous
constituents of concern for which spent pickle liquor was
listed may differ among industries based on process variations;
however, wastes that do not meet the criteria for which pickle
liquor was originally listed may be excluded from regulation
on a site-specific basis (delisting pursuant to 40 CFR 260.20
and 260.22). The Agency also will consider industry-wide
petitions to delist these wastes*
17Although coating of steel with metal (electroplating) is
~" considered "steel finishing,' the Agency did not intend
the K062 listing to include electroplating processes that
generate spent pickle liquor. This would be duplicative
since electroplating wastes are specifically covered
under F006.
2/ Data from the RCRA Notification data base indicate that
"~ a diverse group of industry categories pickle steel and
generate spent pickle liquor (e.g., metal working machinery
and equipment; refrigeration and service industry machinery;
coating, engraving and allied services; sanitary services;
aircraft and parts, and others).
3/ Approximately half the facilities within the porcelain
industry have notified that they generate either K062 or
the lime stabilized waste pickle liquor sludge.
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At this time, the Agency has taken action on a ruleraaking
petition submitted by the American Iron and Steel Institute
(AISI) to remove lime stabilized waste pickle liquor sludge
(LSWPLS) (formerly referred to as lime neutralized waste
pickle liquor sludge) from the presumption of hazardousness
contained in the regulations. This exclusion however, applies
only to LSWPLS that is generated by the iron and steel industry
(SIC Codes 331 and 332). (See 49 FR 23284 - 2328S, June 5,
1984 for specific details regarding the conditions of the
exclusion).
2) Many electroplating operations pickle prior to electroplating.
Is the waste generated from this process considered F006,
K062, D002, or both FOQ6 and K062?
In considering petitions to delist electroplating
waste, the Agency has stated that the F006 listing
includes the acidic wastes (i.e., spent pickle liquor)
from the electroplating process. Electroplating
operations typically pretreat the metal using acidic
baths prior to electroplating. The acidic wastes
from this process are generally mixed with spent
plating bath solutions and lime treated. Sludge
generated from this process is considered FOQ6. For
example, an electroplater acid pickles metal parts
as part of the electroplating process. The resultant
wastewater (including spent pickle liquor and rinsewater)
is neutralized with lime. Sludge generated from
this process is F006. In another example, a galvanizer
also pickles metal parts prior to galvanizing. Since
galvanizing is not included under the electroplating
category, spent pickle liquor from this process
would be. considered EPA Hazardous Waste K062. If
the pickle liquor is lime treated prior to disposal,
the sludge from this process is a hazardous waste by
virtue of the "residue rule" (S261.3(c)(2)).
In cases where acidic wastes from the electroplating
operation remain untreated or are segregated from
other process waste and treated separately, the waste
is then considered K062 (or lime stabilized waste
pickle liquor sludge).
3) Does the K062 listing pertain to spent pickling acids
other than those listed in the background document for
K062 (i.e., H2SO4, HCL, and HN03 •»• HF)?
In developing the background document for K062,
the Agency listed the most commonly used pickling
agents. However, we intended the listing to include
all acids used in the pickling of steel.
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I trust, that this memorandum adequately clarifies the
K062 listing". Should you have questions, or require
additional information, please call Jacqueline Sales at
FTS 382-4770.
cc:
Gene Luceco, OWPE
Kirk sniff, OECM
Bill Hedeman, OWRR
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