PA
United States
Environmental Protection
Agency
OH.ce of
Solid Waste ana
Emergency Response
DIRECTIVE NUMBER: 9441.12(84)
TITLE: Status of Supernatant from Lime Neutralization of
Spent Pickle Liquor
APPROVAL DATE: 6-4-84
EFFECTIVE DATE: 6-4-84
ORIGINATING OFFICE: office of solid waste
E FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
D B — Signed by Office Director
DC — Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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PART 261 SUBPART A - GENERAL
DOC: 9441.12(84)
Key Words: Pickle Liquor, Exclusion
Regulations: 40 CFR 261.4(a)(1)(ii)(2)
Subject: Status of Supernatant from Lime Neutralization of Spent Pickle
Liquor
Addressee: Karl Klepitsch, Chief, Waste Management Branch, Region V
Originator: Matthew Straus, Acting Chief, Waste Identification Branch
Source Doc: #9441.12(84)
Date: 6-4-84
Summa ry:
Supernatant is not included in the industry-wide exclusion of lime-stabilized
waste pickle liquor sludge (LSWPLS) generated from the iron and steel industry.
The exclusion pertains only to sludge generated from the treatment process.
Supernatant is a hazardous waste. However, it is not regulated when
stored in a tank connected to the wastewater treatment system. When supernatant
is discharged either to navigable waters pursuant to the provisions of the
Clean Water Act'or to a POTW, it is excluded from the definition of solid waste,
and therefore the definition of hazardous waste [40 CFR 261.4(a)(1)(ii)(2)].
Supernatant removed from the wastewater treatment system, and otherwise managed,
is regulated under RCRA.
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9441.12 (84)
Status of Supernatant from Lime Neutralization of Spent
Pickle Liquor - . • • -
Matthew Straus, Acting Chief
Waste Identification Branch (WH-562B)
Karl Klepitsch, Chief
Haste Management Branch (Region V)
This memorandum addresses your inquiry regarding the
status of supernatant from line treatment of spent pickle
liquor,
First, you are correct in stating that the supernatant
is not included in the industry-wide exclusion of line-
stabilized waste pickle liquor sludge (LSWPLS) (formerly
known as line neutralised waste pickle liquor sludge)
generated from the iron and steel industry. The exclusion
pertains only to sludge generated from the* treatment process.
Second, the supernatant is a hazardous waste. However,
it is not regulated when stored in a tank connected to the
wastewater treatment system. (This material is generally
stored in a sedimentation tank (clarlfier) prior to discharge)
Zn addition, when discharged, the supernatant is excluded
from the presumption of being a solid waste, and thus, a
hazardous waste (see 40 CFR 261.4U) (1)( 11 ) (2) ) , if it is
discharged either to navigable waters pursuant to the
provisions of the Clean Water Act or to a POTVi. Supernatant
that is removed from the wastewater treatment system, and
is otherwise managed, is regulated under RCRA.
WH-562B:JSALES/MSTRAUS/pes/475-B551/5/31/84 Disk MS840201
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