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

-------
 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.

-------
                                                         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

-------