oEPA
                United States
                Environmental Protection
                Agency
        Office o*
        Solid Waste and
        Emergency Response
                DIRECTIVE NUMBER
                TITLE: RC
           9444.12(84)
                Acid from Electro-
polishing of Stainless Steel
                APPROVAL DATE: 7-30-84
                EFFECTIVE DATE: 7-30-84
                ORIGINATING OFFICE
                01 FINAL
                D DRAFT
                  STATUS:
                            [  ]
           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
ME    DIRECTIVE   DIRECTIVE    Dl

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PART 261  SUBPART D - LISTS
                                                DOC:  9444.12(84)
Key Words:

Regulations

Subject:


Addressee:


Originator:

Source Doc:

Date:

Summary:
Pickle Liquor

40 CFR 261.33

Regulatory Status of Spent Acid from Electropollshing of Stainless
Steel

Kent Gray, Utah State Department of Health, Hazardous Waste
Program, P.O. Box 2500, Salt Lake City, Utah 84110

Matthew Straus, Chief, Waste Identification Branch

#9444.12(84)

7-30-84
     The spent pickle liquor listing applies to those processes where acid is
used to impart a desired surface characteristic to steel or steel products.
The listing includes all acids used in the pickling/cleaning of steel.

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 Kent Cray
'Otah State'Department of Health
 Hazardous waste Frog ran
 P.O. Box 2500
 Salt Lake City, Utah  14110

 Dear Mr. -Grayi

     . This letter responds to your recent inquiry regarding the
 regulatory status of spent acid fro* electropolishing of stainless
 steel (i.e./ whether the vast* is considered EPA Hazardous wast*
 Mo. JtO«2—Sp«nt pickl* liqoor froa.st««l finiahing operations).
*        '*"•!•         "•                .*
 .'.'..  As yod statsd ia aa *arli«r eonV«r»atioa with Jaequi Salesr
>9< »y staff r«lectropolishiM is a process which «tilise« ft •.-_.
'•fititre of solfvrie and phoejhoric scids (pa 1.0) to iatpart a
.shiny finish to stainless steel.  As MS. Sales explained, the
 spent pickle liquor listing was intended to include those processes
 where acid Is used to imjxart" a desired surface characteristic to. '..
 •teei or steel products i in particular, to renove oxide scale. V--~-
 Although the background document for the listing addresses only
 the conwonly used pickling acids (i.e., hydrochloric/ sulfurlc,
 nitric, and hydrof]^/ric), the Agency intended the listing to  *  "
 include all acids used in the pickling/cleaning of steel.  Thus,
"spent acid fro* eleetropolishing is considered the listed waste.

      Z trust that this letter adequately addresses your concerns.
 Should you have additional questions or require further information,
 please call Jaequi Sales at  (202) 382-4770.

                                      Sincerely,
                                      Matthev Straus
                                      Chief
                                      Waste  Identification  Branch
 WH-562B:JSales:bm:7/23/84

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