&EPA
United States
Environmental Protection
Agency
Office or
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9441.27(85)
TITLE: Status of Spent Pickle Liquor Used in Production
of Ferric Chloride
APPROVAL DATE: 7-16-85
EFFECTIVE DATE: 7-16-85
ORIGINATING OFFICE. Office of Solid Waste
B FINAL
D DRAFT
LEVEL OF DRAFT
13 A — Signed by AA or DAA
J B — Signed by Office Director
d C — Review & Comment
REFERENCE (other documents):
WER OS WER OS WER
DIRECTIVE DIRECTIVE Dl
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261 SUBPART A - GENERAL
DOC: 9441.27(85)
Key Words: Pickle Liquor, Recycling
Regulations: 40 CFR 261.2
Subject: Status of Spent Pickle Liquor Used in Production of Ferric Chloride
Addressee: Harry Seraydarian, Director, Toxics and Waste Management Division,
Region IX
Originator: John H. Skinner, Director, Office of Solid Waste
Source Doc: #9441.27(85)
Date:
Summary:
7-16-85
The memo clarifies the status of spent pickle liquor used in the production
of ferrous and ferric chloride at two chemical companies.
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6 8S 9441.27 (85)- -
I(ANDtJM
0
P 1
SUBJ CT atatuw-of Spent Pickle Ldquor Used in the o
of Ferric Chloride
2
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FROM*. 3kinner, Director
- of Solid Waste (WH—562) c
z
TO: Harry Seraydarjan, Director
Toxics and Waste Management Division C
Region IX (T-l)
This memorandum responds to your inquiry of June 18, 1985,
regarding the status of spent pickle liquor used in the production
of ferrous and ferric chloride at Chem West Industries, Inc.
(Fontana, CA) and Imperial West Chemical Company (Ptttsburg, CA).
The information attached to your memorandum indicates
the Chem West Industries, Inc. receives spent pickle liquor
(by pipeline) from Kaiser Steel Corp. The spent material is
piped into tanks containing steel scrap to neutralize the
free hydrochloric acid to below a certain percentage. The
material is then discharged to lined surface thpoundmentg to
concentrate (recover) the ferrous chloride, After nutraltt tfa
of the acid and concentration of the iron, the material is
chl inatecI and sold as technical grade ferric chloride.
A similar situation exists at the Imperial West Chemical
Company. Spent pickle liquor received at this facility is
treated with ferric oxide and lime to decrease its acidity;
this treatment also has the effect of increasing the concen-
tration of ferrous chloridej/ The material is Concentrated
(recovered) in a surface impoundment and sold directly as
ferrous chloride or further processed to produce ferric chloride.
For both Chem West Industries, Inc. and Imperial West Chemical
Company, the process of mixing the spent pickle liquor with
scrap iron or ferric oxide produces ferrous chloride. Thus,
it could be argued that this material is used as an ingredient
Howe t— 5tanding of the process, the primary
purpc j.ng is to reduce the acidity in the spent
picV __Ition, if the acidity (HC1 concentration)
is .J v*1 of concern, this activity would probably
not L.. _ _jd , Thus, we believe that any ferrous chloride
that is gansrated is incidental and not a major purpose of
this particular activity.
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—2-
T p m s emaducted at thee. facilities in which
us.ab ls f.a .4h1Gride is first recovered tr n the spent
pickle 1f4 srs’ it is used to produce ferric chloride
Is coni1d.red sr.clsmati0n activity. According to the
revised d•flnition of solid waste, epent materials, listed
sludges, and listed by—products that are processed to recover
usabl products, or that are regenerated... are solid waete...
(50 PR at 633—634, January 4, 1955). As such, these materials
are subject to regulation under 1CRA prior to the r,clai tton
operation. Once the fsrrous chloride is recovered, th. material
would no longer be a waste. Although It may appear that the
exclusion for secondary materials used as ingredients to make
new products would apply in this case, it is clearly stated in
the pr.amble that if the material is to be put to us. after it
has been reclaimed, the material is still a solid waste until
reclamation is completed. Thus, the fact that wastes may be
used after being reclaimed does not affect their status as
wastes befor, and while being reclaimed.
Cons.qusntly, in the case of Ch.a West Industries, Inc.,
and Imperial West Chemical Company, the spent pickl. liquor
used in the production of ferrous and ferric chlorides at
thu. facilities is regulated under 1CM prior to the r.c1amatiot .
op.ration. Thu., the generators of the spent pickle liquor
must comply with Part 262 and both Impartal West Chemical
Company and Chem Wist Industries, Inc. must comply with Parts
264 and 265 for any storage of the pickle liquor prior U,
recycling. The recycling activity itself (i.e., the r.claiMtion
operation), however, is exempt from regulations thus, the
tanks and surf ace impoundments used as part of their recycling
procue are currently exempt from regulations. If, however,
the material wer, to escape from th. unit used in the recycling
process ( i.e. , leach from the waste in the surface impoundment
and contaminat, ground water), this action would constitute
disposal and would be subject to regulation under 1CM. (See
50 FR 642, January 4, 1985.)
I hop. that this memorandum adequately responds to your
inquiry,. U ye have question or require additional information,
pl.ase t) v Straus or Jacqueline Sales, of my staff, at
(202).
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