JUN 4, 1984
Status of Supernatant from Lime Neutralization of Spent Pickle
Liquor
Matthew Straus, Acting Chief Waste Identification Branch (WH-562B)
Karl Klepitsch, Chief Waste Management Branch (Region V)
This memorandum addresses your inquiry regarding
the status of supernatant from lime treatment of spent pickle
liquor.
First, you are correct in stating that the supernatant is not
included in the industry-wide exclusion of lime-stabilized waste
pickle liquor sludge (LSWPLS) (formerly known as lime neutralized
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 (clarifier) prior to discharge). In addition, when discharged,
the supernatant is excluded from the presumption of being a solid
waste, and thus, a hazardous waste (see 40 CFR 261.4(a)(1)(ii)(2)),
if it is discharged either to navigable waters pursuant to the
provisions of the Clean Water Act or to a POTW. Supernatant that
is removed from the wastewater treatment system, and is otherwise
managed, is regulated under RCRA.