July 30, 1984
Kent Gray
Utah State Department of Health
Hazardous Waste Program
P.O. Box 2500
Salt Lake City, Utah 84110
Dear Mr. Gray:
This letter responds to your recent inquiry regarding the regulatory
status of spent acid from electropolishing of stainless steel
(i.e., whether the waste is considered EPA Hazardous Waste No.
K062--Spent pickle liquor from steel finishing operations).
As you stated in an earlier conversation with Jacqui Sales, of
my staff, electropolishing is a process which utilizes a mixture
of sulfuric and phosphoric acids (pH 1.0) to impart 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 impart a desired surface characteristic to steel or steel
products; in particular, to remove oxide scale. Although the background
document for the listing addresses only the commonly used pickle
acids (i.e., hydrochloric, sulfuric, nitric, and hydrofluoric),
the Agency intended the listing to include all acids used in the
pickling/cleaning of steel. Thus, spent acid from electropolishing
is considered the listed waste.
I trust this letter adequately addresses your concerns. Should
you have additional questions or require further information,
please call Jacqui Sales at (202) 382-4770.
Sincerely,
Matthew Straus
Chief
Waste Identification Branch