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.


Matthew Straus


Waste Identification Branch