Memo Detail

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RCRA Online Number: 11352
Title: SECONDARY MATERIALS REGULATION - USED SULFURIC ACID
Document Date: 1988-06-06
To: Tribble
From: Barnes
Organization of Recipient: American Cyanamid Co.
Description: The 261.4(a)(7) exemption only applies to sulfuric acid used in production of virgin sulfuric acid. Generators of sulfuric acid must have adequate documentation to support any exemption claims. The regulatory status of spent sulfuric acid depends on how it is recycled. Used sulfuric acid produced by sulfonation, alkylation, and dehydration reactions may be regulated as a by-product or co-product. Materials used as ingredients for product fuels or fertilizers are still solid wastes.
Regulatory Citation(s): 261.2(c)(1), 261.1(c)
RPPC Number: 9441.1988(23)
Official ORCR Policy: Yes
Associated Topic(s): Burning, Combustion of Hazardous Waste, Exclusions (RCRA), Generators, Hazardous Waste, Hazardous Waste Recycling