Memo Detail

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RCRA Online Number: 11361
Title: REGULATORY STATUS OF USED SULFURIC ACID
Document Date: 1988-08-09
To: Tribble
From: Barnes
Organization of Recipient: American Cyanamid Co.
Description: Sulfuric acid from chlorine dehydration that is too dilute for reuse without further processing may meet the definition of spent material. If the secondary use of sulfuric acid has the same purpose as the primary use (e.g., once-used sulfuric acid can be directly reused in same or another alkylation reaction), the once-used sulfuric acid may be exempt from definition of solid waste under 261.2(e). Spent sulfuric acid reused as fertilizer ingredient is considered a solid waste and a hazardous waste used in a manner constituting disposal subject to Part 266, Subpart C.
Regulatory Citation(s): 261.2(e), 261.2(c), 261.1(c)
Official ORCR Policy: Yes
Associated Topic(s): Disposal, Hazardous Waste, Hazardous Waste Recycling