Book 1 of 2 Books
Wednesday, December 31, 1980
[SWH-FRL 1717-21
f
Hazardous Waste Management
System: Identification and Listing of
Hazardous"'
AGENCY: U.S. Environmental Protection
Agency.
ACTION: Grant of temporary exclusions
and request for comment.
SUMMARY: The Environmental Protection
Agency (EPA) is today temporarily
excluding solid wastes generated at
several particular generating facilities
from hazardous waste status. This
action responds to delisting petitions
submitted under 40 CFR 260.20 and
260.22 and are granted pursuant to 40
CFR 260.22(m). The effect of this action
is to temporarily exclude certain wastes
generated at particular facilities from
listing as hazardous wastes under 40
CFR Part 261, and from the management
standards issued by EPA under Sections
3002 through 3006 of the Resource
Conservation and Recovery Act of 1976,
as amended (RCRA) (40 Parts 262
through 265 and 122 through 124 of this
Chapter).
DATES: Effective date: December 24,
1980.
EPA will accept public comments on
these temporary exclusions until March
2,1981. Any person may request a
hearing on these temporary exclusions
by filing a request with John P. Lehman,
whose address appears below, by
January 21,1981. The request must
contain the information prescribed in
§ 260.20(d) of this chapter.
ADDRESSES: Comments should be sent
to the Docket Clerk, Office of Solid
Waste (WH-565), U.S. Environmental
Protection Agency, 401 M Street, S.W.,
Washington, D.C. 20460.
Communications should identify the
regulatory docket number "Section
3001/Delisting Petitions."
Requests for hearing should be
addressed to John P. Lehman, Director,
Hazardous and Industrial Waste
Division, Office of Solid Waste (WH-
565), U.S. Environmental Protection
Agency, Washington, D.C. 20460.
The public docket for these temporary
exclusions is located in Room 2711, U.S.
Environmental Protection Agency, 401 M
St., S.W., Washington, D.C. 20460, and is
available for viewing from 9 a.m. to 4
p.m., Monday through Friday, excluding
holidays.
FOR FURTHER INFORMATION CONTACT:
Myles Morse, Office of Solid Waste
(WH-565), U.S. Environmental
Protection Agency, 401 M St., S.W.,
Washington, D.C. (202) 755-9187.
SUPPLEMENTARY INFORMATION: On July
16,1980 and November 12,1980 as part
of its final and interim final regulations
implementing Section 3001 of RCRA,
EPA published lists of hazardous wastes
from non-specific and from specific
sources. See 40 CFR 261.31 and 261,32
(45 FR 47832-47836 and 74890-74892).
These wastes were listed as hazardous
because they typically and frequently
exhibit either any of the characteristics
of hazardous wastes identified in
Subpart C of Part 261 (ignitability,
corrosivity, reactivity and EP toxicity) or
meet the criteria for listing contained in
§ 261.11(a)(2) or § 261.11(a)(3).
The Agency, however, recognizes that
individual waste streams may vary
depending on raw materials, industrial
processes and other factors. Thus, while
a type of waste described in these
regulations generally is hazardous, a
specific waste meeting the listing
description from an individual facility
may not be hazardous. For this reason,
§§ 260.20 and 260.22 provide an
exclusion procedure, allowing persons
to demonstrate that a specific waste
from a particular generating facility
should not be regulated as a hazardous
waste. To be excluded, petitioners must
show that the waste produced at their
facilities does not meet any of the
criteria under which the waste was
listed. (See § 260.22(a).) Wastes which
are "delisted" (i.e., excluded) may,
however, still be hazardous if they
exhibit any of the characteristics of a
hazardous waste and generators remain
obligated to make this determination.
In addition to wastes listed as
hazardous in §§ 261.31 and 261.32,
residues from the treatment, storage, or
disposal of listed hazardous wastes also
are eligible for exclusion and remain
hazardous wastes until excluded. (See
§§ 261.31(c) and (d)(2).) Again, the
substantive standard for "delisting" is
that the waste not meet any of the
criteria for which the waste was listed
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86544
Federal Register / Vol. 45, No. 252 / Wednesday, December 31, 1980 / Notices
originally. Where the waste is derived
from one or more listed hazardous
wastes, the demonstration may be made
with respect to each constituent listed
waste, or the waste mixture as a whole.
(Sea § 260.22(b).) Like other excluded
wastes, excluded hazardous waste „
treatment, storage or disposal residues
temain subject to Subpart C of Part 261,
and so may be hazardous if they exhibit
any of the characteristics of hazardous
waste.
EPA recognizes as well that there will
be circumstances where immediate
action on petitions is appropriate.
Therefore, upon Agency review of a
submitted petition, the Administrator
may under § 260.22(m) grant a
temporary exclusion if there is
substantial likelihood that an exclusion
will finally be granted.
It should be noted that the Agency has
not run spot checks on the test data
submitted to date in exclusion petitions.
The Agency believes that the sworn
affidavits submitted with each petition
sufficiently binds the petitioners to
ensure presentation of truthful and
accurate test results. The Agency may,
however, spot sample and analyze
wastes or groundwater before a final
decision is made whether to exclude any
particular waste from the hazardous
waste regulations.
We also note that the temporary
exclusions granted today apply only to
the Federal hazardous waste
management system established under
the RCRA. States remain free to take
any action they deem appropriate with
regard to these wastes.
The temporary exclusions published
today involve the following petitioners:
Virginia Chemicals Inc. for its facilities
in Bucks, Alabama and Leeds, South
Carolina; Bekaert Steel Wire
Corporation, Rome, Georgia; the Florida
Wire and Cable Company, Jacksonville,
Florida; Wiremill Incorporated,
Sanderson, Florida; the Firestone Steel
Products Company, Spartanburg, South
Carolina; the American Recovery
Company, Baltimore, Maryland; Armco
Incorporated, Middletown, Ohio; the
Reynolds Aluminum Company for its
facilities in Richmond, Virginia; Ewa
Beach, Hawaii; Houston, Texas; Kansas
City, Missouri; Guayama, Puerto Rico;
Woodbridge, New Jersey; Salisbury,
North Carolina; Hayward, California;
Kent, Washington; Tampa, Florida;
Torrance, California; and Middletown,
New York; and Monroe Auto Equipment,
Paragould, Arkansas.
I. Virginia Chemicals Inc.
A. Petition for Exclusion
"Virginia Chemicals Inc. (Virginia
Chemicals), involved in the production
of sodium hydrosulfate, has petitioned
the Agency to exclude its distillation
column bottom sludge presently listed
as EPA Hazardous Waste No. F003, (The
following spent non-halogenated
solvents: Xylene, acetone, ethyl acetate,
ethylbenzene, ethyl ether, methyl
isobutyl ketone, n-butyl alcohol,
cyclohexanone, and methanol; and the
still bottoms from the recovery of these
solvents), at their facilities in Bucks,
Alabama and Leeds, South Carolina.
Virginia Chemicals has petitioned to
exclude its residue because they claim
that its still bottoms no longer meet the
criteria for which the waste was listed
in (40 CFR 261.11(a)(l)).
Virginia Chemicals utilizes the sodium
formate process in the production of
sodium hydrosulfate. The reaction is run
in a methanol solution which is not part
of the reaction. The methanol is then
recovered from the water of reaction .
and recycled to the process. The
distillation still bottoms discharged from
the methanol recovery process are
comprised primarily of sodium and
sulfur salts and are sold as a co-product
of the sodium hydrosulfate process.
Virginia Chemicals has submitted
descriptions of its sodium hydrosulfate
production and methanol recovery
processes, constituent analyses of the
distillation bottom material for
methanol, and flash point tests for this
material. Virginia Chemicals claims that
since its methanol recovery is 99.9+%
efficient, less than 0.1% methanol
remains in the distillation still bottoms
and therefore, this residue cannot be
considered hazardous. Virginia
Chemicals further states that its residue
does not exhibit the characteristic of
ignitability (§ 261.21) for which EPA
Hazardous Waste F003 is listed in Part
261 Subpart D and as described in
§ 261.21 of the regulations.
Results of ignitability tests for both
facilities indicate that the flash point of
the still bottom material is greater than
212°F.
B. Agency Analysis and Action
EPA Hazardous Waste No. F003 is
listed due to the ignitability of spent
nonhalogenated solvents, one of which
is methanol, the solvent used in Virginia
Chemical's process. Analyses submitted
by Virginia Chemicals indicate that
methanol is present in the distillation
still bottoms in only low percentages
(<0.1%) by volume. This is well below
the limit of 24 percent alcohol by volume
set in § 261.21(a)(i) of the regulations.
Section 261.21(a)(i) of the regulations
also indicates that solutions with
flashpoints above 140°F are considered
non-ignitable. Flashpoint tests run on
Virginia Chemicals distillation still
bottom discharges at both facilities
indicate that the flash point is greater
than 212°F.
Virginia Chemicals has sufficiently
demonstrated the non-hazardous nature
of its distillation still bottoms due to the
efficiency of its methanol recovery
system. The Agency, therefore, has
granted a temporary exclusion to
Virginia Chemicals' Bucks, Alabama
and Leeds, South Carolina facilities, for
its distillation bottom discharges from
its sodium hydrosulfite process, as
described in its petition, from its listing
under EPA Hazardous Waste No. F003.
C, Agency Information Needs for Final
Delisting
—The Agency believes that Virginia
Chemicals has submitted sufficient data
for the final delisting of its distillation
still bottoms. The Agency has granted a
temporary exclusion to expedite
delisting action for Virginia Chemicals.
Final exclusion will be granted upon
review of comments received in
response to this publication.
II. Bekaert Steel Wire Corporation
A. Petition for Exclusion
The Bekaert Steel Wire Corporation
(Bekaert), involved in the manufacture
of steel wire, has petitioned the Agency
to exclude its wastewater treatment
sludge, presently listed for the following
EPA Hazardous Wastes: ,•
F006—Wastewater treatment sludges from
electroplating operations except from the
following processes: (1) Sulfuric acid
anodizing of aluminum; (2] tin plating on
carbon steel; (3) zinc plating (segregated
basis) on carbon steel; (4) aluminum or
zinc-aluminum plating on carbon steel; (5)
cleaning/stripping associated with tin, zinc
and aluminum plating on carbon steel; and
(6) chemical etching and milling of
aluminum.
F007—Spent cyanide plating bath solutions
from electroplating operations (except for
precious metals electroplating spent
cyanide plating bath solutions)
F008—Plating bath sludges from the bottom
of plating baths from electroplating
operations where cyanides are used in the
process (except for precious metals
electroplating bath sludges)
F009—Spent stripping and cleaning bath
solutions from electroplating operations
where cyanides are used in the process
(except for precious metals electroplating
spent stripping and cleaning bath solutions)
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Federal Register / Vol. 45. No. 253 / Wednesday, December 31, 1980 /Notices 86545
K063 '—Sludge from lime treatment of spent
pickle liquor from steel finishing
operations.
The constituents of concern for these
wastes are cadmium, chromium, nickel,
cyanide and lead. Bekaert has petitioned
to exclude its waste because it does not
meet the criteria for which they were
listed.
Bekaert utilizes the processes of wire
drawing, hydrochloric acid pickling, and
electroplating of copper and zinc in its
production of steel wire. Bekaert's
wastewater treatment process for
pickling and plating rinse water involves
caustic soda neutralization, chlorine
treatment for cyanide destruction,
calcium hydroxide neutralization (to a •
pH of 8-10), clarification/precipitation,
and pressure filtration. Bekaert claims
that its wastewater treatment process
produces an environmentally stable
sludge containing non-hazardous levels
of cadmium, chromium, nickel, cyanide
and lead.
Bekaert has submitted a detailed
description of its sludge treatment
system, EP toxicity test results for all
toxic constituents specified in § 261.24
of the regulations, and total constituent
analyses of the sludge for cyanide. The
samples were taken over a one month
period which the petitioner claims
represents the uniformity of the
constituent concentrations in the waste.
EP toxicity tests for cadmium; total
chromium, nickel and lead produced
maximum leachate concentrations of
<0.02, 0.05, 0.22, and <0.2 ppm,
respectively. Constituent analysis of the
wastewater sludge for cyanide revealed
a maximum concentration of 0.01 ppm.
B. Agency Analysis and Action
The constituents of concern for which
EPA Hazardous Waste Nos. F006, F007,
F008, F009 and K062 are listed are
cadmium, chromium, nickel, lead and
cyanide. Although each of these
constituents appear in Bekaert's
wastewater, it has sufficiently
demonstrated that its wastewater
treatment sludge is non-hazardous.
Bekaert's waste treatment operation
destroys the majority of cyanides in the
wastewater, leaving residue
concentrations not exceeding 0.01 ppm,
which are considered negligible.
Additionally, the concentrations of
cadmium, chromium, and lead in extract
' On November 12, I960 (45 FR 74884). EPA
removed waste K063 frum the hazardous waste list
(§ 261.32). However, since these lime treatment
sludges are generated from the treatment of a listed
hazardous waste (K062). they still are considered to
be a hazardous waste (§ 261.3(c)(2)). Further, they
remain hazardous wastes until they no longer meet
any of the characteristics of hazardous wastes and
are excluded (§261.3ld)(2)).
samples of this sludge are well below
the EP maximum toxicity levels. These
low leachate levels indicate that the
constituents are present essentially in
an immobile' form. Leachate analyses
also indicate that the nickel present is
substantially immobile and therefore not
of regulatory concern. A final pH range
of 8-10 indicates that Bekaert's waste
treatment system effectively neutralizes
its acid wastes. The Agency therefore
has granted a temporary exclusion to
Bekaert's facility in Rome, Georgia for
its treated electroplating and pickle
liquor rinse waters, as described in its
petition.
III. Florida Wire and Cable Company
A, Petition for Exclusion
The Florida Wire & Cable Company
(FWC), involved in the manufacture of
galvanized high carbon steel wire and
guy wire, has petitioned the Agency to
exclude its sludge, formerly listed as
EPA Hazardous Waste No. K063, sludge
from lime treatment of spent pickle
liquor from steel finishing operations.2
FWC has petitioned to exclude its waste
because it does not meet the criteria for
which it was listed.
FWC's operation includes the
processes of cold drawing, hydrochloric
acid pickling, and hot dip galvanizing,
and stranding in the production of
galvanized high carbon steel wire and
guy wire. Its waste treatment process for
pickle liquor rinse and overflow wastes
involves neutralization, lime and
polymer flocculation, settling, and
pressure filtration. FWC claims that its
sludge is environmentally stable and
non-hazardous, and specifically that the
sludge does not contain hazardous
levels of chromium and lead, the
constituents of concern for spent pickle
liquor (waste K062).
FWC submitted a detailed description
of its sludge treatment system, and EP
toxicity test results for all toxic
constituents specified in § 261.24 of the
regulations. The samples were taken
over a one month period which the
petitioner claims represents the
uniformity of constituent concentrations
in the waste. EP toxicity tests showed
maximum chromium and lead levels in
the waste extract of 0.015 and 0.058 ppm,
respectively.
B. Agency Analysis and Action
The constituents of concern in this
waste, are chromium and lead. EP
extracts from sludge samples analyzed
by FWC show chromium and lead
consistently well below the maximum
EP toxicity levels. These low leachate
levels indicate that the constituents are
present essentially in an immobile form.
A final pH of 8.5 indicates that FWC's
waste treatment process effectively
neutralizes its acid wastes. The Agency
therefore has granted a temporary
exclusion to FWC's facility in
Jacksonville, Florida for its treated
pickle liquor rinse and overflow wastes,
as described in its petition.
IV. Wiremill Incorporated
A. Petition for Exclusion
Wiremill Inc. (Wiremill), involved in
the manufacture of high carbon steel
wire, has petitioned the Agency to delist
its sludge, formerly listed as EPA
Hazardous Waste No. K063, sludge from
time treatment of spent pickle liquor
from steel finishing operations.3
Wiremill has petitioned to exclude its
waste .because it does not meet the
criteria for which it was listed.
Wiremill uses the processes of cold
drawing and hydrochloric acid pickling
in the production of high carbon steel
wire. Its waste treatment process for
pickle liquor rinse and overflow wastes
involves neutralization, lime and
polymer flocculation, clarification, and
pressed filtration. Wiremill claims that
its sludge is environmentally stable and
non-hazardous, and specifically that the
sludge does not contain hazardous
levels of chromium and lead, the
constituents of concern for spent pickle
liquor (waste K062).
Wiremill has submitted a detailed
description of its sludge treatment
system, and EP toxicity test results for
all toxic constituents specified in
§ 261.24 of the regulations. The samples
were taken over a one-month period
which the petitioner claims represents
the uniformity of constituent
concentrations in the waste. EP toxicity
tests produced maximum leachate
concentrations of <0.01 and 0.018 ppm
for chromium and lead, respectively.
B. Agency Analysis and Action
The constituents of concern in this.
waste are chromium and lead. EP '.
extracts from sludge samples analyzed
by Wiremill show chromium and lead
consistently well below the maximum
EP toxicity levels. These low leachate
levels indicate that the constituents are
present essentially in an immobile form.
A final pH of 8.7 indicates that
Wiremill's waste treatment process
effectively neutralizes its acid w&stes.
The Agency therefore, has granted a
. temporary exclusion to Wiremill's
facility in Sanderson, Florida for its
2 See footnote 1.
3 See footnote 1.
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86546
Federal Register / Vol. 45, No. 252 / Wednesday, December 31, 1980 / Nptices
treated pickle liquor rinse and overflow
wastes, as described in its petition.
V. Firestone Steel Products Company
A. Petition for Exclusion
The Firestone Steel Products
Company (Firestone), involved in the
manufacture of stainless steel food
containers and carbon steel automotive
body panels, has petitioned the Agency
to exclude its sludge, formerly listed as
EPA Hnardous Waste No. K063, sludge
from the lime treatment of spent pickle
liquor from steel finishing operations.*
Firestone has petitioned to exclude its
waste because it does not meet the
criteria for which it was listed.
Firestone uses the processes of
forming, welding, assembly, and metal
finishing (nitric and hydrofluoric acid
pickling and sulfuric acid anodizing of
aluminum] in Jie production of food
container. Its waste treatment process
for spent pickle liquor and pickle liquor
rinse and overflow wastes involves
neutralization, lime and polymer
flocculation, clarification, and pressed
filtration. Firestone claims that its
sludge is environmentally stable and
non-hazardous and specifically that the
sludge does not contain hazardous
levels of chromium and lead, the
constituents of concern in the spent
pickle liquor (waste K062).
Firestone has submitted a detailed
description of its sludge treatment
system, and EP toxicity test results for
all toxic constituents specified in
§ 261.24 of the regulations. The samples
were taken over a 2 month period which
the petitioner claims represents the
uniformity of constituent concentrations
in the waste. EP toxicity tests produced
maximum leachate concentrations of
0.16 and 0.056 ppm for chromium and
lead, respectively.
B. Agency Analysis and Action
A final pH range of 6 to 8.5 indicates
that Fireslones' waste treatment system
effectively neutralizes its acid wastes.
EP extracts from sludge samples
analyzed by Firestone show chromium
and lead concentrations consistently
well below the maximum EP toxicity
levels. These low leachate levels
indicate that the constituents of concern
are present essentially in an immobile
form. The Agency therefore has granted
a temporary exclusion to Firestone Steel
Products Company's facility in
Spnrtenburg, South Carolina, for its
treated spent pickle liquor, as described
in its petition.
VI. American Recovery Company
A. Petition for Exclusion
The American Recovery Company
(ARC), located in Baltimore, Maryland
currently operates a waste treatment
facility which neutralizes acidic
electroplating and spent pickle liquor
wastes. ARC has petitioned the Agency
(as required by § 261.3(b)(2)) to exclude
only the treatment residue produced by
its treatment facility for spent pickle
liquor wastes formerly listed as EPA
Hazardous Waste K063, sludge from
lime treatment of spent pickle liquor
from steel finishing operations.5 ARC
claims that its treatment residue for the
spent pickle liquor no longer meets the
criteria for which the waste was'
originally listed, since it is non-corrosive
and the hazardous constitutents of
concern are present in an immobile
form.
ARC has submitted a detailed
description of its treatment process, and
EP toxicity test results for all toxic
constituents specified in § 261.24 of the
regulations. ARC claims that the
samples of residue obtained for analysis
are representative of the range of spent
pickle liquor wastes accepted for
treatment at its facility.
ARC uses a batch treatment process
which involves the separate
neutralization of hydrofluoric, nitric and
sulfuric acid pickle liquor wastes,
followed by the precipitation of metals
as hydroxide salts, and the belt filter
press dewatering of the sludge. The pH,
which is raised to a level of 8.5 is
constantly monitored in the reactor
tank. The supernatent is monitored for
chromium and lead prior to transfer to
the settling tank. Additional liming is
necessary ony if supernatent samples
exceed effluent guideline discharge
permit parameters. The dewatered
sludge is stockpiled for three to five
days prior to landfilling.
Acidic wastes from electroplating
processes are segregated and treated
separately from spent pickle liquor
wastes. The dewatered sludge from
these wastes are currently manifested
and disposed of at a Subtitle C landfill.
ARC claims that there is no commingling
of other wastes with the spent pickle
liquor wastes processed at its facility.
ARC has characterized its treatment
process quantitively for each of the eight
companies utilizing ARG's treatment
services. ARC has assured the Agency
that its treatment process will be
monitored using EP toxicity tests to
calibrate the treatment of any additional
sources of pickle liquor.
Samples of dewatered sludge were
obtained for EP toxicity analyses.
Maximum chromium and lead levels in
the waste extracts were 0.17 and <0.01
ppm, respectively.
3. Agency Analysis and Action
The constituents of concern in this
waste, are chromium and lead. EP
extracts from sludge samples analyzed
by ARC show lead and chromium
consistently well below the maximum
EP toxicity levels. These low leachate
levels indicate that the constituents are
present essentially in an immoble form.
A final pH range of 8.2 to 8.8 indicates
that ARC's waste treatment system
effectively neutralizes its acid wastes.
The Agency therefore, has granted a
temporary exclusion to ARC's facility in
Baltimore, Maryland for its spent pickle
liquor treatment residue, generated from
the treatment process described in its
petition.
VII. Armco Incorporated
A. Petition for Exclusion
Armco Incorporated (Armco),
involved in the manufacture of stainless
and electrical (silicon and high carbon)
sheet steel has petitioned the Agency to
delist its sludge, formerly listed as EPA
Hazardous Waste No. K063, sludge from
lime treatment of spent pickle liquor
from steel finishing operations.6 Armco
has petitioned to exclude their waste
because it does not meet the criteria for
which it was listed.
Armco uses the process of
hydrofluoric, nitric, and sulfuric acid
pickling, for the cleaning of silcon,
carbon and stainless steel produced at
its facility. Its waste treatment process
for spent pickle liquor wastes involves
lime neutralization, settling, and gravity
and pressed filtration. They claim their
sludge is environmentally stable and
non-hazardous, and specifically that the
sludge does not, contain hazardous
levels of chromium and lead, the
constitutents of concern in the spent
pickle liquor (waste K062).
Armco submitted a detailed
description of their sludge treatment
system, and EP toxicity test results for
chromium and lead.- The samples were
taken over a three month period which
the petitioner claims represents the
uniformity of constituent concentrations
in the waste. EP toxicity tests revealed
maximum chromium and lead levels in
the waste extract of 0.17 and 0.19 ppm,
respectively.
B. Agency Analysis and Action
The constituents of concern in this
waste are chromium and lead. EP
•Sec footnote i.
1 See footnote 1.
6 See footnote 1.
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Federal Register / Vol. 45, No. 252 / Wednesday, December 31. 1980 / Notices
86547
extracts from sludge samples analyzed
by Armco show chromium and lead
consistently well below the maximum
EP toxicity levels. These low leachate
levels indicate that the constituents are
present essentially in an immobile form.
A final pH of 8.5 indicates that Armco'a
waste treatment process effectively
neutralizes its spent pickle liquor
wastes. The Agency, therefore, has
granted a temporary exclusion to
Armco's facility in Butler, Pennsylvania
for its treated spent pickle liquor, as
described in its petition. It should be
noted, however, that the Agency is
concerned about the level of nickel in
leachate analyses of the petitioner's
stainless pickle liquor residues, even
though nickel is not listed as a
constitutent of concern. The Agency is
presently analyzing its position on
nickel concentration ranges in EP
leachate. If after further analyses the
Agency determines *hat these levels are
of regulatory concern, nickel leachate
concentrations may be considered prior
to granting a final exclusion to Armco.
VIII. Reynolds Metals Company
A. Petition for Exclusion
The Reynolds Metals Company,
(Reynolds), involved in the manufacture
of one-piece aluminum cans, has
petitioned the Agency to exclude its
wastewater treatment sludge, presently
listed as EPA Hazardous Waste No.
F019, wastewater treatment sludges
frofti the chemical conversion coating of
alurr'num. Reynolds has petitioned to
exclude its waste because it does not
meet the criteria for which it was listed.
Reynolds has indicated that since its
aluminum conversion coating processes
do not use either chromium or cyanide,
the constituents for which Hazardous
Waste F019 is listed, its waste cannot
contain hazardous levels of chromium or
cyanide.
Reynolds has submitted a description
of its wastewater treatement process,
formulation lists from its suppliers of
chemicals and mixtures used in the
chemical conversion process, EP toxicity
test results for all toxic constituents
specified in § 261.24 of the regulations,
and a constituent analysis of the sludge
for cyanide.
Reynold's treatment process of
chemical conversion rinse wastes
involves lime neutralization to a pH of
8.0-8.5, precipitation of metal
hydroxides, and dewatering via pressure
filtration.
Formulation lists indicate that
zirconium and fluoride compounds,
nitric acid, hydrofluoric acid,
hydrofluosilic acid, tannic acid, and
phosphates are the major constituents of
the conversion coatings used by
Reynolds. None of the formulations
contain chromium or cyanide.
EP toxicity test results of dewatered
sludge samples indicate a maximum
chromium concentration of 0.04 ppm.
Constitutent analysis of the sludge
revealed a cyanide concentration of 0.03
ppm.
Reynolds has certified that the
production process, chemical conversion
process, formulation lists, waste
treatment process, EP test data and the
constituent analysis for cyanide are
representative and do not vary at each
of the following facility sites: Richmond,
Virginia; Ewa Beach, Hawaii; Houston,
Texas; Kansas City, Missouri; Guayama,
Puerto Rico; Woodbridge, New Jersey;
Salisbury, North Carolina; Hayward,
California; Kent, Washington; Tampa,
Florida; Torrance, California; and
Middletown, New York.
B. Agency Analysis and Action
It is apparent from the formulation
lists submitted that chromium and
cyanide are not used in Reynold's
chemical conversion process. EP toxicity
data indicate that chromium leachate
concentrations are below the national .
primary interim drinking water
standard. The cyanide concentrations
found in the sludge are considered
negligible and are well below the Public
Health Service's suggested drinking
water standard. The presence of these
constituents in Reynolds wastes is
probably a result of background levels
and non-specific process contamination
sources. Therefore, based on
formulation lists, EP toxicity data,
sludge constituent analysis and since
Reynolds has certified that its
production and treatment processes do
not vary at any of its facilities, the
Agency has granted temporary
exclusions to the Reynolds Metals
Company's facilities in Richmond,
Virginia; Ewa Beach, Hawaii; Houston,
Texas; Kansas City, Missouri; Guayama,
Peurto Rico; Woodbridge, New Jersey;
Salisbury, North Carolina; Hayward,
California; Kent, Washington; Tampa,
Florida; Torrance, California; and
Middletown, New York, for its
wastewater treatment sludge from the
chemical conversion of aluminum, as
described in its petition, from its listing
under EPA Hazardous Waste No. F019.
IX. Monroe Auto Equipment
A. Petition for Exclusion
The Monroe Auto Equipment
Company (Monroe);'involved in the
manufacture of automotive ride control
products (shock absorbers), has
petitioned the Agency to exclude its
treated sludge, presently listed as EPA
Hazardous Waste No. F006—
wastewater treatment sludges from
electroplating operations except from
the following processes: (1) Sulfuric acid
anodizing of aluminum; (2) tin plating on
carbon steel; (3) zinc plating (segregated
basis) on carbon steel; (4) aluminum or
zinc-aluminum plating on carbon steel;
(5) cleaning/stripping associated with
tin, zinc and aluminum plating on
carbon steel; and (6) chemical etching
and milling of aluminum. Monroe has
petitioned to exclude its waste because
it does not meet the criteria for which it
was listed.
The production process at Monroe's
facility which generates the listed
hazardous waste is hard chrome plating
of carbon steel rods. The hazardous
constituents of concern in this waste
(F006) are cadmium, chromium, nickel
and cyanides. Monroe uses only
chromium (chromic acid) in its plating
operation, while cadmium, nickel and
cyanide compounds are not used in any
of its processes. Monroe claims that its
treated wastewater sludge is non-
hazardous due to the immobile and non-
toxic form of chromium and negligible
levels of cadmium, nickel and cyanide in
the sludge.
Monroe has submitted a description of
its wastewater treatment process, EP
toxicity test results for cadmium,
chromium, and nickel, and constituent
analyses of the sludge for cyanide.
Monroe's chromic acid rinse
wastewater passes through a Heil
chrome reduction unit which uses sulfur
dioxide in sulfuric acid to reduce
hexavalent chromium to the trivalent
form. The reduced chromium solution
then enters a Walker process clarifier
along with alkaline cleaning and
phosphating solutions, lime and
ploymers, resulting in neutralization and
precipitation of metal hydroxides. After
settling, the sludge is pumped to a
storage lagoon from where the sludge
passes through vacuum filtration for
dewatering.
EP toxicity tests involving chromium,
cadmium, and nickel produced
maximum leachate levels of 0.75, <0.01,
and 0.05 ppm, respectively. Constituent
analyses of the sludge for total cyanide
produced a maximum concentration of
3.9 ppm, while free cyanide was
reported as <0.001 ppm.
B. Agency Analysis and Action
The constituents for which EPA
Hazardous Waste No. F006 is listed are
cadmium, chromium, nickel, and
cyanide. Monroe has demonstrated that
its hard chromium plating process does
not use cadmium, nickel, and cyanide
compounds. EP extracts show cadmium
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levels consistently below the interim
primary drinking water standard. Nickel
leachate concentrations are considered
negligible as are free cyanide levels in
the dewatered sludge, and are therefore
not of regulatory concern. The low
concentrations of cadmium, nickel, and
cyanide are probably a result of
unknown minor sources of
contamination and background levels,
rather than the direct use of these
constituents in the plating process. Total
chromium concentrations in the EP
extract are consistently well below the
maximum EP toxicity levels. These low
leachate .levels indicate that the
constituents are present essentially in
an immobile form. The Agency
therefore, has granted a temporary
exclusion to Monroe Auto Equipment's
facility in Paragould, Arkansas, for the
treated wastes generated by its hard
chromium pie ting process as described
in its petition, listed under EPA
Hazardous Waste No. F006.
Dated: December 24,1980.
Eckhardt C. Beck,
Assistant Administrator.
1FR Doc SO-W632 Filed lZ-30-afc MS am]
65SO-30-M
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