United States
                 Environmental Protection
                 Agency
             OH.ce of
             Solid Waste ana
             Emergency Response
           PA
DIRECTIVE NUMBER: 9441.24(84)
TITLE: Delisting of Waste Generated from Zinc Phosphating
     on Carbon Steel - F006 (Wastewater Treatment Sludgas
     from Electroplating Operations)
APPROVAL DATE: 9-6-84
EFFECTIVE DATE: 9-6-84
ORIGINATING OFFICE:  office of Solid waste
E FINAL
a DRAFT
  LEVEL OF DRAFT
    DA — Signed by AA or DAA
    D 8 — Signed by Office Director
    DC — Review & Comment
REFERENCE (other documents):
  OS WER       OS WER       OS WER
VE    DIRECTIVE    DIRECTIVE    Dl

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PART 261  SUBPART A - GENERAL
                                                DOC:  9441.24(84)
Key Words:    Electroplating, Zinc Plating

Regulations:  40 CFR 260.22, 261.20

Subject:
Addressee:


Originator:


Source Doc:

Date:

Summary:
Delisting of Waste Generated from Zinc Phosphating on Carbon
Steel - F006 (Wastewater Treatment Sludges from Electroplating
Operations)

Mr. Howard Nash, Vice President, Environmental Technology, Inc.,
Ashland, Virginia

Myles E. Morse, Environmental Protection Specialist, Waste
Identification Branch, Office of Solid Waste

#9441.24(84)

9-6-84
     The Agency's definition of electroplating includes phosphating processes.
Therefore, the exemption for zinc plating (segregated basis) on carbon steel
also applies to zinc phosphating on carbon steel.

     Waste that fails any of the four characteristic tests must be handled as a
hazardous waste.  If the waste is retreated and no longer exhibits the charac-
teristics, it may be handled as a nonhazardous waste.

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                      WASHINGTON. O.C. 20460



                              SEP   6 iS£4
                                                            9441.24 (84)
.Mr. Harold Nash
Vice President
Environmental Technology,
Ashland, Virginia
                                                           OF
                                              SOLID WASTE ANO EMERGENCY RESPONSE
                           Inc.
 Dear  Mr.  Nash:

      The  purpose of  this  letter is  to  respond to our telephone
 conversation of September 4,  1984 and  the  delisting petition
 submitted.for Rappahannock Wire,  Inc.  Fredericksburg,  Virginia.
 The petition addresses  the waste  generated from zinc phosphating
 on carbon steel and  requests  an exclusion  from EPA Hazardous
 Waste No.  F006  (wastewater treatment sludges  from electroplating
 operations) .
•

      There are  several  processes  which are exempt from the F0t)6
 listing,  one of which  is  zinc plating  (segregated basis)  on
 carbon  steel.   Since the  Agency's current  definition of
 electroplating  includes phosphating processes,  the exemption
 for zinc  plating on  carbon steel  also  applies to zinc phosphating
 on carbon steel.  As indicated in the  petition,  Rappahanock
 Wire's  waste is' generated from a  zinc  phosphating operation
 which soley  involves carbon steel as the base metal.
 Furthermore,  you indicated that the phosphating process is
 not used  with any other process which  could generate a
 hazardous  waste,  and the  wastestream from  this process is not
 comingled  with  any other  hazardous  waste.   Therefore you
 characterize Rappahanock  Wire's process as segregated.  If'this
 representation  of Rappahanock Wire's zinc  phosphating process
 is accurate,  the Agency considers the  waste to be .exempt  from
 EPA's F006 Hazardous Waste listing  and therefore not a
 listed  hazardous waste under  the  Federal Hazardous Waste
 Management System.

      As a result of  this  determination no  further action
 will  be taken on the delisting petition received on August 29,1984,
 The phosphating waste may be  handled as a  non-hazardous
 waste providing that the  generator  has fulfilled the
 requirement  of  testing  the waste  for the four characteristics,
 (ignitability,  corrosivity,  reactivity, and EP Toxicity),
 identified under §261.20  of the RCRA regulations.  With
 regard  to this  last  point it  should be noted  that -sample
 number  4-3137 in the petrtion 'failed, the E? Toxicity Limit
 for cadmium  and therefore the waste represented by this
 sample  would be considered hazardous by the EP Toxicity
 characteristic.   Rappahanock  Wire is required to handle all
 waste that fails any characteristic as a hazardous waste.
 The waste may be retreated and if it no longer exhibits the
 characteristic  it may then be handled  as a non-.hazardous  waste.

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                             -2-
     Due to the variability of heavy metal mobility exhibited
.by Rappahanock Wire's waste (as revealed by the EP Toxicity
data in the petition),  the Agency  is very concerned about
the potential fertilizer use option cited in the petition.
Due to the ability of this waste to leach high concentrations
of cadmium, the Agency  cannot recomnend the use of this
waste in the production of fertilizers.  This potential
problem has been noted  by this office and we have informed
both the EPA Region III Office and the Virginia Department
of Health/Division of solid and Hazardous Waste Management
of this situation.

     If you have any questions regarding this letter do not
hesitate to call me at  (202)-382-4782.

                         Sincerly,
                       MyleS E. Morse
             Envirnmental Protection Specialist
                Waste Identification Branch
                   Office of Solid Waste
cc: Sam Rotenberg
    OSW/EPA Region III

    William Gilley
    Solid f* Hazardous Waste
    Virginia Dept. of Health

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