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 ------- 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. ------- 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. ------- -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 ------- |