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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