United States
Environmental Protection
Agency
OH.ce of
Solid Waste ana
Emergency Response
PA
DIRECTIVE NUMBER: 9441.29(84)
TITLE: Zinc Plating (waste streams)
*
APPROVAL DATE: 9-24-84
EFFECTIVE DATE: 9-24-84
ORIGINATING OFFICE: office of solid waste
m FINAL
D DRAFT
LEVEL OF DRAFT
DA Signed by AA or DAA
D B Signed by Office Director
DC Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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PART 261 SUBPART A - GENERAL
DOC: 9441.29(84)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Zinc Plating, Electroplating
40 CFR Parts 262-266, 261.31
Zinc Plating (waste streams)
Michael Sanderson, Chief, Air and Hazardous Waste Compliance
Branch", Air and Hazardous Materials Division, Region VII
Matthew A. Straus, Chief, Waste Identification Branch
#9441.29(84)
9-24-84
Wastewater treatment sludges generated from zinc plating operations, where
the zinc waste stream is combined with other hazardous waste streams (i.e.,
wastewaters from other electroplating operations) are considered EPA Hazardous
Waste No. F006 and subject to regulation under 40 CFR 262-266. If, however, the
waste stream is maintained and treated separately (segregated) from other
hazardous waste streams at the facility, it is considered nonhazardous.
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9441.29 (84)
SEP -2 4 B64
MEMORANDUM
S
. . . .
SUBJECT: -Zinc Plating (segregated basis) on Carbon Steel
ť
FROM:: Matthew A. "Straus, -Chief '! .. . ^
Waste Identification" Branch, (WH-562B)
TO: : Michael Sanderson, ""Chief
73 ; Air and Haz,ardous".Waste Compliance Branch
^ Air and Hazardous Materials .Division
-ť ,E?A Region VII
ąŁ.
(0
* . This is written in response to your September 18 , 198 [4 -
\ request .for clarification regarding zinc plating' (segregated*
2. basis) on carbon ateel.
.**'"
-." - with respect to electroplating operations, wastewater ":->
^ treatment sludges generated from zinc plating on carbon steel
x aro considered non-hazardous only when the waste stream ; -",
!n fron this operation is maintained and 'treated separately :
^ (segregated) froa other hazardous waste "streams generated at a
^ facility. In many cases , however , 'zinc plating is often
,- followed by chemical conversion coating/ which includes
^ coloring^ chromating, and immersion coating, as well "as
^ other plating operations. Chemical conversion- coating
:N is defined in EPA's listing background document as a component
J, of electroplating and therefore, the wastewater treatment V.'-
N sludges generated from this operation would be considered ;~
< hazardous. If the wastewater from a zinc plating line -'
9 is combined with wastewaters from other electroplating
operations, the resultant wastewater treatment, sludge
'* - - '
a would bŤ considered hazardous.
a ''.''-. . "' '-.'-. ", . .
2 Therefore, wastewater treatment .sludges generated from
r> zinc plating operations, where-the zinc waste stream .is
i. combined with other hazardous waste streams, are considered
3. EPA Hazardous Waste.No. P006 >nd subject to regulation under
40 CPR 262-266. :::lf you have "any. further'questions on this , -
matter, please do not'hesitate to contact Mr. William Sproat
,of my staff "at FTS-382-4783. ,;; - ^i. -- -- >/
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