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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