SEPA
UniMdStMM
Envtromnemcl Protection
Agency
Off ic« of
Soltd Wast* and
Em*rg*ncy R*spon»*
DIRECTIVE NUMBER: 9444.01(84)
TITLE: Clarification of the Listings for Metal Heat
Treating Wastes F010, F011, and F012
APPROVAL DATE: 3-5-84
EFFECTIVE DATE: 3-5-84
ORIGINATING OFFICE:
12 FINAL
Office of Solid Waste
D DRAFT
STATUS:
I 1
[ 1
[ ]
[
A- Pending OMB approval
B- Pending AA-OSWER approval
C- For review &/or comment
] D- In development or circulating
REFERENCE (other documents):
headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
-------
PART 261 SUBPART D - LISTS
DOC: 9444.01(84)
Key Words: Cyanide
Regulations: 40 CFR 261.31
Subject:
Addressee:
Date:
Summary:
Clarification of the Listings for Metal Heat Treating Wastes
F010, F011, and F012
James H. Scarbrough, Chief, Residuals Management Branch, Air
and Waste Management Division, Region IV
Originator: Matthew A. Straus, Acting Chief, Waste Identification Branch
Source Doc: #9444.01(84)
3-5-84
If a metal heat treating process uses any form of cyanide—complex or
free—the process is covered by the hazardous waste listings F010, F011, and
F012.
-------
9444.01
xflarificat loir' of the Listings Tor Metal Heat Treating "Wastes
*010,\Fvll, and F012. v -•--..
Matthew A. Straus, Acting enter
Waste Identification Branch {WH-562J
*>•* " --*"' v *
"James- E. Scarbrough, Chief t
Residuals Management Branch
Air & Waste Management Division
Region IV " '* ""
This memorandum is in response to your question
regarding the scope of the cyanide listings for metal heat
treating operations (EPA Hazardous Waste Nos. P010, F011,
and P012). In particular, you asked whether the form of
cyanide (i.e., complex cyanide or free cyanide) was germane
in determining whether one had a listed waste. In short,
the answe-F^ls no. In listing these'wastes as hazardous,
the Agency was (and is still) concerned with the management
(or mismanagement) of cyanide wastes (both complex cyanide
mnd cyanide salts). If the Agency felt that a distinction
was necessary, it would have done so in the listing. For
example., SPA Hazardous Waste No. F012 would have been listed
'as follows:" V .
. " ,"Quenching wastewater treatment sludges from metal
• . heat treating operations where complexed cyanides are
. -. ..used in the process (except for precious metals heat '...
/treating quenching wastewater treatment sludges)." -
In addition, you should be aware .that the form of cyanide
often changes during the heat treating operation or subsequent
treatment; therefore, although you may begin with cyanide
salts (free cyanide) your waste may be primarily Complex
cyanide. The waste listings take this into, account by
differentiating between the form of cyanide present in the
waste (i.e., .only cyanide-salt containing wastes (free
•.cyanides) are listed as posing a reactivity hazard).
•. - • - , ...• . ^ . •.-.•-....
• . .»/ • '. • - ,- * X"' • ' T" «'
J" -Furthermore, it should be noted that although complex
cyanides'are less toxic than free1 cyanides, complex cyanide- ••»
bearing wastes are of concern because of their potential to
undergo photodecomposition to form toxic hydrogen cyanide
and free cyanide decomposition by-products. (See Listing
Background Document for Cyanide Wastes, Response to Cerements
Section, Comment No. 3 for more details.)!./ Therefore, if
the metal heat treating process uses cyanides in any form,
the process is covered by the hazardous waste listings.
V This document is included in the document $$261.31 and
261.32 - Listing of Hazardous Wastes (Pinalization of
May 19, 1980 Hazardous Waste List), #1941.28 November 14,
1980.
------- |