oEPA
tinned St
Environmental Protection
Agency
Off ice of
Solid Wast* and
Emergency Response
DIRECTIVE NUMBER:
TITLE: Zinc Plating (Segregated Basis) on Carbon Steel
APPROVAL DATE: 6-
EFFECTIVE DATE: &~
ORIGINATING OFFICE:
B FINAL
Office of Solid Waste
D DRAFT
STATUS:
[ ] A- Pending OMB approval
f J B- Pending AA-OSWER approval
I j C- For review &/or comment
[ ] D- In development or circulating
REFERENCE (other documents):
headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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PART 261 SUBPART D - LISTS
DOC: 9444.09(84)
Key Words:
Regulations
Subj ect:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Zinc Plating
40 CFR 262-266
Zinc Plating (Segregated Basis) on Carbon Steel
•William H. Minor, Chief, Technical Permits and Compliance Section,
Waste Management Division, Region V
Matthew A. Straus, Acting Chief, Waste Identification Branch
#9444.09(84)
6-13-84
Wastes generated from phosphating, coloring, chromating and immersion
plating are hazardous wastes listed under F006.
Wastewater treatment sludges generated from zinc plating (or zinc
phosphating) operations on carbon steel are not hazardous wastes when the waste
stream from these operations is maintained and treated separately from other
waste streams generated at the facility. However, chrome passivating is con-
sidered a component of chemical conversion coating; therefore, the wastewater
treatment sludges generated from that operation are hazardous.
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9444.09
3 B84 V
RE: WIBBS840102
MEMORANDUM
(
N
SUBJECT: line Plating (Segregated Basis) on Carbon Steel
i
FROM: Matthew A. Straus, Acting Chief
Waste Identification Branch (WH-562B) [
i
TO: William H. Minor, Chief; t
Technical Permits and Compliance Section h
Waste Management Division ^
Region V >
v
o
After evaluating the information supplied by the Gulf and x
Western Stamping Division regarding their phosphating operations H
and zinc plating line, it is our conclusion that the wastes £
generated from both their operations meet the description of _•
EPA Hazardous Waste No. F00.6. More specifically, the EPA ~ * cr
Background Document defines phosphating as a component of 2
electroplating of chemical conversion"coating. Other components =
of this category include coloring, chromating, and immersion o
plating. Accordingly, wastes generated from the phosphating *°
operation at Gulf and Western would be considered hazardous
wastes.
With respect to their other operation, wastewater treatment
sludges gene'rated from zinc plating operations on carbon
steel are not considered hazardous wastes when the waste
stream front these operations is maintained and treated separately
(segregated) from other waste stream generated at the facility.
However', Gulf and Western's zinc plating line also includes
a chromate passivating bath in which the low carbon steel
stampings are dipped after plating. Chrome passivating is
considered a component of chemical conversion coating and
therefore the wastewater treatment sludges generated from
this operation would also be considered hazardous.
Therefore, wastewater treatment sludges generated by
both operations at Gulf and Western are considered EPA
Hazardous Waste No. F006 and subject to regulation under 40
CFR 262-266. If you have further questions regarding this
matter, please do not hesitate to call Mr. William Sproat of
ray staff at FTS 382-4783.
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