oEPA
UniMdSt
Environmental Protection
Agency
Office of
Solid Warn and
DIRECTIVE NUMBER:
TITLE: Application of the" F006 Listing to Wastewater
Treatment Sludges from Electroplating Operations
APPROVAL DATE: 9/3/85
EFFECTIVE DATE: 9/3/85
ORIGINATING OFFICE: osw
m FINAL
O DRAFT
CTATMC.
STATUS.
f I 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
-------
&EPA
.-.-; • • • •' • • .•. .,„,-, Aye:';./
Wasnmgton, uC 20460
OSWER Directive Initiation Request
9444.1385 •
tnfotmar on
Name of Contact Person
Ann Sarro
Mail Code - Branch
Telepnone Numoer
Lead Office
O OERR
LEI OSW
D OUST
D OWPE
D AA-OSWER
Approved tor Review
Signature ol Office Director
Date
Title
Application of the F006 listing to Wastewater Treatment Sludges
From Electroplating Operations
Summary of Directive
The letter discusses application of the F006 listing to wastewater
treatment sludges from electroplating operations
Key Words:
Electroplating
Type of Directive /Manual. Policy Directive. Announcement, etc.i
Status
D Draft
O Final
i U New
I l_l Revision
Does this Directive Supersede Previous Directive!*;? | | Yes | | No Does It Supplement Previous Directive^!' j_J Yes [__) No
If "Yes" to Either Question. What Jirective (number, title/
Review Plan
D AA-OSWER
D OERR
D OSW
D OUST
D OWPE
LJ Regions
D OECM
D OGC
D OPPE
D
Other sSpecifyl
This Request Meets OSWER Directives System Format
Signature of Lead Office Directives Officer
: Date
Signature of OSWER Directives Officer
Date
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
SEP 31985
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
Mr. Ken Chiu
Solid Waste Branch (HS-13)
US EPA
230 S. Dearborn St.
Chicago, IL 60616
Dear Mr. Chiu:
I am writing this letter in response to the question you
posed in our telephone conversation on August 30, 1985. Accord-
ing to the manufacturing process description that you provided,
the surface impoundment at the Rockwell International, Newark,
Ohio facility is considered a hazardous waste impoundment, listed
as EPA Hazardous Waste No. F006.
It is my understanding that Rockwell International manufactures
automotive gears. These gears are placed in an iron/manganese/
phosphate tank to provide lubrication. The gears are then dipped
in a rinse tank, and this contaminated rinse water enters the
impoundment. The F006 listing applies to wastewater treatment
sludges from electroplating operations. Any sludge that precipitates
out of Rockwell International's wastewater is classified as hazar-
dous .
Rockwell International's lubrication coating process is con-
sidered electroplating, as defined in the listing background
document. A number of production processes, including coating,
are considered subcategories of the electroplating industry.
Electroplating is defined as the application of a surface coating,,
usually, but not always, by electrodeposition to provide corrosion
protection, erosion resistance, anti-frictional characteristics
or decoration. In particular, phosphate conversion coating pro-
duces a layer of insoluble crystalline phosphate on the surface
of a metal that provides a base for lubricants.1
Consequently, Rockwell International's iron/manganese/phosphate
lubricating process is considered electroplating, and sludge that
results from treatment of the wastewater is considered hazardous
V US EPA. Development document for existing source pretreatment
standards for electroplating point source category. EPA No.440/
1-79/003. August, 1979.
-------
and listed as EPA Hazardous Waste No. F006. If Rockwell Inter-
national feels that their sludge is non-hazardous, then please
advise them to call this office and discuss submitting a delist-
ing petition.
I hope that this letter helps to clarify the issue. If you
have any additional questions, please do not hesitate to call
me at (202) 382-4519.
Sincerely,
Ann Burke Sarno
Environmental Protection Specialist
Waste Identification Branch (WH-562B)
------- |