oEPA United States Environmental Protection Agency Off ice of Solid Waste and Emergency Response DIRECTIVE NUMBER: 9445.03(85) TITLE: Clarification of F019 Listing APPROVAL DATE: 5-31-85 EFFECTIVE DATE: 5-31-85 ORIGINATING OFFICE: office of solid waste B FINAL D DRAFT STATUS: A- Pending am approval B- Pending AA-OSWER approval C- For review 4/or cement [ ] D- In development or circulating REFERENCE (othtr documents): ""'quartera I ] ] OSWER OSWER OSWER VE DIRECTIVE DIRECTIVE Dl ------- PART 261 - APPENDICES DOC: 9445.03(85) Key Words: Regulations: Subject: Addressee: Originator: Date: Source Doc: Summary: F-Wastes Clarification of F019 Listing William L. Ramus, Water Management, Inc., 2480 Broadway Avenue, Cleveland, Ohio 44115 David A. Topping, Jr., Environmental Scientist, Waste Identification Branch 5-31-85 #94A 5.03(85) The F019 listing is a subcategory of the F006 listing. Therefore, since wastewater treatment sludges from sulfuric acid anodizing of aluminum are excluded from the F006 listing, the sludges are also excluded under F019. ------- 9445.03 (85) Mr. William L. Ramus Water Management, Inc. 2480 Broadway Avenue Cleveland, OH 44115 Dear Mr. Ramusi This letter is in response to your May 17, 1985 letter to Mr. Matthew Straus of the Waste Identification Branch. Specifically, you requested a clarification of the F0.19 listing and its applicability to wastewater treatment sludges from sulfuric acid anodising of aluminum. The P006 listing of wastewater treatment sludges from electroplating operations was published Interim Final on Hay 19, 1980 (45 PR 33123). Comments were taken on the proposed listing, whicTT~prompted several modifications. These modifications were incorporated into the final listing on November 12, 1980 (45 PR 74886-74887). First, waatewater treatment sludges from several specific processes were excluded from the listing. These processes include sulfuric acid anodizing of aluminum. Also, wastewater treatment sludges from chemical conversion coating of aluminum were listed separately, as F019, because these sludges were not expected to contain significant concentrations of cadmium and nickel. Thus, the P019 listing is, in effect, a subcategory of the P006 listing. Since wastewater treatment sludges from sulfuric acid anodizing of aluminum are specifically excluded from the POO6 listing, the sludges are not included under F019. At present, this exclusion also includes the coloring step and, thus, the process you describe results in an excluded waste unless the sludge is hazardous by characteristic (ignitability, corrosivity, reactivity, or BP toxicity). WH-562B/DTOPPING/rpj/382-4690/5-31-85/DISK DT 01 ------- It is important to note that this waste is excluded from the listings because it meets the description in the F006 exclusion and not because the chemical conversion baths contain no chromium. Apart from the F006 exclusions/wastewater treatment sludges from all chemical conversion coating processes are listed hazardous wastes (F019 for aluminum, F006 other metals). However, the Agency is currently re-evaluating the electroplating and metal finishing listings to determine whether phosphating and some other processes should continue to be included. Should you have any questions related to this clarification or other aspects of the electroplating and metal finishing listings, please feel free to contact me at (202) 382-4690. Sincerely, David A. Topping, Jr. Environmental Scientist Waste Identification Branch (WH-562B) cc: Sally Swanson, EPA Region V ------- |