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
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  OSWER      OSWER      OSWER
VE   DIRECTIVE   DIRECTIVE   Dl

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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.

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                                                              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

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     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

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