SEP 25 1986


SUBJECT: Repromulgation of F006 Hazardous Waste Category

FROM: J. Winston Porter

Assistant Administrator for Solid Waste and Emergency Response

TO Valdas V. Adamkus

Regional Administrator

Thank you for your August 18, 1986 memorandum regarding the repromulgation of the F006 hazardous waste category.

After a briefing with the staff from the Office of Solid Waste, Office of General Counsel, and the Office of Waste Programs Enforcement (OWPE), I decided to re-interpret the F006 listing to only include those processes that can be implicated, either directly or indirectly, in the language of the listing. During this briefing, I was presented with five options which are described in the attached material. I selected option three because it provides a sound legal argument and is cost effective--it saves resources. Realizing that option three may create problems with existing enforcement actions involving F006 wastes, I have requested OWPE to develop guidance which you should find helpful. In addition, we expect to re-visit the scope of the F--6 listing as part of our relisting effort.

The details of the decision are as follows: the F006 listing would include wastewater treatment sludges from the following processes: (1) common and precious metals electroplating, (2) anodizing (3) chemical etching and milling and (4) cleaning and shipping associated with common and precious metal electroplating. The following processes are not included under the F006 listing: (1) chemical conversion coating, (2) electroless plating, (3) printed circuit board manufacturing and (4) the six processes explicitly excluded from F006. Let me elaborate two fine points regarding the processes that are not listed. First, wastewater treatment sludges from the chemical conversion coating of aluminum are listed as EPA hazardous waste No. F019. Second, wastewater treatment sludges from printed circuit board manufacturing operations that include processes which are within the scope of the listing (i.e. chemical etching) are listed as EPA hazardous waste No. F006.

We have drafted a Federal Register notice which presents our re-interpretation of the F006 listing. This notice has been forwarded to the Regions for comment. In addition, a meeting was held with the Regions in Atlanta on September 16, 1986 to discuss our approach.

I hope this memorandum and the attached briefing material explains how I made my decision and how I plan to proceed. If I can be of further assistance, please let me know.