Mr. Paul M. Frank

ACR Electronics Inc.

5757 Ravenswood Road

P.O. Box 5247

Ft. Lauderdale, Florida 33310-5247

Re: Status of Delisting Petition #0297

Dear Mr. Frank:

The purpose of this letter is to inform you that the Agency as reevaluated its previous interpretation of the hazardous waste listing for F006 wastes (Wastewater treatment sludges from electroplating operations) and has determined that it is overly broad. In particular, we believe that certain of the processes identified in the Listing Background Document that are not directly or indirectly implicated in the actual listing are not covered under regulations as listed hazardous wastes. As a result, we now believe that F006 includes only common and precious metals electroplating, anodizing, chemical etching and milling, and cleaning and stripping when associated with these processes. On the other had, the following processes are not included under the F006 listing: chemical conversion coating (1), electrolysis plating, and printed circuit board manufacturing(2). The Agency will be publishing an explanation of its determination on the F006 listing in the Federal Register in the near future.

(1)Wastewater treatment sludges from the chemical conversion coating of aluminum is listed as EPA Hazardous Waste No. F019.

(2)Wastewater treatment sludges from printed circuit board manufacturing operations that include processes which are within the scope of the listing (e.g., chemical etching) are regulated as EPA Hazardous Waste No. F006.

Our records indicate that your petitioned waste is generated from processes that are not included in the scope of the F006 listing as described above. Therefore, we have discontinued the review of your petition. It should be noted that if your petitioned wastes are mixed with listed F006 wastes or any other listed hazardous wastes, the resulting mixture would be considered hazardous. Also, if your petitioned wastes or any mixture of wastes exhibit one or more of the characteristics of hazardous waste (40 CFR 261 Subpart C) then that waste would be considered hazardous. If our records are incorrect or if your petitioned wastes are mixed with other hazardous wastes for which you still seek delisting, please contact us as soon as possible so that we can reactivate our review. Also, please note that this decision does not apply to any other listed wastes that may be generated at your facility.

If you have any questions regarding this matter, please contact Myles Morse of my staff, at (202) 382-4788.


Bruce Weddle


Permits and State Programs