United States Environmental Protection Agency

Washington, D.C. 20460

Office of Solid Waste and Emergency Response

September 24, 1993

Mr. Eli Hoffman

Technical Advisory Services

358 Rolling Rock Road

Mountainside, New Jersey 07092-2120

Dear Mr. Hoffman:

This letter is written in response to your letters of March 13, 1992; January 16, 1992, and October 7, 1991. EPA regrets the delay in responding to your inquiries. The Agency has recently completed review of materials submitted by the Lead Industries Association Inc. (LIA) on spent solder baths also known as "pot dumps". As you know, EPA has previously provided guidance on the status of skimmings, sometimes called "solder dross" and the enclosed letter provides guidance on pot dumps.

Based on the information we reviewed, EPA has determined that pot dumps generally meet the definition of scrap metal (40 CFR 261.1(c)(6)) and therefore are not currently subject to regulation when reclaimed (see enclosed letter from Jeffery D. Denit to Jeffrey T. Miller, dated September 20, 1993). I hope this information is helpful. If you have any additional questions regarding this matter, please contact Paul Borst of my staff at (202) 260-8551.


Michael J. Petruska, Chief

Regulatory Development Branch