May 2, 1986

Mr. Donald P. Duffy

Pace Laboratories, Inc

1710 Douglas Drive North

Minneapolis, MN 55422

Dear Mr. Duffy:

This letter is in response to your request for an interpretation of the electroplating listings (EPA Hazardous Waste Nos. F006 and F019). Our responses to your specific questions are as follows:

1. "Electroplating operations" includes electroplating of common metals, electroplating of precious metals, anodizing, coatings, chemical etching and milling, electroless plating, and printed circuit board manufacturing.

2. The only phosphating processes that are not included in the F006 listing are phosphating on aluminum. These processes are included in the F019 listing.

3. The exclusion "...(3) zinc plating (segregated basis) on carbon steel..." refers to non-cyanide zinc plating processes. That is, zinc plating processes which use cyanide are not excluded from the F006 listing.

4. The zinc plating exclusion does not encompass any wastes from chemical conversion coating processes (e.g., chromating). Thus, when chromating processes contribute to the wastewater stream, the resultant wastewater treatment sludges are included in the F006 listing.

5. The F006 and F019 listings are currently being reevaluated. At present, the primary focus of this effort is on phosphating processes; several trade associations are now gathering data to support our re-evaluation.

Should you have any questions regarding this interpretation, please contact either Mr. Matthew Straus or Mr. David Topping of my staff at (202) 475-8551.

Sincerely yours,

Eileen Claussen


Characterization and

Assessment Division (WH-562B)