OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE

JAN 28 1987

Mr. Steven H. White
Tricil Environmental Services, Inc.
Talbott Tower, Suite 510
131 North Ludlow
Dayton, OH  45402

Dear Mr. White:

This letter is in response to your January 5, 1987 inquiry concerning the scope of EPA Hazardous Waste No. F006.  Specifically, you requested an interpretation as to the status of wastewater treatment sludges that result from a waterfall curtain used in electrostatic painting operations.

Wastewater treatment sludges from electrostatic painting operations are not included in the F006 listing.  Thus, the waste would only be considered hazardous if it: (1) exhibits a hazardous waste characteristic (e.g., ignitability, corrosivity, reactivity, or extraction procedure (EP) toxicity) or (2) is mixed with a hazardous waste (e.g., F019 from pre-painting conversions coating operations on aluminum).

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

Sincerely,

Original Document signed

Matthew A. Straus, Chief
Waste Characterization Branch