May 22, 1986
Mr. Paul Yancey
Facility Engineer
Whirlpool Corporation
6400 Jenny Lind Road
Fort Smith, AR 72903
Dear Mr. Yancey:
The purpose of this letter is to respond to your question regarding
the classification of sludge generated from
treatment of cleaner solutions at your Fort Smith, Arkansas
facility. It is my understanding that the first stages of your
phosphating process are the cleaner stages. Treatment of the wastewater
from the cleaning baths involves pH adjustment, flocculant addition,
and filtration. The sludge that results from this treatment is
not considered listed hazardous waste as long as wastewater generated
from the listed process is kept entirely separate (the listed
process occurs further down the line). The cleaning process is
not a listed process, so this wastewater treatment sludge is not
listed. This sludge may still be hazardous by characteristic,
however, and you will need to test for that. If you have any further
questions, please do not hesitate to call me at (202) 382-4519.
Sincerely,
Ann Burke Sarno
Environmental Protection
Specialist
Waste Identification Branch
(WH-562B)
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