FEB 5 1987

Mr. Paul F. Crosser
Manufacturing Research Engineer
HON Industries
414 East Third Street
Muscatine, Iowa  52761

Dear Mr. Crosser:

I am responding to your letter dated January 15, 1987 requesting an interpretation of the land disposal restriction regulations as applied to a paint sludge waste.  According to your letter, this waste is created in a water-wall spray booth which prevents oversprayed paint particles from being discharged to the atmosphere.

I concur with your interpretation that this waste is a manufacturing process waste based on the description of a
manufacturing process waste on page 40697 of FR 51, published on November 7, 1986.

In regard to your request for a copy of the "BDAT Background Document for F001-F005 Spent Solvents", this three-volume set (identified as PB-87-120-259) can be purchased from NTIS, 5285 Port Royal Rd., Springfield, VA 22161.  Their telephone number is (703) 487-4650.  The cost for the set is $63.00.  Also, these documents are available for viewing at any EPA regional library.

I hope this information is helpful.  If you have additional questions, you may call Ed Abrams of my staff at (202) 382-4787.


Original Document signed

Robert M. Scarberry