Respondent incorrectly manifested the wastewater treatment sludge (filter cake) from its chemical conversion coating of aluminum as non-hazardous and failed to determine whether the sludge was a listed hazardous waste (F019).
Respondent caused its hazardous waste F019 to be transported to a facility not authorized to manage the hazardous waste F019, and caused the disposal of 61 total totes of hazardous waste F019 sludge at a facility that was not permitted to receive such waste under RCRA.