Posted on Tue, Sep 08, 2009 @ 03:06 PM
By Marissa Palisoul, Technical Services Representative
The RCRA definition of F006 is “Wastewater Treatment Sludge from Electroplating Operations except from the following processes…”. It goes on to list things like sulfuric acid anodizing, or tin plating of steel as being exempt. This seems straightforward enough. So you are probably thinking ‘we do not do electroplating in my plant, we have no F006 waste’. Hold on- you could be wrong!
F006 also includes certain processes that the EPA considers Electroplating Operations:
Alkaline Surface Cleaning
Zinc Plating on Carbon Steel using Cyanides
Zinc Plating on Gray Cast Iron
Iron Plating on Aluminum
PreCleaning activities prior to electroplating
Ion-exchange resins from rinsewater treatment (assuming F006 precursor)
Photoresist Stripping
Cleaning and Stripping in the printing industry
Bright Dipping
Silicon water etching
Spent Activated Carbon from rinse water treatment (assuming F006 precursor)
If any of these occur onsite, and the waste water from the process is treated in a waste water treatment system, then sludge from this treatment would be considered F006! If you are unsure if any of these categories apply to you, please check with your hazardous waste professional for advice. Remember- sometimes it is better to over -code your waste then to be missing applicable waste codes! One way to avoid the entire problem is to minimize or eliminate the generation of F006. Try cleaning and drying your electroplated or etched components in a separate step to eliminate contaminants being carried into the waste water treatment system. Or with low enough levels of contaminants generated you might be eligible to get your F006 de-listed. Check with your local EPA Regional office for more information on this process.
Resource: McCoy’s RCRA Unraveled