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EPA May Delist Electroplating Sludge from RCRA Hazardous Waste Definition

Posted on 7/17/2017 by Roger Marks

In response to a petition from Samsung Austin Semiconductor, US EPA has announced a proposal to delist Copper filter cake generated by the electroplating process (an F006 waste) from the definition of hazardous waste under the Resource Conservational and Recovery Act (RCRA). 

Samsung does not believe that this electroplating waste meets the criteria of an F006 listed waste. Under the RCRA hazardous waste regulations, EPA can delist a waste produced at a particular facility from the definition of hazardous waste per 40 CFR 260.22.

electroplating-2.jpgIn order to successfully delist the waste, the petitioner must “demonstrate that the waste… does not meet any of the criteria under which the waste was listed as a hazardous or acutely hazardous waste….” This includes proving that the waste in question does not exhibit any hazardous waste characteristic—ignitability (I), corrosivity (C), reactivity (R), or toxicity (E).

EPA will accept public comment until August 14, 2017 on the petition to remove Copper filter cake generated at Samsung’s electroplating facility. Read more about the petition in the Federal Register, here.

What Are F-List Hazardous Wastes Under RCRA?

Within the RCRA regulations, US EPA has organized hazardous wastes into four lists—the F List, the U List, the K List, and the P List.

Two of these lists, F and K, are reserved for spent materials from non-specific (F List) or specific (K List) sources. The other two, P and U, are comprised of unused chemical substances. EPA added the F and K Lists to RCRA in January 1981 and has amended the lists several times.

F006 wastes, with a few exceptions, are defined as “Wastewater treatment sludges from electroplating operations.” This waste is listed with a (T) hazard code in RCRA, meaning it exhibits the toxicity characteristic. To successfully have the waste delisted, Samsung will have to prove the Copper filter cake its facility generates does not exhibit that characteristic.

What is Electroplating?

Used since the 1800’s, electroplating is the process by which manufacturers add a layer of metal to a product, like jewelry, using electricity. In essence, the product is placed in an electrolyte bath with the plating metal, with both connected to charged electrodes. An electric current is applied, oxidizing and effectively dissolving the metal atoms in the bath. The dissolved metal is then reduced and placed on the piece.  

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