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RCRA definition of F006The Resource Conservation and Recovery Act or RCRA (pronounced "rick-rah") is the central law that gave EPA the authority to control hazardous waste from the "cradle-to-grave." This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. One of the most common RCRC regulated wastes generated by the printed wiring board (PWB) and metal finishing industry is waste code F006. This waste is defined as wastewater treatment sludge from electroplating operations except from the following processes:
However, if wastewaters from the above exempted processes are combined with other electroplating wastewaters, then the entire quantity of resultant sludge falls under the definition of F006. The F006 listing extends to any material removed from an electroplating wastewater treatment system other than treated effluent (e.g., paper filters used for polishing the effluent). Due to its regulatory listing, F006 waste can only be accumulated on-site by a generator for up to 90 days. It must them be shipped to a permitted treatment/disposal facility or recycling facility. Many PWB manufacturing and metal finishing companies generate relatively small or moderate quantities of F006 waste. This situation limits the management options of the waste. For example, the quantity accrued in 90 days may be less than a full transportation load (e.g., roll-off), resulting in higher unit costs ($/lbs. of sludge) for transportation. Recycling sites are often located further distances than landfills and generators are more likely to opt for the lowest cost option. As an outgrowth of the U.S. Environmental Protection Agency's (EPA) Common Sense Initiative the EPA changed the federal rules to allow large quantity generators ( LQG) of the listed hazardous waste F006 (wastewater treatment sludge from electroplating operations) to accumulate this waste on site for up 180 days and in certain instances, up to 270 days without a RCRA permit. Many states have adopted this rule (check state rules here). This rule is meant to provide incentives to promote metals recovery from F006 rather than treatment and disposal of the waste. The conditions include:
More information: EPA F006 Rule. |