Delisting Plating Waste
Question: Several months ago, we changed our metal finishing operations so that we are only performing non-cyanide zinc plating on carbon steel followed by chromating.
Share
Question:
Several months ago, we changed our metal finishing operations so that we are only performing non-cyanide zinc plating on carbon steel followed by chromating. Our wastewater treatment filter press cake has been classified as a listed RCRA hazardous waste under F006. We have been attempting to get our filter press cake approved into a licensed sanitary landfill as a non-hazardous waste, but the state EPA still considers the waste as F006 because of the chromating after plating. Do you have any guidance on the issue that could help our case? We have done extensive testing of the filter press cake, and it does not meet the RCRA hazardous waste characteristics. S.J.
Answer:
The problem is that your state EPA is referring to the original background documents for the listing of F006 sludges from electroplating operations where chromat-ing is described as a chemical conversion process. We strongly recommend that you direct your state EPA to the 12/2/86 Federal Register, page 43,351. In this interpretative rule, U.S.EPA clarified the F006 listing by stating “. . . the F006 listing included only common and precious metals electroplating, anodizing, chemical etching and milling, and cleaning and stripping when associated with these processes. Although the listing background document noted other processes, these were not part of the promulgated listing. Accordingly, the following processes are not included under the F006 listing: chemical conversion coating, electroless plating and printed circuit board manufacturing.” Armed with this information, we believe you will be successful in obtaining approval, for we have done so twice within the last year.
One of the interesting results of this rule is that treatment of wastewater from steel phosphating does not produce a listed RCRA hazardous waste while aluminum phosphating does produce a listed RCRA hazardous waste under F019 wastewater treatment sludges from chemical conversion coating of aluminum.
Related Content
-
NASF/AESF Foundation Research Project #120: Electrochemical Destruction of Perfluorooctanesulfonate in Electroplating Wastewaters - April 2022-March 2023
This NASF-AESF Foundation research project report covers project work from April 2022 to March 2023 at the University of Illinois at Chicago. The overall objective of this work is to utilize a cost-effective reactive electrochemical membrane (REM) for the removal of PFAS from synthetic electroplating wastewater. Initial results for the oxidation of PFOA with three different catalysts are discussed.
-
NASF/AESF Foundation Research Project #122: Electrochemical Approaches to Treatment of PFAS in Plating Wastewater - 12th Quarterly Report
This NASF-AESF Foundation research project report covers the 12th quarter of project work (October – December 2023) at the University of Georgia. In our previous report, we described our work on performance and effect of surface fluorinated Ti4O7 anodes on PFAS degradation in reactive electrochemical membrane (REM) mode. This quarter, our experiments involved utilizing porous Ti4O7 plates serving both as anodes and membranes. Tests compared pristine and F-18.6 Ti4O7 anodes at current densities of 10 mA/cm2 and 40 mA/cm2. This 12th quarterly report discusses the mechanisms of the effects on EO performance by anode surface fluorination.
-
NASF/AESF Foundation Research Project #122: Electrochemical Approaches to Treatment of PFAS in Plating Wastewater - 10th Quarterly Report
The NASF-AESF Foundation Research Board selected a project addressing the problem of PFAS and related chemicals in plating wastewater streams. This report covers the 10th quarter of work (April-June 2023). Here, we examine the effect of surface fluorination of Ti4O7 anodes on PFAS degradation performance in terms of energy performance as well as formation of chlorate and perchlorate when chloride is present in the solution. The full paper on this work can be accessed and printed at short.pfonline.com/NASF24Feb2.