Perspectives: Reconciling RCRA


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For platers, the Resource Conservation and Recovery Act (RCRA) is synonymous with F006 hazardous waste or electroplating sludge. F006 is full of metals removed from the rinse water generated in plating operations. Often valuable chemicals such as nickel, tin, gold, silver and more can be recovered from this sludge.

Because of regulations that create recycling barriers, most of this sludge is landfilled, unfortunately. The RCRA-required treatment for F006 is stabilization, which usually involves mixing it with cement, tripling the original volume.

The Policy Group, which is the government relations group for the surface finishing industry, is a leading proponent of incremental regulatory changes to promote environmentally beneficial results. It believes that RCRA should create incentives for developing innovative recycling and waste treatment techniques. The industry is working with EPA to minimize the regulatory barriers associated with the management of F006 and promote the recycling of it.

EPA is working with finishers to develop a new RCRA regulation that would conditionally exempt the rinse water treatment sludge from listing as a hazardous waste, provided that the sludge is recycled for metals recovery. It would grant regulatory flexibility of the management of ion exchange technology that is designed to remove metals from rinse water and minimize the amount of F006 sludge generated. It would examine whether a generic delisting would be appropriate for facilities that have successfully used source reduction techniques to lower the amount of hazardous constituents in their sludge.

According to representatives from The Policy Group, this initiative most likely will be instituted. The industry needs you to contact your Congressmen and women and have them support EPA’s regulatory flexibility initiatives.

In a recent development, the Federal Court granted U.S. EPA 45 days to finalize the MP&M rule, since it was at risk of not completing the package by the year-end deadline. Under the terms of the consent decree, EPA has until February 14, 2003, to finalize the rule.

Government relations asked agency officials to confirm that EPA will maintain its current position of “no further regulation” for job shops and captive operations. One of the reasons for the delay is that EPA is undecided on whether to impose new MP&M effluent limits on facilities discharging directly to water bodies. All job shops and captive facilities that discharge to municipal waste treatment works are expected to see no new MP&M limits.