Metal Finishing Guide Book


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environmental controls THE OPERATIONAL BENEFITS IN DELISTING HAZARDOUS WASTES GENERATED BY THE FINISHING INDUSTRY BY WILLIAM R. MILLER III, PH.D. SENIOR CLIENT PROGRAM MANAGER, SHAW ENVIRONMENTAL & INFRASTRUCTURE, COROLLA, N.C. The U.S. Code defines a hazardous waste as: (1) …a solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may— a. cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or b. pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed.i Further, the Resource Conservation and Recovery Act or RCRA defines hazardous wastes as: (1) Wastes that are contained on an EPA List ( e.g., electroplating wastes like F006, F009, and F019), or (2) Wastes that are characteristically hazardous (e.g., corrosive, ignitable, reactive), or (3) Wastes that are mixtures of hazardous wastes and solid wastes (e.g., a mixture of F019 wastes and filters), or (4) Wastes that are derived from hazardous wastes (e.g., wastewater treatment plant sludge from a process that meets the definition of a F006 waste).ii Metal finishing processes frequently generate objectionable by-products that might include, for example, air emissions, wastewater treatment plant sludges, characteristically hazardous corrosive wastes, organic halogenated solvents, and cyanide. An overview of the wastes typical of the metal finishing industry is provided in Table 1. It is not unusual for waste disposal to be one of the more costly operating expenses at a metal finishing plant. Managing hazardous wastes at a plant is also a very resource-intensive activity. Tasks such as labeling, storing, manifesting, training, signage, spill response, closure, and long-term liability are all integral to the proper management of hazardous wastes. The most common waste codes applicable to the metal finishing sector are F-Codes F006, F009, and F019. F006 and F009 deal with electroplating while F019 pertains to the chemical conversion coating of aluminum. It is not uncommon for facilities to spend well over $100,000/year dealing with these F-coded wastes. Disposal 680

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