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Hazardous Waste Delisting

Q. I heard that if a Plating facility generates sludge (F006,F007 etc.) and does not use cyanide in any processes, that the sludge can be de-listed and designated and handled as non-hazardous waste. Is this accurate and where might I find more information. I have looked in the CFR and couldn't find anything.

Thanks,

Frank K [last name deleted for privacy by Editor]
- Hackensack, New Jersey
2002

I don't believe that is correct, Frank. If you study the section of the CFR where it defines F006 (I think you can search for this term on an EPA site), I think you will find that F006 is a "categorically" hazardous sludge. Read that section carefully, but I think you will find that the fact that it came from an electroplating facility and doesn't meet any exemption makes it a hazardous waste regardless of what is actually in it.

Ted Mooney, P.E.
Striving to live Aloha
finishing.com - Pine Beach, New Jersey
2002

The rule seems like it has flaws in it to me if the goal is to minimize introducing waste into the environment.

Nickel and zinc are not hazardous wastes but PLATING sludge containing them is. Why? If nickel and zinc are so hazardous that they need to be considered hazardous waste in plating sludge, then why are they not considered hazardous wastes on their own? And if nickel and zinc are safe enough NOT to be considered hazardous wastes on their own then why are they considered hazardous wastes in PLATING sludge?

Chris Ballew
- Newport, Tennessee
2002

If you think your sludge may be non-hazardous, then have it tested. But if your sludge contains any lead, nickel, chromium or a number of other metals, then it will probably fail the EPA's TCLP test. This is EPA's test to determine whether or not a waste is hazardous with regard to heavy metals, and almost any commercial lab can do it for you.

There are some platers who have only zinc and iron in their sludge that have successfully delisted it. You may or may not fall into this category.

If it passes, then you may need a consultant or environmental lawyer to take you through the EPA's protocol for delisting it. It is not as difficult as it used to be, but it is kind of complex the first time around.

If it doesn't pass, there may still be hope. Sometimes by isolating just one source and treating it separately you can remove the hazardous constituent from the majority of your sludge.

Lyle Kirman
consultant - Cleveland Heights, Ohio
2002

A. Hazardous waste delistings are a very site specific matter. EPA has developed a lot of information (available on EPA's Region 6 website) about the process.

Regards,

Bill Miller
- Corolla, North Carolina
March 10, 2010

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Ed. note: Thanks for the update, Bill!

I have heard of hazardous waste delisting, how can this be done? Do you use lime to neutralise the waste? What other chemicals are involved in this process? I would like to start this in South Africa, any body got any advice for me?

Neal Mc Arthur
industrial cleaners - South Africa
2005

First of two simultaneous responses --

The requirements are government specific, so you would be better off asking South African authorities.

James Totter, CEF
- Tallahassee, Florida
2005

Second of two simultaneous responses --

I don't know about your environmental laws there, but in the USA, "delisting" has nothing to do with treating or making a hazardous waste into something non-hazardous. That procedure is identified as "treatment of hazardous waste" and does not eliminate any environmental responsibility for the waste or cause it to be delisted.

"Delisting" in the USA is defined as demonstrating that the waste does not, prior to any treatment, have any of the characteristics which caused it to be listed in the first place. For example, sludge from metal finishing wastewater treatment is listed because it is expected to contain one or more heavy metals or cyanide complexes. If you demonstrated that it did not contain hazardous heavy metals or cyanides, you could apply for delisting. You may not treat it first and apply for delisting later.

Jeffrey Holmes, CEF
Spartanburg, South Carolina
2005

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