WORKGROUP
REPORT:
F006
BENCHMARKING
STUDY
September
1998
TABLE
OF
CONTENTS
EXECUTIVE
SUMMARY
....................................................
3
I.
BACKGROUND
......................................................
8
A.
What
is
the
Common
Sense
Initiative?
................................
8
B.
The
Metal
Finishing
Industry
and
Electroplating
Wastewater
Treatment
Sludges
............................................................
10
C.
F006
Sludge
Generation
and
Management
............................
10
D.
Basis
for
Listing
F006­
Electroplating
Wastewater
Treatment
Sludges
as
a
RCRA
Hazardous
Waste
in
1980
.........................................
12
E.
Reasons
this
Study
was
Conducted
..................................
16
F.
Worker
Health
and
Safety.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
17
II.
NATIONAL
F006
BENCHMARKING
STUDY
APPROACH
..................
20
A.
Overview
.....................................................
20
B.
Methodology
..................................................
20
1.
Regional
Benchmarking
Study
...................................
21
2.
National
Benchmarking
Study
...................................
23
3.
Statistical
Analysis
of
the
Regional
and
National
Benchmarking
Data
.....
23
4.
Survey
of
Commercial
Recyclers
.................................
24
5.
Survey
of
Community
Environmental
Groups
.......................
24
III.
RESULTS
OF
THE
F006
BENCHMARKING
STUDY
.......................
24
A.
Summaries
of
Regional
and
National
Benchmarking
F006
Waste
Characterization
Data
.........................................................
24
1.
Benchmarking
Summary
Tables
..................................
24
2.
Statistical
Analysis:
Does
this
Data
Come
from
"Typical"
Metal
Finishers?
.......................................................
24
3.
Results
of
Commercial
Recyclers
and
Citizen
Group
Surveys
............
25
B.
Detailed
Results
of
the
Regional
and
National
Benchmarking
Studies
...........
29
1.
The
Milwaukee
Benchmarking
Study
..............................
29
2.
Chicago
Benchmarking
Study
...................................
47
3.
Phoenix
Benchmarking
Study
...................................
64
4.
Detailed
Results
of
the
National
Benchmarking
Study
.................
79
Appendix
A:
Summary
of
the
10
Issue
Areas
Identified
for
the
Metal
Finishing
Sector
...........
99
Appendix
B:
F006
Management
Contained
in
EPA's
1995
Biennial
Report
Database
...........
101
Appendix
C:
Observed
F006
Handling
Practices
at
Metal
Finishing
Facilities
and
List
of
Worker
Health
and
Safety
Regulations
................................................
105
September
1998
2
F006
Benchmarking
Study
Appendix
D:
Checklist
Used
to
Identify
Pollution
Prevention
Technologies
at
Metal
Finishing
Facilities
.................................................................
114
Appendix
E:
Laboratory
Analysis
Information:
Constituents,
Methods,
and
Detection
Limits
Used
in
the
Benchmarking
Studies
.............................................
117
Appendix
F:
Regional
Benchmarking
Survey
.........................................
125
Appendix
G:
National
Benchmarking
Survey
.........................................
132
Appendix
H:
National
Benchmarking
Commercial
Recyclers
Survey
........................
140
Appendix
I:
Responses
to
Citizen
Group
Phone
Survey
.................................
143
Appendix
J:
Statistical
"Representativeness"
of
the
National
Benchmarking
Study
.............
146
Borst,
Paul
A.
U.
S.
EPA,
Office
of
Solid
Waste.
Recycling
of
Wastewater
Treatment
Sludges
from
1
Electroplating
Operations,
F006.
1997.

September
1998
3
F006
Benchmarking
Study
EXECUTIVE
SUMMARY
This
report
presents
current
information
about
the
metal
finishing
industry
in
the
U.
S.,
and
is
the
result
of
a
two
year
effort
of
the
Metal
Finishing
workgroup
of
the
Common
Sense
Initiative
(CSI).
The
CSI
was
begun
by
the
Environmental
Protection
Agency
(EPA)
in
1994
to
explore
"cleaner,
cheaper,
and
smarter"
environmental
strategies
beyond
those
required
by
regulation.
Using
the
special
authorities
of
the
Federal
Advisory
Committee
Act
(FACA),
EPA
brought
together
representatives
from
federal,
state,
and
local
governments,
industry,
community­
based
and
national
environmental
interest
groups,
environmental
justice
groups
and
organized
labor
to
explore
opportunities
for
managing
environmental
issues
in
new
ways.
Six
industry
sectors
were
chosen
for
the
initial
CSI
efforts,
including
petroleum
refining,
automobile
manufacturing,
iron
and
steel
production,
electronics,
printing
and
metal
finishing.

Overview
of
the
Metal
Finishing
Industry
and
Hazardous
Waste
Management.

Metal
finishing
refers
to
processes
which
deposit
or
"plate"
a
thin
layer
of
metal
and/
or
apply
an
additional
organic
topcoat
as
an
outer
coating
on
products
received
from
other
manufacturing
operations.
Metal
finishing
is
performed
for
either
functional
or
decorative
purposes
and
affects
many
products
we
use
everyday.
For
example,
hard
chrome
plating
is
a
functional
plating
process
that
increases
the
hardness
and
durability
of
engine
parts.
Chrome
plating
automobile
bumpers
is
an
example
of
a
decorative
plating
process.

EPA
estimated
that
there
were
approximately
13,400
metal
finishing
establishments
in
the
United
States.
Of
the
total,
approximately
10,000
metal
finishing
facilities
are
estimated
to
be
"captive"
shops
contained
inside
a
larger
manufacturing
operation.
The
balance
of
3,400
metal
finishing
facilities
are
"job
shops"
or
"independent"
metal
finishing
operations
that
operate
on
a
job­
specific
contract
basis.
The
total
number
of
plating
shops
has
decreased
significantly
since
1
the
1970's,
mainly
as
a
result
of
increasing
regulations
and
competition.

As
in
many
manufacturing
processes,
some
portion
of
the
materials
used
in
production
or
in
the
product
itself
are
not
totally
captured
as
salable
product,
and
exit
the
process
in
wastewater,
solid
waste,
airborne
emissions,
scrap
metal,
or
off­
spec
products.
Prior
to
1980,
there
were
no
federal
regulations
covering
the
discharge
or
disposal
of
wastes
from
metal
finishing
operations,
and
the
wastes,
which
contained
metals
as
well
as
other
substances,
were
often
directly
discharged
to
surface
waters
or
disposed
of
in
landfills
or
lagoons.

In
1980,
EPA
issued
the
Nation's
first
hazardous
waste
management
regulations,
which
"listed"
sludges
from
electroplating
wastewater
treatment
as
a
hazardous
waste
(F006),
and
set
standards
for
the
storage,
transportation,
treatment
and
disposal
of
these
sludges.
EPA
simultaneously
developed
regulations
that
require
metal
finishers
to
significantly
reduce
or
eliminate
pollutants
in
wastewaters
discharged
to
publically
owned
wastewater
treatment
systems
Borst,
Paul
A.
U.
S.
EPA,
Office
of
Solid
Waste.
Recycling
of
Wastewater
Treatment
Sludges
from
2
Electroplating
Operations,
F006.
1997.

September
1998
4
F006
Benchmarking
Study
(final
"pretreatment
regulations
were
issued
in
1986).

As
a
result
of
the
strengthening
of
the
federal
regulations,
the
metal
finishing
industry
implemented
many
improvements
in
material
use,
production
processes
and
waste
management
methods.

Metals
contained
in
F006
have
commercial
value
if
they
are
present
in
sufficient
concentrations
and
if
other
analytes
in
the
sludge
are
below
levels
which
would
interfere
with
the
metal
recovery
process.
There
may
be
other
materials
contained
in
the
sludge
which
do
not
interfere
with
metals
recovery,
but
which
could
be
hazardous
if
improperly
managed.
The
economics
of
hazardous
waste
management
is
a
strong
determinant
of
whether
metal
finishers
send
sludges
for
land
disposal
or
to
recycling
facilities.
Estimates
of
the
amounts
of
sludge
that
are
recycled
or
land
disposed
vary
widely.
One
source
estimates
that
between
10
and
20
percent
is
recycled
and
between
80
and
90
percent
is
treated
and
land
disposed.
2
Why
was
this
study
conducted?

The
CSI
Metal
Finishing
Subcommittee
focused
on
the
metal
finishing
industry's
belief
that
process
improvements
made
by
many
metal
finishers
during
the
past
20
years
have
significantly
changed
the
composition
of
the
F006
material
that
was
listed
and
regulated
in
1980,
and
it
is
the
industry's
belief
that
modification
of
EPA's
hazardous
waste
regulations
for
F006
could
increase
the
metal
finishing
industry's
ability
to
recover
and
recycle
more
commercially
valuable
metals
from
F006
than
they
currently
recover,
and
simultaneously
decrease
the
amount
of
metal
finishing
wastes
disposed
of
in
regulated
landfills.

In
order
to
evaluate
the
current
status
of
the
industry,
the
Subcommittee
formed
a
workgroup
to
complete
a
characterization
of
F006
and
to
report
on
the
results
as
the
foundation
for
any
further
discussions
regarding
potential
modifications
to
F006
regulations.

This
report
simply
presents
the
data
collected
during
the
F006
Benchmarking
Study
as
a
foundation
for
further
evaluation
of
F006.
The
CSI
Workgroup
did
not
attempt
to
analyze
the
data
to
determine
the
extent
to
which
the
characteristics
of
F006
have
changed
based
on
industry
pollution
prevention
practices
or
other
factors.
In
Phase
2
of
this
effort,
the
Workgroup
will
analyze
the
information
presented
in
this
report,
and
examine
whether
potential
modifications
of
the
current
regulations
applicable
to
F006
should
be
considered
by
EPA.

Worker
Health
and
Safety
As
part
of
the
benchmarking
study,
the
workgroup
collected
information
on
F006
handling
practices,
identified
the
potential
hazards
to
workers,
and
described
possible
hazard
control
September
1998
5
F006
Benchmarking
Study
methods.
In
addition,
the
workgroup
developed
a
list
of
the
current
worker
health
and
safety
regulations
and
policies
that
may
apply
to
on­
site
and
off­
site
management
of
F006.
This
information
is
presented
in
Appendix
C
of
this
report.
Beyond
this
information,
the
workgroup
did
not
attempt
to
complete
a
comprehensive
review
of
worker
health
and
safety
issues
associated
with
F006
management.

As
indicated
above,
in
Phase
II
of
this
effort
the
workgroup
will
examine
whether
possible
modifications
of
the
current
regulations
for
F006
should
be
considered
based
on
the
information
in
this
study.
As
part
of
this
effort,
the
workgroup
will
consider
potential
worker
health
and
safety
issues
when
examining
possible
regulatory
changes
for
F006.

The
F006
Benchmarking
Study
Approach
The
workgroup
focused
on
three
analytical
questions
to
guide
its
work
on
characterizing
current
practices
in
the
metal
finishing
industry,
and
the
composition
and
management
of
F006:

1)
What
are
the
characteristics
of
F006?
2)
What
can
metal
finishers
do
to
make
F006
more
recyclable,
while
optimizing
pollution
prevention?
What
pollution
prevention
practices
are
in
place
at
metal
finishing
facilities?
3)
What
are
the
environmental
impacts
of
F006
recycling?

While
not
an
initial
focus
in
this
effort,
the
workgroup
also
examined
worker
health
and
safety
impacts
in
this
study.

To
answer
these
questions,
the
workgroup
designed
a
five
part
"benchmarking
study"
to
gather
current
information
on
the
metal
finishing
industry.
This
approach
carefully
balances
the
need
to
gather
detailed
information
from
a
diverse
industry
with
funding
and
schedule
limitations.
The
workgroup
believes
the
study
approach
and
the
data
presented
in
this
report
provide
a
very
useful
characterization
of
a
cross
section
of
"typical"
metal
finishing
facilities
and
a
strong
sense
for
the
environmental
awareness
of
many
metal
finishing
companies.
The
workgroup
also
recognizes
that
there
are
facilities
in
the
metal
finishing
industry
which
do
not
fit
within
the
range
of
activities
and
practices
characterized
in
this
report,
and
that
discussion
of
the
data
presented
in
this
report
should
take
that
into
account.
The
workgroup
also
discussed
the
possibility
that,
despite
the
usefulness
of
the
data
gathered
in
the
Benchmarking
study,
additional
data
might
be
needed
if
subsequent
discussions
of
policy
options
and/
or
regulatory
options
analysis
warranted
more
data.

The
study
components
summarized
below,
which
are
discussed
in
detail
in
the
report,
include:

A
Regional
Benchmarking
Study
that
involved
site
visits
to
29
metal
finishing
shops
in
three
cities
to
gather
detailed
data
on
plating
processes,
pollution
prevention
practices,
F006
chemical
analysis
and
F006
handling
and
management
practices;
September
1998
6
F006
Benchmarking
Study
A
National
Benchmarking
Study
that
used
a
mail
survey
to
gather
less
detailed
data
on
metal
finishing
operations,
pollution
prevention
practices,
F006
characteristics
and
management
practices
from
a
broad
range
of
metal
finishers;

An
Analysis
of
Statistical
Representation
to
determine
the
extent
to
which
the
companies
participating
in
the
regional
and
national
benchmarking
studies
represent
the
universe
of
metal
finishers.

A
Commercial
Recycling
Company
Mail
Survey
to
gather
data
on
the
amount
and
chemical
composition
of
F006
accepted
for
recycling
by
commercial
recycling
companies,
and
A
Community
Interest
Group
Phone
Survey
to
assess
whether
community
groups
in
the
vicinity
of
commercial
recycling
companies
believe
those
companies
are
good
environmental
and
economic
neighbors.

Results
of
the
National
F006
Benchmarking
Study
The
results
of
the
five
components
of
the
study
are
presented
in
the
main
body
of
the
report.
The
results
of
the
Regional
and
National
Benchmarking
Studies
are
presented
in
summary
form
and
in
detail.
The
data
describe
the
range
of
production,
pollution
prevention
and
waste
management
practices
employed
by
the
facilities
studied
and
the
present
information
about
the
quantity
and
composition
of
F006
wastes
produced.
For
example,
the
minimum,
mean,
median,
and
maximum
values
of
F006
laboratory
analyses
are
provided
in
a
format
that
allows
the
reader
to
compare
regional
and
national
data.
Detailed
data
for
each
of
the
29
facilities
that
participated
in
the
Regional
study,
and
detailed
results
from
the
National
study
are
also
presented.

The
workgroup's
statistical
analysis
examined
the
extent
to
which
the
data
gathered
in
the
Regional
and
National
Benchmarking
studies
represents
the
metal
finishing
universe,
keeping
in
mind
that
the
Regional
and
National
Benchmarking
studies
were
designed
to
give
the
workgroup
descriptive
data
for
facilities
which
operate
the
most
commonly
used
metal
finishing
processes.
The
Benchmarking
study
was
not
designed
to
capture
data
on
the
full
range
of
metal
finishing
operations.
In
short,
the
statistical
analysis
that
was
completed
indicates
that
the
Benchmarking
Study
results
can
not
be
assumed
to
statistically
represent
the
entire
metal
finishing
universe.
This
result
does
not
diminish
the
value
of
the
Benchmarking
study
data.
The
Benchmarking
Study
does
provide
substantial
additional
data
characterizing
the
F006
wastestream
and
provides
a
sound
starting
point
for
further
discussion.

The
workgroup
was
not
able
to
obtain
enough
data
to
complete
the
commercial
recycling
study,
therefore
no
results
are
presented.
Results
of
the
community
group
survey,
which
was
designed
to
accompany
the
results
of
the
commercial
recycling
survey,
are
summarized
even
though
the
commercial
recycling
study
was
not
completed.

The
Appendices
of
this
report
contain
further
details
supporting
various
aspects
of
the
study.
September
1998
7
F006
Benchmarking
Study
Project
participants:

The
following
people
participated
in
this
project:

John
Linstedt
(Artistic
Plating,
Inc.),
Diane
Cameron
(Natural
Resources
Defense
Council),
Bill
Sonntag,
Al
Collins,
and
participating
members
of
the
American
Electroplaters
and
Surface
Finishers
Society,
National
Association
of
Metal
Finshers,
and
the
Metal
Finishing
Suppliers
Association,
Andy
Comai
(United
Auto
Workers),
Tom
Wallin
(Illinois
EPA),
Doreen
Sterling
(US
EPA),
Mike
Flynn
(US
EPA),
Jim
Lounsbury
(US
EPA),
Jeff
Hannapel
(US
EPA)
John
Lingelbach
(facilitator,
Decisions
and
Agreements,
LLC)
and,
the
SAIC
Contractor
Support
Team.
September
1998
8
F006
Benchmarking
Study
I.
BACKGROUND
A.
What
is
the
Common
Sense
Initiative?

In
1994,
the
Administrator
of
the
Environmental
Protection
Agency,
Carol
Browner,
launched
the
Common
Sense
Initiative
(CSI),
describing
it
as
a
"fundamentally
different
system"
to
explore
industry­
specific
strategies
for
environmental
protection.
The
program
is
designed
to
promote
"cleaner,
cheaper,
and
smarter"
environmental
performance,
using
a
non­
adversarial,
stakeholder
consensus
process
to
test
innovative
ideas
and
approaches.
Six
industry
sectors
were
selected
to
participate
in
CSI:
Petroleum
Refining,
Auto
Manufacturing,
Iron
and
Steel,
Metal
Finishing,
Printing,
and
Computers
and
Electronics.

In
January
of
1995,
the
Environmental
Protection
Agency
(EPA)
chartered
the
Metal
Finishing
Sector
Subcommittee
of
the
Common
Sense
Initiative
under
the
Federal
Advisory
Committee
Act.
The
Metal
Finishing
Subcommittee
includes
representatives
of
EPA
Headquarters
and
Regional
offices,
the
metal
finishing
industry
and
its
suppliers,
state
government,
Publicly
Owned
Treatment
Works
(POTWs),
national
and
regional
environmental
organizations,
the
environmental
justice
community,
and
organized
labor.

The
CSI
Metal
Finishing
Sector
was
challenged
by
Administrator
Carol
Browner
to
develop
a
consensus
package
of
"cleaner,
cheaper,
and
smarter"
policy
actions
for
the
industry
as
a
whole,
based
on
the
lessons
learned
from
the
Sector's
projects
and
dialogue.
Based
on
this
challenge
the
Subcommittee
established
a
workgroup
to
develop
a
strategic
policy
and
program
framework
for
the
industry.

The
Metal
Finishing
Strategic
Goals
Program,
designed
by
this
multi­
stakeholder
group,
establishes
a
set
of
voluntary
National
Performance
Goals
for
the
industry
that
represent
"better
than
compliance"
environmental
performance
for
metal
finishers.
The
Metal
Finishing
Goals
Program,
summarized
in
Table
1,
includes
facility­
based
numerical
performance
targets
which
track
the
CSI
themes
of
cleaner,
cheaper,
and
smarter
performance.

The
goals
program
also
includes
a
detailed
Action
Plan
that
addresses
nine
important
issue
areas
(listed
in
Appendix
A)
for
the
metal
finishing
industry.
By
implementing
the
Action
Plan,
stakeholders
provide
incentives,
create
tools,
and
remove
barriers
for
metal
finishers
to
achieve
the
National
Performance
goals.
Today's
report
presents
the
results
of
the
first
phase
of
the
Waste
Minimization
and
Recovery
issue
area.

The
Waste
Minimization
and
Recovery
Issue
examines
the
metal
finishing
industry's
belief
that
process
improvements
made
by
many
metal
finishers
during
the
past
20
years
have
significantly
changed
the
nature
of
the
industry's
wastewater
treatment
sludges,
which
are
regulated
as
a
hazardous
waste
known
as
F006
under
the
Resource
Conservation
and
Recovery
Act
(RCRA).
The
metal
finishing
industry
also
believes
that
modification
of
EPA's
hazardous
waste
regulations
for
F006
could
increase
the
metal
finishing
industry's
ability
to
recover
more
commercially
valuable
metals
(contained
in
F006)
than
they
currently
recover,
and
simultaneously
decrease
the
amount
of
metal
finishing
wastes
disposed
of
in
regulated
landfills.
September
1998
9
F006
Benchmarking
Study
Table
1:
National
Metal
Finishing
Performance
Goals
(By
Year
2002)

(1)
Improved
Resource
Utilization
("
Smarter")

(a)
98%
of
metals
ultimately
utilized
on
product.
(b)
50%
reduction
in
water
purchased/
used
(from
1992
levels).
(c)
25%
reduction
in
facility­
wide
energy
use
(from
1992
levels)

(2)
Reduction
in
Hazardous
Emissions
and
Exposures
(i.
e.,"
Cleaner")

(a)
90%
reduction
in
organic
TRI
emissions
and
50%
reduction
in
metals
emissions
to
air
and
water
(from
1992
levels).
(b)
50%
reduction
in
land
disposal
of
hazardous
sludge
and
a
reduction
in
sludge
generation
(from
1992
levels).
(c)
Reduction
in
human
exposure
to
toxic
materials
in
the
facility
and
the
surrounding
community,
clearly
demonstrated
by
action
selected
and
taken
by
the
facility.
Such
actions
may
include,
for
example,
pollution
prevention,
use
of
state­
of
the­
art
emission
controls
and
protective
equipment,
use
of
best
recognized
industrial
hygiene
practices,
worker
training
in
environmental
hazards,
or
participation
in
the
Local
Emergency
Planning
Committees.

(3)
Increased
Economic
Payback
and
Decreased
Costs
("
Cheaper")

(a)
Long­
term
economic
benefit
to
facilities
achieving
Goals
1
and
2.
.
(b)
50%
reduction
in
costs
of
unnecessary
permitting,
reporting,
monitoring,
and
related
activities
(from
1992
levels),
to
be
implemented
through
burden
reduction
programs
to
the
extent
that
such
efforts
do
not
adversely
impact
environmental
outcomes.

(4)
Industry­
Wide
Achievement
of
Facility
Goals.

(a)
80%
of
facilities
nationwide
achieve
Goals
1
­
3.

(5)
Industry­
Wide
Compliance
with
Environmental
Performance
Requirements.

(a)
All
operating
facilities
achieve
compliance
with
Federal,
State,
and
local
environmental
performance
requirements.
(b)
All
metal
finishers
wishing
to
cease
operations
have
access
to
a
government
sponsored
"exit
strategy"
for
environmentally
responsible
site
transition.
(c)
All
enforcement
activities
involving
metal
fishing
facilities
are
conducted
in
a
consistent
manner
to
achieve
a
level
playing
field,
with
a
primary
focus
on
those
facilities
that
knowingly
disregard
environmental
requirements.

Note:
At
facilities
where
outstanding
performance
levels
were
reached
prior
to
1992,
the
percentage­
reduction
targets
for
Goals
1
(b)
and
(c),
and
2
(a)
and
(b)
may
not
be
fully
achievable,
or
the
effort
to
achieve
them
may
not
be
the
best
use
of
available
resources.
In
these
instances,
a
target
should
be
adjusted
as
necessary
to
make
it
both
meaningful
and
achievable.

The
group
formed
to
address
this
issue
is
the
Metal
Finishing
F006
Benchmarking
Workgroup,
comprised
of
representatives
from
the
metal
finishing,
the
recycling
industry,
environmental
interests,
organized
labor,
local
government
and
the
EPA.
The
workgroup
has
completed
a
two
year
effort
to
gather
new
information
on
the
generation,
characteristics
and
USEPA,
Office
of
Policy,
Planning
and
Evaluation.
SUSTAINABLE
INDUSTRY:
Promoting
3
Environmental
Protection
in
the
Industrial
Sector,
Phase
1
Report.
June
1994.

Borst,
Paul
A.
U.
S.
EPA,
Office
of
Solid
Waste.
Recycling
of
Wastewater
Treatment
Sludges
from
4
Electroplating
Operations,
F006.
1997.

Kirk­
Othmer.
Encyclopedia
of
Chemical
Technology
(4th
ed.),
199­­
888,
v.
9
5
USEPA,
Office
of
Solid
Waste,
Hazardous
Waste
F006
Listing
Background
Document,
p.
107.
6
September
1998
10
F006
Benchmarking
Study
management
of
electroplating
wastewater
treatment
sludges
(F006).
The
workgroup's
approach
and
results
are
described
in
detail
in
the
remainder
of
this
report.

B.
The
Metal
Finishing
Industry
and
Electroplating
Wastewater
Treatment
Sludges
EPA
estimated
that
there
were
approximately
13,400
metal
finishing
establishments
in
the
United
States.
Of
the
total,
approximately
10,000
metal
finishing
facilities
are
estimated
to
be
3
"captive"
shops
where
the
metal
finishing
operation
is
contained
inside
a
larger
manufacturing
operation.
The
balance
of
3,400
metal
finishing
facilities
are
"job
shops"
or
"independent"
metal
finishing
operations.
Job
shops
are
usually
small
businesses
that
operate
on
a
job­
specific
contract
basis.
The
total
number
of
plating
shops
has
decreased
since
the
1970's,
mainly
as
a
result
of
4
increasing
regulatory
burden
and
competition.
One
source
estimates
that
the
number
of
metal
finishers
decreased
to
as
low
as
7,200
in
1992.
5
Metal
finishing
refers
to
processes
which
deposit
or
"plate"
a
thin
layer
of
metal
and/
or
an
additional
organic
topcoat
as
an
outer
coating
on
products
received
from
other
manufacturing
operations.
Metal
finishing
is
performed
for
either
functional
or
decorative
purposes
and
affects
many
products
we
use
everyday.
A
large
percentage
of
all
metal
or
metalized
products
require
surface
finishing
before
the
product
is
ready
for
final
use.
Some
examples
of
functional
uses
include:
hard
chrome
plating
to
increase
hardness
and
durability
in
engine
parts;
zinc
plating
to
increase
the
corrosion
resistance
of
fasteners;
tin
and
silver
plating
electrical
contacts
in
electrical
distribution
switches
for
electrical
enhancement
and
corrosion
resistance;
and
gold
plating
in
high
quality
communications
applications.
Chrome
plating
automobile
bumpers
is
an
example
of
a
decorative
plating
process.
6
Metal
plating
involves
a
sequence
of
steps,
including
metal
surface
preparation
and
cleaning,
metal
deposition,
rinsing,
and
wastewater
treatment.
The
electroplating
step
involves
immersing
an
object
into
a
solution
of
metal
ions
and
applying
an
external
reductive
source.
Control
of
the
electrical
current,
solution
temperature,
pH,
and
solution
chemistry
determines
the
thickness
of
the
deposit.
Other
forms
of
metal
finishing
and
plating
are
used
by
some
shops,
e.
g.,
electroless
plating,
however,
they
are
not
the
focus
of
this
study.
Table
2,
below,
lists
frequently
used
metals
and
their
applications.

C.
F006
Sludge
Generation
and
Management
September
1998
11
F006
Benchmarking
Study
As
in
many
manufacturing
processes,
some
portion
of
the
materials
used
in
production
or
in
the
product
itself
are
not
totally
captured
as
salable
product,
and
exit
the
process
in
wastewater,
solid
waste,
airborne
emissions,
scrap
metal,
or
off­
spec
products.
Captive
shops,
which
repeat
the
same
plating
operations
over
time,
use
a
relatively
homogeneous
mix
of
Table
2.
Frequently
Used
Metals
and
Their
Applications
Property/
Function
Principal
Plating
Metals
Decorative
Chromium,
copper,
nickel,
brass,
bronze,
gold,
silver,
platinum,
zinc
Corrosion
resistance
Nickel,
chromium,
electroless
nickel,
zinc,
cadmium,
copper,
copper
alloys,
silver,
tin,
gold
Wear,
lubricity,
hardness
Chromium,
electroless
nickel,
bronze,
nickel,
cadmium,
silver,
tin,
metal
composites
Bearings
Copper,
bronze,
silver,
silver
alloys,
lead­
tin
Joining,
soldering,
brazing,
electrical
Nickel,
electroless
nickel,
electroless
copper,
copper,
cadmium,
gold,
contact
resistance,
conductivity
silver,
lead­
tin,
tin,
cobalt
Barrier
coatings,
anti­
diffusion,
heat­
Nickel,
cobalt,
iron,
copper,
bronze,
tin­
nickel,
palladium
treatment
Electromagnetic
shielding
Copper,
electroless
copper,
nickel,
electroless
nickel,
zinc
Paint/
lacquer
base,
rubber
bonding
Zinc,
tin,
chromium,
brass
Electroforming
manufacturing
Copper,
nickel
Electronics
manufacturing
Electroless
copper,
copper,
electroless
nickel,
nickel,
gold,
palladium
Dimensional
buildup,
salvage
of
worn
parts
Chromium,
nickel,
electroless
nickel,
iron,
silver
Source:
Electroplating
Engineering
Handbook,
1996.

chemicals
and,
consequently,
generate
a
relatively
contant
mix
of
wastes.
Job
shops
are
more
likely
to
change
processes
to
meet
the
demand
of
a
range
of
customers,
which
changes
the
mix
of
materials
used
to
plate
products
and
the
mix
and
concentration
of
wastes
generated.
This
difference
in
operations
drives
differences
in
the
wastes
generated
by
these
shops.

F006
sludge
is
formed
by
adding
precipitation
chemicals
in
electroplating
wastewater
treatment
systems.
The
precipitation
chemicals
are
used
to
remove
toxic
metals
and
other
hazardous
constituents
from
the
wastewater,
a
large
portion
of
which
settle
to
the
bottom
as
sludge.
The
sludge
(F006)
is
a
very
wet
metal
hydroxide
mixture
that
is
removed
from
the
treatment
tank
and
usually
"dewatered"
in
large
presses,
leaving
a
wet
mud
that
is
generally
25
percent
solids
by
weight.
Sludges
are
sometimes
dried
to
further
reduce
moisture
content
and
weight.
The
sludge
is
stored
in
containers,
such
as,
"super
sacks,"
or
larger
"roll
off
boxes,"
and
is
sent
by
truck
or
rail
to
RCRA
permitted
treatment
and
disposal
facilities,
or
to
hazardous
waste
Borst,
Paul
A.
U.
S.
EPA,
Office
of
Solid
Waste.
Recycling
of
Wastewater
Treatment
Sludges
from
7
Electroplating
Operations,
F006.
1997.

op.
cit.
8
Prior
to
land
disposal,
F006
must
be
treated
to
meet
the
treatment
standards
specified
in
EPA's
Land
9
Disposal
Restrictions
regulations,
40
CFR
Part
268,
to
immobilize
toxic
constituents,
mainly
metals.
Stabilization
is
one
technology
that
may
be
utilized,
however,
other
technologies
may
be
used.

The
Biennial
Reporting
System
is
not
designed
to
provide
"treatment
train"
(e.
g.,
stabilization
followed
by
10
landfilling)
information.
Therefore,
in
an
effort
to
avoid
double
counting,
these
quantities
were
calculated
from
facilities
reporting
F006
management
as
either
recycling
or
landfilling.
In
other
words,
the
majority
of
the
wastes
go
through
some
interim
management
steps
(e.
g.,
stabilization,
blending)
not
accounted
for
in
these
calculations.
It
would
be
virtually
impossible
to
account
for
the
final
management
of
sludge
going
through
offsite
treatment
prior
to
final
disposition.
In
this
case,
only
about
25%
of
the
volume
generated
is
accounted
for.

September
1998
12
F006
Benchmarking
Study
permitted
recycling
facilities,
which
recover
economically
valuable
metals
from
the
sludge
and
land
dispose
the
remaining
material.

The
metals
contained
in
F006
have
commercial
value
if
they
are
present
in
sufficient
concentrations
and
if
other
analytes
in
the
sludge
are
below
levels
which
would
interfere
with
the
metal
recovery
process.
There
may
be
other
materials
contained
in
the
sludge
which
do
not
interfere
with
metals
recovery,
but
which
could
be
hazardous
if
improperly
managed.
Recycling
facilities
generally
blend
F006
shipments
from
several
generators
to
meet
recycling
specifications
for
a
particular
target
metal
in
the
sludge.
Secondary
smelting,
which
is
the
most
frequently
used
recovery
technology,
"melts"
a
target
metal
(e.
g.,
copper)
from
mixtures
of
F006,
scrap
copper,
and
other
copper
containing
secondary
materials.
Often
multiple
metals
are
captured.
Smelting
wastes
are
generally
land
disposed.

Estimates
of
the
amounts
of
sludge
that
are
recycled
or
land
disposed
vary
widely.
One
source
estimates
that
between
10
and
20
percent
is
recycled
and
between
80
and
90
percent
of
F006
is
treated
and
disposed
of
through
stabilization
and
placement
in
RCRA
hazardous
waste
landfills.
In
1993,
the
National
Association
of
Metal
Finishers
estimated
that
approximately
15
to
7
20
percent
of
F006
is
recycled
for
metal
recovery.
EPA's
Biennial
Reporting
System
(BRS)
8
indicates
that
824
metal
finishers
which
are
large
quantity
(more
than
1,000
kg/
month)
generators
of
hazardous
waste)
recycled
282,000
tons
of
F006
in
1995,
and
283
large
quantity
metal
finishing
generators
treated
and
disposed
of
99,000
tons
of
F006
in
RCRA
regulated
landfills
per
9
year.
The
results
contained
in
today's
report
are
inconclusive
and
do
not
narrow
the
wide
variation
in
recycling
estimates.
These
figures
are
explained
in
more
detail
in
Appendix
B.
10
D.
Basis
for
Listing
F006­
Electroplating
Wastewater
Treatment
Sludges
as
a
RCRA
Hazardous
Waste
in
1980
In
the
early
1970's,
the
U.
S.
enacted
legislation
to
reduce
discharges
of
pollutants
to
U.
S.
waters.
In
subsequent
years,
EPA,
States
and
local
governments
developed
wastewater
pretreatment
regulations
which
require
industry,
including
metal
finishers,
to
significantly
reduce
or
eliminate
pollutants
from
their
wastewater
before
sending
their
wastewater
to
publicly
owned
A
solid
waste
may
be
classified
as
a
hazardous
wastes
if:
1)
it
exhibits
a
characteristic
for
ignitability,
11
corrosivity,
reactivity,
or
toxicity
(40
CFR
Part
261
Subpart
C),
or
2)
if,
classified
as
a
listed
waste
(40
CFR
Subpart
D).

September
1998
13
F006
Benchmarking
Study
sewer
treatment
systems
(40
CFR
Part
413).
Final
Federal
standards
were
promulgated
July,
1986
(at
40
CFR
§§
413
and
433).

Solid
waste
legislation
in
1976,
i.
e.,
RCRA,
required
EPA
to
designate
categories
of
industrial
waste
which
are
"hazardous,"
and
to
issue
regulations
which
ensure
safe
generation,
storage,
transportation,
treatment
and
disposal
of
these
wastes.
Metal
finishers
were
among
the
first
industries
to
be
regulated
under
the
hazardous
waste
regulations
in
1980.

EPA
"listed"
the
wastewater
treatment
sludges
from
certain
electroplating
operations
as
a
hazardous
waste
(hazardous
waste
code
F006)
under
Subtitle
C
of
RCRA
in
1980
based
on
a
11
variety
of
factors
(45
F.
R.
74884,
November
12,
1980).
Key
to
this
decision
were
typically
high
levels
of
cadmium,
nickel,
hexavalent
chromium
and
complexed
cyanides
in
the
sludge
that
could
pose
a
substantial
present
or
potential
hazard
to
human
health
and
the
environment
if
improperly
managed.
The
Extraction
Procedure
Toxicity
Characteristic
(or
EP)
test
used
at
that
time
(at
43
FR
58956­
58957);
and
the
ASTM
distilled
water
leaching
test,
showed
that
these
metals
leached
out
of
the
sludge
in
significant
concentrations,
which
increased
the
possibility
of
groundwater
contamination
if
these
wastes
were
improperly
disposed.
Leaching
tests
run
by
the
American
Electroplaters'
Society
(AES)
under
an
EPA
grant
yielded
cyanide
leach
concentrations
of
0.5
to
170
mg/
l,
cadmium
levels
of
non­
detectable
to
268
mg/
l,
and
chromium
levels
of
0.12
to
400
mg/
l.

At
that
time,
EPA
also
estimated
that
a
majority
of
metal
finishers
discharged
their
wastewater
to
POTWs
without
treating
the
wastewater.
The
remainder
discharged
to
waters
of
the
U.
S.,
on­
site
lagoons,
or
surface
impoundments.
Based
upon
data
collected
from
48
facilities
that
did
not
treat
their
waste
in
1976,
EPA
estimated
that
20
percent
disposed
of
their
solid
waste
on­
site
while
80
percent
sent
their
solid
waste
off­
site
for
disposal
in
a
municipal
or
commercial
landfill.

Prior
to
the
issuance
of
RCRA
hazardous
waste
regulations
in
1980,
there
were
no
Federal
requirements
for
management
of
metal
finishing
sludges.
Disposal
practices
included
landfilling,
lagooning,
drying
beds
and
drum
burial.
These
sites
frequently
lacked
leachate
and
runoff
control
practices,
which
increased
the
risk
of
percolation
of
heavy
metals
and
cyanides
into
soils,
groundwater
and
surface
waters.
Numerous
damage
incidents
(e.
g.,
contaminated
wells,
destruction
of
animal
life)
attributable
to
improper
electroplating
waste
disposal
were
reported,
indicating
that
mismanagement
was
an
actual,
rather
than
a
perceived
or
potential
threat.
The
long
term
persistence
of
heavy
metals
in
the
environment
increased
the
potential
for
risk.
The
data
EPA
used
for
its
listing
determination
came
from
various
sources.
Some
of
the
data
was
over
20
years
old
while
other
data
used
in
the
determination
was
current
at
that
time.

Tables
3a
and
3b
are
taken
from
EPA's
F006
listing
regulatory
support
documents
(1980).
Table
3a
summarizes
the
chemical
composition
of
typical
electroplating
baths
used
in
the
1970's.
Table
3b
summarizes
information
on
heavy
metal
concentrations
in
sludges.
September
1998
14
F006
Benchmarking
Study
Table
3a:
Typical
Electroplating
Baths
and
Their
Chemical
Composition
Plating
Compound
Constituents
Concentration
(g/
l)

1.
Cadmium
Cyanide
Cadmium
oxide
22.5
Cadmium
19.5
Sodium
cyanide
77.9
Sodium
hydroxide
14.2
2.
Cadmium
Fluoborate
Cadmium
fluoborate
251.2
Cadmium
(metal)
94.4
Ammonium
fluoborate
59.0
Boric
acid
27.0
Licorice
1.1
3.
Chromium
Electroplate
Chromic
acid
172.3
Sulfate
1.3
Fluoride
0.7
4.
Copper
Cyanide
Copper
cyanide
26.2
Free
sodium
cyanide
5.6
Sodium
carbonate
37.4
Rochelle
salt
44.9
5.
Electroless
Copper
Copper
nitrate
15
Sodium
bicarbonate
10
Rochelle
salt
30
Sodium
hydroxide
20
Formaldehyde
(37%)
100
ml/
l
6.
Gold
Cyanide
Gold
(as
potassium
gold
cyanide)
8
Potassium
cyanide
30
Potassium
carbonate
30
Depotassium
phosphate
30
7.
Acid
Nickel
Nickel
sulfate
330
Nickel
chloride
45
Boric
acid
37
8.
Silver
Cyanide
Silver
cyanide
35.9
Potassium
cyanide
59.9
Potassium
carbonate
15.0
Metallic
silver
23.8
Free
cyanide
41.2
9.
Zinc
Sulfate
Zinc
sulfate
374.5
Sodium
sulfate
71.5
Magnesium
sulfate
59.9
Source:
EPA
F006
Listing
Background
Document,
1980
September
1998
15
F006
Benchmarking
Study
Table
3b:
Heavy
Metal
Content
for
Chromium
and
Cadmium
in
Electroplating
Sludges
(Dry
Weight
ppm)

Primary
Plating
Process
Chromium
Cadmium
Segregated
Zinc
200
<100
Segregated
Cadmium
62,000
22,000
Zinc
Plating
and
Chromating
65,000
1,100
Copper­
Nickel­
Chromium
on
Zinc
500
ND
Aluminum
anodizing
(chromic
process)
1,700
ND
Nickel­
Chromium
on
steel
14,000


Multi­
process
job
25,000
1,500
Electroless
Copper
on
Plastic,
Acid
Copper,
Nickel
Chromium
137,000
ND
Multi­
process
with
Barrel
or
Vibratory
Finish
570


Printed
Circuits
3,500
<100
Nickel­
Chromium
on
Steel
79,200
<100
Cadmium­
Nickel­
Copper
on
Brass
and
Steel
48,900
500
Source:
EPA
F006
Listing
Background
Document,
1980
Only
certain
metal
finishing
sludges
were
listed
as
hazardous
wastes.
Others
studied
were
determined
to
not
pose
a
substantial
hazard.
Regulated
F006
includes:

Wastewater
treatment
sludges
from
electroplating
operations
except
from
the
following
processes:
(1)
sulfuric
acid
anodizing
of
aluminum;
(2)
tin
plating
on
carbon
steel;
(3)
zinc
plating
(segregated
basis)
on
carbon
steel;
(4)
aluminum
or
zinc­
aluminum
plating
on
carbon
steel;
(5)
cleaning/
stripping
associated
with
tin,
zinc,
and
aluminum
plating
on
carbon
steel;
and
(6)
chemical
etching
and
milling
of
aluminum.
(see
40
CFR
261.31)

The
promulgation
of
effluent
guidelines
for
the
metal
finishing
industry
in
1986
significantly
increased
the
quantities
of
wastewater
treatment
sludge
generated.
This
increase
occurred
because
the
guidelines
required
metal
finishers
to
treat
their
wastewater
to
remove
or
reduce
pollutants
prior
to
discharge
to
either
a
publicly
owned
treatment
works
(POTW)
or
directly
to
waters
of
the
U.
S.
To
comply
with
the
effluent
guidelines,
metal
finishers
added
iron,
lime
and
other
chemicals
to
precipitate
out
or
destroy
pollutants
such
as
chrome,
zinc,
copper
and
cyanide.
The
precipitate
formed
F006
sludge,
which
was
then
filtered
and
managed
in
compliance
with
RCRA
regulations.

Current
estimates
of
annual
F006
generation
in
the
United
States
range
from
360,000
tons
dry
weight
equivalent
(F006
industry
estimate)
to
500,000
tons
dry
weight
equivalent
1,252,072
Borst,
Paul
A.
U.
S.
EPA,
Office
of
Solid
Waste.
Recycling
of
Wastewater
Treatment
Sludges
from
12
Electroplating
Operations,
F006.
1997.

September
1998
16
F006
Benchmarking
Study
tons/
wet
weigth
(1989
EPA
estimate).
Most
of
this
material
is
in
the
physical
form
of
metal
hydroxide
sludges.
12
F006
is
subject
to
the
full
set
of
RCRA
hazardous
waste
regulations
(e.
g.,
manifesting
burden,
training,
emergency
response
plans).
Metal
finishers
are
also
subject
to
OSHA
and
EPA
worker
health
and
safety
regulations
to
protect
workers
from
the
potential
effects
of
any
toxic
materials
or
other
hazards
in
the
workplace.
Appendix
C
provides
a
list
of
the
worker
health
and
safety
regulations
and
their
applicability
to
metal
finishers.

E.
Reasons
this
Study
was
Conducted
The
metal
finishing
industry
believed
that
many
metal
finishers
have
significantly
changed
the
way
they
operate
since
1980,
and
that
the
chemical
makeup
of
F006
is
more
amenable
to
recycling
than
it
was
in
1980.
The
strengthening
of
wastewater
pretreatment,
hazardous
waste
management,
and
hazardous
waste
minimization
requirements
since
1980
have
had
a
positive
impact
on
materials
used,
improved
process
operations,
and
better
waste
management
practices
in
the
metal
finishing.
These
improvements
have
reduced
the
pollutants
contained
in
F006.
The
industry
also
believed
that
these
changes
may
be
substantial
enough
to
warrant
modification
of
regulatory
controls.
This
report
provides
current
information
about
the
metal
finishing
industry
in
the
U.
S.
and
presents
data
characterizing
F006.

The
metal
finishing
industry
responded
to
the
strengthening
of
wastewater
and
hazardous
waste
regulations
with
improvements
in
alternative
plating
chemistries,
production
management
practices,
equipment,
and
waste
management
technology.
For
example,
the
installation
of
countercurrent
flow,
spray
rinsing
and
drag
out
reduction
methods
are
examples
of
techniques
that
reduce
wastewater
volumes
and
the
amount
of
metals
and
other
chemicals
used.
Some
metal
finishing
companies
installed
pollution
prevention
methods
which
are
targeted
at
further
reducing
or
eliminating
the
use
of
specific
toxic
materials.
The
most
notable
have
been:
the
replacement
of
traditional
cyanide­
based
plating
solutions
(e.
g.,
for
zinc
and
copper
plating)
with
alkaline­
based
plating
solutions;
the
substitution
of
trivalent
chromium
for
highly
toxic
hexavalent
chromium
for
some
applications;
and
the
replacement
of
some
single
metal
systems
with
alloy
systems
(e.
g.,
replacing
cadmium
with
zinc­
nickel).

In
1980,
EPA
published
regulations
which
set
standards
for
permitting
hazardous
waste
land
disposal
facilities,
and
in
1988,
EPA
promulgated
land
disposal
restrictions
regulations
which
require
metal
finishers
to
treat
F006
to
meet
the
treatment
standards
specified
in
this
rule.
The
rule
requires
F006
to
be
treated
to
immobilize
toxic
constituents,
mainly
metals.
Stabilization
is
one
technology
that
may
be
utilized,
however,
other
technologies
may
be
used.
methods
before
disposing
of
the
waste
in
landfills.

The
economics
of
waste
disposal
result
in
most
F006
being
land
disposed
rather
than
recycled
because
recycling
is
typically
more
expensive.
This
means
potentially
recoverable
metals
NCMS/
NAMF.
Pollution
Prevention
and
Control
Technology
for
Plating
Operations.
1994.
13
September
1998
17
F006
Benchmarking
Study
(i.
e.,
those
which
are
land
disposed)
are
no
longer
available
for
commerce.
Several
of
the
more
prominent
metals
(e.
g.,
nickel
and
chromium)
are
strategic
metals
which
are
not
available
in
the
U.
S.

The
results
of
a
1993
study
by
the
National
Center
for
Manufacturing
Sciences
(NCMS)
and
the
National
Association
of
Metal
Finishers
(NAMF)
show
that
90
percent
of
the
318
facilities
that
responded
(16%
response
rate
of
1,971
facilities
queried)
use
pollution
prevention
methods
and
benefitted
from
them.
Water
conservation
and
in
process
recycling
techniques
were
noted
to
be
more
frequently
used
than
chemical
recovery.
Approximately
60
percent
of
respondents
attempted
material
substitution
to
reduce
or
eliminate
one
or
more
of
the
following
materials:
cadmium,
chromium
(hexavalent),
cyanide,
and
chlorinated
solvents.
13
Some
metal
finishers
recover
precious
or
other
metals
on
site
(the
number
of
facilities
that
conduct
on­
site
recovery
is
not
available).
Other
facilities
ship
F006
to
recycling
facilities
to
recover
commercially
valuable
metals,
or
to
RCRA
permitted
treatment
and
disposal
facilities.
Table
4
summarizes
an
array
of
pollution
prevention
measures
that
may
be
used
in
metal
finishing
operations.

Worker
Health
and
Safety
As
part
of
the
benchmarking
study,
the
workgroup
collected
information
on
F006
handling
practices,
identified
the
potential
hazards
to
workers,
and
described
possible
hazard
control
methods.
In
addition,
the
workgroup
developed
a
list
of
the
current
worker
health
and
safety
regulations
and
policies
that
may
apply
to
on­
site
and
off­
site
management
of
F006.
This
information
is
presented
in
Appendix
C
of
this
report.
Beyond
this
information,
the
workgroup
did
not
attempt
to
complete
a
comprehensive
review
of
worker
health
and
safety
issues
associated
with
F006
management.

This
report
presents
data
collected
during
the
F006
Benchmarking
Study
as
a
foundation
for
further
evaluation
of
F006.
The
CSI
Workgroup
did
not
attempt
to
analyze
the
data
to
determine
the
extent
to
which
the
characteristics
of
F006
have
changed
based
on
industry
pollution
prevention
practices
or
other
factors.
In
Phase
2
of
this
efort,
the
Workgroup
will
analyze
the
information
presented
in
this
report,
and
examine
whether
potential
modifications
of
the
current
regulations
applicable
to
F006
should
be
considered
by
EPA.

Table
4:
Examples
of
Pollution
Prevention
Measures
Method
Pollution
Prevention
Benefits
Improved
Operating
Practices
Table
4:
Examples
of
Pollution
Prevention
Measures
Method
Pollution
Prevention
Benefits
September
1998
18
F006
Benchmarking
Study
Remove
cadmium
and
zinc
anodes
from
bath
°
Eliminates
cadmium/
zinc
buildup
causing
decanting
of
when
it
is
idle.
Anodes
baskets
can
be
placed
on
solution
due
to
galvanic
cell
set
up
between
steel
anode
basket
removable
anode
bars
that
are
lifted
from
tank
by
and
cadmium/
zinc
anodes
an
overhead
hoist
°
Maintains
bath
within
narrow
Cd/
Zn
concentration
providing
more
predictable
plating
results
Eliminate
obsolete
processes
and/
or
unused
or
°
Reduces
risks
associated
with
hazardous
chemicals
infrequently
used
processes
°
Creates
floor
space
to
add
countercurrent
rinses
or
other
P2
methods
°
Creates
safer
and
cleaner
working
environment
Waste
stream
segregation
of
contact
and
non­
°
Eliminates
dilution
of
process
water
prior
to
treatment
which
contact
wastewaters
can
increase
treatment
efficiency
°
Reduces
treatment
reagent
usage
and
operating
costs
Establish
written
procedures
for
bath
make­
up
°
Prevents
discarding
process
solutions
due
to
incorrect
and
additions.
Limit
chemical
handling
to
trained
formulations
or
contamination
personnel.
Keep
tank
addition
logs
°
Improves
plating
solution
and
work
quality
consistency
°Improves
shop
safety
Install
overflow
alarms
on
all
process
tanks
to
°
Minimizes
potential
for
catastrophic
loss
of
process
solution
prevent
tank
overflow
when
adding
water
to
make
via
overflow
up
for
evaporative
losses
°
Prevents
loss
of
expensive
chemicals
Conductivity
and
pH
measurement
instruments
°
Identifies
process
solution
overflows
and
leaks
before
total
and
alarm
system
for
detecting
significant
loss
occurs
chemical
losses
°
Alerts
treatment
operators
to
potential
upset
condition
°
Reduces
losses
of
expensive
plating
solutions
Control
material
purchases
to
minimize
obsolete
°
Reduces
hazardous
waste
generation
material
disposal
°
Reduces
chemical
purchases
Use
process
baths
to
maximum
extent
possible
°
Prevents
discarding
of
solutions
prematurely
before
discarding.
Eliminate
dump
schedules.
°
Reduces
chemical
costs
Perform
more
frequent
chemical
analysis
°
Chemical
adjustments
of
baths
will
improve
work
quality
Reduce
bath
dumps
by
using
filtration
to
remove
°
Extends
bath
life
suspended
solids
contamination
°
Reusable
filter
cartridges
reduce
solid
waste
generation
°
Improves
bath
performance
Deburring
containment
°
Segregates
waste
Ultrafiltration,
oil
removal
°
Removes
contaminants
from
cleaning
wastes,
promotes
recycling
Process/
Chemical
Substitution
Substitute
cyanide
baths
with
alkaline
baths
when
°
Eliminates
use
of
CN
possible
Substitute
trivalent
chromium
for
hexavalent
°
Reduces/
eliminates
use
of
hexavalent
chromium
chromium
when
product
specifications
allow.
Table
4:
Examples
of
Pollution
Prevention
Measures
Method
Pollution
Prevention
Benefits
September
1998
19
F006
Benchmarking
Study
Eliminate
use
of
cadmium
plating
if
product
°
Eliminates
the
use
of
cadmium
specifications
allow
Eliminate
cyanide
copper
°
Eliminates
use
of
CN
Introduce
deposit
substitutes:
e.
g.,
Zn­
Ni
alloy
°
Eliminates
use
of
Cd
replaces
cadmium
Drag­
Out
Reduction
Methods
that
Reduce
Waste
Generation
Install
fog
rinses
or
sprays
over
process
tanks
to
°
Can
inexpensively
recover
a
substantial
portion
of
drag
out
remove
drag
out
as
rack/
part
exits
bath
and
does
not
require
additional
tankage
Minimize
the
formation
of
drag
out
by:
°Reduces
pollutant
mass
loading
on
treatment
processes,
redesigning
parts
and
racks/
barrels
to
avoid
cup
treatment
reagent
usage,
and
resultant
sludge
generation
shapes,
etc.
that
hold
solution;
properly
racking
°
May
improve
treatment
operation/
removal
efficiency
parts;
and
reducing
rack/
part
withdraw
speed
°
Reduces
chemical
purchases
and
overall
operating
costs
Introduction
of
barrel
spray
rinsing
°
Reduces
pollutant
mass
loading
on
treatment
processes,
treatment
reagent
usage,
and
resultant
sludge
generation
Automation
control
°
Reduces
process
error
and
process
waste
Rinse
Water
Reduction
Methods
that
Reduce
Waste
Generation
Install
flow
restrictors
to
control
the
flow
rate
of
°
Reduces
water
use
and
aids
in
reducing
variability
in
water
wastewater
flow
°
Very
inexpensive
to
purchase
and
install
Install
conductivity
or
timer
rinse
controls
to
°
Coordinates
water
use
and
production
when
properly
match
rinse
water
needs
with
use
implemented
°
Provides
automatic
control
of
water
use
Use
counter­
current
rinse
arrangement
with
two
°
Major
water
reduction
can
be
achieved
to
four
tanks
in
series
depending
on
drag
out
rate
°
High
impact
on
water
bills
°
May
reduce
the
size
of
needed
recovery/
treatment
equipment
Track
water
use
with
flow
meters
and
°
Identifies
problem
areas
including
inefficient
processes
or
accumulators.
Keep
logs
on
water
use
for
personnel
individual
operations
°
Helps
management
to
determine
cost
for
individual
plating
processes.

Install
pulsed
spray
rinsing
°
Reduced
wastewater
generation
Source:
NCMS/
NAMF.
Pollution
Prevention
and
Control
Technology
for
Plating
Operations.
1994
USEPA,
Office
of
Solid
Waste.
Quality
Assurance
Project
Plan
For
the
Metal
14
Finishing
Industry.
October,
1997.

September
1998
20
F006
Benchmarking
Study
II.
NATIONAL
F006
BENCHMARKING
STUDY
APPROACH
A.
Overview
The
workgroup
focused
on
three
analytical
questions
to
guide
its
work
on
characterizing
current
practices
in
the
metal
finishing
industry,
and
the
composition
and
management
of
F006:

1)
What
are
the
characteristics
of
F006?
2)
What
can
metal
finishers
do
to
make
F006
more
recyclable,
while
optimizing
pollution
prevention?
What
pollution
prevention
measures
are
in
place
at
metal
finishing
facilities?
3)
What
are
the
environmental
impacts
of
F006
recycling?

While
not
an
initial
focus
in
this
effort,
the
workgroup
also
examined
worker
health
and
safety
impacts
in
this
study.

The
workgroup
then
designed
a
two
year
study
methodology
to
address
the
three
analytical
objectives.
The
study
methodology
is
discussed
below.

The
technical
work
required
for
this
study
was
completed
by
Science
Applications
International
Corporation
under
contract
to
EPA.
The
contract
work
was
managed
by
an
EPA
workgroup
member
working
in
close
coordination
with
the
workgroup.
The
workgroup
monitored
progress
and
critiqued
results
throughout
the
analysis
process.

B.
Methodology
The
workgroup
designed
a
five
part
"benchmarking"
study
approach
to
address
the
three
analytical
questions
identified
above.
A
Quality
Assurance
Project
Plan
was
developed
and
approved
for
this
study
and
is
available
in
a
separate
report
.
The
five
portions
of
the
study
are
14
summarized
below
and
discussed
in
more
detail
in
the
remainder
of
this
section.
The
five
study
portions
include:

D.
A
"Regional
Benchmarking
Study"
that
involved
site
visits
to
29
metal
finishing
shops
in
three
cities
to
gather
detailed
data
on
plating
processes,
pollution
prevention
practices,
F006
chemical
analysis
and
F006
handling
and
management
practices;

E.
A
"National
Benchmarking
Study"
that
used
a
mail
survey
to
gather
less
detailed
data
on
metal
finishing
operations,
pollution
prevention
practices,
F006
characteristics
and
management
practices
from
a
broad
range
of
metal
finishers;
September
1998
21
F006
Benchmarking
Study
C
An
analysis
which
evaluates
the
extent
to
which
the
regional
and
national
benchmarking
studies
represent
the
universe
of
metal
finishers.

C
A
Survey
of
Commercial
Recycling
Companies
to
gather
data
on
the
amount
of
F006
recycled
and
the
chemical
composition
of
F006
accepted
for
recycling,
and
C
A
"Community
Interest
Group
Phone
Survey"
to
assess
whether
community
groups
in
the
vicinity
of
commercial
recycling
companies
believe
those
companies
are
good
environmental
and/
or
economic
neighbors.
Each
of
the
above
components
of
the
study
involved
a
series
of
analytical
steps.
The
approach
used
to
complete
each
study
component
is
described
below.
The
results
are
presented
in
Section
III
of
this
report.

1.
Regional
Benchmarking
Study
The
workgroup
developed
a
method
for
identifying
and
gathering
information
from
metal
finishing
companies
that
are
judged
to
be
"typical"
facilities
in
the
metal
finishing
universe.

The
workgroup
identified
ten
cities
that
are
known
to
have
high
populations
of
metal
finishing
facilities.
Milwaukee,
Chicago,
and
Phoenix
were
chosen
as
cities
which
are
representative
of
the
metal
finishing
industry
in
terms
of
the
processes
they
use
and
the
industries
they
serve.

The
workgroup
agreed
on
a
list
of
criteria
for
selecting
facilities,
and
tried
to
include,
as
much
as
possible,
a
balanced
distribution
of
the
following
criteria
in
making
facility
selections:

C
Type
of
shop:
captive/
job,
C
Size:
number
of
employees,
C
Type
of
deposition
process
in
use,
C
Pollution
prevention
technologies
in
use,
C
In­
house
metal
recovery
technologies:
­­
counterflow
rinse,
­­
ultrafiltration/
microfiltration,
­­
other
ion
exchanges,
­­
electrolytic
metal
recovery,
­­
electrodialysis,
or
­­
reverse
osmosis;
and
C
F006
treatment
technology:
­­
alkaline
precipitation,
­­
offsite
metals
recovery,
­­
landfilling
of
F006,
­­
other.

The
workgroup
developed
additional
information
regarding
the
third
criteria
listed
above,
"type
of
deposition
process
in
use.
The
workgroup
identified
five
plating
processes
which
are
among
the
most
frequently
used
processes
in
the
metal
finishing
industry.
Studying
facilities
that
September
1998
22
F006
Benchmarking
Study
operate
these
processes
would
provide
the
workgroup
with
key
information
about
these
common
processes.
The
five
processes
included:

­Zinc
(Zn)
plated
on
steel,
­Nickel
(Ni)/
chromium
(Cr)
plated
on
steel,
followed
by
plated
on
steel,
­Cu/
Ni/
Cr
on
non­
ferrous
alloys,
­Cu
plating/
stripping
in
the
printed
circuit
industry,
and
­Cr
on
steel.

These
five
processes
are
among
the
25
most
common
processes
identified
in
the
NCMS/
NAMF
study
(1994),
and
were
the
main
criteria
in
selecting
facilities
in
Milwaukee.
Facility
selection
in
Chicago
began
using
the
five
processes,
but
resulted
in
a
principal
focus
on
facilities
that
operate
copper/
nickel/
chromium
electroplate
on
nonferrous
processes,
a
plating
process
used
by
one­
half
of
Chicago
platers.
Facility
selection
in
Phoenix
focused
on
obtaining
data
from
metal
finishers
that
serviced
the
printed
circuit
board
and
aerospace
industries.

The
workgroup
identified
a
Point
of
Contact
(POC)
in
each
city.
The
POC
and
the
workgroup
identified
10
facilities
and
several
alternates
located
in
or
near
each
of
the
three
benchmarking
cities
that
fit
the
criteria
sought
for
each
city
and
were
willing
to
participate
in
the
study.
At
their
request,
facilities
remained
anonymous
to
the
workgroup
throughout
the
selection
and
information
gathering
process.
Facilities
are
identified
as
F1,
F4,
F11,
etc.

A
facility
selection
table
was
completed
for
each
city
(see
Section
IV),
and
the
workgroup
made
its
selections
based
on
the
criteria
discussed
above.
An
overview
of
facility
selection
for
each
city
is
discussed
below.

Milwaukee:
The
POC
gathered
information
on
15
facilities,
from
which
the
workgroup
selected
10
facilities
and
three
alternates.
Each
of
the
10
facilities
and
three
alternates
was
contacted
to
schedule
a
site
visit
for
completing
a
profile
of
operations
and
waste
sampling
and
analysis.
Three
of
the
10
facilities
were
eliminated
during
the
site
visits
because
it
was
determined
that
their
sludges
are
not
F006,
and
the
three
alternates
were
added.
The
third
alternate
was
subsequently
eliminated
because
their
sludge
is
excluded
from
the
definition
of
F006.
Consequently,
only
nine
facilities
were
included
in
the
Milwaukee
benchmarking
study.

Chicago:
The
POC
in
Chicago
identified
14
metal
finishers
willing
to
participate
in
the
study,
from
which
the
workgroup
selected
10
and
three
alternates.
Each
of
the
ten
facilities
and
alternates
was
contacted
to
schedule
site
visits.

Phoenix:
The
POC
in
Phoenix
identified
13
metal
finishers,
from
which
the
workgroup
selected
10
facilities
and
three
alternates.
One
facility
was
eliminated
during
the
site
visit
because
it
plated
every
two
months
as
a
batch
operation
and
no
F006
sludge
was
available
during
the
time
of
the
study.
An
alternate
site
was
added.

A
survey
was
mailed
to
each
facility
to
gather
basic
data
from
facility
records
(Appendix
F
contains
a
copy
of
the
Regional
Benchmarking
Survey).
On­
site
visits
were
completed
to
gather
detailed
data
on
metal
finishing
processes,
pollution
prevention
practices,
recycling
practices,
September
1998
23
F006
Benchmarking
Study
F006
quantities,
and
F006
handling
and
management
practices
(handling
practices
were
recorded
only
in
Chicago
and
Phoenix).
The
site
visit
information
collection
protocol
is
provided
in
Appendix
D.

In
addition
to
gathering
information
on
plating
processes,
pollution
prevention
methods,
F006
generation
quantities
and
F006
management,
a
total
of
46
composite
samples
of
F006
were
collected
from
the
29
facilities
and
transported
to
an
EPA
certified
laboratory
for
chemical
analysis
and
quality
assurance
methods.
Two
samples
of
F006
sludge
were
collected
at
some
facilities
(selected
at
random)
as
spot
checks
for
variability
in
chemical
content.
All
samples
were
analyzed
for
total
concentrations
of
metals,
TCLP
metals,
and
general
chemistry
analytes.
Four
of
the
samples
collected
in
Milwaukee
were
also
analyzed
for
total
volatile
and
semivolatile
organic
constituents,
and
TCLP
volatile
and
semivolatile
organic
constituents,
but
since
the
results
of
the
organic
analysis
in
Milwaukee
showed
nondetectable
levels
in
nearly
all
cases,
no
further
organics
testing
was
completed
in
the
remaining
two
cities.
See
Appendix
E
for
a
list
of
all
chemicals
analyzed.
The
laboratory
results
were
reviewed
for
accuracy
and
completeness
and
provided
to
each
facility
for
review
and
comment.

2.
National
Benchmarking
Study
The
workgroup
developed
a
survey
for
gathering
data
on
metal
finishing
operations,
pollution
prevention
practices,
F006
characteristics
and
sludge
management
practices
from
a
large
sample
of
the
universe
of
metal
finishers.
The
data
categories
contained
in
the
survey
are
similar
to
the
regional
benchmarking
protocol,
but
less
detailed.
Appendix
G
contains
the
survey
used
for
the
National
Benchmarking
Study.

Nearly
2,000
surveys
were
distributed
by
mail
using
the
mailing
list
of
NAMF
and
AESF,
and
by
hand
at
a
metal
finishers
national
technical
conference.
186
responses
(9
percent)
were
received.
The
data
was
compiled
into
a
computer
data
base.

3.
Statistical
Analysis
of
the
Regional
and
National
Benchmarking
Data
A
chi­
squares
analysis
was
completed
to
determine
the
extent
to
which
the
facilities
included
in
the
regional
and
national
benchmarking
studies
represent
the
universe
of
metal
finishers
for
demographic
parameters.
Benchmarking
results
were
compared
to
the
universe
of
F006
generators
in
the
Dunn
&
Bradstreet
and
EPA
1995
Biennial
Report
national
databases.
The
results
are
presented
in
Section
III.

4.
Survey
of
Commercial
Recyclers
The
workgroup
developed
a
survey
to
gather
data
from
six
commercial
recycling
companies
believed
to
be
representative
of
the
commercial
F006
recycling
industry.
The
survey
requested
data
on
the
amount
and
chemical
composition
of
F006
they
recycle.
Few
data
were
received.
The
results
were
inclusive
and
are
not
provided
in
this
report.
A
copy
of
the
Recyclers'
Survey
is
contained
in
Appendix
H.

5.
Survey
of
Community
Environmental
Groups
September
1998
24
F006
Benchmarking
Study
A
"community
interest
group
phone
survey"
was
developed
by
the
workgroup
to
make
a
preliminary
assessment
of
whether
ten
community
groups
community
groups
in
the
vicinity
of
commercial
recycling
companies
believe
those
companies
are
good
environmental
and/
or
economic
neighbors.
In
order
to
promote
candid
responses,
the
workgroup
agreed
that
respondents
could
remain
anonymous.
Each
group
was
asked
the
following
questions:

C
Is
the
group
aware
of
environmental
impacts
from
the
recycling
facility?
C
Is
the
group
aware
of
economic
impacts
from
the
recycling
facility?
C
Is
the
facility
considered
a
"good
neighbor?"

A
summary
of
responses
is
provided
in
Section
IV.
Individual
responses
are
provided
in
Appendix
I.

III.
RESULTS
OF
THE
F006
BENCHMARKING
STUDY
The
Regional
and
National
Benchmarking
Studies
produced
a
large
body
of
current
data
concerning
facility
operations,
pollution
prevention
activities,
F006
generation
and
management,
and
F006
composition.
Section
A
below
presents
summaries
of
the
data.
Section
B
presents
the
data
in
detail.

A.
Summaries
of
Regional
and
National
Benchmarking
F006
Waste
Characterization
Data
1.
Benchmarking
Summary
Tables
Table
5
summarizes
the
minimum,
mean,
median,
and
maximum
analytical
results
for
each
chemical
analyzed
for
each
of
the
three
cities.
The
values
presented
represent
only
clearly
measurable
laboratory
results.
Non­
detected
samples
(i.
e.,
samples
below
laboratory
detection
limits)
and
samples
detected
but
below
the
laboratory
quantitation
limit
(below
the
limit
for
accurate
chemical
measurement)
are
not
included.
Table
6
compares
same
statistics
for
the
three
cities
to
F006
waste
composition
data
received
in
the
National
Benchmarking
Survey.
Table
7
summarizes
the
results
of
the
National
Survey.

2.
Statistical
Analysis:
Does
this
Data
Come
from
"Typical"
Metal
Finishers?

Statistical
analyses
are
often
used
to
determine
the
extent
to
which
a
sample
selected
from
a
population
represents
the
larger
population
from
a
statistical
perspective,
require
carefully
designed
sample
selection
and
testing
procedures,
and
are
generally
time
consuming
and
expensive.
Because
of
its
specialized
design
(i.
e.,
to
provide
the
workgroup
with
a
highly
descriptive
set
of
data
from
metal
finishing
facilities
which
run
the
most
"typical"
plating
processes
in
the
industry),
the
workgroup
was
limited
in
its
abililty
to
compare
Benchmarking
data
to
other
databases
which
contain
information
on
the
metal
finishing
universe.
Notwithstanding
the
specialized
design
of
the
Benchmarking
study,
the
workgroup
completed
a
statistical
comparison
of
Benchmarking
results
to
two
national
databases
which
contain
some
information
on
the
metal
finishing
universe.
September
1998
25
F006
Benchmarking
Study
The
analysis
used
a
chi­
squares
statistical
method
to
compare
the
only
three
parameters
(facility
size
and
location,
and
the
amount
of
F006
waste
generated)
contained
in
the
benchmarking
studies
and
in
other
national
databases
which
contain
information
on
metal
finishing
facilities,
i.
e.,
the
Dun
&
Bradstreet
(D&
B)
business/
economic
database
and
EPA's
1995
Biennial
Reporting
System
(BRS)
database.
The
analysis
results
show
that
the
facilities
participating
are
not
necessarily
representative
of
the
universe
of
metal
finishers.
It
is
possible
that
a
larger
number
of
participants
in
the
Benchmarking
Studies
or
a
different
mix
of
participants
could
have
provided
results
that
show
a
more
direct
relationship
between
Benchmarking
and
national
data
(D&
B
and
BRS).
This
result
does
not
diminish
the
value
of
the
Benchmarking
study.
The
Benchmarking
Study
provides
substantial
additional
data
characterizing
the
industry's
wastestream
and
provides
a
sound
starting
point
for
further
discussion.

3.
Results
of
Commercial
Recyclers
and
Citizen
Group
Surveys
The
workgroup
received
too
few
responses
to
the
commercial
recyclers
survey
to
draw
any
conclusions.
Responses
to
the
citizen
group
brief
phone
interviews
received
nearly
complete
responses
and
revealed
no
significant
adverse
opinions
regarding
whether
these
facilities
are
perceived
as
good
environmental
and
economic
neighbors.
The
results
of
the
citizen
group
phone
survey
is
summarized
Appendix
I.
September
1998
26
F006
Benchmarking
Study
This
page
and
the
next
page
become
large
fold
out
tables
5&
6.
Pull
this
double
sided
page
and
insert
tables
5/
6
here.
September
1998
27
F006
Benchmarking
Study
September
1998
28
F006
Benchmarking
Study
Table
7:
F006
Analytical
Data
from
the
National
Survey:
Excludes
non­
detects
and
includes
only
values
above
method
quantitation
limit.
70
of
186
respondents
submitted
characterization
data.

Constituent
#
of
Reported
Minimum
Mean
Median
Maximum
Detections
Total
Metals
(mg/
kg)

Aluminum
(Al)
34
0.59
13,387.89
1,725.00
76,100.00
Antimony
(Sb)
22
1.80
2,188.23
67.40
34,800.00
Arsenic
(As)
35
2.00
489.67
10.00
8,780.00
Barium
(Ba)
38
6.00
199.27
73.70
1,080.00
Beryllium
(Be)
20
0.59
12.55
8.50
37.00
Bismuth
(Bi)
7
2.10
50.86
29.00
398.00
Cadmium
(Cd)
39
2.10
6,122.32
22.00
71,300.00
Calcium
(Ca)
28
682.00
37,239.28
17,250.00
143,000.00
Chromium
(Cr)
60
10.00
39,601.20
13,900.00
206,000.00
Copper
(Cu)
51
33.60
55,474.35
10,620.00
631,000.00
Iron
(Fe)
38
364.00
82,420.74
48,950.00
560,000.00
Lead
(Pb)
47
5.00
5,754.10
346.00
175,000.00
Magnesium
(Mg)
14
187.00
48,798.09
10,800.00
336,000.00
Manganese
(Mn)
28
13.00
830.91
563.00
3,300.00
Mercury
(Hg)
30
0.05
0.39
0.30
2.00
Nickel
(Ni)
44
51.00
23,456.33
5,935.00
180,000.00
Selenium
(Se)
35
1.900
7.86
6.50
16.60
Silver
(Ag)
30
1.50
169.64
87.50
1,190.00
Sodium
(Na)
9
25.00
18,458.37
11,000.00
89,200.00
Tin
(Sn)
28
9.00
20,906.06
1,100.00
467,000.00
Zinc
(Zn)
48
57.00
88,692.44
24,600.00
460,000.00
TCLP
(mg/
l)

Arsenic
(As)
17
ND
ND
ND
ND
Barium
(Ba)
16
0.26
1.29
1.45
2.20
Cadmium
(Cd)
18
0.02
8.36
0.11
144.00
Chromium
(Cr)
20
0.02
9.48
0.92
56.20
Lead
(Pb)
18
0.06
113.97
0.13
1,630.00
Mercury
(Hg)
15
0.001
0.005
0.005
0.011
Selenium
(Se)
16
0.08
0.08
0.08
0.08
Silver
(Ag)
17
0.01
0.67
0.06
3.80
General
Chemistry
(mg/
kg)

Chloride
(Cl)
20
64
8,035.09
2,225.00
70,100.00
Fluoride
(F)
13
1.2
719.06
161.00
4,240.00
Chromium,
hex
15
0.1
108.89
11.00
1,190.00
Cyanide,
Total
(CN)
25
0.8
692.47
114.50
3,920.00
Cyanide,
Am
(CN)
11
2.6
609.56
51.00
5,340.00
Percent
Solids
13.5
37.65
30.80
94.10
September
1998
29
F006
Benchmarking
Study
B.
Detailed
Results
of
the
Regional
and
National
Benchmarking
Studies
This
section
provides
the
detailed
results
of
data
gathering
for
the
Regional
and
National
Benchmarking
Studies.

1.
The
Milwaukee
Benchmarking
Study
This
section
provides
a
detailed
presentation
of
data
gathered
in
the
Milwaukee
Benchmarking
Study
(MBS),
including
a
characterization
of
plating
processes,
pollution
prevention
and
recycling
practices,
F006
characteristics,
and
site
specific
variations
in
the
generation
and
management
of
F006
for
nine
facilities
in
Milwaukee.
Table
8
is
the
facility
selection
matrix
used
to
select
10
facilities
from
13
candidates.
Table
9
presents
information
collected
for
each
facility
in
the
study.
Table
10
summarizes
the
results
of
the
laboratory
analyses
of
F006
data
and
Table
11
presents
detailed
laboratory
analysis
results
for
each
facility.

Six
of
the
nine
facilities
reported
waste
generation
rates.
The
total
reported
waste
quantity
for
Milwaukee
is
approximately
590.5
tons/
year.
Four
facilities
reported
landfilling
their
F006
waste
while
four
facilities
reported
recycling
their
F006
wastes.
One
facility
sent
half
of
its
F006
waste
to
landfills,
and
the
other
half
to
commercial
recycling.
Sixteen
laboratory
samples
were
gathered
from
nine
facilities.
Four
of
these
samples
were
for
organic
chemicals.
September
1998
30
F006
Benchmarking
Study
Table
8:
Milwaukee
Metal
Finishing
Facility
Selection
Matrix
Selection
Criteria
Fac
1*
Fac
2*
Fac
3*
Fac
4
Fac
5
Fac
6
Fac
7
Fac
8
Fac
9
(Selected)
(Selected)
(Alternate)
(Selected)
(Selected)
(Selected)
(Selected)

Type:
Captive/
Job
Job
Job
Job
Captive
Job
Captive
Job
Job
Job
Size
16
152
95
2000/
20
50
900/
30
160
35
180
Main
Treatment
Technology
Alk/
PPT
Other
­
Al
Alk/
PPT
Alk/
PPT
Alk/
PPT
Alk/
PPT
Alk/
PPT
Alk/
PPT
Alk/
PPT
reuse
Off
IX
Treatment
Technology
CFR
CFR
EMR
CFR
CFR
CFR
CFR
CFR
Other
Other
CFR
Vacuum
&
IX
Evp.

Onsite
Recycle
No
No
No
25%
No
No
60%
No
95%

Landfill
100%
No
100%
Yes
Yes
5%
40%
100%
5%

Main
Mgmt.
Method
LF
Recycle
LF
LF
LF
95%
Rec
Recycle
LF
Recycle
Finishing
Processes
Zn/
Fe
Cu
Zn/
Fe
Zn/
Fe
HCr
Zn/
Fe
Zn/
Fe
HCr
&
EN
Zn/
Fe
NiCr
HCr/
Al
Cu/
Ni/
Cr
Zn/
Br
Cu/
Ni/
Cr/
F
Cu/
Ni/
Cr
Ni/
Cr
Ni/
Cr
e
HCr
Zn/
Fe
*
Eliminated
because
they
do
not
generate
F006.
ED
Electrodialysis
Key:
RO
Reverse
osmosis
Alk/
PPT
Alkaline
precipitation
Zn/
Fe
Zinc
electroplate
on
steel
IX
Ion
exchanges
Ni/
Cr
Nickel
chromium
Electroplate
on
steel
Ultra
Ultrafiltration/
Microfiltration
Cu/
Ni/
Cr
Copper
nickel
chromium
on
nonferrous
CFR
Counterflow
rinse
Cu
Copper/
PC
bands
EMR
Electrolytic
metal
recovery
HCr
Hard
chromium
on
steel
September
1998
31
F006
Benchmarking
Study
Milwaukee
Metal
Finishing
Facility
Selection
Matrix
(cont.)

Selection
Criteria
Fac
10*
Fac
11
Fac
12
Fac
13
Fac
14
Fac
15
Fac
16
Fac
17
Fac
18
(Alternate)
(Alternate)
(Selected)
(Selected)
(Selected)
(Selected)

Type:
Captive/
Job
Job
Job
Job
Job
Job
Captive
Captive
Captive
Job
Size
40
50­
60
15
70
110
700/
14
500/
90
1550/
37
35
Main
Treatment
Technology
Alk/
PPT
Alk/
PPT
Offsite
Offsite
Alk/
PPT
Alk/
PPT
Alk/
PPT
Alk/
PPT
Alk/
PPT
other
other
offsite
Treatment
Technology
CFR
other
CFR
Evap
CFR
CFR
CFR
other
CFR
EMR
IX
CFR
CFR
RO
CFR
IX
IX
IX
Ultra
IX
EMR
other
other
Other
Onsite
Recycle
No
Yes
Yes
Yes
95%
Yes
No
Yes
20%

Landfill
Yes
No
No
No
5%
Yes
Yes
Yes
20%

Main
Mgmt.
Method
LF
Recycle
Recycle
Recycle
Recycle
LF
LF
LF
80%
Rec
Finishing
Processes
Zn/
Fe
Cu
Ni
Cr
Zn
Ni/
Cr
Ni/
Cr
Zn/
Fe
Dupl
Ni
Ni/
Cr
/Br
Zn/
Fe
HCr
Ni
Sn
Ag
Brite
Ni
Hex
Cr
*
Eliminated
because
they
do
not
generate
F006.
ED
Electrodialysis
Key:
RO
Reverse
osmosis
Alk/
PPT
Alkaline
precipitation
Zn/
Fe
Zinc
electroplate
on
steel
IX
Ion
exchanges
Ni/
Cr
Nickel
chromium
Electroplate
on
steel
Ultra
Ultrafiltration/
Microfiltration
Cu/
Ni/
Cr
Copper
nickel
chromium
on
nonferrous
CFR
Counterflow
rinse
Cu
Copper/
PC
bands
EMR
Electrolytic
metal
recovery
HCr
Hard
chromium
on
steel
September
1998
32
F006
Benchmarking
Study
Table
9:
Facility­
Specific
Information
for
Milwaukee
Facilities
Facility
F4
Plating
Process
F006
Quantity
and
Management
Sample
Description
Nickel­
chrome
on
Aluminum
146
tons/
yr
F1­
01
­
Sludge
sample
collected
Zinc
(non­
CN)
on
Steel
directly
from
drop
bin
Decorative
nickel­
chrome
on
Steel
Landfill
F1­
02
­
Sludge
collected
from
supersack
dated
the
previous
month
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
Implementation
of
high
temperature
zinc
baths
to
eliminate
partial
bath
Total
(mg/
kg)
Total
(mg/
kg)
dumps
Al
­
31,200
Al
­
17,300
Replaced
hexavalent
Cr
with
Trivalent
Cr
on
decorative
Cr
line
Sb
­
5.5
Sb
­
1.8
Elimination
of
all
cyanide
plating
baths
As
­
9.9
As
­
9.3
Substitution
of
chromate
and
dichromate
seal
with
non­
chrome
sealer
Ba
­
41.9
Ba
­
34.3
Constant
development
of
alternative
plating
technologies
Be
­
ND
Be
­
ND
Filtration
on
nickel
recovery
unit
Bi
­
2.7
Bi
­
3.3
Electrolytic
dummying
Cd
­
7.5
Cd
­
9.6
Precipitation
and
monitoring
of
spent
plating
solutions
Ca
­
24,800
Ca
­
17,500
Uses
purer
anodes
and
bags
Cr
­
59,500
Cr
­
64,900
Tooling
attention/
maintenance
on
scrubbers
Hex.
Cr
­
0.6
Hex.
Cr
­
0.6
Evaporation
techniques
on
nickel
portion
of
chrome
line
Cu
­
130
Cu
­
1,480
Chemical
usage
reduction
through
substitution
­
replaced
hard
chrome
with
Fe
­
25,000
Fe
­
27,700
decorative
chrome
Pb
­
297
Pb
­
366
Oil
removal
techniques
Mg
­
15,800
Mg
­
17,400
DRAG­
OUT
REDUCTION
Hg
­
2
Hg
­
ND
Enhanced
product
hang
times
Ni
­
19,900
Ni
­
18,200
Uses
wetting
agents
occasionally
Se
­
16.6
Se
­
16
Drainage
boards
Ag
­
267
Ag
­
97.9
Strategic
workpiece
positioning
Na
­
8,360
Na
­
21,700
Withdrawal
and
drainage
time
Sn
­
404
Sn
­
582
Diking
Zn
­
336,000
Zn
­
335,000
RINSEWATER
Counter­
current
flow
rinse
systems
for
1
plating
line
TCLP
(mg/
l)
TCLP
(mg/
l)
Flow
restrictors
done
with
weirs
As
­
ND
As
­
ND
Use
conductivity
meters
to
monitor
the
quality
of
final
rinses
Ba
­
0.3
Ba
­
1.4
Reuse
electrocleaner
rinse
water
as
dilute
plating
bath
solution
Cd
­
0.04
Cd
­
0.1
Reuse
acid
rinse
waters
for
rinsing
racks
exiting
soak
cleaner
Cr
­
40.6
Cr
­
56.2
Evaporative
recovery
of
Ni
rinse
waters
Pb
­
ND
Pb
­
0.1
Closed­
loop
wastewater
systems
on
Ni
and
Hex.
Cr
lines
Hg
­
ND
Hg
­
ND
OTHER
Ag
­
0.05
Ag
­
ND
Chemical
inventory
and
control
Conducts
annual
plant
assessments
and
housekeeping
Preventive
maintenance
systems
Increased
temperature
of
bath
Product
longevity
through
specification
alteration
F1
­
01
F1
­
02
Mn
­
1,710
Mn
­
399
CN
­
ND
CN
­
ND
Se
­
ND
Se
­
ND
September
1998
33
F006
Benchmarking
Study
Table
9
(cont'd):
Facility­
Specific
Information
for
Milwaukee
Facilities
Facility
F5
Plating
Process
F006
Quantity
and
Management
Sample
Description
Zinc
(non­
CN)
on
steel
42.5
tons/
yr
F5­
01
­
Collected
from
sludge
drier
Cu/
Ni/
Cr
on
steel
F5­
02
­
Collected
from
rolloff
bin
Nickel
chrome
on
steel
Recycle
(Horsehead)
accumulated
~1
month
previously
Nickel
plating
Hard
chrome
on
steel
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTION
Copper
and
nickel
strips
are
sent
out
in
liquid
form
for
recycling
reducing
Total
(mg/
kg)
Total
(mg/
kg)
quantity
of
F006
Al
­
3,690
Al
­
1,710
Filtration,
carbon
treatment,
replenishment,
and
electrolytic
dummying
for
Sb
­
67.4
Sb
­
45
bath
life
extension
As
­
15.4
As
­
18.3
Replaced
cyanide
zinc
plating
with
zinc
alkaline
plating
Ba
­
843
Ba
­
157
Planning
to
change
to
non­
cyanide
copper
plating
in
1997.
Be
­
0.6
Be
­
0.7
Oil
removal
techniques
on
pre­
cleaning
line
Bi
­
2.1
Bi
­
3.2
Chemical
usage
reduction
through
automated
addition
of
brightener
Cd
­
9.6
Cd
­
13.4
Product
longevity
through
specification
alteration
Ca
­
21,400
Ca
­
23,200
Alternate
stripping
methodologies
­
replaced
cyanide
solution
with
non­
Cr
­
92,000
Cr
­
71,000
cyanide
solution
to
strip
nickel
Hex.
Cr
­
0.6
Hex.
Cr
­
0.1
DRAG
OUT
REDUCTION/
RECOVERY
Fe
­
92,100
Fe
­
105,000
Mesh
pad
Mist
eliminators
on
2
of
3
chrome
lines
for
drag­
out
recovery
Pb
­
976
Pb
­
556
Enhanced
product
hang
times
Mg
­
13,000
Mg
­
12,500
New
plating
barrel
reduces
drag
out
Mn
­
1,200
Mn
­
1,340
Increase
drain
time
over
process
tanks
Hg
­
0.3
Hg
­
0.26
Drag
out
tanks
and
counter­
current
flow
used
where
feasible.
Ni
­
104,000
Ni
­
105,000
Increased
withdrawal
and
drainage
time
Se
­
10.6
Se
­
11.5
Uses
wetting
agents
Ag
­
8.7
Ag
­
3.4
Strategic
workpiece
positioning
Na
­
5,950
Na
­
6,830
Spray
rinses
Sn
­
429
Sn
­
337
RINSEWATER
CN
­
700
CN
­
900
Flow
restrictors
Spray
rinsing
on
1
line
TCLP
(mg/
l)
TCLP
(mg/
l)

OTHER
Ba
­
1.7
Ba
­
2.2
Tooling
attention/
maintenance
Cd
­
0.05
Cd
­
0.1
Waste
collection
plumbing
alterations
or
improvements
Cr
­
27.2
Cr
­
12.1
Diking
Pb
­
ND
Pb
­
ND
Energy
savings
techniques
Hg
­
ND
Hg
­
ND
Conducts
annual
plant
assessments
and
plant
housekeeping
Se
­
ND
Se
­
ND
F5
­
01
F5
­
02
Cu
­
39,900
Cu
­
41,500
Zn
­
126,000
Zn
­
158,000
Ar
­
ND
As
­
ND
Ag
­
ND
Ag
­
ND
September
1998
34
F006
Benchmarking
Study
Table
9
(cont'd):
Facility­
Specific
Information
for
Milwaukee
Facilities
Facility
F8
Plating
Process
F006
Quantity
and
Management
Sample
Description
Hard
Chrome
on
Steel
unreported
F8­
01
­
Collected
from
supersack
Landfill
F8­
02
­
Collected
from
supersack
dated
that
week
dated
the
previous
month
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTION
Ion
exchange
resin
system
­
echo­
tec
Total
(mg/
kg)
Total
(mg/
kg)

DRAG
OUT
REDUCTION/
RECOVERY
Sb
­
161
Sb
­
110
Strategic
workpiece
positioning
As
­
5.5
As
­
11.8
OTHER
Be
­
ND
Be
­
ND
Annual
plant
assessments
Bi
­
ND
Bi
­
ND
Diked
tanks
Cd
­
10.1
Cd
­
42.7
High
efficiency
lighting
Ca
­
67,400
Ca
­
50,800
Plant
Housekeeping
Cr
­
193,000
Cr
­
91,500
Preventive
Maintenance
systems
Hex.
Cr
­
0.4
Hex.
Cr
­
0.2
Installed
waste
collection
hard
piping
to
control
chemicals
Cu
­
24,500
Cu
­
41,100
Tooling
maintenance
once
per
year
Fe
­
110,000
Fe
­
279,000
F8­
01
F8­
02
Al
­
19,300
Al
­
8,560
Ba
­
83.4
Ba
­
33.3
Pb
­
858
Pb
­
231
Mg
­
9,710
Mg
­
11,100
Mn
­
1,360
Mn
­
1,080
Hg
­
ND
Hg
­
1.2
Ni
­
1,130
Ni
­
744
Se
­
ND
Se
­
ND
Ag
­
ND
Ag
­
ND
Na
­
19,600
Na
­
49,400
Sn
­
129
Sn
­
96.3
Zn
­
3,790
Zn
­
9,610
CN
­
ND
CN
­
ND
TCLP
(mg/
l)
TCLP
(mg/
l)
As
­
ND
As
­
ND
Ba
­
0.3
Ba
­
0.7
Cd
­
0.01
Cd
­
0.3
Cr
­
54.1
Cr
­
12.8
Pb
­
0.1
Pb
­
ND
Hg
­
N
D
Hg
­
0.005
Se
­
ND
Se
­
ND
Ag
­
ND
Ag
­
ND
September
1998
35
F006
Benchmarking
Study
Table
9
(cont'd):
Facility­
Specific
Information
for
Milwaukee
Facilities
Facility
F9
Plating
Process
F006
Quantity
and
Management
Sample
Description
Chrome
on
aluminum
150
tons/
yr
F9­
01
­
Collected
from
supersack
Bright
dip
on
brass
loaded
that
day
Copper,
nickel,
chrome
on
steel
Recycle
(Encycle/
Horsehead
97%)
F9­
02
­
Collected
by
facility
about
2
Hard
chrome
on
steel
Landfill
(3%)
weeks
later
Nickel
chrome
on
nonferrous
Zinc
(non­
CN)
on
steel
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTION
Eliminated
cadmium
plating
line
Total
(mg/
kg)
Total
(mg/
kg)
Replace
some
hexavalent
chrome
lines
with
trivalent
chrome
Al
­
27,000
Al
­
13,200
Utilizes
filtration
carbon
treatment,
replenishment,
and
electrolytic
Sb
­
5.4
Sb
­
13.5
dummying
for
general
bath
life
extension
As
­
4.8
As
­
3.1
Uses
precipitation,
monitoring,
carbonate
agitation,
and
electrowinning
on
Ba
­
298
Ba
­
257
spent
solutions
Be
­
ND
Be
­
ND
Uses
evaporative
techniques
on
nickel
plating
bath
Bi
­
72.5
Bi
­
31.5
Chemical
usage
reduction
through
automation
and
substitution
Cd
­
2.1
Cd
­
17.3
Increased
temperature
of
bath
Ca
­
87,000
Ca
­
70,000
DRAG
OUT
REDUCTION/
RECOVERY
Hex.
Cr
­
29
Hex.
Cr
­
1,000
Drag
out
and
counter­
current
flow
rinse
systems
Cu
­
20,700
Cu
­
15,000
Ion
exchange
systems
Fe
­
105,000
Fe
­
80,800
Evaporation
and
Mesh
pad
mist
eliminators
for
drag­
out
recovery
Pb
­
439
Pb
­
410
Spray
rinsing
and
drag­
out
tankage
Mg
­
44,300
Mg
­
30,300
Enhanced
product
hang
times
Mn
­
1,070
Mn
­
1,170
Withdrawal
and
drainage
time
Hg
­
0.35
Hg
­
0.6
Uses
wetting
agents
and
drainage
boards
Ni
­
14,800
Ni
­
18,700
Spray
rinses
only
on
nickel
boards
Se
­
1.9
Se
­
ND
Utilizes
strategic
workpiece
positioning
Ag
­
65
Ag
­
230
RINSEWATER
Sn
­
1,100
Sn
­
681
Implemented
a
strict
control
program
for
monitoring
incoming
water
to
each
Zn
­
67,200
Zn
­
83,900
separate
production
line
CN
­
46
CN
­
74
Company­
wide
water
conservation
program
(e.
g.,
spray
rinses,
flow
restrictors
water
meters,
etc.)
TCLP
(mg/
l)
TCLP
(mg/
l)
Use
spent
acid
bath
for
pH
adjustment
in
WWT
As
­
ND
As
­
ND
Reuse
treated
wastewater
in
production
lines
Ba
­
1.1
Ba
­
0.8
Replaced
solvent­
based
washers
with
aqueous
systems
(increasing
sludge
Cd
­
ND
Cd
­
ND
generation)
Cr
­
0.9
Cr
­
13.1
Flow
restrictors
Pb
­
ND
Pb
­
ND
OTHER
Se
­
ND
Se
­
0.04
Use
sludge
dryer
to
reduce
sludge
volume
and
transportation
costs
Ag
­
ND
Ag
­
ND
Reduced
cyanide
use
by
80%
Conduct
annual
training
for
waste
treatment
operators
on
chemical
use
and
how
this
affects
sludge
volumes
Tooling
attention/
maintenance
Chemical
inventory
and
control
Waste
collection
plumbing
alterations
or
improvements
Diking
Incorporated
energy
savings
techniques
Conducts
annual
plant
assessments
and
housekeeping
Uses
preventive
maintenance
systems
F9­
01
F9­
02
Cr
­
28,200
Cr
­
94,000
Na
­
15,900
Na
­
39,000
Hg
­
ND
Hg
­
ND
September
1998
36
F006
Benchmarking
Study
Table
9
(cont'd):
Facility­
Specific
Information
for
Milwaukee
Facilities
Facility
F11
Plating
Process
F006
Quantity
and
Management
Sample
Description
Zinc
(non­
CN)
on
steel
unreported
F11­
01
­
Collected
from
sludge
drier
Tin
on
non­
ferrous
and
steel
F11­
02
­
Collected
from
supersack
Nickel­
chrome
plating
Recycle
(Encycle)
dated
the
previous
month
Copper­
nickel
on
steel
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTION
Eliminated
cyanide
cadmium
plating
Total
(mg/
kg)
Total
(mg/
kg)
Replaced
zinc
cyanide
plating
with
zinc
alkaline
plating
Al
­
1,800
Al
­
1,650
Spent
alkaline
baths
are
used
for
pH
adjustment
Sb
­
14.2
Sb
­
11.1
Oil
removal
techniques
As
­
13
As
­
6.5
Chemical
usage
reduction
through
substitution
Ba
­
227
Ba
­
159
Utilizes
filtration,
carbon
treatment,
replenishment,
and
electrolytic
Be
­
ND
Be
­
ND
dummying
Bi
­
1.7
Bi
­
1.8
DRAG
OUT
REDUCTION/
RECOVERY
Ca
­
16,100
Ca
­
14,800
Drag
out
recovery
on
chrome
and
nickel
lines
Cr
­
31,100
Cr
­
48,100
Enhanced
product
hang
times
Hex.
Cr
­
26
Hex.
Cr
­
0.4
Installed
atmospheric
evaporators
on
automatic
chrome
line
for
drag
out
Cu
­
8,980
Cu
­
11,300
recovery
Fe
­
58,800
Fe
­
69,300
Wetting
agents
and
drainage
boards
Pb
­
527
Pb
­
230
Strategic
workpiece
positioning
Mg
­
13,500
Mg
­
13,700
Increase
in
withdrawal
and
drainage
time
Mn
­
557
Mn
­
707
RINSEWATER
Ni
­
180,000
Ni
­
84,600
Counter­
current
flow
rinse
systems
Se
­
7.3
Se
­
5
Monitors
solutions
and
uses
purer
anodes
and
bags
Ag
­
163
Ag
­
657
Utilizes
exit
spray
rinse
Na
­
22,700
Na
­
84,300
Uses
atmospheric
and
simple
evaporation
techniques
Sn
­
3,550
Sn
­
8,070
Flow
restrictors
Zn
­
129,000
Zn
­
94,400
Conductivity
controls
CN
­
16
CN
­
6.6
OTHER
TCLP
(mg/
l)
TCLP
(mg/
l)
Installed
sludge
drier
to
reduce
sludge
volume
As
­
ND
As
­
ND
Train
staff
on
causes
of
increase
in
hazardous
waste
production
Ba
­1.3
Ba
­
0.11
Tooling
attention/
maintenance
Cd
­
0.1
Cd
­
0.64
Chemical
inventory
and
control
Cr
­
3.1
Cr
­
ND
Waste
collection
alterations
or
improvements
Pb
­
ND
Pb
­
ND
Diking
Hg
­
ND
Hg
­
ND
Product
longevity
through
specification
alteration
Se
­
ND
Se
­
ND
Energy
saving
techniques
Ag
­
ND
Ag
­
0.08
Plant
housekeeping
and
annual
plant
assessment
Automatic
leak
detection
system
Preventive
maintenance
system
F11
­
01
F11­
02
Cd
­
12.5
Cd
­
7.3
Hg
­
ND
Hg
­
0.3
September
1998
37
F006
Benchmarking
Study
Table
9
(cont'd):
Facility­
Specific
Information
for
Milwaukee
Facilities
Facility
F13
Plating
Process
F006
Quantity
and
Management
Sample
Description
Nickel
chrome
on
steel
15
tons/
yr
F13­
01
­
did
not
meet
the
regulatory
Recycle
(Inmetco)
F13­
02
­
Collected
from
sludge
definition
of
F006
supersack
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTION
Oil
removal
and
filtration
techniques
Total
(mg/
kg)
Promote
product
longevity
through
specification
alteration
Al
­
311
Uses
alternate
stripping
methodologies
­
switched
from
cyanide
to
non­
Sb
­
0.6
cyanide
stripping
As
­
2.3
Evaporation
to
concentrate
plating
by­
products
Ba
­
6
Substituted
hexavalent
chrome
with
trivalent
chrome
Be
­
ND
Set
up
pilot
line
to
evaluate
a
liquid
addition
agent
for
cleaning
Bi
­
ND
Require
operators
to
log
plating
parameters
daily
which
improves
their
Cd
­
ND
control
Ca
­
855
Uses
purer
anodes
and
bags
and
fume
suppressors
Cr
­
193
DRAG
OUT
REDUCTION/
RECOVERY
Cu
­
33.6
Enhanced
product
hang
times
Fe
­
3,350
Wetting
agents
Pb
­
0.6
Air
knives
Mg
­
355
Spray
or
fog
rinses
Mn
­
3.8
Drainage
boards
Hg
­
ND
Increased
withdrawal
and
drainage
time
Ni
­
76,000
Strategic
workpiece
positioning
Se
­
ND
RINSEWATER
Na
­
16,400
Other
than
cooling
water
and
water
used
to
process
incoming
water,
this
is
a
Sn
­
9.0
zero
discharge
facility
(from
the
process
units)
Zn
­
6.1
Rinse
water
is
recycled
through
filtration,
carbon
absorption
in
waste
CN
­
2.0
treatment
section,
replenishment
and
ion
exchange
Counter­
current
flow
rinse
systems
Utilizes
electrocoagulation
for
cleaning
(and
reusing)
rinse
waters
Flow
restrictors
Reverse
osmosis
utilized
on
incoming
water
OTHER
Tooling
attention/
maintenance,
preventive
maintenance
systems
Improved
record
keeping
demonstrates
areas
to
be
considered
for
improvement
Installed
filter
press
and
sludge
drier
to
reduce
sludge
volume
Chemical
inventory
and
control
Waste
collection
plumbing
alterations
or
improvements
Diking
High
efficiency
lighting
Conducts
annual
plant
assessments
and
plant
housekeeping
F13­
02
Hex.
Cr
­
0.5
Ag
­
ND
September
1998
38
F006
Benchmarking
Study
Table
9
(cont'd):
Facility­
Specific
Information
for
Milwaukee
Facilities
Facility
F14
Plating
Process
F006
Quantity
and
Management
Sample
Description
Zinc
(CN)
on
Steel
196
tons/
yr
F14­
01
­
Sludge
from
drier
output
Recycle
(Horsehead
58%)
Landfill
(42%)

Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
Separated
the
process
chemistry
and
wastewater
treatment
departments
Total
(mg/
kg)
TCLP
(mg/
l)
Cyanide
bath
carbonate
freezing
to
prolong
life
Al
­2,320
As
­
ND
Utilize
bags
on
1
chloride
bath
Sb
­
2
Ba
­
1.3
Oil
removal
techniques
on
1
barrel
As
­
13.4
Cd
­
0.03
DRAG­
OUT
REDUCTION
Be
­
ND
Pb
­
ND
Workpiece
positioning
Bi
­ND
Hg
­
ND
Increase
dwell
(rinse)
cycles
Cd
­
3.9
Se
­
ND
Wetting
Agents
Ca
­18,000
Ag
­
ND
Prolonged
withdrawal
and
drainage
time
Cr
­26,900
Drainage
boards
Hex.
Cr
­
2.6
RINSEWATER
Fe
­
194,000
Counter­
current
flow
rinse
systems
Pb
­
64.8
Flow
restrictors
Mg
­
9,990
Spray
rinse
and
multiple
rinses
Mn
­
979
Evaporators
and
filters
on
3
of
4
baths
Hg
­
ND
Larger
hole
barrels
Ni
­
57.1
Use
alkaline
cleaner
baths
for
wastewater
pH
adjustment
Se
­
5.7
Sludge
dryer
reduces
volume
by
65%.
Ag
­
4.4
Assessed
source
by
source
water
use
to
eliminate
major
changes
in
flow
Na
­
3,830
which
upsets
WWT
performance
Sn
­
19.5
Employed
an
environmental
engineering
company
to
assist
in
water
control
Zn
­
277,000
and
reduction.
CN
­
200
OTHER
Eliminated
several
plating
services:
cadmium,
nickel,
hard
chrome,
tin,
copper,
and
brass
plating
and
aluminum
anodizing
Replacing
CN
baths
with
alkaline
baths
by
end
of
1997.
Diking
of
all
4
production
lines
Plant
Housekeeping
Annual
plant
assessments
Hazardous
waste
leak
detection
system
Preventive
maintenance
system
Installed
waste
collection
hard
plumbing
on
every
machine
F14
­
01
Ba
­29.2
Cr
­
0.2
Cu
­
54.6
September
1998
39
F006
Benchmarking
Study
Table
9
(cont'd):
Facility­
Specific
Information
for
Milwaukee
Facilities
Facility
F16
Plating
Process
F006
Quantity
and
Management
Sample
Description
Nickel
chrome
on
non­
ferrous
41
tons/
yr
F16­
01
­
Collected
from
supersack
Gold
plating
dated
that
day
Landfill
F16­
02
­
Collected
by
facility
about
2
weeks
later
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTION
Filtration
Total
(mg/
kg)
Total
(mg/
kg)
Improved
SOPs
by
tracking
water
flow
reducing
the
level
of
chrome
in
the
Al
­
3,940
Al
­
1,210
hot
rinse
>90%
Sb
­
3.5
Sb
­
2.7
Leak
detection
systems
on
plating
bath
As
­
9.4
As
­
7
Metals
recovery
system
via
ion
exchange
reclaims
Cr
and
Ni
from
rinse
Ba
­
73.7
Ba
­
24.5
waters
Be
­
ND
Be
­
ND
Oil
removal
techniques
on
pre­
cleaning
line
Bi
­
5.4
Bi
­
2.2
DRAG
OUT
REDUCTION/
RECOVERY
Ca
­
97,300
Ca
­
105,000
Conductivity
meters
Cr
­
13,800
Cr
­
5,520
Rack
design
eliminates
drag
out
Hex.
Cr
­
0.2
Hex.
Cr
­
0.1
Enhanced
product
hang
times
on
pre­
cleaning
line
Cu
­
13,600
Cu
­
5,520
Wetting
agents
on
chrome
line
Fe
­
114,000
Fe
­
189,000
Spray
rinses
and
drainage
boards
Pb
­
2,870
Pb
­
778
RINSEWATER
Mn
­
671
Mn
­
950
Counter­
current
flow
rinsing
on
plating
and
pre­
cleaning
lines
Hg
­
0.4
Hg
­
ND
Flow
restrictors
Ni
­
ND
Ni
­
ND
Spray
rinsing
on
some
pre­
cleaning
lines
Se
­
30,700
Se
­
16,800
Replaced
solvent­
based
washers
with
aqueous
systems
(increasing
sludge
Ag
­
47.4
Ag
­
20.2
generation)
Na
­
5,490
Na
­
7,900
Continually
searching
for
new
environmentally
safe
cleaners
Sn
­
497
Sn
­
50.8
OTHER
CN
­
ND
CN
­
ND
Operators
are
certified
and
receive
on­
going
training
Tooling
attention/
maintenance
TCLP
(mg/
l)
TCLP
(mg/
l)
Chemical
inventory
and
control
As
­
ND
As
­
ND
Diking
Ba
­
0.9
Ba
­
0.2
Utilize
high
efficiency
motors
Cd
­
0.03
Cd
­
ND
Conduct
annual
plan
assessments
Cr
­
14.5
Cr
­
12.7
Ongoing
plant
housekeeping
and
chemical
usage
reduction
Pb
­
0.3
Pb
­
1.3
Preventive
maintenance
systems
Hg
­
0.005
Hg
­
0.01
Employ
monitoring
and
utilize
bags
Se
­
ND
Se
­
ND
F16­
01
F16­
02
Cd
­
1.3
Cd
­
1.3
Mg
­
10,400
Mg
­
4,250
Zn
­
14,200
Zn
­
5,790
Ag
­
ND
Ag
­
0.04
September
1998
40
F006
Benchmarking
Study
Table
9
(cont'd):
Facility­
Specific
Information
for
Milwaukee
Facilities
Facility
F17
Plating
Process
F006
Quantity
and
Management
Sample
Description
Zn
(non­
CN)
on
steel
unreported
F17­
01
­
Collected
from
sludge
drier
Chrome
on
nonferrous
F17­
02
­
Collected
from
supersack
Copper­
nickel
on
nonferrous
Landfill
dated
the
previous
month
Copper­
nickel
on
steel
Cadmium
on
steel
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTION
Uses
vapor
recompression
evaporation
and
carbonate
removal
system
for
Total
(mg/
kg)
Total
(mg/
kg)
recovery
Al
­
1,260
Al
­
1,360
Employs
filtration,
carbon
treatment,
replenishment,
and
electrolytic
Sb
­
0.6
Sb
­
0.6
dummying
As
­
3.8
As
­
4.1
Utilizes
cyanide
bath
carbonate
freezing
to
extend
life
of
solution
Ba
­
29.4
Ba
­
43.5
Reduced
50%
of
cadmium
to
zinc
Be
­
ND
Be
­
ND
Oil
removal
techniques
on
pre­
cleaning
line
Bi
­
ND
Bi
­
ND
Alternate
stripping
methodologies
­
formerly
used
cyanide
based
stripper;
Cd
­
39,300
Cd
­
21,600
but
now
outsourced
Ca
­
141,000
Ca
­
140,000
DRAG
OUT
REDUCTION/
RECOVERY
Hex.
Cr
­
19
Hex.
Cr
­
3.7
Uses
stagnant
rinse
tanks
or
drag
out
tanks
Cu
­
21,900
Cu
­
18,600
Drag
out
waters
replace
drag
in
waters
or
added
back
to
plating
bath
Fe
­
24,300
Fe
­
17,400
Spray
rinses
and
diking
Pb
­
221
Pb
­
237
Enhanced
product
hang
times
Mg
­
12,900
Mg
­
12,300
Utilizes
wetting
agents
and
drainage
boards
Mn
­
244
Mn
­
199
Increased
temperature
bath,
withdrawal
and
drainage
time
Hg
­
ND
Hg
­
0.12
RINSEWATER
Se
­
2.1
Se
­
2.1
Segregate
wastewater
streams
Ag
­
0.5
Ag
­
1.5
Counter­
current
flow
rinse
systems
Na
­
11,700
Na
­
17,700
Flow
restrictors
Sn
­
11.2
Sn
­
13.8
Conductivity
meters
Zn
­
35,500
Zn
­
44,600
Uses
reverse
osmosis
(3
units)
and
atmospheric
and
vacuum
distillation
CN
­
380
CN
­
99
evaporation
to
recycle
rinse
waters
Ion
exchange
for
water
delivered
to
plating
baths
TCLP
(mg/
l)
TCLP
(mg/
l)

OTHER
Ba
­
1.3
Ba
­
1.1
Planning
to
re­
engineer
the
WWT
to
segregate
the
nickel
sludge
from
the
Cd
­
13.3
Cd
­
5.7
cadmium
sludge
to
enable
recycling
of
the
nickel
sludge
to
Encycle.
Cr
­
ND
Cr
­
ND
Cadmium
sludge
will
be
landfilled.
Pb
­
ND
Pb
­
ND
Chemical
inventory
and
control
Hg
­
ND
Hg
­
ND
Redesigned
waste
plumbing
Se
­
0.01
Se
­
ND
Utilizes
energy
saving
techniques
Ag
­
ND
Ag
­
ND
Conducts
annual
plant
assessments
and
weekly
plant
housekeeping
Preventive
maintenance
systems
and
leak
detection
on
reverse
osmosis
equipment
F17­
01
F17­
02
Cr
­
14,000
Cr
­
9,250
Ni
­
83,000
Ni
­
35,100
As
­
ND
As
­
ND
September
1998
41
F006
Benchmarking
Study
Table
10:
Overview
of
Milwaukee
F006
Analytical
Data:
#
of
Samples
Which
Were:
Not­
Detected;
"C"
values
(i.
e.,
Statistically
Estimated
Values
Above
Instrument
Detection
Limit,
but
Below
Method
Quantitation
Limit);
Above
MethodQuantitation
Limit
Constituent
#
Samples
#
Non
#
Samples
#
Samples
Above
Method
Detects
Above
Instrument
Quantitation
Limit
Detection,
Below
Method
Quantitation
Total
Metals
Concentration
(mg/
kg)

Aluminum
16
0(
0%)
0(
0%)
16(
100%)

Antimony
16
0(
0%)
6(
37%)
10(
63%)

Arsenic
16
0(
0%)
2(
12%)
14(
88%)

Barium
16
0(
0%)
3(
19%)
13(
81%)

Beryllium
16
14(
87%)
0(
0%)
2(
13%)

Bismuth
16
6(
37%)
3(
19%)
7(
44%)

Cadmium
16
1(
6%)
2(
12%)
13(
82%)

Calcium
16
0(
0%)
0(
0%)
16(
100%)

Chromium
16
0(
0%)
0(
0%)
16(
100%)

Copper
16
0(
0%)
0(
0%)
16(
100%)

Iron
16
0(
0%)
0(
0%)
16(
100%)

Lead
16
0(
0%)
1(
6%)
15(
94%)

Magnesium
16
0(
0%)
0(
0%)
16(
100%)

Manganese
16
0(
0%)
1(
6%)
15(
94%)

Mercury
16
6(
37%)
4(
25%)
6(
37%)

Nickel
16
2(
12%)
0(
0%)
14(
88%)

Selenium
16
2(
12%)
0(
0%)
12(
75%)

Silver
16
3(
37%)
1(
6%)
12(
75%)

Sodium
16
0(
0%)
0(
0%)
16(
100%)

Tin
16
0(
0%)
0(
0%)
16(
100%)

Zinc
16
0(
0%)
1(
6%)
15(
94%)

TCLP
(mg/
l)

Arsenic
16
16(
100%)
0(
0%)
0(
0%)

Barium
16
0(
0%)
12(
75%)
4(
25%)

Cadmium
16
4(
25%)
4(
25%)
8(
50%)

Chromium
16
2(
12%)
0(
0%)
14(
88%)

Lead
16
12(
75%)
0(
0%)
4(
25%)

Mercury
16
13(
81%)
0(
0%)
3(
19%)

Selenium
16
14(
87%)
1(
6%)
1(
6%)

Silver
16
12(
75%)
3(
19%)
1(
6%)

General
Chemistry
(mg/
kg)

Chloride
16
0(
0%)
0(
0%)
16(
100%)

Fluoride
16
0(
0%)
1(
6%)
15(
94%)

Chromium,
hexavalent
16
0(
0%)
0(
0%)
16(
100%)

Total
Cyanide
16
4(
25%)
0(
0%)
12(
75%)

Amenable
Cyanide
16
4(
25%)
0(
0%)
12(
75%)

Percent
Solids
16
0(
0%)
0(
0%)
16(
100%)
September
1998
42
F006
Benchmarking
Study
Table
11:
Analytical
Data
for
the
Milwaukee
Facilities.

Constituent
CAS
No.
F1­
01
F9­
01
F16­
01
F17­
01
1
Volatile
Organics
­
Method
8260A
µg/
kg
Acetone
67641
210
B
7,500
B
290
24
2­
Butanone
78933
J
B
58
B
69
J
2­
Hexanone
591786
ND
ND
JB
ND
Benzene
71432
ND
53
J
ND
Chloroform
67663
J
6
ND
ND
Chlorobenzene
108907
ND
J
ND
ND
Trichloroethene
79016
ND
ND
J
ND
4­
Methyl­
2­
pentanone
108101
ND
16
64
ND
Toluene
108883
J
J
20
ND
Ethylbenzene
100414
ND
ND
J
ND
m,
p­
Xylenes
108383
/
106423
ND
ND
J
ND
o­
Xylene
95476
ND
ND
J
ND
Semivolatile
Organics
­
Method
8270B
µg/
kg
bis(
2­
Ethylhexyl)
phthalate
117817
59,000
55,000
180,000
28,000
Di­
n­
octylphthalate
117840
J
ND
ND
ND
Fluoranthene
206440
4,900
ND
ND
ND
Phenanthrene
85018
4,600
ND
ND
ND
Pyrene
129000
J
ND
ND
ND
Phenol
108952
3,600
3,600
ND
ND
Benzyl
alcohol
100516
7,900
7,900
ND
ND
Notes:
All
results
reported
on
a
dry­
weight
basis.
1.
Facility
F4's
F006
samples
were
designated
as
F1.
J
Mass
spectral
data
indicate
the
presence
of
a
compound
that
meets
the
identification
criteria
for
which
the
result
is
less
than
the
laboratory
detection
limit,
but
greater
than
zero.
B
Analyte
also
detected
in
the
associated
method
blank
analysis.
ND
Non­
detect
Volatiles
analyzed
for
but
not
detected
include:
Chloromethane,
Vinyl
Chloride,
Bromomethane,
Chloroethane,
Trichlorofluoromethane,
2­
Chloroethyl
vinyl
ether,
1,1­
Dichloroethene,
Methylene
Chloride,
Carbon
Disulfide,
Vinyl
Acetate,
1,1­
Dichloroethane,
trans­
1,2­
Dichloroethene,
cis­
1,2­
Dichloroethene,
1,1,1­
Trichloroethane,
Carbon
Tetrachloride,
1,2­
Dichloroethane,
Benzene,
1,2­
Dichloropropane,
Bromodichloromethane,
cis­
1,3­
Dichloropropene,
trans­
1,3­
Dichloropropene,
1,1,2­
Trichloroethane,
Dibromochloromethane,
Tetrachloroethene
(PCE),
Styrene,
Bromoform,
1,1,2,2­
Tetrachloroethane,
1,3­
Dichlorobenzene,
1,4­
Dichlorobenzene,
and
1,2­
Dichlorobenzene.
Semivolatiles
analyzed
for
but
not
detected
include:
bis(
2­
Chloroethyl)
ether,
2­
Chlorophenol,
2,3­
Dichlorobenzene,
1,4­
Dichlorobenzene,
1,2­
Dichlorobenzene,
2­
Methylphanol,
bis((
2­
Chloroisopropyl)
ether,
4­
Methyphenol,
NNitroso
di­
n­
propylamine,
Hexachloroethane,
Nitrobenzene,
Isophorone,
2­
Nitrophenol,
2,4­
Dimethylphenol,
bis(
2­
Chloroethoxy)
methane,
Benzoic
acid,
2,4­
Dichlorophenol,
1,2,4­
Trichlorobenzene,
Naphthalene,
4­
Chloroaniline,
Hexachlorobutadiene,
4­
Chloro­
3­
methylphenol,
2­
Methylnaphthalene,
Hexachlorocyclopentadiene,
2,4,6­
Trichlorophenol,
2,4,5­
Trichlorophenol,
2­
Chloronaphthalene,
2­
Nitroaniline,
Dimethylphthalate,
Acenaphthylene,
2,6­
Dinitrotoluene,
3­
Nitroaniline,
Acenaphthene,
2,4­
Dinitrophenol,
4­
Nitrophanol,
4­
Nitrophenol
,Dibenzofuran,
2,4­
Dinitrotoluene,
Diethyphthalate,
4­
Chlorophenyl­
phenylether,
Fluorene,
4­
Nitroaniline,
4,6­
Dinitro­
2­
methylphenol,
N­
Nitrosodiphenylamine,
4­
Bromophenyl­
phenylether,
Hexachlorobenzene,
Pentachloropheno,
l
Anthraoene,
Carbazole,
Di­
n­
butylphthalate,
Butylbenzylphthalate,
3,3'­
Dichlorobenzidine,
Benzo(
a)
anthracene,
Chrysene,
Din­
octylphthalate,
Benzo(
b)
fluoranthene,
Benzo(
k)
fluoranthene,
Benzo(
a)
pyrene,
Indeno(
1,2,3­
cd)
pyrene,
Dibenz(
a,
h)
anthracene,
and
Benzo(
g,
h,
f)
perylene
September
1998
43
F006
Benchmarking
Study
Table
11
(cont'd):
Analytical
Data
for
the
Milwaukee
Facilities.

Constituent
CAS
No.
F1­
01
F1­
02
F5­
01
F5­
02
F16­
01
F16­
02
F8­
01
F8­
02
1
Total
Metals
­
Methods
6020,
7471
mg/
kg
Aluminum
7429905
31,200
17,300
3,690
1,710
3,940
1,210
19,300
8,560
Antimony
7440360
C
5.5
C
1.8
67.4
45.0
C
3.5
C
2.7
161
110
Arsenic
7440382
C
9.9
C
9.3
15.4
18.3
9.4
7.0
C
5.5
11.8
Barium
7440393
C
41.9
C
34.3
843
157
73.7
C
24.5
83.4
C
33.3
Beryllium
7440417
ND
ND
C
0.59
C
0.69
ND
ND
ND
ND
Bismuth
7440699
C
2.7
C
3.3
C
2.1
3.2
5.4
C
2.2
ND
ND
Cadmium
7440439
7.5
9.6
9.6
13.4
C
1.3
C
1.3
10.1
42.7
Calcium
7440702
24,800
17,500
21,400
23,200
97,300
105,000
67,400
50,800
Chromium
7440473
59,500
64,900
92,000
71,000
13,800
5,520
193,000
91,500
Copper
7440508
130
1,480
39,900
41,500
13,600
5,320
24,500
41,100
Iron
7439896
25,000
27,700
92,100
105,000
114,000
189,000
110,000
279,000
Lead
7439921
297
366
976
556
2,870
778
858
231
Magnesium
7439954
15,800
17,400
13,000
12,500
10,400
4,250
9,710
11,100
Manganese
7439965
1,710
399
1,200
1,340
671
950
1,360
1,080
Mercury
7439976
2.0
ND
C
0.33
C
0.26
C
0.40
ND
ND
C
1.2
Nickel
7440020
19,900
18,200
104,000
105,000
ND
ND
1,130
744
Selenium
7782492
16.6
16.0
10.6
11.3
30,700
16,800
ND
ND
Silver
7440224
267
97.9
8.7
3.4
47.4
20.2
ND
ND
Sodium
7440235
8,360
21,700
5,950
6,830
5,490
7,900
19,600
49,400
Tin
7440315
404
582
429
337
497
50.8
129
96.3
Zinc
7440666
336,000
335,000
126,000
158,000
14,200
5,790
3,790
9,610
TCLP
Metals
­
Methods
1311,
6010,
7470
mg/
L
Arsenic
7440382
ND
ND
ND
ND
ND
ND
ND
ND
Barium
7440393
C
0.26
1.4
C
1.7
2.2
C
0.9
C
0.2
C
0.3
B
0.7
Cadmium
7440439
C
0.04
0.07
C
0.05
0.08
C
0.03
ND
C
0.01
0.3
Chromium
7440473
40.6
56.2
27.2
12.1
14.5
12.7
54.1
12.8
Lead
7439921
ND
0.11
ND
ND
0.3
1.3
0.1
ND
Mercury
7439976
ND
ND
ND
ND
0.005
0.009
ND
0.005
Selenium
7782492
ND
ND
ND
ND
ND
ND
ND
ND
Silver
7440224
C
0.05
ND
ND
ND
ND
C
0.04
ND
ND
Table
11
(cont'd):
Analytical
Data
for
the
Milwaukee
Facilities.

Constituent
CAS
No.
F1­
01
F1­
02
F5­
01
F5­
02
F16­
01
F16­
02
F8­
01
F8­
02
1
September
1998
44
F006
Benchmarking
Study
General
Chemistry
mg/
kg
Chloride
16887006
2,400
13,000
1,000
1,200
2,200
190
8,800
8,000
Fluoride
16984488
300
1,600
82
120
61
120
48
17
Hex.
Chromium
18540299
C
0.66
C
0.60
0.66
C
0.10
C
0.18
C
0.10
C
0.43
C
0.19
Total
Cyanide
57125
ND
ND
700
900
ND
ND
ND
ND
Amenable
Cyanide
E­
10275
**
12
**
18
**
2,700
**
1,300
ND
ND
ND
ND
Percent
Solids
14.8
16.5
43.5
45.9
25.1
31.3
19.9
18.8
Notes:
All
results
reported
on
a
dry­
weight
basis
1.
Facility
F4's
F006
samples
were
designated
as
F1.
B
Analyte
also
detected
in
the
associated
method
blank
analysis.
C
Reported
value
is
less
than
the
method
quantitation
limit
(QL)
but
greater
than
the
instrument
detection
limit
(IDL).
**
Reported
value
is
the
concentration
of
cyanide
after
chlorination.
Since
this
value
is
greater
than
the
total
cyanide
result,
a
value
for
the
cyanide
amenable
to
chlorination
cannot
be
calculated.
ND
Non­
detect
September
1998
45
F006
Benchmarking
Study
Table
11
(cont'd):
Analytical
Data
for
the
Milwaukee
Facilities.

Constituent
CAS
No.
F17­
01
F17­
02
F11­
01
F11­
02
F13­
02
F14­
01
F9­
01
F9­
02
Total
Metals
­
Methods
6020,
7471
mg/
kg
(cont.)

Aluminum
7429905
1,260
1,360
1,800
1,650
311
2,320
27,000
13,200
Antimony
7440360
C
0.62
C
0.63
14.2
11.1
C
0.57
C
2.0
5.4
13.5
Arsenic
7440382
3.8
4.1
13.0
6.5
C
2.3
13.4
4.8
3.1
Barium
7440393
29.4
43.5
227
159
C
6.0
29.2
298
257
Beryllium
7440417
ND
ND
ND
ND
ND
ND
ND
ND
Bismuth
7440699
ND
ND
C
1.7
C
1.8
ND
ND
72.5
31.5
Cadmium
7440439
39,300
21,600
12.5
7.3
ND
3.9
2.1
17.3
Calcium
7440702
141,000
140,000
16,100
14,800
855
18,000
87,000
70,000
Chromium
7440473
14,000
9,250
31,100
48,100
193
26,900
28,200
94,000
Copper
7440508
21,900
18,600
8,980
11,300
33.6
54.6
20,700
15,000
Iron
7439896
24,300
17,400
58,800
69,300
3,350
194,000
105,000
80,800
Lead
7439921
221
237
527
230
C
0.59
64.8
439
410
Magnesium
7439954
12,900
12,300
13,500
13,700
355
9,990
44,300
30,300
Manganese
7439965
244
199
557
707
C
3.8
979
1,070
1,170
Mercury
7439976
ND
C
0.12
ND
C
0.29
ND
ND
0.35
0.58
Nickel
7440020
83,000
35,100
180,000
84,600
76,000
57.1
14,800
18,700
Selenium
7782492
2.1
2.1
7.3
5.0
ND
5.7
1.9
ND
Silver
7440224
C
0.52
1.5
163
657
ND
4.4
65.0
230
Sodium
7440235
11,700
17,700
22,700
84,300
16,400
3,830
15,900
39,000
Tin
7440315
11.2
13.8
3,550
8,070
9.0
19.5
1,100
681
Zinc
7440666
35,500
44,600
129,000
94,400
C
6.1
277,000
67,200
83,900
TCLP
Metals
­
Methods
1311,
6010,
7470
mg/
L
Arsenic
7440382
ND
ND
ND
ND
ND
ND
ND
ND
Barium
7440393
C
1.3
C
1.1
C
1.3
C
0.7
C
0.4
C
1.3
C
1.1
C
0.8
Cadmium
7440439
13.3
5.7
0.06
0.11
ND
C
0.03
ND
ND
Chromium
7440473
ND
ND
3.1
0.64
1.9
0.2
0.9
13.1
Lead
7439921
ND
ND
ND
ND
ND
ND
ND
ND
Mercury
7439976
ND
ND
ND
ND
ND
ND
ND
ND
Selenium
7782492
0.08
ND
ND
ND
ND
ND
ND
C
0.04
Silver
7440224
ND
ND
ND
C
0.08
ND
ND
ND
ND
Table
11
(cont'd):
Analytical
Data
for
the
Milwaukee
Facilities.

Constituent
CAS
No.
F17­
01
F17­
02
F11­
01
F11­
02
F13­
02
F14­
01
F9­
01
F9­
02
September
1998
46
F006
Benchmarking
Study
General
Chemistry
mg/
kg
Chloride
16887006
5,500
13,000
690
30,000
17,000
2,700
12,000
23,000
Fluoride
16984488
C
0.7
1.2
99
48
120
250
200
1,400
Chromium,
18540299
19
C
3.7
26
0.43
0.50
2.6
29
1,000
hexavalent
Total
Cyanide
57125
380
99
16
6.6
2.0
200
46
74
Amenable
Cyanide
E­
10275
**
940
**
180
3.0
3.3
**
11
30
12
51
Percent
Solids
65.9
77.4
38.2
54.9
54.1
37.7
74.3
69.1
Notes:
*
All
results
reported
on
a
dry­
weight
basis.
B
Analyte
also
detected
in
the
associated
method
blank
analysis.
C
Reported
value
is
less
than
the
method
quantitation
limit
(QL)
but
greater
than
the
instrument
detection
limit
(IDL).
**
Reported
value
is
the
concentration
of
cyanide
after
chlorination.
Since
this
value
is
greater
than
the
total
cyanide
result,
a
value
for
the
cyanide
amenable
to
chlorination
cannot
be
calculated.
ND
Non­
detect
September
1998
47
F006
Benchmarking
Study
2.
Chicago
Benchmarking
Study
This
section
provides
a
detailed
presentation
of
data
gathered
in
the
Chicago
Benchmarking
Study,
including
a
characterization
of
plating
processes,
pollution
prevention
and
recycling
practices,
F006
characteristics,
and
site
specific
variations
in
the
generation
and
management
of
F006
for
ten
facilities
in
Milwaukee.
Table
12is
the
facility
selection
matrix
used
to
select
10
facilities
from
13
candidates.
Table
13
presents
information
collected
for
each
facility
in
the
study.
Table
14
summarizes
the
results
of
the
laboratory
analyses
of
F006
data
and
Table
15
presents
detailed
laboratory
analysis
results
for
each
facility.

All
Chicago
facilities
reported
an
annual
quantity
of
waste
generated.
The
total
amount
generated
from
all
10
facilities
is
approximately
1712
tons/
year.
Nine
of
the
facilities
recycle
their
F006
waste.
One
facility
landfills
its
F006
waste.
Fifteen
F006
laboratory
samples
gathered.
September
1998
48
F006
Benchmarking
Study
Table
12:
Chicago
Metal
Finishing
Facility
Selection
Matrix
Selection
C7
C10
C11
C12
Criteria
Alternate
Alternate
Alternate
Eliminated
C1
C2
C3
C4
C5
C6
C8
C9
C13
C14
Selected
Selected
Selected
Selected
Selected
Selected
Selected
Selected
Selected
Selected
Type:
Job
Job
Job
Job
Job
Job
Job
Job
Job
Job
Job
Job
Job
Job
Captive/
Job
Size
80
150
37
43
70
30
60
50
35
120
150
Main
Alk/
Alk/
Alk/
Alk/
Alk/
Alk/
Alk/
Alk/
Alk/
Alk/
Alk/
Alk/
Alk/
Alk/
Treatment
PPT
PPT
PPT/
IX
PPT/
PPT
PPT
PPT
PPT
PPT
PPT
PPT
PPT
PPT
PPT
Technology
Cr
Treatment
CFR
CFR/
IX
CFR
CFR
CFR/
IX
CFR
CFR
CFR
CFR
CFR
CFR
CFR
CFR
CFR
Technology
Onsite
No
Yes
Yes
Electro­
Au/
Ag
No
No
No
Yes
No
Au/
Ag
IX
No
Recycle
winning
Closed
System
System
Landfill
No
No
No
No
No
No
Yes
Yes
Yes
Yes
No
Yes
Main
Recycle
Recycle
Recycle
Recycle
Reclaim
Recycle
LF
LF
Lf/
Recycle
LF
Reclaim
LF
Management
Method
Finishing
Cu/
Ni/
Cr
Cu/
Ni/
Cr
CdCN
Cu/
Ni/
Cr
AuCN
Cu/
Ni
CdCN
Cu/
Ni/
Cr
Zn/
Fe
CuCN/
Ni
Cu/
Ni/
Cr
Electro­
AuCN
Zn(
CN)/
Processes
E­
Ni
Zn(
nCN)/
Zn(
CN)/
AgCN
Zn(
nCN)/
Zn(
nCN)/
Cu/
Ni/
Cr
BrassCN
E­
Ni
polish
AgCN
Fe
HCr
Fe
Fe
Nickel
Fe
Fe
E­
Ni
HCr
Zn
Zn(
nCN)/
Copper
Zn/
Fe
Zn(
nCN)/
(nCN)
Fe
Fe
SURVEY?
Y
N
Y
Y
Y
N
N
Y­
SAIC
Y­
SAIC
N
Y­
SAIC
Y
N
Y
September
1998
49
F006
Benchmarking
Study
Table
13:
Facility­
Specific
Information
for
Chicago
Facilities
Facility
C1
Plating
Process
F006
Quantity
and
Management
Sample
Description
Cu­
CN
Cd­
CN
24
­
28
tons/
yr
C1­
01
­
sludge
collected
from
Cu­
Tin­
Zn
Au­
CN
supersack
at
drier
output;
slightly
Bright
dip
of
Cu
alloy
Ag­
CN
Recycle
(World
Resources)
warm;
gray­
green
color
Ni/
Cr
on
steel
Acid­
Cu
Electroless
Ni
Chrome
Tins
Tin­
Ni
Tin­
Zn
Tin­
acid
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
C1
­
01
Filtration
­
E­
Ni,
Ni,
Cu,
Cd,
Au,
Sn,
Ag
Total
(mg/
kg)
TCLP
(mg/
l)
Carbon
treatment
­
occasional
use
for
Ni/
as
needed
Al
­
4,390
As
­
ND
Replenishment
­
complete
change
for
E­
Ni
only/
soap
dumped
periodically
Sb
­
ND
Ba
­
ND
Purified
water
­
DI
treated
on­
site
As
­
ND
Cd
­
1.0
Electrolytic
dummying
­
as
needed
­
Ni
­
primary
Ba
­
1,080
Cr
­
2.8
Cyanide
bath
carbonate
freezing
­
Na­
CN
every
winter,
Cd
Be
­
ND
Pb
­
ND
Precipitation
­
combined
with
bath
filtration
of
carbon
Bi
­
ND
Hg
­
0.001
Monitor
pH
daily
Cd
­
17,300
Se
­
ND
Drag­
in
Reduction
­
pre­
rinse
with
DI
water
Ca
­
47,400
Ag
­
3.8
High
purity
anodes
(some
tanks
bagged)
Cr
­
83,000
Non­
chelated
process
chemistries
in
Tin­
Zn
bath
Hex.
Cr
­
1,190
Non­
CN
process
chemicals
­
approx.
1/
3
of
chemicals
non­
CN
Cu
­
40,000
Solvent
degreasing
alternatives
­
mineral
spirits
and
limited
ultrasonic.
Fe
­
27,800
Alkaline
Cleaners
­
skimming,
chrome
reducers
Pb
­
10,300
Have
written
procedures
for
bath
make­
up
and
additions
Mg
­
51,100
Use
process
baths
to
maximum
extent
possible
(no
dump
schedule)
Mn
­
332
Remove
anodes
from
bath
when
they
are
idle
Hg
­
ND
Perform
regular
maintenance
of
racks/
barrels
Ni
­
98,800
Pre­
inspect
parts
to
prevent
processing
of
obvious
rejects
Se
­
ND
DRAG­
OUT
REDUCTION/
RECOVERY
Na
­
22,100
Process
Bath
Operating
Conc.
­
checked
every
other
week
Sn
­
13,800
Process
Bath
Operating
Temp.
­
automated;
daily
Zn
­
17,100
Wetting
agents
­
some
CN
­
1,800
Workpiece
positioning
Withdrawal
and
Drainage
Time
­
manual
(operators
trained)
Drainage
boards
between
all
baths
returned
to
bath
Drag­
out
tanks
on
some
tanks
returned
to
bath
Electrowinning
on
Au
only
Meshpad
Mist
Eliminators
­
chrome
RINSE
WATER
Spray
or
Fog
Rinse/
Rinse
Water
Agitation
Increased
Contact
Time/
Multiple
Rinses
Countercurrent
rinsing
and
flow
restrictors
Recycling/
Recovery
of
rinsewater
Manually
turning
off
rinsewater
when
not
in
use
Air
agitation
in
rinse
tanks
OTHER
Established
a
formal
policy
statement
with
regard
to
P2
and
control
Established
a
formal
P2
program
Conduct
employee
education
for
P2
Establish
a
preventative
maintenance
program
for
tanks
Ag
­
280
September
1998
50
F006
Benchmarking
Study
Table
13
(cont'd):
Facility­
Specific
Information
for
Chicago
Facilities
Facility
C2
Plating
Process
F006
Quantity
and
Management
Sample
Description
Mg
Anodizing
Gold­
CN
~347
tons/
yr
C2­
01
­
Sludge
from
roll­
off
bin;
not
Cu/
NiCr
Electroless
Ni
dried;
ambient
temp.
cool;
Zn
(nCN)
on
Fe
Chromic
acid
Recycle
(Horsehead)
consistency
of
fudge;
chunky;
Cu
plating
(nCN)
orange­
brown;
moist
Ag­
CN
C2­
02
­
Sludge
from
drier;
consistency
of
dirt;
chocolate
color
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
C2
­
01
C2­
02
Filtration
­
some
continuous
Total
(mg/
kg)
Total
(mg/
kg)
Carbon
treatment
to
remove
organic
contaminants
on
some
baths
Al
­
45,900
Al
­27,900
Purified
water
­
DI
Sb
­ND
Sb
­
ND
Precipitation
combined
with
filtration
on
certain
baths
As
­ND
As
­
ND
Monitoring
­
daily
with
on­
site
lab
Ba
­65
Ba
­
76
Purer
Anodes
and
Bags
­
depends
on
bath
Be
­ND
Be
­
ND
Nonchelated
Process
Chemistries
Bi
­
66
Bi
­
19
Non­
CN
process
chemicals
except
Au/
Ag
Cd
­3,740
Cd
­
4,440
Solvent
Degreasing
Alternatives
including
Hot
alkaline
cleaning
and
Ca
­32,900
Ca
­
26,400
Electrocurrent
Cr
­9,300
Cr
­
18,700
Alkaline
Cleaners
including
Skimming
and
Coalescer
on
barrel
lines
Hex.
Cr
­
53
Hex.
Cr
­
11
Acid
Purification
­
Ion
exchange
removes
metals
Cu
­1,210
Cu
­
1,600
DRAG­
OUT
REDUCTION/
RECOVERY
Pb
­
170
Pb
­
161
Wetting
Agents
­
required
Mg
­161,000
Mg
­
111,000
Workpiece
positioning
Mn
­1,240
Mn
­
1,010
Withdrawal
and
Drainage
Time
Hg
­
ND
Hg
­
ND
Drainage
boards
between
tanks
Ni
­
1,640
Ni
­
7,390
Drag­
out
tanks
Se
­
ND
Se
­
ND
Ion
Exchange
chrome
rinses
(off­
site)
Ag
­27
Ag
­
88
RINSE
WATER
Sn
­1,270
Sn
­
2,090
Increased
Contact
Time/
Multiple
Rinses
­
manual
rinse
with
DI
water
Zn
­62,000
Zn
­
89,200
Countercurrent
Rinsing
­
some
but
limited
space
for
more
CN
­
3.3
CN
­
0.8
Flow
controls
­
Flow
restrictors
Recycle
rinse
water
TCLP
(mg/
l)
TCLP
(mg/
l)
Recycle
solvents
via
Safety
Kleen
As
­ND
As
­
ND
Fe
­
29,500
Fe
­
40,400
Na
­29,600
Na
­
33,100
Ba
­ND
Ba
­
ND
Cd
­0.19
Cd
­
0.16
Cr
­
0.08
Cr
­
0.09
Pb
­
ND
Pb
­
ND
Hg
­ND
Hg
­
ND
Se
­
ND
Se
­
ND
Ag
­ND
Ag
­
ND
September
1998
51
F006
Benchmarking
Study
Table
13
(cont'd):
Facility­
Specific
Information
for
Chicago
Facilities
Facility
C3
Plating
Process
F006
Quantity
and
Management
Sample
Description
Cd­
CN
~90
tons/
yr
C3­
01S
­
Sludge
from
left
filter
Zn(
non
CN)
on
Steel
press;
mix
of
wet/
soft
and
wet/
hard
Recycle
(Horsehead)
sludge;
brown
color;
fudge
consistency
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
C3
­
01S
General
Bath
Life
Extensions
Total
(mg/
kg)
TCLP
(mg/
l)
Carbon
Treatment
­
as
needed
Al
­597
As
­ND
Monitoring
­
3­
4
times
/
day
Sb
­ND
Ba
­0.7
Housekeeping
­
1
person
in
charge
of
bath
chemistry
As
­39
Cd
­1.57
Nonchelated
Process
Chemistries
Ba
­167
Cr
­
ND
Solvent
Degreasing
Alternatives
­
Hot
Alkaline
Cleaning
and
Electrocurrent
Be
­ND
Pb
­
ND
Alkaline
Cleaners
­
Skimming
Bi
­
ND
Hg
­ND
DRAG­
OUT
REDUCTION
Ca
­30,200
Ag
­ND
Process
Bath
Operating
Concentration
Cr
­10,700
Process
Bath
Operating
Temperature
­
in
the
process
of
installing
temp.
Hex.
Cr
­
33
controls
Cu
­86
Withdrawal
and
Drainage
Time
Fe
­
156,000
Drainage
Boards
Pb
­
581
Drag­
Out
Tanks
­
Cd
line
has
dead
rinse
and
is
returned
to
plating
bath
Mg
­27,200
RINSE
WATER
Hg
­
ND
Improved
Rinsing
Efficiency
­
Countercurrent
Rinsing
Ni
­
106
Flow
Restrictors
Se
­
ND
Cd
­788
Se
­
ND
Mn
­3,300
Ag
­ND
Na
­8,200
Sn
­68
Zn
­262,000
CN
­
3,240
September
1998
52
F006
Benchmarking
Study
Table
13
(cont'd):
Facility­
Specific
Information
for
Chicago
Facilities
Facility
C4
Plating
Process
F006
Quantity
and
Management
Sample
Description
Cu/
Ni/
Cr
on
brass
Zn­
CN
~73
tons/
yr
C4­
01S
­
Sludge
from
lugger
box
Cu
(Alkaline)
Cd­
CN
under
filter
press:
fudge
consistency,
Dull
and
Bright
Ni
Sn­
acid
Recycle
(Horsehead)
cool,
chocolate­
brown
color,
cake
Ni/
Cr
on
steel
formed
into
1
½
inch
thick
layers,
Bright
dip
of
Cu
estimated
at
75%
water
Zn
phosphate
Chromating
of
Al
60/
40
(Sn/
Pb)
solder
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
C4
­
01S
Filtration
on
the
Tin,
Ni,
and
Cu
baths
Total
(mg/
kg)
TCLP
(mg/
l)
Carbon
Treatment
in
the
Ni
and
Cu
baths
Al
­41,000
As
­ND
Replenishment
Sb
­ND
Ba
­ND
Electrolytic
Dummying
for
Ni,
Cu,
Cd,
Zn,
Cr
As
­ND
Cd
­1.26
Cyanide
Bath
Carbonate
Freezing
Ba
­715
Cr
­
ND
Precipitation
­
occasionally
on
tins
Be
­37
Pb
­
ND
Monitoring
­
once/
wk
at
minimum
Bi
­
ND
Hg
­ND
Purer
Anodes
and
Bags
Cd
­6,040
Se
­
ND
Hexavalent
for
trivalent
Chrome
in
clear
chromate
conversion
coating
Ca
­63,500
Ag
­ND
Solvent
Degreasing
alternatives:
hot
alkaline
cleaning,
electrocurrent,
&
Cr
­50,800
ultrasonic
Hex.
Cr
­
28
Alkaline
Cleaners
­
skimming
Cu
­9,940
Waste
reduction
study
conducted
Fe
­
124,000
Pre­
inspect
parts
to
prevent
processing
of
obvious
rejects
Pb
­
2,320
Perform
regular
maintenance
of
racks/
barrels
Mg
­49,500
Remove
anodes
from
bath
when
they
are
idle
Mn
­1,690
Use
process
baths
to
maximum
extent
possible
Hg
­
ND
Have
written
procedures
for
bath
make­
up
and
additions
Ni
­
11,300
Waste
stream
segregation
of
contact
and
non­
contact
wastewaters
Se
­
ND
Strict
chemical
inventory
control
Ag
­110
Evaluation
of
recycling
alternatives
Na
­4,440
DRAG­
OUT
REDUCTION/
RECOVERY
Zn
­176,000
Process
Bath
Operating
Concentration
and
Temperature
CN
­
3,740
Wetting
Agents
­
add
to
Ni
baths
Workpiece
Positioning
Withdrawal
and
Drainage
Time
and
Boards
Drag­
Out
Tanks
Electrowinning
for
Cd
RINSE
WATER
Spray
Rinse/
Rinse
Water
Agitation
­
some
tin
Countercurrent
Rinsing
­
2
and
3­
stage
Recycle/
Recovery
of
Rinse
Water
Recycle/
Recovery
of
Solvents
Eliminate
rinsewaters
to
waste
treatment
Manually
turning
off
rinsewater
when
not
in
use
Flow
restrictors
OTHER
Conduct
employee
education
for
P2
Housekeeping
­
QA
manager
controls
bath
chemistry
Sn
­36,200
September
1998
53
F006
Benchmarking
Study
Table
13
(cont'd):
Facility­
Specific
Information
for
Chicago
Facilities
Facility
C6
Plating
Process
F006
Quantity
and
Management
Sample
Description
Electroless
Ni
Ni
~15
tons/
yr
C6­
01
­
Sludge
from
plant
1;
sludge
Cu­
CN
Sn
mixed
with
absorbent
called
Zn
Ag­
CN
Recycle
(World
Resources)
Absorbex;
black
and
greenish­
gray;
Au­
CN
sludge
is
2
days
old
C6­
02
­
Sludge
from
superbag
in
plant
2;
green/
gray
and
brown;
clay
consistency;
sludge
generated
the
previous
week
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
C6
­
01
C6­
02
Filtration
­
continuous
Total
(mg/
kg)
Total
(mg/
kg)
Carbon
Treatment
­
periodically
Al
­5,350
Al
­
1,740
Purified
Water
­
for
Ni
Sb
­207
Sb
­
ND
Electrolytic
Dummying
­
for
Ni
As
­ND
As
­ND
Cyanide
Bath
Carbonate
Freezing
­
annually
Ba
­119
Ba
­
54
Precipitation
­
periodically
Be
­20
Be
­
10
Monitoring
­
weekly
to
outside
labs/
daily­
weekly
internally
Bi
­
ND
Bi
­
35
Housekeeping
­
lab
controls
bath
chemistry
Cd
­51
Cd
­
ND
Purer
Anodes
and
Bags
­
Silver
99.998%;
Gold
99.999%;
Nickel
98%
Ca
­63,000
Ca
­
13,000
Hexavalent
Chrome
Alternatives
­
Trivalent
chrome
for
clear/
blue
bright
Cr
­698
Cr
­
59,400
conversion
coatings
Hex.
Cr
­
7
Hex.
Cr
­
174
Solvent
Degreasing
Alternatives
­
Hot
Alkaline
Cleaning
and
Electrocurrent
Cu
­37,500
Cu
­
21,900
Alkaline
Cleaners
­
Skimming
Fe
­
24,600
Fe
­
47,000
DRAG­
OUT
REDUCTION/
RECOVERY
Mg
­53,400
Mg
­
6,100
Wetting
Agents
­
present
in
formula
from
vendor
Mn
­799
Mn
­
746
Withdrawal
and
Drainage
Time
­
Training
Hg
­
ND
Hg
­
ND
Drainage
Boards
Ni
­
77,100
Ni
­
21,500
Drag­
Out
Tanks
(Dead
Rinse)
Se
­
ND
Se
­
ND
Electrowinning
­
Gold
(periodic);
Silver
(continuous)
Ag
­272
Ag
­
32
Nickel
drag
out
sent
back
to
plating
bath
Na
­37,200
Na
­
89,200
RINSE
WATER
Zn
­24,400
Zn
­
81,400
Improved
Rinsing
Efficiency
CN
­
373
CN
­
240
Spray
Rinse/
Rinse
Water
Agitation
(Air
Spargers)
Countercurrent
Rinsing
­
2­
stage
TCLP
(mg/
l)
TCLP
(mg/
l)
Flow
Restrictors
As
­ND
As
­
ND
Pb
­
326
Pb
­
109
Sn
­9,740
Sn
­
12,100
Ba
­ND
Ba
­
ND
Cd
­ND
Cd
­
ND
Cr
­
ND
Cr
­
0.08
Pb
­
ND
Pb
­
ND
Hg
­0.002
Hg
­
ND
Se
­
ND
Se
­
ND
Ag
­
0.29
Ag
­
ND
September
1998
54
F006
Benchmarking
Study
Table
13
(cont'd):
Facility­
Specific
Information
for
Chicago
Facilities
Facility
C7
Plating
Process
F006
Quantity
and
Management
Sample
Description
Plant
1:
Plant
2:
~
65
tons/
yr
C7­
01S
­
From
supersack;
reddishAg
(CN)
Sn
(Dull)
brown
and
some
greenish­
gray,
Cu­
CN
Ni
(Sulfamate)
Recycle
(World
Resources)
muddy/
clayey
consistency
Acid­
Sn
Cu­
CN
C7­
02S
­
from
supersack,
big
Electroless
Ni
Sn
(Bright
Acid)
chunks,
very
hard
but
breakable,
Cu­
acid
Solder
red­
brown,
ambient
temperature,
smells
like
paint
­Plant
2
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
C7
­
01S
C7­
02S
Filtration
­
removes
organics
Total
(mg/
kg)
Total
(mg/
kg)
Carbon
Treatment
Al
­4,510
Al
­493
Purified
Water
­
DI
Sb
­ND
Sb
­
ND
Electrolytic
Dummying
As
­ND
As
­
ND
Precipitation
Ba
­20
Ba
­
27
Monitoring
­
at
least
weekly
Be
­ND
Be
­
ND
Purer
Anodes
and
Bags
­
99.9%
Bi
­
ND
Bi
­54
Solvent
Degreasing
Alternatives
­
Hot
Alkaline
Cleaning
and
Electrocurrent
Cd
­9
Cd
­
ND
Alkaline
Cleaners
­
Skimming
for
oil
Ca
­11,000
Ca
­
16,100
DRAG­
OUT
REDUCTION/
RECOVERY
Hex.
Cr.
­
ND
Hex.
Cr
­
ND
Process
Bath
Operating
Concentration
Cu
­21,400
Cu
­
23,800
Process
Bath
Operating
Temperature
Fe
­
1,510
Fe
­
131,000
Wetting
Agents
­
in
Brightener
Pb
­
47
Pb
­
2,080
Workpiece
Positioning
Mg
­336,000
Mg
­
242,000
Withdrawal
and
Drainage
Time
Mn
­103
Mn
­
523
Silver
rinse
­
Either
electrowinning
or
electrodialysis
Hg
­
ND
Hg
­
ND
RINSE
WATER
Se
­
ND
Se
­
ND
Spray
Rinse/
Rinse
Water
Agitation
­
Air
agitation
Ag
­253
Ag
­
ND
Countercurrent
Rinsing
­
2­
stage
on
most
lines
Na
­1,060
Na
­
1,230
Flow
Restrictors
Sn
­9,680
Sn
­
36,600
Cr
­161
Cr
­
127
Ni
­
27,100
Ni
­
10,100
Zn
­1,070
Zn
­
2,060
CN
­
2,480
CN
­
725
TCLP
(mg/
l)
TCLP
(mg/
l)
As
­ND
As
­
ND
Ba
­ND
Ba
­
ND
Cd
­ND
Cd
­
ND
Cr
­
ND
Cr
­
ND
Pb
­
ND
Pb
­
ND
Hg
­ND
Hg
­
ND
Se
­
ND
Se
­
ND
Ag
­0.07
Ag
­
ND
September
1998
55
F006
Benchmarking
Study
Table
13
(cont'd):
Facility­
Specific
Information
for
Chicago
Facilities
Facility
C8
Plating
Process
F006
Quantity
and
Management
Sample
Description
Zn
plating
~135
tons/
yr
C8­
01
­
Sludge
from
supersack
at
Acid
Chloride
continuous
filter
press;
soft
and
Alkaline
­
non
CN
BFI
landfill
moist;
waxy;
green/
gray
Chromating
C8­
02
­
Sludge
from
batch
tank
filter
press;
clay
consistency;
green/
gray;
outer
layer
has
rust
color
probably
due
to
iron
oxidation.

Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
C8
­
01
C8­
02
Continuous
Filtration
Total
(mg/
kg)
Total
(mg/
kg)
Carbon
Treatment
­
intermittently
Al
­204
Al
­153
Replenishment
­
bleed
off
growth
Sb
­ND
Sb
­
ND
Electrolytic
Dummying
­
as
needed
As
­ND
As
­
ND
Monitoring
­
daily
Ba
­58
Ba
­
45
Purer
Anodes
and
Bags
­
99.99%
Zinc
Be
­ND
Be
­
ND
Hexavalent
Chrome
Alternatives
­
Trivalent
clear
chrome
Bi
­
ND
Bi
­
ND
Nonchelated
Process
Chemistries
Cd
­11
Cd
­
ND
Non­
Cyanide
Process
Chemicals
­
Dropped
Cyanide
plating
in
1993
Ca
­15,000
Ca
­
4,040
Solvent
Degreasing
Alternatives:
Hot
alkaline
cleaning
and
Electrocurrent
Cr
­11,000
Cr
­
59,000
Alkaline
Cleaners
­
Skimming
Hex.
Cr
­160
Hex.
Cr
­
29
DRAG­
OUT
REDUCTION/
RECOVERY
Fe
­
24,600
Fe
­
56,300
Process
Bath
Operating
Concentration
Pb
­
30
Pb
­
49
Process
Bath
Operating
Temperature
Mg
­10,800
Mg
­
1,340
Wetting
Agents
Mn
­438
Mn
­
569
Workpiece
Positioning
Hg
­
ND
Hg
­
ND
Withdrawal
and
Drainage
Time
Ni
­
452
Ni
­
257
Spray
or
Fog
Rinses
Se
­
ND
Se
­
ND
Drainage
Boards
Ag
­109
Ag
­
112
Drag­
Out
Tanks
­
plating
baths
Na
­10,400
Na
­
56,400
Portion
of
drag
out
returned
to
plating
bath
Sn
­ND
Sn
­
ND
RINSE
WATER
CN
­
3
CN
­
285
Improved
Rinsing
Efficiency:
Spray
Rinse/
Rinse
Water
Agitation
Countercurrent
Rinsing
where
feasible
TCLP
(mg/
l)
TCLP
(mg/
l)
Flow
Restrictors
As
­ND
As
­
ND
Cu
­401
Cu
­
120
Zn
­460,000
Zn
­
345,000
Ba
­ND
Ba
­
0.80
Cd
­0.02
Cd
­
ND
Cr
­
0.04
Cr
­
ND
Pb
­
ND
Pb
­
ND
Hg
­ND
Hg
­
ND
Se
­
ND
Se
­
ND
Ag
­ND
Ag
­
ND
September
1998
56
F006
Benchmarking
Study
Table
13
(cont'd):
Facility­
Specific
Information
for
Chicago
Facilities
Facility
C9
Plating
Process
F006
Quantity
and
Management
Sample
Description
Zn­
acid
plating
230­
300
tons/
yr
C9­
01
­
Dried
sludge
from
Cd­
acid
plating
supersack
after
sludge
drier,
warm,
Cu/
Ni
Recycle
(Envirite)
dark
chocolate­
brown
color,
Chromating
granular
to
powdery
consistency
Phosphating
C9­
02
­
Sludge
from
a
supersack
dated
the
previous
week,
dry/
moist
mix,
reddish­
brown,
chunky
and
powdery,
ambient
air
temp
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
C9
­
01
C9­
02
Filtration
­
Zn
baths
as
needed
Total
(mg/
kg)
Total
(mg/
kg)
Carbon
Treatment
­
as
needed
Al
­298
Al
­311
Purified
Water
­
DI
for
chromates
Sb
­ND
Sb
­
ND
Precipitation
­
Fe
removal
in
Zn
baths,
combined
with
filtration
As
­ND
As
­
ND
Monitoring
­
daily
Ba
­578
Ba
­
789
Housekeeping
­
manager
authorizes
bath
additions/
changes
Be
­ND
Be
­
ND
Purer
Anodes
and
Bags
­
min.
99.9%
Bi
­
ND
Bi
­
ND
Hexavalent
Chrome
Alternatives
­
Trivalent
chrome
for
clear
chromates
Cd
­
27,600
Cd
­
13,800
Nonchelated
Process
Chemistries
Ca
­
8,630
Ca
­
17,000
Non­
Cyanide
Process
Chemicals
­
No
CN
Cr
­
40,400
Cr
­
32,200
Solvent
Degreasing
Alternatives:
Hot
alkaline
cleaning
and
Electrocurrent
Hex.
Cr
­6
Hex.
Cr
­11
DRAG­
OUT
REDUCTION
Fe
­
185,000
Fe
­
257,000
Wetting
Agents
Pb
­
5
Pb
­
9
Workpiece
Positioning
Mg
­2,120
Mg
­
4,190
Withdrawal
and
Drainage
Time
Mn
­2,130
Mn
­
2,950
Drainage
Boards
Hg
­
ND
Hg
­
ND
Drag
out
Tanks
­
on
rinses
only
Ni
­
707
Ni
­
2,730
RINSE
WATER
Ag
­225
Ag
­
173
Countercurrent
Rinsing
­
2
­
3­
stage
Na
­7,840
Na
­
11,600
Flow
Restrictors
Sn
­ND
Sn
­
ND
Recycle/
Recovery
Rinse
Water
Zn
­115,000
Zn
­
175,000
Cu
­
388
Cu
­
4,230
Se
­
ND
Se
­
NA
CN
­
2.6
CN
­
1.6
TCLP
(mg/
l)
TCLP
(mg/
l)
As
­ND
As
­
ND
Ba
­ND
Ba
­
ND
Cd
­144
Cd
­
15.8
Cr
­
0.14
Cr
­
0.02
Pb
­
ND
Pb
­
ND
Hg
­ND
Hg
­
ND
Se
­
ND
Se
­
ND
Ag
­ND
Ag
­
ND
September
1998
57
F006
Benchmarking
Study
Table
13
(cont'd):
Facility­
Specific
Information
for
Chicago
Facilities
Facility
C13
Plating
Process
F006
Quantity
and
Management
Sample
Description
Cu­
CN
Ni
3
tons/
yr
C13­
01
­
Sludge
from
filter
press
Au­
CN
Ag­
CN
bag;
30­
day
old
sludge;
consistency
Sn
Recycle
(United
Refining)
of
cookies;
chocolate­
brown
in
color
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTION
C13
­
01
Filtration
­
as
needed
Total
(mg/
kg)
TCLP
(mg/
l)
Carbon
Treatment
­
as
needed
(rarely)
Al
­564
As
­ND
Purified
Water
Sb
­90
Ba
­ND
Electrolytic
Dummying
­
Silver
uses
As
­ND
Cd
­ND
Monitoring
­
once
a
month/
weekly
additions
Ba
­143
Cr
­
ND
Housekeeping
­
QC
program
to
calculate
usage
Be
­7
Pb
­
ND
Purer
Anodes
and
Bags
­
Silver
99.99%
Bi
­
ND
Hg
­
0.011
Solvent
Degreasing
Alternatives
­
Electrocurrent
Cd
­22
Se
­
ND
DRAG­
OUT
REDUCTION/
RECOVERY
Cr
­73
Wetting
Agents
Hex.
Cr
­4
Withdrawal
and
Drainage
Time
­
Training
Cu
­91,600
Drag­
Out
Tanks
(Dead
Rinse)
Fe
­
69,000
Ion
Exchange
for
Gold
Pb
­
189
Electrowinning
for
Silver
­
commercial
unit
Mg
­10,800
RINSE
WATER
Hg
­
ND
Countercurrent
Rinsing
­
2­
stage
for
tin
Ni
­
9,010
Flow
Restrictors
Se
­
ND
Recycling/
Recovery
of
Solvents
(sent
to
off­
site
recovery)
Ag
­351
Ca
­83,900
Ag
­0.85
Mn
­343
Na
­1,420
Sn
­41,200
Zn
­3,590
CN
­
3,310
September
1998
58
F006
Benchmarking
Study
Table
13
(cont'd):
Facility­
Specific
Information
for
Chicago
Facilities
Facility
C14
Plating
Process
F006
Quantity
and
Management
Sample
Description
Zn­
CN
730
tons/
yr
C14­
01
­
Sludge
from
the
Zn­
Ni
(CN)
luggerbox;
orange­
brown;
dry;
Zn
Ni
(Alkaline?)
Recycle
(Horsehead
and
Envirite)
chunks
the
size
of
dimes
and
smaller.
Carbonate
from
carbonate
freezing
of
Ni
bath
combined
with
dewatered
sludge
sent
to
driers
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
C14
­
01
Filtration
­
continuous
(paper/
cartridges)
for
alkaline­
Zn­
Ni
and
alkaline­
Zn
Total
(mg/
kg)
TCLP
(mg/
l)
Purified
Water
­
for
some
applications
Al
­390
As
­ND
Cyanide
Bath
Carbonate
Freezing
for
Zn­
CN
and
Zn­
alkaline­
Ni
Sb
­ND
Ba
­ND
Monitoring
­
daily
or
every­
other
day
As
­ND
Cd
­0.06
Housekeeping
­
use
assigned
personnel
for
chemical
additions
Ba
­48
Cr
­
0.02
Purer
Anodes
and
Bags
Be
­ND
Pb
­
ND
Hexavalent
Chrome
Alternatives
­
Cr
in
blue
dip
process
Bi
­
ND
Hg
­ND
+3
Nonchelated
Process
Chemistries
­
no
chelated
cleaners
Cd
­31
Se
­
ND
Solvent
Degreasing
Alternatives
­
hot
alkaline
cleaning
and
electrocurrent
Ca
­18,200
Ag
­ND
(no
solvents
in
process)
Cr
­24,200
Alkaline
Cleaners
­
Skimming
grease
and
oil
(investigating
filtration
and
Hex.
Cr
­18
centrifuging)
Cu
­220
Stricter
conformance
with
line
preventative
maintenance
schedule
Fe
­
129,000
Stricter
conformance
with
SPC
procedures
Pb
­
149
Strict
chemical
inventory
control
Mg
­5,360
Perform
routine
bath
analysis
Mn
­858
Maintain
bath
analysis/
addition
logs
Hg
­
ND
Have
written
procedures
for
bath
make­
up
and
additions
Ni
­
128
Remove
anodes
from
bath
when
they
are
idle
Se
­
ND
Regularly
retrieve
fallen
parts/
racks
from
tanks
Ag
­87
Perform
regular
maintenance
of
racks/
barrels
Na
­16,500
Pre­
inspect
parts
to
prevent
processing
of
obvious
rejects
Sn
­ND
Evaluate
recycling
alternatives
Zn
­375,000
Research
alternative
plating
technologies
CN
­
3,920
DRAG­
OUT
REDUCTION/
RECOVERY
Process
Bath
Operating
Concentration
and
Temperature
­
Daily
Wetting
Agents
­
rinsate
chemicals;
acid­
inhibitor
in
pickling
acids
Workpiece
Positioning
Withdrawal
and
Drainage
Time
Electrodialysis
for
black
chromate
RINSE
WATER
Spray
Rinse/
Rinse
Water
Agitation
Countercurrent
Rinsing
­
2­
stage
in
most
processes
Flow
Restrictors
Recycle
rinse
waters
­
treated
wastewaters
recycled
as
needed
Drip
shields
between
tanks
Lower
bath
concentration
Manually
turning
off
rinsewater
when
not
in
use
Establish
a
preventative
maintenance
program
for
tanks
September
1998
59
F006
Benchmarking
Study
Table
14:
Summary
of
Chicago
F006
Analytical
Data
Constituent
#
Samples
#
Non
Detects
#
Samples
Above
Method
Quantitation
Limit
Total
Metals
Concentration
(mg/
kg)

Aluminum
15
0(
0%)
15(
100%)

Antimony
15
13(
87%)
2(
13%)

Arsenic
15
1(
7%)
14(
93%)

Barium
15
0(
0%)
15(
100%)

Beryllium
15
11(
73%)
4(
27%)

Bismuth
15
11(
73%)
4(
27%)

Cadmium
15
3(
20%)
12(
80%)

Calcium
15
0(
0%)
15(
100%)

Chromium
15
0(
0%)
15(
100%)

Copper
15
0(
0%)
15(
100%)

Iron
15
0(
0%)
15(
100%)

Lead
15
0(
0%)
15(
100%)

Magnesium
15
0(
0%)
15(
100%)

Manganese
15
0(
0%)
15(
100%)

Mercury
15
10(
67%)
5(
33%)

Nickel
15
0(
0%)
15(
100%)

Selenium
15
15(
100%)
0(
0%)

Silver
15
2(
13%)
13(
87%)

Sodium
15
0(
0%)
15(
100%)

Tin
15
5(
33%)
10(
67%)

Zinc
15
0(
0%)
15(
100%)

TCLP
(
mg/
l)

Arsenic
15
15(
100%)
0(
0%)

Barium
15
14(
93%)
1(
7%)

Cadmium
15
6(
40%)
9(
60%)

Chromium
15
7(
47%)
8(
53%)

Lead
15
15(
100%)
0(
0%)

Mercury
15
12(
80%)
3(
20%)

Selenium
15
15(
100%)
0(
0%)

Silver
15
11(
7%)
4(
93%)

General
Chemistry
(mg/
kg)

Chloride
15
0(
0%)
15(
100%)

Fluoride
15
5(
33%)
10(
67%)

Chromium,
hexavalent
15
2(
13%)
13(
87%)

Total
Cyanide
15
0(
0%)
15(
100%)

Amenable
Cyanide
15
0(
0%)
15(
100%)

Percent
Solids
15
0(
0%)
15(
100%)
September
1998
60
F006
Benchmarking
Study
Table
15:
Detailed
Chicago
Analytical
Data
Constituent
CAS
No.
C1­
01
C2­
01
C2­
02
C3­
01S
C4­
01S
C6­
01
C6­
02
Total
Metals
­
Methods
6010A,
7471A,
7060A,
7421,
7740
mg/
kg
Aluminum
7429905
4,390
45,900
27,900
597
41,000
5,350
1,740
Antimony
7440360
ND
ND
ND
ND
ND
207
ND
Arsenic
7440382
ND
ND
ND
39
ND
ND
ND
Barium
7440393
1,080
65
76
167
715
119
54
Beryllium
7440417
ND
ND
ND
ND
37
20
10
Bismuth
7440699
ND
66
19
ND
ND
ND
35
Cadmium
7440439
17,300
3,740
4,440
788
6,040
51
ND
Calcium
7440702
47,400
32,900
26,400
30,200
63,500
63,000
13,000
Chromium
7440473
83,000
9,300
18,700
10,700
50,800
698
59,400
Copper
7440508
40,000
1,210
1,600
86
9,940
37,500
21,900
Iron
7439896
27,800
29,500
40,400
156,000
124,000
24,600
47,000
Lead
7439921
10,300
170
161
581
2,320
326
109
Magnesium
7439954
51,100
161,000
111,000
27,200
49,500
53,400
6,100
Manganese
7439965
332
1,240
1,010
3,300
1,690
799
746
Mercury
7439976
ND
ND
0
ND
0
0
0
Nickel
7440020
98,800
1,640
7,390
106
11,300
77,100
21,500
Selenium
7782492
ND
ND
ND
ND
ND
ND
ND
Silver
7440224
280
27
88
ND
110
272
32
Sodium
7440235
22,100
29,600
33,100
8,200
4,440
37,200
89,200
Tin
7440315
13,800
1,270
2,090
68
36,200
9,740
12,100
Zinc
7440666
17,100
62,000
89,200
262,000
176,000
24,400
81,400
TCLP
Metals
­
Methods
1311,
6010A,
7470A
mg/
L
Arsenic
7440382
ND
ND
ND
ND
ND
ND
ND
Barium
7440393
ND
ND
ND
0.7
ND
ND
ND
Cadmium
7440439
1.0
0.19
0.16
1.57
1.26
ND
ND
Chromium
7440473
2.8
0.08
0.09
ND
ND
ND
0.08
Lead
7439921
ND
ND
ND
ND
ND
ND
ND
Mercury
7439976
0.001
ND
ND
ND
ND
0.002
ND
Selenium
7782492
ND
ND
ND
ND
ND
ND
ND
Silver
7440224
3.8
ND
ND
ND
ND
0.29
ND
Table
15:
Detailed
Chicago
Analytical
Data
Constituent
CAS
No.
C1­
01
C2­
01
C2­
02
C3­
01S
C4­
01S
C6­
01
C6­
02
September
1998
61
F006
Benchmarking
Study
General
Chemistry
­
Methods
300.0,
335.2,
335.1,
7195/
6010A
mg/
kg
Chloride
16887006
2,720
7430
59,800
5,980
959
2,140
322
Fluoride
16984488
166
4210
1180
ND
96.5
128
347
Chromium,
hex
18540299
1,190
53
11
33
28
7
174
Total
Cyanide
57125
1,800
3.3
0.8
3,240
3,740
373
240
Amen.
Cyanide
E­
10275
110
**
6.2
**
2.6
**
4,940
**
5,340
**
471
**
354
Percent
Solids
57.0
13.5
44
15.3
14.7
25
30.3
Notes:
*
All
results
reported
on
a
dry­
weight
basis.
**
Reported
value
is
the
concentration
of
cyanide
after
chlorination.
Since
this
value
is
greater
than
the
total
cyanide
result,
a
value
for
the
cyanide
amenable
to
chlorination
cannot
be
calculated.
ND
=
Not
detected
September
1998
62
F006
Benchmarking
Study
Table
15:
Detailed
Chicago
Analytical
Data
Constituent
CAS
No.
C7­
01S
C7­
02S
C8­
01
C8­
02
C9­
01
C9­
02
C13­
01
C14­
01
Total
Metals
­
Methods
6010A,
7471A,
7060A,
7421,
7740
mg/
kg
Aluminum
7429905
4,510
493
204
153
298
311
564
390
Antimony
7440360
ND
ND
ND
ND
ND
ND
90
ND
Arsenic
7440382
ND
ND
ND
ND
ND
ND
ND
ND
Barium
7440393
20
27
58
45
578
789
143
48
Beryllium
7440417
ND
ND
ND
ND
ND
ND
7
ND
Bismuth
7440699
ND
54
ND
ND
ND
ND
ND
ND
Cadmium
7440439
9
ND
11
ND
27,600
13,800
22
31
Calcium
7440702
11,000
16,100
15,000
4,040
8,630
17,000
83,900
18,200
Chromium
7440473
161
127
11,000
59,000
40,400
32,200
73
24,200
Copper
7440508
21,400
23,800
401
120
388
4,230
91,600
220
Iron
7439896
1,510
131,000
24,600
56,300
185,000
257,000
69,600
129,000
Lead
7439921
47
2,080
30
49
5
9
189
149
Magnesium
7439954
336,000
242,000
10,800
1,340
2,120
4,190
10,800
5,360
Manganese
7439965
103
523
438
569
2,130
2,950
343
858
Mercury
7439976
ND
ND
ND
ND
ND
ND
0
ND
Nickel
7440020
27,100
10,100
452
257
707
2,730
9,010
128
Selenium
7782492
ND
ND
ND
ND
ND
ND
ND
ND
Silver
7440224
253
ND
109
112
225
173
351
87
Sodium
7440235
1,060
1,230
10,400
56,400
7,840
11,600
1,420
16,500
Tin
7440315
9,680
36,600
ND
ND
ND
ND
41,200
ND
Zinc
7440666
1,070
2,060
460,000
345,000
115,000
175,000
3,590
375,000
TCLP
Metals
­
Methods
1311,
6010A,
7470A
mg/
L
Arsenic
7440382
ND
ND
ND
ND
ND
ND
ND
ND
Barium
7440393
ND
ND
ND
0.80
ND
ND
ND
ND
Cadmium
7440439
ND
ND
0.02
ND
144
15.8
ND
0.06
Chromium
7440473
ND
ND
0.04
ND
0.14
0.02
ND
0.02
Lead
7439921
ND
ND
ND
ND
ND
ND
ND
ND
Mercury
7439976
ND
ND
ND
ND
ND
ND
0.011
ND
Selenium
7782492
ND
ND
ND
ND
ND
ND
ND
ND
Silver
7440224
0.07
ND
ND
ND
ND
ND
0.85
ND
General
Chemistry
­
Methods
300.0,
335.2,
335.1,
7195/
6010A
mg/
kg
Chloride
16887006
421
594
11,300
70,100
2,380
7,250
2,380
1,270
Table
15:
Detailed
Chicago
Analytical
Data
Constituent
CAS
No.
C7­
01S
C7­
02S
C8­
01
C8­
02
C9­
01
C9­
02
C13­
01
C14­
01
September
1998
63
F006
Benchmarking
Study
Fluoride
16984488
42.4
17.5
ND
ND
343
ND
ND
416
Chromium,
hex.
18540299
ND
ND
160
29
6
11
4
18
Total
Cyanide
57125
2,480
725
3
285
2.6
1.6
3,310
3,920
Amen.
Cyanide
E­
10275
**
4,050
**
1,100
**
4.3
285
**
3.5
**
3.1
250
830
Percent
Solids
47.4
41.1
15.8
23.5
45.7
41.4
32.8
40.4
Notes:
*
All
results
reported
on
a
dry­
weight
basis.
**
Reported
value
is
the
concentration
of
cyanide
after
chlorination.
Since
this
value
is
greater
than
the
total
cyanide
result,
a
value
for
the
cyanide
amenable
to
chlorination
cannot
be
calculated.
ND
=
Not
detected
September
1998
64
F006
Benchmarking
Study
3.
Phoenix
Benchmarking
Study
This
section
provides
a
detailed
presentation
of
data
gathered
in
the
Phoenix
Benchmarking
Study,
including
a
characterization
of
plating
processes,
pollution
prevention
and
recycling
practices,
F006
characteristics,
and
site
specific
variations
in
the
generation
and
management
of
F006
for
ten
facilities
in
Phoenix.
Table
16
is
the
facility
selection
matrix
used
to
select
10
facilities
from
13
candidates.
Table
17
presents
information
collected
for
each
facility
in
the
study.
Table
18
summarizes
the
results
of
the
laboratory
analyses
of
F006
data
and
Table
19
presents
detailed
laboratory
analysis
results
for
each
facility.

The
10
Phoenix
facilities
generate
approximate
1428
tons
of
F006
per
year.
Eight
facilities
recycle
their
waste
and
two
facilities
send
their
waste
to
be
landfilled.
Fifteen
F006
laboratory
samples
were
gathered.
September
1998
65
F006
Benchmarking
Study
Table
16:
Phoenix
Metal
Finishing
Facility
Selection
Matrix
Selection
Criteria
P
1
P
2
P
3
P
4
P
5
P
6
P
7*
P8
P
9
P
10
P
11
P
12*
P13
Status
Selected
Selected
Selected
Selected
Selected
Selected
Alternate
Selected
Selected
Eliminated
Selecte
Alternate
Selected
d
Type:
Captive/
Job
Captive
Job
Job
Captive
Captive
Job
Job
Job
Captive
Job
Job
Job
Captive
Size
35
200
75
10
24
175
105
150
75­
100
165
47
450
70
Treatment
Technology
CFR,
IX,
IX,
CFR
CFR,
IX,
CFR,
ED
CFR,
CFR
IX
for
Ag
CF2,
IX,
MS
CFR,
MS,
CFR,
IX
IX,
MS
ER
Diagn.
RO
DOR
DOR
FM
Onsite
Recycle
water
water
No
No
No
Off­
spec
No
No
water
No
IX
closed
Cu­
water
in
reuse
process
loop
bearing
drag­
out
foil
from
IX;
tanks
EW
Landfill
No
No
No
Yes
Yes
No
No
No
No
No
No
No
No
Main
Mgmt.
Method
Filter
Press
Filter
Filter
Filter
Press
Filter
Filter
Filter
Press
Filter
Filter
Filter
Filter
Filter
Filter
Press
Press
Press
Press;
Press
Press
Press
Press
Press
Press
Drier
(not
in
use)

Finishing
Processes
Cu,
Ni,
Au,
Cr
Cu­
CN
Cu,
Ag,
Cu­
CN,
Cu
Cr,
Ag,
Cu­
foil,
Anodize,
E­
Cu;
Cu/
Ag/
Cu,
Tin,
Acid­
Cu,
HCl­
Cu
Acid­
Cu,
Tin
Cd­
CN
Cr,
E­
Ni,
strip,
Ni,
Cu
on
hard
CR
Chem­
Cu;
black
Ni
Tin­
Pb,
Tin,
Tin­
etching
Ni,
AuAnodiz
Anodiz,
Etching,
E­
steel/
Ni/
plating,
Film­
Cr
on
oxide;
Ni,
Au­
Pb,
Tin­
CN
Phosphat.
Cu/
Ag/
Ni,
Ni
Cr
brass­
CN
Ti,
Al,
Fe,
Au­
CN;
CN
Ni,
NiCC
Ni
Ni
(produces
Cr,
Ag,
Ni
Ni
Au(
CN)
Cu­
foil)

*
Facility
operates
as
a
metal
finisher
and
not
an
electroplater
but
manages
sludge
as
F006.

Key:
MS
Material
Substitution
ER
Electrowinning
Ni/
Cr
Nickel
chromium
Electroplate
on
steel
Alk/
PPT
Alkaline
precipitation
FM
Flow
Meter
Cu/
Ni/
Cr
Copper
nickel
chromium
on
nonferrous
IX
Ion
exchanges
DOR
Drag­
Out
Reduction
Cu
Copper/
PC
bands
Ultra
Ultrafiltration/
Microfiltration
CC
Chrome
conversions
HCr
Hard
chromium
on
steel
CFR
Counterflow
rinse
Ni
Nickel
electroplating
Cu­
CN
Copper
cyanide
electroplating
EMR
Electrolytic
metal
recovery
Au
Gold
electroplating
Cd­
CN
Cadmium
cyanide
electroplating
ED
Electrodialysis
E­
Ni
Electroless­
Nickel
electroplating
Ag
Silver
electroplating
RO
Reverse
osmosis
Zn/
Fe
Zinc
electroplate
on
steel
September
1998
66
F006
Benchmarking
Study
Table
17:
Facility­
Specific
Information
for
Phoenix
Facilities
Facility
P1
Plating
Process
F006
Quantity
and
Management
Sample
Description
Acid
Cu
Electroless
Ni
~445
tons/
yr
P1­
01
­
collected
from
roll­
off,
Au­
CN
Electroless
Cu
includes
sludge
generated
from
Tin­
Pb
Recycle
(World
Resources)
separate
alkaline
etch
batch
treatment
press
P1­
02
­
composite
of
sludge
collected
from
two
roll­
offs
containing
sludge.

Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
P1
­
01
P1
­
02
Filtration
Total
(mg/
kg)
Total
(mg/
kg)
Carbon
treatment
Al
­
3,420
Al
­
44,700
Bath
replenishment
Sb
­
ND
Sb
­
ND
Purified
water
­
utilize
Reverse
Osmosis
(RO)
and
Electrodialytic
Removal
As
­
2
As
­
8
(EDR)
Ba
­
6
Ba
­
22
Electrolytic
dummying
Bi
­
ND
Bi
­
ND
Monitoring
­
90%
of
baths
changed
via
throughput
­
some
constant
Cd
­
ND
Cd
­
ND
feed/
bleed
Ca
­
15,100
Ca
­
15,300
Housekeeping
via
checklists
Cr
­
10
Cr
­
23
Drag­
in
reduction
­
drip
boards/
rack
orientation
Hex.
Cr
­
ND
Hex.
Cr
­
ND
Purer
anodes
and
bags
­
currently
using
purest
level
per
specifications
Cu
­
7,690
Cu
­
28,100
Facility
has
explored
electrowinning
Cu
Fe
­
5,050
Fe
­
4,020
Solvent
degreasing
alternatives
­
currently
use
alkaline/
aqueous
Pb
­
2,590
Pb
­
194
DRAG­
OUT
REDUCTION/
RECOVERY
Mn
­
101
Mn
­
288
Wetting
agents
­
contained
in
some
chemistries
Hg
­
ND
Hg
­
ND
Workpiece
positioning
­
some
racks
set
at
angle
Ni
­
3,080
Ni
­
4,450
Withdrawal
and
drainage
time
­
increased
hang
time
Se
­
ND
Se
­
ND
Spray
or
fog
rinses
­
all
horizontal
equipment
Ag
­
8
Ag
­
22
Drainage
boards
­
automated
line
equipped
w/
drainage
boards
that
move
Na
­
4,050
Na
­
4,780
w/
racks
Sn
­
2,370
Sn
­
1,710
Drag­
out
tanks
­
replenish
baths
with
drag­
out
tanks
Zn
­
57
Zn
­
190
Replenish
plating
baths
with
drag­
out
tanks
CN
­
ND
CN
­
ND
RINSEWATER
TCLP
(mg/
l)
TCLP
(mg/
l)
Spray
rinse/
rinse
water
agitation
­
air
agitation
in
most
cases
As
­
ND
As
­
ND
Increased
contact
time/
multiple
rinses
Ba
­
ND
Ba
­
ND
Countercurrent
rinsing
Cd
­
ND
Cd
­
ND
Flow
restrictors
­
horizontal
flow
sensors
­
flow
restrictors
on
most
rinses
Cr
­
ND
Cr
­
ND
Conductivity­
actuated
flow
control
­
rinse
after
micro­
etch
on
oxide
line
Pb
­
0.12
Pb
­
0.08
Recycling
of
rinse
water
via
a
closed
loop
system
for
etch
rinses
Hg
­
ND
Hg
­
ND
Mg
­
319,000
Mg
­
245,000
Se
­
ND
Se
­
ND
Ag
­
ND
Ag
­
ND
September
1998
67
F006
Benchmarking
Study
Table
17
(cont'd):
Facility­
Specific
Information
for
Phoenix
Facilities
Facility
P2
Plating
Process
F006
Quantity
and
Management
Sample
Description
Hard
chrome
Zinc
~40
tons/
yr
P2­
01
­
collected
directly
from
rollSulfuric
acid
phosphating
off,
brownish­
green
mixed
with
a
anodizing
Manganese
Recycle
(World
Resources)
white
and
green
layer
chromic
Acid
phosphating
anodizing
Chromate
Hard
anodizing
conversion
Electroless
Ni
coatings
Sulfamate
Ni
passivation
Cd­
CN
Cu­
CN
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
P2
­
01
Filtration
­
seals,
anodize,
sulfamate/
electroless
Ni,
Cu,
Cd
Total
(mg/
kg)
TCLP
(mg/
l)
Carbon
Treatment
on
CN
rinses,
periodically
on
sulfamate
nickel
Al
­72,300
As
­
ND
Replenishment
­
process
tanks
have
drag­
out
w/
replenishment
of
Cd,
Cu,
Sb
­
ND
Ba
­
ND
Cr,
anodize
As
­
12
Cd
­
ND
Purified
Water
­
RO/
DI,
not
all
rinse
tanks
use
purified
water
Ba
­
67
Cr
­
0.1
Electrolytic
Dummying
­
Woods
Ni,
strike,
sulfamate
Ni,
Cr
anodize,
Cr
Bi
­
71
Pb
­
0.12
plate,
Cu
Cd
­
77
Hg
­
ND
Precipitation
­
hard
Cr
­
BaCl2
precipitates
sulfate
Ca
­15,800
Se
­
ND
Monitoring
­
wet
lab/
computerized
cleaners­
chronological
Cr
­
25,700
Ag
­
ND
Drag­
in
Reduction
­
training
on
rinsing,
minimum
of
2
counterflow
rinses
Hex.
Cr
­
5
Purer
Anodes
and
Bags
­
already
employed
(Cd
99.999%)
­
all
highest
grade
Cu
­2,660
Ventilation/
Exhaust
Systems
­
Cr
scrubber
reused
for
evaporation
losses
Fe
­
13,600
Solvent
Degreasing
Alternatives
­
use
vapor
degreaser
­
not
using
Pb
­
1,160
perchloroethylene,
but
instead
a
brominated
solvent
Mg
­
198,000
Acid
Purification
­
chromic
acid
purification
(hard
chrome).
Uses
EcoTech
Mn
­
116
system
Hg
­
0.3
DRAG­
OUT
REDUCTION/
RECOVERY
Se
­
ND
Process
Bath
Operating
Concentration
­
chromic
acid
concentrations
have
Ag
­7
been
looked
at
to
reduce
drag­
out
­
limitations
due
to
specs
Na
­
15,800
Workpiece
positioning
­
racking
Sn
­171
Withdrawal
and
Drainage
Time
­
spraying
over
bath
Zn
­
251
Spray
or
Fog
Rinses
over
drag­
out
tanks
CN
­
ND
Spent
Plating
Solutions
­
Replenishment
RINSE
WATER
Spray
Rinse/
RinseWater
Agitation
­
air
agitation
in
some
tanks
Increased
Contact
Time/
Multiple
Rinses
Countercurrent
Rinsing
Flow
Restrictors
in
all
cases
Conductivity­
Actuated
Flow
Control
­
all
rinses
are
conductivity/
pH
controlled
via
lab
Rinse
Water
­
recycling/
recovery
of
CN
rinses
Ni
­
4,480
September
1998
68
F006
Benchmarking
Study
Table
17
(cont'd):
Facility­
Specific
Information
for
Phoenix
Facilities
Facility
P3
Plating
Process
F006
Quantity
and
Management
Sample
Description
Hard
chrome
Sulfamate
Ni
37
tons/
yr
P3­
01
­
taken
from
roll­
off,
blueCu
CN
Electroless
Ni
greenish
color
Ag­
CN
Bright
Ni
Recycle
(Word
Resources)
P3­
02
­
taken
from
same
roll­
off,
Sulfuric
anodizing
sample
collected
from
obviously
Chrome
anodizing
different
press
load
­
brownish­
green
in
color
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
P3
­
01
P3
­
02
Filtration
on
all
process
tanks
Total
(mg/
kg)
Total
(mg/
kg)
Carbon
treatment
used
in
regular
filters
Al
­
76,100
Al
­
74,500
Replenishment
Sb
­
ND
Sb
­
ND
Purified
water
­
RO/
DI
As
­
11
As
­
12
Electrolytic
Dummying
­
Ag/
Nickel
baths
Ba
­
686
Ba
­
371
Cyanide
Bath
Carbonate
Freezing
­
precipitate
AgCN
from
bath
Bi
­
19
Bi
­
29
Precipitation
­
precipitate
Al
out
of
anodize
bath
Cd
­
5
Cd
­
30
Monitoring
­
most
tanks
weekly
­
either
scheduled
or
monitored
Ca
­
35,300
Ca
­
63,300
replacements
Cr
­
205,000
Cr
­
118,000
Housekeeping
­
tank
covers,
clean
anode/
cathode
bars
Hex.
Cr
­
8
Hex.
Cr
­
11
Drag­
in
Reduction
­
Counter
Flow
rinses
Cu
­
5,670
Cu
­
11,500
Purer
Anodes
and
Bags
­
already
using
high
purity
Ni/
Cu/
Ag
Fe
­
6,450
Fe
­
7,990
Hexavalent
Chrome
Alternatives
­
MILSPEC,
etc.
limits
options
Pb
­
191
Pb
­
500
Non­
cyanide
Process
Chemicals
­
MILSPEC
limitations,
also
would
need
to
Mg
­
15,500
Mg
­
30,300
redo
permit
to
use
these
chemistries
Mn
­
183
Mn
­
184
Solvent
Degreasing
Alternatives
­
used
to
use
Vapor
degreaser
Hg
­
ND
Hg
­
ND
(perchloroethylene)
switched
~1995
to
aqueous­
based
Ni
­
4,400
Ni
­
4,390
Alkaline
Cleaners
­
skimming
on
semi­
aqueous
cleaners
(alkaline
based)
Se
­
ND
Se
­
ND
Acid
Purification
­
chrome
baths
­
constant
ion
exchange,
after
8
days,
baths
Ag
­23
Ag
­
1,190
are
"dead"
and
are
diluted
by
half
and
run
through
ion
exchange,
then
Na
­15,600
Na
­
19,800
evaporated
to
working
concentration
(can
recover
~98%
of
original
bath)
Sn
­382
Sn
­
182
DRAG­
OUT
REDUCTION/
RECOVERY
CN
­
2.4
CN
­
579
Wetting
Agents
­
some
tanks
have
agents
(Cu,
Ni,
fume
suppressant­
mist
control)
TCLP
(mg/
l)
TCLP
(mg/
l)
Workpiece
Positioning
­
incorporated
(optimization
between
drag­
out
and
As
­
ND
As
­
ND
throwing
power)
Ba
­
ND
Ba
­
ND
Withdrawal
and
Drainage
Time
­
operator
subjective
(training)
Cd
­
ND
Cd
­
0.02
Spray
or
Fog
Rinses
in
chrome
baths
­
RO
water
spray
Cr
­
0.92
Cr
­
0.56
Drag­
out
Tanks
­
Ag
tanks,
chromic
anodize,
3
rinse
on
chrome
tank,
Pb
­
0.06
Pb
­ND
replenish
bath
Hg
­
0.003
Hg
­
ND
RINSE
WATER
Ag
­
ND
Ag
­
ND
Spray
Rinse/
Rinse
Water
Agitation
­
some
rinses
have
air
agitation
Increased
Contact
Time/
Multiple
Rinses
Countercurrent
Rinsing
Zn
­
7,390
Zn
­
29,100
Se
­
ND
Se
­
ND
September
1998
69
F006
Benchmarking
Study
Table
17
(cont'd):
Facility­
Specific
Information
for
Phoenix
Facilities
Facility
P4
Plating
Process
F006
Quantity
and
Management
Sample
Description
Ni­
Cr
on
steel
85
tons/
yr
P4­
01
­
collected
directly
from
rollHard
chrome
on
steel
off,
reddish­
brown
in
color
Cu­
CN
Subtitle
C
Landfill
Sulfuric
acid
anodizing
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
P4
­
01
Replenishment
on
all
tanks
Total
(mg/
kg)
TCLP
(mg/
l)
Purified
Water
­
DI
water
Al
­
2,180
As
­
ND
Electrolytic
Dummying
­
hard
chrome
(regeneration
automatically
in
tank)
Sb
­
ND
Ba
­
ND
Monitoring
once
a
week
As
­
10
Cd
­
ND
Housekeeping
­
training
for
drag­
out,
air
drying
Ba
­
49
Cr
­
ND
Ventilation/
Exhaust
Systems
Bi
­
ND
Pb
­
ND
Nonchelated
Process
Chemistries
­
segregate
chelating
chemistries,
Cd
­
ND
Hg
­
ND
investigated
material
substitutions
Ca
­15,700
Se
­
ND
Solvent
Degreasing
Alternatives
­
all
cleaning
is
aqueous
based
Cr
­
5,680
Ag
­
ND
DRAG­
OUT
REDUCTION/
RECOVERY
Cu
­
417
Wetting
Agents
­
exploring
with
vendor
Fe
­
560,000
Workpiece
Positioning
Pb
­
80
Withdrawal
and
Drainage
Time
­
procedures
set
guideline
Mg
­
6,310
Drainage
boards
and
drag­
out
tanks
Mn
­
2,070
Drag­
out
used
as
make­
up
in
baths
Hg
­
ND
RINSE
WATER
Se
­
ND
Spray
Rinse/
Rinse
Water
Agitation
­
air
and
water
agitation
Ag
­
ND
Increased
Contact
Time/
Multiple
Rinses
Na
­
6,700
Countercurrent
Rinsing
Sn
­
38
Rinse
Water
­
counterflow
recycling/
recovery
Zn
­
258
Spent
Process
Baths
­
a
portion
of
FeCl
is
used
in
Waste
water
treatment
for
CN
­
ND
flocculation
Hex.
Cr
­
75
Ni
­
1,530
September
1998
70
F006
Benchmarking
Study
Table
17
(cont'd):
Facility­
Specific
Information
for
Phoenix
Facilities
Facility
P5
Plating
Process
F006
Quantity
and
Management
Sample
Description
Hard
chrome
Sulfamate
Ni
50
tons/
yr
P5­
01
­
composited
a
variety
of
Cu­
CN
Ag­
CN
different
press
loads
into
a
single
Aluminum
anodizing
Subtitle
C
Landfill
sample,
colors
ranged
from
dark
brown
to
light
brown
to
greenishbrown
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
P5
­
01
Filtration
of
most
baths
Total
(mg/
kg)
TCLP
(mg/
l)
Replenishment
of
most
baths
Al
­
2,270
As
­
ND
Purified
Water
­
RO/
DI
Sb
­
ND
Ba
­
ND
Electrolytic
Dummying
­
hard
chrome
As
­
160
Cd
­
ND
Cyanide
Bath
Carbonate
Freezing
for
all
CN
plating
(CaCO
drops
out)
Ba
­
387
Cr
­
1.06
3
Monitoring
­
wet
chemistry
­
all
changes
are
based
on
testing
Bi
­
ND
Pb
­
ND
Housekeeping
­
designated
bath
maintenance
person
Cd
­
806
Hg
­
ND
Ventilation/
Exhaust
Systems
­
scrubbers
segregated
as
well
Ca
­
29,300
Se
­
ND
Nonchelated
Process
Chemistries
­
segregated
(electroless
Ni)
Cr
­
206,000
Ag
­
ND
Solvent
Degreasing
Alternatives
­
all
cleaning
aqueous
based
Hex.
Cr
­
77
Alkaline
Cleaners
­
coalesce/
disk
filter
to
remove
contaminants
Cu
­
23,500
DRAG­
OUT
REDUCTION/
RECOVERY
Pb
­
377
Wetting
Agents
Mg
­
31,300
Workpiece
positioning
Mn
­
556
Withdrawal
and
Drainage
Time
­
SOP's
Hg
­
ND
Air
Knives
­
some
used
for
drying
Ni
­
10,300
Spray
or
Fog
Rinses
­
some
drag­
out
tanks
have
spray
rinse
Se
­
ND
Drainage
boards
and
drag­
out
tanks
Ag
­
457
Sent
back
for
replenishment
of
plating
baths
Na
­
15,300
RINSE
WATER
Zn
­
291
Spray
Rinse/
Rinse
Water
Agitation
­
air
agitation
CN
­
102
Increased
Contact
Time/
Multiple
Rinses
Countercurrent
Rinsing
Flow
restrictors
set
at
5
gpm
(timed)
Spent
Process
Baths
­
copper
alkaline
strip
recycled/
recovered
off­
site
at
a
smelter
Solvents
­
oil
based
wax
removal
sent
off
site
for
fuel
blending
Fe
­
35,200
Sn
­
546
September
1998
71
F006
Benchmarking
Study
Table
17
(cont'd):
Facility­
Specific
Information
for
Phoenix
Facilities
Facility
P6
Plating
Process
F006
Quantity
and
Management
Sample
Description
Cu
sulfate
~590
tons/
yr
P6­
01
­
"fresh"
sludge
sample
from
Hard
chrome
roll­
off
currently
in
use(
sludge
Cyanide­
based
brass
Recycle
(World
Resources)
dropped
that
day),
sludge
was
a
mixture
of
bluish
and
dark
brown
P6­
02
­
"old"
sludge
from
hopper
accumulated
the
previous
week,
appeared
brownish
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
P6
­
01
P6
­
02
Filtration
on
all
baths
­
cartridge,
bags,
and
diatomaceous
earth
filters
Total
(mg/
kg)
Total
(mg/
kg)
Carbon
Treatment
­
electroforming
Al
­
511
Al
­
233
Replenishment
­
continuous
circulation
Sb
­
221
Sb
­
153
Purified
Water
­
RO
As
­
8,780
As
­
5,600
Monitoring
­
on­
line
XRF,
wet
lab
Ba
­
67
Ba
­
11
Drag­
in
Reduction
­
multiple
rinses,
squeegees
Bi
­
ND
Bi
­
ND
Ventilation/
Exhaust
Systems
Cd
­3
Cd
­
ND
Non­
cyanide
Process
Chemicals
­
looking
at
material
substitutions
Ca
­1,440
Ca
­
1,980
Caustic
Etch
Solution
Regeneration
­
plate­
out
removes
all
copper
Cr
­10,000
Cr
­
7,820
Acid
Purification
­
filtration
Hex.
Cr
­
548
Hex.
Cr
­
466
DRAG­
OUT
REDUCTION/
RECOVERY
Fe
­
6,650
Fe
­
2,670
Spray
or
Fog
Rinses
­
some
replenish
to
prior
tank
Pb
­
19,800
Pb
­
14,800
All
Drag­
Out
to
Waste
Water
Treatment
Mg
­
1,320
Mg
­
1,590
RINSE
WATER
Hg
­
ND
Hg
­
ND
Spray
Rinse/
Rinse
Water
Agitation
Ni
­
99
Ni
­
51
Increased
Contact
Time/
Multiple
Rinses
Se
­
ND
Se
­
ND
Flow
Restrictors
­
some
used
but
operators
can
adjust
flow
manually
Ag
­3
Ag
­
ND
Conductivity­
Actuated
Flow
Control
Na
­
60
Na
­
25
Spent
Process
Baths
­
Recycling/
Recovery
of
electroforming
bath
­
Solvent
Sn
­
3,570
Sn
­
3,850
Extraction
of
copper
off­
site
Zn
­
31,600
Zn
­
24,600
Cu
­552,000
Cu
­
463,000
Mn
­
72
Mn
­
24
CN
­
169
CN
­
127
TCLP
(mg/
l)
TCLP
(mg/
l)
As
­
ND
As
­
ND
Ba
­
ND
Ba
­
ND
Cd
­
0.02
Cd
­
0.03
Cr
­
ND
Cr
­
ND
Pb
­
35.40
Pb
­
39.80
Hg
­
ND
Hg
­
ND
Se
­
ND
Se
­
ND
Ag
­
ND
Ag
­
ND
September
1998
72
F006
Benchmarking
Study
Table
17
(cont'd):
Facility­
Specific
Information
for
Phoenix
Facilities
Facility
P8
Plating
Process
F006
Quantity
and
Management
Sample
Description
Electroless
Cu
Acid
Cu
64
tons/
yr
P8­
01
­
sample
collected
directly
Ni
sulfamate
Au­
CN
from
hopper,
appeared
brownish
in
Tin­
lead­
copper
Recycle
(World
Resources)
color
and
was
dropped
that
day
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
P8
­
01
Filtration
on
acid
Cu,
Au,
Ni,
black
oxide,
pre­
cleaning
lines
Total
(mg/
kg)
TCLP
(mg/
l)
Carbon
Treatment
on
acid
Cu/
Sn­
Pb/
Au,
Ni
Al
­
60,800
As
­
ND
Purified
Water
­
RO/
UV/
ion
exchange
­
incoming
water
Sb
­
ND
Ba
­
1.5
Electrolytic
Dummying
­
acid
Cu
primarily
(Sn)
As
­
3
Cd
­
ND
Monitoring
­
lab
does
chemical
maintenance
­
computer
controlled
(staff
Ba
­
125
Cr
­
0.02
monitors)
Bi
­
ND
Pb
­
0.64
Housekeeping
­
drip
trays,
daily
inspection
Cd
­
ND
Hg
­
ND
Drag­
in
Reduction
­
manual
lines
­
training
Ca
­
9,710
Se
­
ND
Ventilation/
Exhaust
Systems
­
fume
scrubbers
on
roof,
ventilation
on
tanks
Cr
­
248
Ag
­
ND
that
are
heated
Hex.
Cr
­
ND
Alkaline
cleaners
­
Filtration
and
Skimming
Cu
­
124,000
DRAG­
OUT
REDUCTION/
RECOVERY
Pb
­
3,610
Process
Bath
Operating
Concentration
­
standard
and
well
addressed
Mg
­
6,620
Process
Bath
Operating
Temperature
­
already
optimized
Mn
­
496
Air
Knives
and
squeegee
rollers
Hg
­
0.3
Spray
or
Fog
Rinses
Ni
­
2,900
Drainage
Boards
­
drip
pads
between
tanks
Se
­
ND
Drag­
Out
Tanks
Ag
­
835
RINSE
WATER
Sn
­
14,700
Spray
Rinse/
Rinse
Water
Agitation
­
air
agitation
on
a
few
tanks
Zn
­
782
Countercurrent
Rinsing
­
used
in
all
processes
CN
­
ND
Flow
restrictors
isolated
and
operator
controlled
Spent
Process
Baths
­
ammonium
hydroxide
etching
recycled
off
site
Fe
­
50,900
Na
­
2,050
September
1998
73
F006
Benchmarking
Study
Table
17
(cont'd):
Facility­
Specific
Information
for
Phoenix
Facilities
Facility
P9
Plating
Process
F006
Quantity
and
Management
Sample
Description
Copper
sulfate
109
tons/
yr
P9­
01
­
chelate
sludge
sampled
Nickel
sulfate
directly
from
small
hopper
prior
to
Au
immersion
(CN)
Recycle
(World
Resources)
moving
to
final
storage
roll­
off
Tin
where
commingled
with
non­
chelate
Electrolytic
Au
(CN
)
sludge
Electroless
nickel
P9­
02
­
non­
chelate
sludge
sampled
directly
from
final
storage
hopper
avoiding
chelate
sludge
(some
minor
mixing
of
the
two
occurred)

Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
P9
­
01
P9
­
02
Particulate
filtration
Total
(mg/
kg)
Total
(mg/
kg)
Carbon
treatment
Al
­
4,110
Al
­
59
Replenishment
Sb
­
44
Sb
­
ND
Purified
Water
­
RO/
DI
As
­
26
As
­
9
Electrolytic
Dummying
­
Ni/
Cu
Ba
­
40
Ba
­
9
Monitoring
­
AA
testing,
titrations,
and
microetch
Cu
testing
Bi
­
21
Bi
­
ND
Housekeeping
Cd
­
ND
Cd
­
ND
Drag­
in
Reduction
Ca
­
6,880
Ca
­
682
Purer
Anodes
and
Bags
are
already
implemented
(function
of
industry)
Cr
­
100
Cr
­
34
Ventilation/
Exhaust
Systems
Hex.
Cr
­
ND
Hex.
Cr
­
31
Nonchelated
Process
Chemistries
­
chelating
chemistries
are
segregated
Cu
­
48,700
Cu
­
631,000
Solvent
Degreasing
Alternatives
­
removed
vapor
degreaser
Fe
­
204,000
Fe
­
364
Caustic
Etch
Solution
Regeneration
­
Cu
Ammonium
chlorite
recycled
off
Pb
­
1,660
Pb
­
ND
site
Mg
­
10,700
Mg
­
230
DRAG­
OUT
REDUCTION/
RECOVERY
Hg
­
ND
Hg
­
ND
Process
Bath
Operating
Concentration
­
optimized
Ni
­
1,990
Ni
­
10,800
Process
Bath
Operating
Temperature
­
optimized
Se
­
ND
Se
­
ND
Wetting
Agents
­
Ni
and
Cu
bath
Ag
­
38
Ag
­
12
Workpiece
Positioning
­
looking
at
positioning
sheets
at
10°
drip
angle
Na
­
36,900
Na
­
41,600
Withdrawal
and
Drainage
Time
­
automatic
lines
are
programmed
with
dwell
Sn
­
37,200
Sn
­
402
and
rate
of
removal
Zn
­
389
Zn
­
2.750
Air
Knives
and
squeegees
on
conveyors
CN
­
9.1
CN
­
ND
Spray
or
Fog
Rinses
Drainage
Boards
­
used
some
in
electrolytic
gold
and
used
in
conveyors
TCLP
(mg/
l)
TCLP
(mg/
l)
Drag­
Out
Tanks
As
­
ND
As
­
ND
Evaporation
­
Ni
drag­
out
replenished
to
Ni
plate
bath
Ba
­
ND
Ba
­
ND
RINSE
WATER
Cr
­
ND
Cr
­
ND
Spray
Rinse/
Rinse
Water
Agitation
Pb
­
ND
Pb
­
0.08
Increased
Contact
Time/
Multiple
Rinses
Hg
­
ND
Hg
­
ND
Countercurrent
Rinsing
Se
­
ND
Se
­
ND
Flow
Restrictors
Ag
­
ND
Ag
­
ND
Conductivity­
Actuated
Flow
Control
­
used
on
large
Cu­
Tin
line
Rinse
Water
­
approximately
30
to
35%
of
total
flow
is
recycled
Spent
Process
Baths
­
Au
recovered
on
site
Mn
­
191
Mn
­
104
Cd
­
ND
Cd
­
ND
September
1998
74
F006
Benchmarking
Study
Table
17
(cont'd):
Facility­
Specific
Information
for
Phoenix
Facilities
Facility
P11
Plating
Process
F006
Quantity
and
Management
Sample
Description
Acid
Cu
Ni
sulfate
~4
tons/
yr
P11­
01
­
sludge
from
supersack
Tin­
Pb
Acid
Tin
Au
­CN
Recycle
(World
Resources)

Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
P11
­
01
Filtration
on
all
process
baths
Total
(mg/
kg)
TCLP
(mg/
l)
Carbon
treatment
on
acid­
Cu
quarterly
and
others
periodically
Al
­
819
As
­
ND
Replenishment
of
baths
with
drag­
out
Sb
­
ND
Ba
­
ND
Purified
water
­
use
deionized
water
As
­
ND
Cd
­
ND
Electrolytic
dummying
periodically
Ba
­
17
Cr
­
ND
Monitoring
via
wet
lab
(pH,
titration);
baths
replaced
based
on
sq.
ft.
plated
Bi
­
ND
Pb
­
0.13
Drag­
in
reduction
­
drain
times/
dwell
times
Cd
­ND
Hg
­
ND
Segregate
chelating
process
chemistries
(magnesium
sulfate
used
on
a
batch­
Ca
­11,400
Se
­
ND
by­
batch
basis)
Cr
­
119
Ag
­
ND
Solvent
degreasing
alternatives
­
all
cleaners
are
aqueous­
based
Hex.
Cr
­
ND
Alkaline
cleaners
­
resist
strip
is
filtered
Cu
­
125,000
DRAG­
OUT
REDUCTION/
RECOVERY
Pb
­
6,080
Workpiece
positioning
­
racks
are
coated
Mg
­
72,600
Optimize
withdrawal
and
drainage
time
Mn
­
2,080
Use
squirt
bottles
for
rinsing
Au/
Ni
solution
back
into
bath
Hg
­
ND
Utilize
Drag­
out
tanks
Ni
­
1,030
Some
drag­
out
tanks
are
used
to
replenish
hot
plating
baths
Se
­
ND
RINSE
WATER
Na
­
13,400
Spray
rinse/
rinse
water
agitation
Sn
­
131,000
Increased
contact
time/
multiple
rinses
Zn
­
820
Countercurrent
rinsing
CN
­
ND
Flow
restrictors
Conductivity­
actuated
flow
control
Recycling/
recovery
of
rinse
water
­
closed­
loop
on
metal­
bearing
rinses
Fe
­
75,800
Ag
­
14
September
1998
75
F006
Benchmarking
Study
Table
17
(cont'd):
Facility­
Specific
Information
for
Phoenix
Facilities
Facility
P13
Plating
Process
F006
Quantity
and
Management
Sample
Description
Copper
(CN)
Au­
CN
~4
tons/
yr
P13­
01
­
"old"
sample
collected
Ni
from
top
of
superbag,
appeared
dry,
Recycle
(World
Resources)
and
dense
P13­
02
­
"fresh"
sample
collected
directly
from
small
hopper
under
filter
press
Pollution
Prevention
Practices
Sample
Characteristics
(Dry
wt.)

SPENT
PLATING
SOLUTIONS
P13
­
01
P13
­
02
Filtration
Total
(mg/
kg)
Total
(mg/
kg)
Carbon
Treatment
for
alkaline
rinse
Al
­
1,370
Al
­
2,860
Purified
Water
­
DI
system
Sb
­
34,800
Sb
­
1,250
Electrolytic
Dummying
­
Ni
baths
As
­
ND
As
­
10
Monitoring
via
in­
house
lab
­
conductivity
on
rinse
tanks,
going
to
add
Ba
­
253
Ba
­
198
turbidity
monitor
to
alkaline
rinse
Bi
­
398
Bi
­
32
Housekeeping
­
process
tanks
are
covered
at
end
of
the
day
and
also
replace
Cd
­
ND
Cd
­
3
baths
chronologically
visually
Ca
­
2,690
Ca
­
143,000
Drag­
in
Reduction
­
spray
rinses
with
double
dipping
Cr
­
29
Cr
­
170
Ventilation/
Exhaust
Systems
Hex.
Cr
­
ND
Hex.
Cr
­
ND
Nonchelated
Process
Chemistries
­
electrowinning
helps,
and
add
reducing
Cu
­3,660
Cu
­
6,430
agents
Fe
­
3,500
Fe
­
17,100
DRAG­
OUT
REDUCTION/
RECOVERY
Mg
­
187
Mg
­
2,640
Workpiece
Positioning
­
looking
into
new
racks
Mn
­
13
Mn
­
92
Withdrawal
and
Drainage
Time
­
subject
to
plater
on
manual
lines
(Au
racks
Hg
­
0.5
Hg
­
0.4
are
left
to
sit
~10
minutes)
Ni
­
2,420
Ni
­
71,900
Spray
or
Fog
Rinses
­
stagnant
spray
rinses
(with
water)
Se
­
ND
Se
­
ND
Drag­
Out
Tanks
Ag
­
113
Ag
­
40
Electrowinning
­
Ni,
Cu
Na
­
310
Na
­
5,660
RINSE
WATER
Zn
­
672
Zn
­
357
Spray
Rinse/
RinseWater
Agitation
­
air
agitation
CN
­
ND
CN
­
ND
Increased
Contact
Time/
Multiple
Rinses
Countercurrent
Rinsing
TCLP
(mg/
l)
TCLP
(mg/
l)
Flow
Restrictors
­
spray
rinses
As
­
ND
As
­
ND
Conductivity­
Actuated
Flow
Control
­
conductivity
meters,
but
not
controlled
Ba
­
ND
Ba
­
ND
because
generate
too
much
water
Cd
­
0.1
Cd
­
ND
Rinse
Water
­
Ni
rinse
with
ion
exchange
is
recycled
Cr
­
ND
Cr
­
ND
Pb
­
175,000
Pb
­
13,000
Sn
­
467,000
Sn
­
15,300
Pb
­
1,630
Pb
­
1.26
Hg
­
ND
Hg
­
ND
Se
­
ND
Se
­
ND
Ag
­
ND
Ag
­
ND
September
1998
76
F006
Benchmarking
Study
Table
18:
Summary
of
Phoenix
F006
Analytical
Data:
#
of
Samples
Which
Were:
Not
Detected;
Above
Method
Quantitation
Limit
Constituent
#
Samples
#
Non
Detects
#
Samples
Above
(%)
(%)
Method
Quantitation
Limit
(%)

Total
Metals
Concentration
(mg/
kg)
Aluminum
15
0(
0%)
15(
100%)
Antimony
15
10(
67%)
5(
33%)
Arsenic
15
2(
13%)
13(
87%)
Barium
15
0(
0%)
15(
100%)
Beryllium
0
0
0
Bismuth
15
9(
60%)
6(
40%)
Cadmium
15
9(
60%)
6(
40%)
Calcium
15
0(
0%)
15(
100%)
Chromium
15
0(
0%)
15(
100%)
Copper
15
0(
0%)
15(
100%)
Iron
15
0(
0%)
15(
100%)
Lead
15
1(
7%)
14(
93%)
Magnesium
15
0(
0%)
15(
100%)
Manganese
15
0(
0%)
15(
100%)
Mercury
15
11(
73%)
4(
27%)
Nickel
15
0(
0%)
15(
100%)
Selenium
0
0
0
Silver
15
2(
13%)
13(
87%)
Sodium
15
0(
0%)
15(
100%)
Tin
15
0(
0%)
15(
100%)
Zinc
15
0(
0%)
15(
100%)
TCLP
(mg/
l)
Arsenic
0
0
0
Barium
8
7(
87%)
1(
13%)
Cadmium
15
11(
73%)
4(
27%)
Chromium
15
10(
67%)
5(
33%)
Lead
15
4(
27%)
11(
73%)
Mercury
7
6(
86%)
1(
14%)
Selenium
0
0
0
Silver
0
0
0
General
Chemistry
(mg/
kg)
Chloride
15
0(
0%)
15(
100%)
Fluoride
15
1(
7%)
14(
93%)
Chromium,
hexavalent
15
7(
46%)
8(
54%)
Total
Cyanide
15
8(
54%)
7(
46%)
Amenable
Cyanide
15
1(
7%)
14(
93%)
Percent
Solids
15
0(
0%)
15(
100%)
September
1998
77
F006
Benchmarking
Study
Table
19:
Detailed
Analytical
Data
for
the
Phoenix
Facilities
Constituent
CAS
No.
P1­
01
P1­
02
P2­
01
P3­
01
P3­
02
P4­
01
P5­
01
Total
Metals
­
Methods
6010A,
7471A,
7060A,
7421,
7740
mg/
kg
Aluminum
7429905
3,420
44,700
72,300
76,100
74,500
2,180
2,270
Antimony
7440360
ND
ND
ND
ND
ND
ND
ND
Arsenic
7440382
2
8
12
11
12
10
16
Barium
7440393
6
22
67
686
371
49
387
Beryllium
7440417
ND
ND
ND
ND
ND
ND
ND
Bismuth
7440699
ND
ND
71
19
29
ND
ND
Cadmium
7440439
ND
ND
77
5
30
ND
806
Calcium
7440702
15,100
15,300
15,800
35,300
63,300
15,700
29,300
Chromium
7440473
10
23
25,700
205,000
118,000
5,680
206,000
Copper
7440508
7,690
28,100
2,660
5,670
11,500
417
23,500
Iron
7439896
5,050
4,020
13,600
6,450
7,990
560,000
35,200
Lead
7439921
2,590
194
1,160
191
500
80
377
Magnesium
7439954
319,000
245,000
198,000
15,500
30,300
6,310
31,300
Manganese
7439965
101
288
116
183
184
2,070
556
Mercury
7439976
ND
ND
0.3
ND
ND
ND
ND
Nickel
7440020
3,080
4,450
4,480
4,400
4,390
1,530
10,300
Selenium
7782492
ND
ND
ND
ND
ND
ND
ND
Silver
7440224
8
22
7
23
1,190
ND
457
Sodium
7440235
4,050
4,780
15,800
15,600
19,800
6,700
15,300
Tin
7440315
2,370
1,710
171
382
182
38
546
Zinc
7440666
57
190
251
7,390
29,100
258
291
TCLP
Metals
­
Methods
1311,
6010A,
7470A
mg/
L
Arsenic
7440382
ND
ND
ND
ND
ND
ND
ND
Cadmium
7440439
ND
ND
ND
ND
0.02
ND
ND
Chromium
7440473
ND
ND
0.1
0.92
0.56
ND
1.06
Lead
7439921
0.12
0.08
0.12
0.06
ND
ND
ND
Mercury
7439976
ND
ND
ND
0.003
ND
ND
ND
Selenium
7782492
ND
ND
ND
ND
ND
ND
ND
Silver
7440224
ND
ND
ND
ND
ND
ND
ND
General
Chemistry
­
Methods
300.0,
335.2,
335.1,
7195/
6010A
mg/
kg
Chloride
16887006
542
3,950
451
430
566
8,120
4,790
Fluoride
16984488
49.5
804
782
3,090
4,240
ND
161
Hex.
Chromium
18540299
ND
ND
5
8
11
75
77
Total
Cyanide
57125
ND
ND
1.1
2.4
579
ND
102
Amen.
Cyanide
E­
10275
**
13.3
**
89.7
**
8.4
**
7
**
809
ND
**
156
Percent
Solids
60.1
30.1
27.3
27.8
20.9
28
28.5
Notes:
ND
­
not
detected
*All
results
reported
on
a
dry­
weight
basis.
**
Reported
value
is
the
concentration
of
cyanide
after
chlorination.
Since
this
value
is
greater
than
the
total
cyanide
result,
a
value
for
the
cyanide
amenable
to
chlorination
cannot
be
calculated.
September
1998
78
F006
Benchmarking
Study
Table
19
(con't):
Detailed
Analytical
Data
for
the
Phoenix
Facilities
Constituent
CAS
No.
P6­
01
P6­
02
P8­
01
P9­
01
P9­
02
P11­
01
P13­
01
P13­
02
Total
Metals
­
Methods
6010A,
7471A,
7060A,
7421,
7740
mg/
kg
Aluminum
7429905
511
233
60,800
4,110
59
819
1,370
2,860
Antimony
7440360
221
153
ND
44
ND
ND
34,800
1,250
Arsenic
7440382
8,780
5,600
3
26
9
ND
ND
10
Beryllium
7440417
ND
ND
ND
ND
ND
ND
ND
ND
Barium
7440393
67
11
125
40
9
17
253
198
Bismuth
7440699
ND
ND
ND
21
ND
ND
398
32
Cadmium
7440439
3
ND
ND
ND
ND
ND
ND
3
Calcium
7440702
1,440
1,980
9,710
6,880
682
11,400
2,690
143,000
Chromium
7440473
10,000
7,820
248
100
34
119
29
170
Copper
7440508
552,000
463,000
124,000
48,700
631,000
125,000
3,660
6,430
Iron
7439896
6,650
2,670
50,900
204,000
364
75,800
3,500
17,100
Lead
7439921
19,800
14,800
3,610
1,660
ND
6,080
175,000
13,000
Magnesium
7439954
1,320
1,590
6,620
10,700
230
72,600
187
2,640
Manganese
7439965
72
24
496
191
104
2,080
13
92
Mercury
7439976
ND
ND
0.3
ND
ND
ND
0.5
0.4
Nickel
7440020
99
51
2,900
1,990
10,800
1,030
2,420
71,900
Selenium
7782492
ND
ND
ND
ND
ND
ND
ND
ND
Silver
7440224
3
ND
835
38
12
14
113
40
Sodium
7440235
60
25
2,050
36,900
41,600
13,400
310
5,660
Tin
7440315
3,570
3,850
14,700
37,200
402
131,000
467,000
15,300
Zinc
7440666
31,600
24,600
782
389
2,750
820
672
357
TCLP
Metals
­
Methods
1311,
6010A,
7470A
mg/
L
Arsenic
7440382
ND
ND
ND
ND
ND
ND
ND
ND
Barium
7440393
ND
ND
1.5
ND
ND
ND
ND
ND
Cadmium
7440439
0.02
0.03
ND
ND
ND
ND
0.1
ND
Chromium
7440473
ND
ND
0.02
ND
ND
ND
ND
ND
Lead
7439921
35.4
39.8
0.64
ND
0.08
0.13
1,630
1.26
Mercury
7439976
ND
ND
ND
ND
ND
ND
ND
ND
Selenium
7782492
ND
ND
ND
ND
ND
ND
ND
ND
Silver
7440224
ND
ND
ND
ND
ND
ND
ND
ND
General
Chemistry
­
Methods
300.0,
335.2,
335.1,
7195/
6010A
mg/
kg
Chloride
16887006
1,630
1,490
590
2,250
24,000
4,110
64
905
Fluoride
16984488
ND
ND
100
3,090
ND
ND
ND
ND
Hex.
Chromium
18540299
548
466
ND
ND
31
ND
ND
ND
Total
Cyanide
57125
169
127
ND
9.1
ND
ND
ND
ND
Amen.
Cyanide
E­
10275
**
359
**
369
**
3.9
**
75.1
**
20.8
**
16.6
**
14.7
**
39.4
Percent
Solids
27.5
29.3
34.4
34.9
27.2
45.2
94.1
41.1
Notes:
ND
­
not
detected
*All
results
reported
on
a
dry­
weight
basis.
**
Reported
value
is
the
concentration
of
cyanide
after
chlorination.
Since
this
value
is
greater
than
the
total
cyanide
result,
a
value
for
the
cyanide
amenable
to
chlorination
cannot
be
calculated.
September
1998
79
F006
Benchmarking
Study
4.
Detailed
Results
of
the
National
Benchmarking
Study
Tables
20­
32
present
detailed
results
of
the
National
Benchmarking
Study.
The
data
gathered
is
similar
in
type
but
is
often
less
detailed
than
the
data
gathered
in
the
Regional
Benchmarking
Study.
Data
categories
include:
metal
finishing
operations,
pollution
prevention
practices,
F006
characteristics
and
sludge
management
practices
from
a
broad
range
of
metal
finishers
(Appendix
G
contains
the
survey
instrument).
The
survey
was
distributed
by
mail
to
member
companies
of
NAMF
and
AESF,
and
at
a
metal
finishers
national
technical
conference
(SURFIN
97).
In
all,
nearly
2,000
surveys
were
distributed.
One
hundred
eighty­
six
(186)
responses
were
received
and
compiled
into
a
computer
data
base.
A
variety
of
firms
responded.
The
number
of
employees
of
respondents
ranged
from
4
to
7,250
with
an
average
of
229.
The
survey
question
number
is
indicated
in
the
summaries
below
in
[brackets].

a.
Characterization
of
the
Survey
Respondents
Average
number
of
employees
responding:
229
Maximum
number
of
employees
responding:
7,250
Minimum
number
of
employees
responding:
4
A
total
of
186
surveys
were
received.

Number
of
respondents
to
this
question:
171
/
186
=
92
%

b.
Product
and
Waste
Stream
Characterization
[C1]

Respondents
reported
product
weight
using
different
units:
Average
of
the
responses
reported
in
cubic
yards
:
60,867
tons
Average
of
the
responses
reported
in
barrel
loads:
150,000
barrel
loads
Number
of
responses
to
this
question:
88
/
186
=
47%

c.
Total
quantity
of
F006
waste
generated
in
1996
[C4]

Average
of
reponses
reported
in
tons:
1016
tons
Number
of
responses
to
this
question:
161
/
186
=
87%

d.
F006
segregation
[C2]

Facilities
reporting
that
F006
wastes
are
combined
in
the
wastewater:
139
Facilities
reporting
that
F006
wastes
are
process­
specific:
22
Number
of
responses
to
this
question:
161
/
186
=
87%

e.
Cyanide
sludge
segregation
[C3]

Facilities
reporting
that
cyanide­
bearing
F006
sludges
are
segregated:
33
Facilities
reporting
that
cyanide­
bearing
F006
sludges
are
not
segregated:
151
Number
of
responses
to
this
question:
184
/
186
=
99%

f.
Quantity
of
F006
waste
generated
by
process
[C5]

Respondents
reported
generating
an
average
1,016
tons
of
F006
sludge
annually.
As
noted
in
the
statistical
analysis
section,
larger
companies
tended
to
respond
more
than
smaller
companies.
A
summary
of
F006
sludge
generated
by
groups
of
plating
processes
is
provided
in
Table
20.
Table
21
presents
the
estimates
of
process­
September
1998
80
F006
Benchmarking
Study
specific
F006
waste
generation
for
1996.
The
quantities
assume
that
all
units
are
equivalent
(e.
g.,
cubic
yards
and
dry
tons).

Table
20:
Summary
of
F006
Sludge
Generation
by
Plating
Category
Plating
Category
Quantity
(dry
tons)

Mixed
Acids
118750.47
Anodizing
19.05
Bright
Dip
of
Copper/
alloy
74.82
Cadmium
6373.50
All
Chrome
55467.93
Cleaner
122.65
All
Copper
7419.35
All
Cyanide
8328.32
All
Electroless
Nickel
14.88
All
Ion
Exchange
14.42
All
Nickel
23019.36
Silver
Plate
75.65
Stainless
Electropolish
68.63
Tin
51.45
All
Zinc
15938.36
Table
21.
Process­
Specific
F006
Waste
Generation
for
1996
Facility
Process
Quantity
Measure
027
Not
available
1.00
Cubic
Yards
064
Not
available
30.30
Dry
Tons
022
Not
available
Dry
Tons
016
Not
available
0.56
Dry
Tons
016
Not
available
0.14
Dry
Tons
078
ABS/
Steel
Chromium
plating
78.47
Dry
Tons
123
acid
80.00
Cubic
Yards
037
acid
batch
treat
0.13
Dry
Tons
090
acid
copper
6.04
Dry
Tons
037
acid
rinses
26.50
Dry
Tons
083
acid­
alkali
wastewater
118388.00
Dry
Tons
145
acid­
chloride
zinc
90.00
Dry
Tons
075
acid/
alkaline
141.84
Long
Tons
023
acid/
alkaline
rinses
17.97
Metric
Tons
001
alum
treating
8.00
Dry
Tons
036
anodizing
0.50
Cubic
Yards
148
anodizing
1.00
Cubic
Yards
146
anodizing
7.50
Dry
Tons
144
sulfuric
acid
anodizing
0.05
Dry
Tons
174
Sulfuric
Anodize/
Hardcoat
2.00
Dry
Tons
144
bright
dip
of
copper/
alloys
6.00
Dry
Tons
035
black
oxide
25.00
Cubic
Yards
112
brass
plating
0.50
Dry
Tons
Table
21.
Process­
Specific
F006
Waste
Generation
for
1996
Facility
Process
Quantity
Measure
September
1998
81
F006
Benchmarking
Study
138
brass
waste
treatment
40.60
Dry
Tons
057
bright
dip
of
copper/
alloy
0.13
Dry
Tons
156
bright
dip
of
copper/
alloy
2.60
Dry
Tons
155
bronze
line
cleaner
side
overflowing
rinse
10.00
Dry
Tons
027
cadmium
1.00
Cubic
Yards
026
barrel
cadmium
3126.00
Dry
Tons
173
cadmium
1.00
Dry
Tons
066
cadmium
26.00
Cubic
Yards
057
cadmium
plating
0.50
Dry
Tons
120
cadmium
plating
14.00
Dry
Tons
114
cadmium
and
other
processes
14.00
Dry
Tons
133
cyanide
cadmium
plating
55.00
Cubic
Feet
026
rack
cadmium
3126.00
Dry
Tons
119
chelate
20.00
Dry
Tons
048
chromating
3.22
Dry
Tons
119
chrome
15.00
Dry
Tons
096
chrome
8.10
Dry
Tons
075
chrome
54.75
Long
Tons
065
chrome
anodize
1.50
Dry
Tons
080
chrome
hydroxide
55.70
Dry
Tons
183
chrome
plate
10245.00
Dry
Tons
038
chrome
plating
1.00
Dry
Tons
051
chrome
plating
10.92
Dry
Tons
059
chrome
plating
and
chromating
61.00
Cubic
Yards
082
chrome
plating
and
chromating
43.75
Dry
Tons
023
chrome
rinses
5.39
Metric
Tons
134
chrome
rinses
46.50
Dry
Tons
085
chrome/
nickel
155.50
Dry
Tons
054
chromic
anodize
16.00
Dry
Tons
174
chromic
anodize
0.25
Dry
Tons
090
chromium
9.98
Dry
Tons
058
chromium
0.99
Dry
Tons
083
chromium
contaminated
wastewater
35687.00
Dry
Tons
049
hard
chrome
7508.00
Dry
Tons
046
hard
chrome
7.38
Dry
Tons
034
hard
chrome
7.00
Dry
Tons
039
hard
chrome
plating
1500.00
Cubic
Feet
174
Conversion
Coating
0.25
Dry
Tons
148
conversion
coatings
2.00
Cubic
Yards
156
Chromate
conversion
on
aluminum
1.75
Dry
Tons
116
cleaner
tank
bottoms
0.15
Dry
Tons
141
cleaning
5.00
Dry
Tons
104
cleaning
(soap
and
acid);
aluminum
cleaning
10.00
Dry
Tons
004
cleaning
rinses
93.50
Dry
Tons
185
batch
treats(
cleaners
&
Microetch)
14.00
Dry
Tons
Table
21.
Process­
Specific
F006
Waste
Generation
for
1996
Facility
Process
Quantity
Measure
September
1998
82
F006
Benchmarking
Study
110
copper
nickel
plating
75.00
Dry
Tons
042
copper
5.51
Dry
Tons
021
copper
&
brass
2.60
Dry
Tons
112
copper
nickel
chrome
plating
on
non
ferrous
40.00
Dry
Tons
112
copper
nickel
chrome
plating
on
steel
0.50
Dry
Tons
183
copper
plate
657.00
Dry
Tons
061
copper
plate
40.00
Dry
Tons
036
copper
plate
0.50
Cubic
Yards
057
copper
plating
0.13
Dry
Tons
082
copper
plating
27.50
Dry
Tons
136
copper,
nickel,
chromium
on
steel
23.00
Dry
Tons
145
copper­
nickel­
chrome
9.00
Dry
Tons
053
copper/
ni/
chrome
on
ABS
140.00
Dry
Tons
027
copper/
nickel/
chrome
2.00
Cubic
Yards
016
copper/
nickel/
chrome
6.30
Dry
Tons
049
copper/
nickel/
chrome
6000.00
Dry
Tons
170
copper/
nickel/
chrome
decorative
plating
42.00
Cubic
Yards
157
copper/
nickel/
chrome
plating
on
plastic
300.00
Dry
Tons
014
Cu,
Ni,
Cr
23.50
Dry
Tons
137
Cu/
Ni/
Cr
on
non­
ferrous
5.55
Dry
Tons
090
cyanide
copper
4.03
Dry
Tons
147
cyanide
copper
plating
on
zinc
die
cast
0.24
Dry
Tons
086
cyanide
copper/
cyanide
brass
15.00
Cubic
Yards
083
cyanide
contaminated
wastewater
7930.00
Dry
Tons
123
cyanide
200.00
Cubic
Yards
119
cyanide
7.50
Dry
Tons
075
cyanide
52.26
Long
Tons
010
cyanide
bearing
rinse
waters
1.37
Dry
Tons
031
Cyanide
destruction
3.70
Dry
Tons
085
cyanide
processes
93.30
Dry
Tons
023
cyanide
rinses
8.99
Metric
Tons
134
cyanide
rinses
11.00
Dry
Tons
037
cyanide
rinses
3.45
Dry
Tons
029
misc
cyanide
wastes
16.75
Dry
Tons
055
electroless
nickel
1.10
Dry
Tons
048
electroless
nickel
and
gold
plating
12.88
Dry
Tons
038
electroless
nickel
plating
0.90
Dry
Tons
140
hot
dip
galv
21.00
Dry
Tons
117
ion
exchange
10.14
Dry
Tons
050
ion
exchange
regen
4.28
Dry
Tons
038
iron
plating
1.75
Dry
Tons
041
lead
plating
14.85
Cubic
Yards
019
Mn
&
zinc
phosphate
7.00
Dry
Tons
137
Ni/
Cr
on
steel
9.25
Dry
Tons
096
nickel
0.90
Dry
Tons
Table
21.
Process­
Specific
F006
Waste
Generation
for
1996
Facility
Process
Quantity
Measure
September
1998
83
F006
Benchmarking
Study
042
nickel
63.31
Dry
Tons
035
nickel
10.00
Cubic
Yards
021
nickel
2.00
Dry
Tons
173
nickel
2.00
Dry
Tons
050
nickel
6.42
Dry
Tons
090
nickel
8.42
Dry
Tons
010
nickel
bearing­
acid/
alkali
rinses
3.00
Dry
Tons
036
nickel
plate
3.00
Cubic
Yards
183
nickel
plate(
incl.
Electroless
Nickel)
684.00
Dry
Tons
004
nickel
plating
25.00
Dry
Tons
038
nickel
plating
0.40
Dry
Tons
033
nickel
plating
3.00
Dry
Tons
082
nickel
plating
37.50
Dry
Tons
059
nickel
plating
60.00
Cubic
Yards
146
nickel
plating
0.50
Dry
Tons
047
nickel
plating
3.00
Dry
Tons
065
nickel
plating
1.00
Dry
Tons
175
nickel
plating
21.00
Dry
Tons
051
nickel
plating
10.49
Dry
Tons
012
nickel
plating
(all
types)
30.25
Dry
Tons
147
nickel
plating
on
zinc
die
cast
0.21
Dry
Tons
029
nickel
plating
treatment
11.92
Dry
Tons
132
nickel,
silver,
chrome,
tin,
and
E­
coat
1.00
Dry
Tons
054
nickel/
chrome
10.00
Dry
Tons
026
automatic
nickel/
chrome
18756.00
Dry
Tons
173
nickel/
chrome
0.50
Dry
Tons
100
nickel/
chrome
plating
1.00
Dry
Tons
105
nickel/
chrome
plating
23.69
Dry
Tons
073
nickel/
chromium
plating
7.05
Dry
Tons
080
nickel/
copper
hyd.
51.80
Dry
Tons
071
nickel
chromium
plating
55.00
Dry
Tons
026
barrel
nickel
3126.00
Dry
Tons
146
passivation
2.00
Dry
Tons
066
phosphate
100.00
Cubic
Yards
183
Silver
Plate
71.00
Dry
Tons
111
silver
plating
operations
2.65
Long
Tons
148
silver,
tin,
electroless
nickel
2.00
Cubic
Yards
105
stainless
electropolish
3.38
Dry
Tons
144
stainless
steel
passivation
0.25
Dry
Tons
180
Steel
65.00
Dry
Tons
141
stripping
5.00
Dry
Tons
021
tin
0.30
Dry
Tons
019
tin
plating
1.00
Dry
Tons
004
tin
plating
50.00
Dry
Tons
041
tin/
lead
plating
0.15
Cubic
Yards
Table
21.
Process­
Specific
F006
Waste
Generation
for
1996
Facility
Process
Quantity
Measure
September
1998
84
F006
Benchmarking
Study
071
titanium
5.00
Dry
Tons
014
zinc
20.00
Dry
Tons
084
zinc
15.00
Dry
Tons
072
zinc
224.00
Dry
Tons
071
zinc
20.00
Dry
Tons
066
zinc
126.00
Cubic
Yards
027
zinc
1.00
Cubic
Yards
021
zinc
76.50
Dry
Tons
180
zinc
5.00
Dry
Tons
042
zinc
206.44
Dry
Tons
148
zinc
and
cadmium
plating
15.00
Cubic
Yards
095
zinc
cyanide
1.00
Dry
Tons
104
zinc
cyanide
plating
and
chromate
conversion
30.00
Dry
Tons
094
zinc
electroplating
300.00
Cubic
Yards
125
zinc
electroplating,
zinc
nickel
alloy
electropl.
575.00
Cubic
Yards
109
zinc
electrotherapy
on
steel
148.00
Dry
Tons
080
zinc
hydroxide
57.30
Dry
Tons
137
zinc
on
steel
18.50
Dry
Tons
136
zinc
on
steel
19.50
Dry
Tons
144
zinc
phosphate
0.05
Dry
Tons
061
zinc
plate
70.00
Dry
Tons
008
zinc
plating
5507.20
Dry
Tons
140
zinc
plating
175.00
Dry
Tons
003
zinc
plating
5507.20
Dry
Tons
065
zinc
plating
25.00
Dry
Tons
001
zinc
plating
5.00
Dry
Tons
132
zinc
plating
19.00
Dry
Tons
082
zinc
plating
16.25
Dry
Tons
004
zinc
plating
150.00
Dry
Tons
045
zinc
plating
1040.00
Cubic
Yards
070
zinc
plating
80.00
Cubic
Yards
105
zinc
plating
40.62
Dry
Tons
059
zinc
plating
235.00
Cubic
Yards
019
zinc
plating
300.00
Dry
Tons
048
zinc
plating
144.90
Dry
Tons
100
zinc
plating
11.40
Dry
Tons
035
zinc
plating
200.00
Cubic
Yards
012
zinc
plating
(all
types)
60.50
Dry
Tons
088
zinc
plating
on
steel
155.00
Dry
Tons
120
zinc
plating
on
steel
140.00
Dry
Tons
156
zinc
plating
on
steel
83.00
Dry
Tons
145
zinc­
phosphate
1.00
Dry
Tons
098
ZnNi
alloy
plating
&
chromating
of
Zn
&
ZnNi
7.00
Dry
Tons
102
chloride
zinc
on
steel
23.00
Cubic
Yards
118
all
zinc
plating
84.00
Cubic
Yards
September
1998
85
F006
Benchmarking
Study
g.
On­
site
recycling
techniques
prior
to
discharge
[C6]

Number
of
responses
to
this
question:
36/
186
=
19%

On­
site
recycling
techniques
that
were
mentioned
by
more
than
one
company:
°
Electrowinning
°
Counter
flow
rinsing
°
Drag
out
rinses
returned
to
plating
tank
°
Electrodialysis
°
Evaporation
°
Precipitation
Metals
that
are
recovered:
brass,
cadmium,
chrome,
copper,
nickel,
gold,
silver.

Table
22
contains
individual
responses.

Table
22.
On­
Site
Recycling
Techniques
Facility
Description
Quantity
Measure
023
BEWT
Chemelec
Unit,
Reverse
Cn
Stip,
Jaynor
Units
1.70
Dry
Tons
018
brass
0.10
Dry
Tons
018
cadmium
0.10
Dry
Tons
075
cadmium
electrowinning
0.25
Dry
Tons
001
chrome
recovery
2.00
Dry
Tons
110
chromic
acid
through
demineralizes
50.00
Dry
Tons
018
copper
0.15
Dry
Tons
160
copper
grinding
swarf
2.50
Dry
Tons
157
Corning
Evaporators
for
Chrome
Drag­
out
75.00
Dry
Tons
038
counter
flow
rinsing
chrome
plate
1.00
Dry
Tons
038
counter
flow
rinsing
nickel
plating
0.75
Dry
Tons
141
drag
out
rinses
1.00
Dry
Tons
095
drag
out
tanks
used
for
tank
replenishment
1.00
Cubic
Yards
098
drag
out
from
plating
tanks
returned
to
bath
6.50
Dry
Tons
106
electrodialysis
of
rinsewater
0.25
Dry
Tons
124
electroless
nickel
directly
reduced
0.05
Dry
Tons
168
electrowinning
of
gold
solutions
500.00
Dry
Tons
168
electrowinning
of
silver
solutions
3000.00
Dry
Tons
168
electrowinning
of
solder
and
tin
solutions
1.00
Dry
Tons
010
electrowinning­
plating
cells
0.06
Dry
Tons
116
evaporating
recovery
0.20
Dry
Tons
180
evaporators
30.00
Dry
Tons
180
ion
exchangers
10.00
Dry
Tons
138
metal
recovery
systems
3.50
Dry
Tons
075
nickel
evaporation
0.75
Dry
Tons
055
nickel
plate
out
from
electroless
nickel
solution
0.05
Dry
Tons
157
nickel
precipitation
as
carbonate
35.00
Dry
Tons
008
precipitation,
filtration,
&
drying
5507.20
Dry
Tons
160
re­
sell
copper
turnings
7.50
Dry
Tons
Table
22.
On­
Site
Recycling
Techniques
Facility
Description
Quantity
Measure
September
1998
86
F006
Benchmarking
Study
041
reclaim
tanks
(dead
rinse)
used
some
solution
104.00
Cubic
Feet
009
silver
electrowinning
0.25
Dry
Tons
093
silver
reclaim
using
plate
out
unit
0.08
Dry
Tons
163
six
Eco­
tec
ion
exchange
units
4.20
Dry
Tons
055
sulfuric
acid
reclamation
from
anodize
tank
Dry
Tons
155
use
rinse
water
from
plating
side
for
bath
makeup
1.40
Dry
Tons
034
washdown
from
fume
scrubbers
returned
to
tank
1.00
Dry
Tons
h.
Off­
site
recycling
companies
[C7]

Number
of
respondents:
15/
186
=
8%

The
following
processes
were
used
to
recycle
F006
wastes:
°
Blending
°
High
temperature
incineration
°
Hydro
metallurgical
°
Pyrometallurgical
°
Smelting
°
Thermo
concentration
and
compounding
Off­
site
recycling
companies:
°
World
Resources
Corp
°
Horsehead
Resource
Development
Corp
°
Encycle/
Texas
Inc
°
21
Century
EMI
st
°
Republic
Environmental
Table
23
contains
individual
responses.

Table
23.
Off­
Site
Recycling
Techniques
Facility
Process
Quantity
Measure
Name
Location
023
Blending
47.00
Cubic
Yards
World
Resources
Pottsville,
PA
136
high
temp
incineration
42.50
Dry
Tons
Horsehead
Chicago,
Il
070
high
temp
incineration
60.00
Cubic
Yards
Horsehead
Chicago,
IL
014
high
temp
incineration
43.50
Dry
Tons
Horsehead
Chicago,
IL
137
Hydro
Metallurgical
37.00
Dry
Tons
Encycle/
Texas
Inc
Corpus
Christi,
TX
134
Pyrometallurgical
61.80
Dry
Tons
Horsehead
Chicago,
IL
075
Pyrometallurgical
248.84
Dry
Tons
World
Resources
Pottsville,
PA
050
Pyrometallurgical
14.85
Dry
Tons
21st
century
EMI
Fernly,
NV
043
Pyrometallurgical
13.20
Dry
Tons
World
Resources
Phoenix,
AZ
020
Pyrometallurgical
36.00
Dry
Tons
Republic
Environmental
Hamilton,
Ontario
008
Pyrometallurgical
5507.20
Dry
Tons
World
Resources
Phoenix,
AZ
Table
23.
Off­
Site
Recycling
Techniques
Facility
Process
Quantity
Measure
Name
Location
September
1998
87
F006
Benchmarking
Study
003
Pyrometallurgica
22.00
Long
Tons
World
Resources
Pheonix,
AZ
051
smelting
22.40
Dry
Tons
World
Resources
Phoenix,
AZ
031
thermo
concentration
and
18.53
Dry
Tons
World
Resources
Phoenix,
AZ
compounding
024
thermo
concentration
and
55.00
Dry
Tons
World
Resources
Phoenix,
AZ
compounding
i.
Management
methods
for
F006
wastes
[C8]

Number
of
responses:
57
Management
methods:
°
Incineration
°
Neutralization
°
Recycling
°
Solidification
°
Stabilization,
landfilling
°
Subtitle
C
landfill
Receiving
facilities:
°
Envirite
°
Chemical
Waste
Management
°
Wayandot
Landfill
°
Peoria
Disposal
°
LWD
°
LESI
°
Cynochem
°
USPCI
°
Envotech
°
Cycle
Chem
°
Stablex
Canada
°
Northland
Environment
°
Heritage
Environmental
°
Phillips
Environmental
°
Threamionic
°
Chief
Supply
°
Romic
Environmental
Table
24
contains
individual
responses.

Table
24.
Waste
Management
Methods
F006
Wastes
Mgt
Facility
Quantity
Measure
Name
Location
delisted
facility
002
26.00
Cubic
Yards
Envirite
Thomaston,
CT
delisted
facility
170
42.00
Cubic
Yards
Wayandot
Landfill
Carey,
OH
43316
delisted
facility
115
24.00
Cubic
Yards
Envirite
Canton,
OH
delisted
facility
125
575.00
Cubic
Yards
Envirite
of
Illinois
Harvey,
IL
delisted
facility
052
320.20
Dry
Tons
Envirite
Corporation
Canton,
OH
delisted
facility
066
100.00
Dry
Tons
Envirite
incineration
029
16.75
Dry
Tons
LWD
Calventy
City,
KY
incineration
133
55.00
Cubic
Feet
Cynochem
Detroit,
MI
neutralization
152
4850.00
gal
Cyanokem
Detroit,
MI
recycle
063
274.50
Dry
Tons
recycle
179
35.01
Dry
Tons
World
Resource
Co.
Pheonix,
AZ
Solidification
100
11.50
Dry
Tons
Envirite
Corp.
Canton,
OH
Solidification
108
28.00
Dry
Tons
Envotech
(EQ)
Belleville,
MI
Table
24.
Waste
Management
Methods
F006
Wastes
Mgt
Facility
Quantity
Measure
Name
Location
September
1998
88
F006
Benchmarking
Study
Solidification
098
7.00
Dry
Tons
Envirite
Canton,
OH
Stabilization
&
048
154.00
Dry
Tons
Stablex
Canada,
Inc.
Blainville,
Quebec,
fixation
Canada
Stabilization,
065
1.50
Dry
Tons
Heritage­
nickel
sludge
Indianapolis,
IN
landfilling
Stabilization,
090
311.95
Dry
Tons
Heritage
Environmental
Indianapolis,
IN
landfilling
Stabilization,
065
25.00
Dry
Tons
Heritage­
zinc
hydroxide
sludge
Indianapolis,
IN
landfilling
Stabilization,
065
1.00
Dry
Tons
Heritage­
chrome
sludge
Indianapolis,
IN
landfilling
Stabilization,
064
30.30
Dry
Tons
Envirite
Corp.
Canton,
OH
landfilling
Subtitle
C
Landfill
083
2.20
Dry
Tons
Stablex
Canada
Subtitle
C
Landfill
004
293.00
Dry
Tons
Stablex
Canada
Inc.,
solidification
Canada
and
C
landfill
Subtitle
C
Landfill
005
11.50
Dry
Tons
Stablex
Canada
Inc.
Canada
Subtitle
C
Landfill
093
20.00
Cubic
Yards
Envirite
Canton,
OH
Subtitle
C
Landfill
026
38100.00
Dry
Tons
Envirite
Canton,
OH
Subtitle
C
Landfill
041
3.00
Dry
Tons
Envirite
Corp.
Harvey,
IL
Subtitle
C
Landfill
071
44.00
Dry
Tons
Threamionic
Canada
Subtitle
C
Landfill
054
29.00
Dry
Tons
Romic
Environmental
Subtitle
C
Landfill
074
131.00
Dry
Tons
Chemical
Waste
Management
Fort
Wayne,
IN
(Adams
Center)

Subtitle
C
Landfill
071
36.00
Dry
Tons
Stablex
Canada
Subtitle
C
Landfill
062
12.00
Dry
Tons
Heritage
Env.
Service
Charlotte,
NC
Subtitle
C
Landfill
066
146.00
Dry
Tons
Peoria
Disposal
Subtitle
C
Landfill
034
8.00
Dry
Tons
Waste
Management
Indiana
Subtitle
C
Landfill
157
227.00
Dry
Tons
Heritage
Environmental
Indianapolis,
IN
Subtitle
C
Landfill
063
30.50
Dry
Tons
Subtitle
C
Landfill
179
62.21
Dry
Tons
Stablex
Quebec,
Canada
Subtitle
C
Landfill
165
50.60
Dry
Tons
LESI
­
Lone
Mt
Waynoka,
OK
Subtitle
C
Landfill
164
863.00
Dry
Tons
LESI
­
Lone
Mt.
Waynoka,
OK
Subtitle
C
Landfill
163
1330.00
Dry
Tons
LESI
­
Lone
Mt
Facility
Waynoka,
OK
Subtitle
C
Landfill
162
505.00
Dry
Tons
LESI
­
Lone
Mt.
Waynoka,
OK
Subtitle
C
Landfill
161
945.00
Dry
Tons
USCPI
­
Laidlaw
Lone
Mountain,
OK
Subtitle
C
Landfill
113
58.00
Dry
Tons
Envirosafe
Services
of
Idaho,
Inc.
Boise,
ID
Subtitle
C
Landfill
041
11.00
Dry
Tons
Heritage
Environmental
Ser.
Indianapolis,
IN
Subtitle
C
Landfill
094
300.00
Cubic
Yards
hydroxide
sludge
non­
hazardous
So.
Elgin,
IL
Subtitle
C
Landfill
157
73.00
Dry
Tons
USPCI
Lone
Mountain,
OK
Subtitle
C
Landfill
155
320.00
Dry
Tons
USPCI
Lone
Mountain
Oklahoma
Subtitle
C
Landfill
151
9.35
Dry
Tons
Envirite
Corp.
North
Canton,
OH
Subtitle
C
Landfill
147
0.60
Dry
Tons
Cycle
Chem
Elizabeth,
NJ
Subtitle
C
Landfill
146
10.00
Dry
Tons
Northland
Environmental
Providence,
RI
Subtitle
C
Landfill
134
4.90
Dry
Tons
Chemical
Waste
Management
Inc
Menomonee
Falls,
WI
Table
24.
Waste
Management
Methods
F006
Wastes
Mgt
Facility
Quantity
Measure
Name
Location
September
1998
89
F006
Benchmarking
Study
Subtitle
C
Landfill
132
20.00
Dry
Tons
Envirite
of
Ohio
Canton,
OH
Subtitle
C
Landfill
131
4.10
Dry
Tons
chromic,
muratic
acid
NV
Subtitle
C
Landfill
119
64.00
Dry
Tons
Phillips
Environmental
Canada
Subtitle
C
Landfill
118
84.00
Cubic
Yards
Envirite
Corporation
Canton,
OH
Subtitle
C
Landfill
156
87.35
Dry
Tons
USPCI
Lone
Mountain,
OK
73860
thermal
treatment
029
4.53
Dry
Tons
Northeast
Environmental
Wompsville,
NY
thermal
treatment
029
6.03
Dry
Tons
Chief
Supply
Haskl,
OK
j.
Exported
Waste
[C9]

Ten
respondents
reported
exporting
their
F006
wastes,
the
responses
are
presented
in
Table
25
The
other
174
respondents
are
not
exporting
F006
waste.

Table
25.
Export
Quantities
of
F006
Facility
No.
Exported
Waste
(dry
tons)

004
293.0
005
11.5
009
32.0
048
154.0
071
80.0
083
2.2
114
39
119
64
169
30
179
64.7
k.
Wastewater
Treatment
[C10]

Table
26
summarizes
the
number
of
respondents
who
are
conducting
wastewater
treatment
prior
to
discharge.

Table
26.
Facilities
Conducting
Wastewater
Treatment
Prior
to
Discharge
PROCESS
NUMBER
OF
RESPONDENTS
ANSWERING
"YES"

Waste
stream
segregation
92
Hexavalent
chrome
reduction
119
Cyanide
oxidation
69
Neutralization,
flocculation,
clarification,
effluent
polishing
143
Sludge
blending
to
achieve
desired
concentration
20
l.
Plating
Operations
[B]
September
1998
90
F006
Benchmarking
Study
Table
27
summarizes
responses
to
question
B,
"what
type
of
plating
operations
are
conducted
by
your
facility?".

Table
27.
Types
of
Plating
Conducted
by
Respondents
PROCESS
NUMBER
OF
NUMBER
OF
RESPONDENTS
RESPONDENTS
ANSWERING
"YES"
ANSWERING
"NO"

Zinc
plating
on
steel
92
92
Zinc
plating
on
steel
­
cyanide
23
161
Zinc
plating
on
steel
–
non­
cyanide
57
127
Nickel
chromium
82
102
Copper/
nickel/
chrome
62
122
Copper
plating/
stripping
7
177
Hard
chromium
36
148
Copper
plating
85
99
Tin
57
127
Cadmium
45
139
Sulfuric
acid
45
139
Silver
56
128
Gold
48
136
Bright
dip
56
128
Other
95
89
m.
Pollution
Prevention
Waste
Minimization
Activities
[E]

The
respondents
were
asked
to
complete
a
checklist
of
59
individual
waste
minimization
techniques
broken
into
three
main
categories
(i.
e.,
reduce
drag
out
losses,
reduce
rinse
water,
and
various
operating
practices).
Table
28
presents
the
total
number
of
positive
responses
for
each
of
59
waste
minimization
technique
broken
into
three
main
categories
(i.
e.
reduce
drag
out
losses,
reduce
rinse
water,
and
various
operating
practices).
Three
groups
of
facilities
were
identified:
small,
medium,
and
large.
Each
group
contained
an
equal
number
of
facilities
(i.
e.,
61)
to
enable
a
comparison
of
techniques
by
facility
size.
Based
on
the
analysis,
it
appears
as
though
facility
size
is
not
a
deciding
factor
in
determining
the
number
or
type
of
waste
minimization
techniques
implemented.
This
may
be
because
the
techniques
included
in
the
survey
are
relatively
low
cost
and
easy
to
implement.
Larger
facilities
may
be
able
to
afford
more
sophisticated
waste
minimization
improvements
(e.
g.,
process
changes)
that
were
not
included
in
the
survey.
Table
29
identifies
pollution
prevention
measures
by
technique.

Table
28:
Summary
of
Techniques
Used
by
Facility
Size*

Technique
(<
30
employees)
(>
31
and
<
65
employees)
(>
65
employees)
Small
Facilities
Medium
Facilities
Large
Facilities
Reduce
drag­
out
losses
Total
182
175
232
Allow
rack/
part
to
drip
over
plating
tank
33
27
38
Using
drag­
out
rinse
tanks
and
returning
27
30
33
chemicals
to
the
process
bath
Drip
shields
between
tanks
18
22
29
Reduce
rinse
water
use
Total
151
166
285
Flow
restrictors
26
39
58
Countercurrent
rinses
30
38
61
Manually
turn­
off
rinse
waters
22
28
47
Air
agitation
in
rinse
tanks
22
22
37
Various
operating
practices
586
659
781
Total
Training
and
programs
subtotal
120
114
152
Table
28:
Summary
of
Techniques
Used
by
Facility
Size*

Technique
(<
30
employees)
(>
31
and
<
65
employees)
(>
65
employees)
Small
Facilities
Medium
Facilities
Large
Facilities
September
1998
91
F006
Benchmarking
Study
Conduct
employee
education
21
22
30
Establish
preventive
maintenance
program
15
22
28
Use
specifically
assigned
personnel
27
35
40
Procedures
subtotal
200
213
271
Perform
routine
bath
analysis
34
33
41
Maintain
bath
analysis
logs
33
33
39
Use
process
baths
to
maximum
29
30
31
Have
written
procedures
25
28
37
F006
volume
reduction
subtotal
58
88
86
Sludge
dewatering
28
47
50
Closed
loop
recycling
16
15
10
Use
control
method
6
14
10
Inspections
/
maintenance
subtotal
60
66
73
Perform
regular
maintenance
of
26
24
29
racks/
barrels
Pre­
inspect
parts
22
23
24
Research
/
evaluations
subtotal
60
73
91
Evaluation
of
recycling
alternatives
16
21
27
Increase
drain
time
19
20
22
Research
of
alternative
plating
technologies
13
18
21
Elimination
/
Replacement
/
Substitutions
88
105
108
subtotal
Eliminate
obsolete
processes
20
19
22
Replace
cyanide
based
plating
14
21
23
Eliminate
plating
service
16
17
1
*
number
of
positive
responses
by
facility
Table
9.0
summarizes
the
results
of
the
responses
to
each
of
the
59
individual
techniques.
September
1998
92
F006
Benchmarking
Study
Table
29.
Pollution
Prevention
Benefits
by
Technique
Technique
Number
of
Number
of
Number
of
P2
BENEFIT
"Yes"
"No"
Manual
Vs.
Responses
Responses
Automatic
1
=
low
success,
5
=
high
success
Responses
1
2
3
4
5
Reduce
Drag­
out
Losses
Using
drag­
out
rinse
tanks
and
87
94
Manual:
57
3
4
17
20
27
returning
chemicals
to
the
process
Automatic:
22
bath
Using
drip
tanks
and
returning
36
145
Manual:
27
3
0
10
8
6
chemicals
to
the
process
bath
Automatic:
6
Reducing
speed
of
rack/
part
63
118
Manual:
43
5
9
20
11
6
withdrawal
Automatic:
20
Allowing
rack/
part
to
drip
over
96
85
Manual:
63
3
10
33
19
15
plating
tank
Automatic:
33
Using
a
drag­
in/
drag­
out
40
141
Manual:
26
3
2
8
6
10
arrangement
(i.
e.,
use
of
same
Automatic:
14
rinse
tank
before
and
after
plating
also
referred
to
as
a
double­
dip
or
double­
use
rinse)
Fog
or
spray
rinses
installed
over
36
145
Manual:
21
1
2
6
9
7
process
bath
Automatic:
12
Air
knives
that
blow
off
drag­
out
16
165
Manual:
1
1
1
3
7
3
Automatic:
15
Drip
shields
between
tanks
66
115
Manual:
34
3
5
18
15
16
Automatic:
52
Lower
bath
concentration
35
146
Not
applicable
2
5
14
6
4
Increasing
solution
temperature
13
168
Not
applicable
4
0
4
4
0
(reduces
viscosity)
Using
a
wetting
agent
(reduces
48
133
Not
applicable
5
1
18
13
4
viscosity)
Positioning
work
piece
to
minimize
65
116
Not
applicable
2
2
17
13
20
solution
holdup
Other,
specify
4
3
Not
applicable
0
0
0
1
2
Reduce
Rinse
Water
Use
Manually
turning
off
rinse
water
73
108
Not
applicable
4
8
20
10
20
when
not
in
use
Table
29.
Pollution
Prevention
Benefits
by
Technique
Technique
Number
of
Number
of
Number
of
P2
BENEFIT
"Yes"
"No"
Manual
Vs.
Responses
Responses
Automatic
1
=
low
success,
5
=
high
success
Responses
1
2
3
4
5
September
1998
93
F006
Benchmarking
Study
Conductivity
or
pH
rinse
controls
22
159
Not
applicable
1
2
8
4
3
Timer
rinse
controls
24
157
Not
applicable
1
4
3
8
5
Flow
restrictors
103
78
Not
applicable
1
3
17
26
21
Counter
current
rinses
113
68
Not
applicable
0
3
13
26
33
Spray
rinses
59
122
Not
applicable
2
4
9
15
11
Air
agitation
in
rinse
tanks
73
86
Not
applicable
1
3
20
17
20
Use
flow
meters/
accumulators
to
23
136
Not
applicable
1
0
8
3
5
track
water
use
at
each
rinse
tank
or
plating
line
Reactive
rinsing
or
cascade
rinsing
22
136
Not
applicable
1
1
2
5
9
Other,
specify
7
4
Not
applicable
0
0
0
1
2
Various
Operating
Practices
Training
and
Programs
Established
a
formal
policy
60
99
Not
applicable
11
6
11
12
11
statement
with
regard
to
pollution
prevention
and
control
Established
a
formal
pollution
64
95
Not
applicable
7
6
23
6
12
prevention
program
Conduct
employee
education
for
73
86
Not
applicable
4
9
22
13
12
pollution
prevention
Establish
a
preventive
maintenance
66
93
Not
applicable
2
6
22
14
13
program
for
tanks
Use
specifically
assigned
personnel
99
60
Not
applicable
2
6
12
24
34
for
chemical
additions
Procedures
Stricter
conformance
with
Line
31
127
Not
applicable
3
1
7
9
7
Preventive
Maintenance
Schedule
Stricter
conformance
with
SPC
26
133
Not
applicable
3
2
8
6
5
Procedures
Waste
stream
segregation
of
38
121
Not
applicable
0
1
8
8
16
contact
and
non
contact
wastewater
Table
29.
Pollution
Prevention
Benefits
by
Technique
Technique
Number
of
Number
of
Number
of
P2
BENEFIT
"Yes"
"No"
Manual
Vs.
Responses
Responses
Automatic
1
=
low
success,
5
=
high
success
Responses
1
2
3
4
5
September
1998
94
F006
Benchmarking
Study
Strict
chemical
inventory
control
59
100
Not
applicable
4
4
12
11
20
Perform
routine
bath
analyses
99
60
Not
applicable
0
2
17
30
32
Maintain
bath
analyses/
addition
96
63
Not
applicable
2
6
24
19
28
logs
Have
written
procedures
for
bath
83
76
Not
applicable
3
4
19
22
22
make­
up
and
additions
Use
process
baths
to
maximum
83
76
Not
applicable
0
3
13
24
26
extent
possible
(no
dump
schedule)
Remove
anodes
from
bath
when
36
123
Not
applicable
2
1
9
6
11
they
are
idle
(e.
g.,
cadmium,
zinc)
Regularly
retrieve
fallen
80
79
Not
applicable
3
2
30
12
20
parts/
racks
from
tanks
F006
Volume
Reduction
Methods
Closed­
loop
recycling
34
124
Not
applicable
2
0
1
3
9
Use
control
method
for
adding
29
130
Not
applicable
1
2
6
5
8
water
to
process
tanks
Sludge
dewatering
(Vacuum
filter,
113
46
Not
applicable
0
0
10
17
37
Solid
bowl
centrifuge,
Imperforate
basket
centrifuge,
belt
filter
press,
Recessed
plate
filter
press,
sludge
drying
beds,
sludge
lagoons,
sludge
dryers,
etc.)
Install
overflow
alarms
on
process
19
140
Not
applicable
3
0
6
3
5
tanks
Install
other
spill/
leak
detection
15
144
Not
applicable
3
0
1
3
5
system,
specify
Inspections
/
Maintenance
Perform
regular
maintenance
of
73
86
Not
applicable
3
8
24
20
7
racks/
barrels
Pre­
inspect
parts
to
prevent
64
95
Not
applicable
1
7
14
16
15
processing
of
obvious
rejects
Waste
Reduction
Study
conducted
48
111
Not
applicable
2
5
14
14
7
Research
/
Evaluation
Table
29.
Pollution
Prevention
Benefits
by
Technique
Technique
Number
of
Number
of
Number
of
P2
BENEFIT
"Yes"
"No"
Manual
Vs.
Responses
Responses
Automatic
1
=
low
success,
5
=
high
success
Responses
1
2
3
4
5
September
1998
95
F006
Benchmarking
Study
Evaluation
of
recycling
alternatives
59
100
Not
applicable
4
7
16
13
8
Increasing
drain
time
over
process
55
104
Not
applicable
4
7
16
13
8
tanks
Research
of
alternative
plating
51
108
Not
applicable
6
7
10
6
13
technologies
Development
of
tracking
system
19
140
Not
applicable
4
0
7
1
3
for
monitoring
flow
from
different
areas
Monitoring
of
incoming
water
with
26
133
Not
applicable
3
0
4
6
4
strict
control
program
Two
separate
labs
for
process
2
157
Not
applicable
0
0
1
1
0
chemistry
Elimination
/
Replacement
/
Substitutions
Eliminate
obsolete
processes
57
102
Not
applicable
1
2
16
14
14
and/
or
unused
or
infrequently
used
processes
Replace
cyanide­
based
plating
56
103
Not
applicable
3
2
6
7
24
solution
with
alkaline­
based
solutions
Elimination
of
rinse
waters
to
25
134
Not
applicable
3
2
4
5
3
waste
treatment
(nickel,
chrome)
Substitution
of
chromate
and
2
157
Not
applicable
0
0
2
0
0
dichromate
sealer
with
nonchromate
sealer
Elimination
of
plating
services
48
111
Not
applicable
1
3
7
8
15
(cadmium,
tin,
nickel,
copper,
brass,
and
hard
chrome)
Elimination
of
vapor
degreasing
46
113
Not
applicable
1
1
4
3
29
Implementation
of
a
multi­
stage
30
129
Not
applicable
2
1
3
5
14
cyanide
destruct
system
Elimination
of
chelated
cleaners
34
125
Not
applicable
0
1
5
9
10
Other,
specify
5
6
Not
applicable
0
0
0
3
3
Table
29.
Pollution
Prevention
Benefits
by
Technique
Technique
Number
of
Number
of
Number
of
P2
BENEFIT
"Yes"
"No"
Manual
Vs.
Responses
Responses
Automatic
1
=
low
success,
5
=
high
success
Responses
1
2
3
4
5
September
1998
96
F006
Benchmarking
Study
E
­
Additional
3
156
Not
applicable
n/
a
n/
a
n/
a
n/
a
n/
a
September
1998
97
F006
Benchmarking
Study
n.
Waste
Minimization
Techniques
by
Generating
Process
Table
30
summarizes
the
types
of
waste
minimization
techniques
reported
by
facilities
that
conducted
only
one
type
of
plating.
The
four
processes
were
selected
for
analysis
because
they
are
most
representative
of
the
plating
industry
and
the
most
problematic
from
a
regulatory
perspective.
A
handful
of
facilities
only
performed
tin
plating,
bright
dip,
and
sulfuric
acid
anodizing.

Table
30.
Summary
of
Waste
Minimization
Techniques
TECHNIQUE
NICKEL
COPPER
CHROME
ZINC
CADMIUM
Reduce
drag­
out
losses
55
47
23
62
30
Reduce
rinse
water
use
67
52
25
78
36
Training
and
programs
subtotal
53
41
21
78
28
Procedures
subtotal
52
43
20
55
26
F006
volume
reduction
subtotal
68
52
33
54
36
Inspections
/
maintenance
subtotal
42
34
15
72
23
Research
/
evaluations
subtotal
41
34
13
45
20
Elimination
/
Replacement
/
Substitutions
54
41
20
63
26
Various
operating
practices
310
245
122
159
Total
o.
Impact
of
Waste
Minimization
Projects
on
Wastewater
Discharge
Rates
[E2]

Number
of
positive
responses:
63
Number
of
negative
responses:
156
p.
Recycle
and
Recovery
Technologies
[E3]

Table
31
summarizes
the
use
of
recycle
and
recovery
technologies.

Table
31.
Summary
of
Recycling
and
Recovery
Technologies
TECHNIQUE
Number
of
Positive
Responses
Number
of
Negative
Responses
Electrodialysis
7
152
Electrowinning
26
133
Evaporator
39
120
Ion
flotation
1
158
Ion
exchange
28
131
Mesh
pad
mist
eliminator/
recycle
15
144
Reverse
osmosis
8
151
Ultrafiltration
5
154
Other
11
2
q.
Solution
Maintenance
Techniques
[E4]

Table
32
summarizes
the
solution
maintenance
techniques.

Table
32.
Summary
of
Solution
Maintenance
Techniques
TECHNIQUE
#
of
Positive
Responses
#
of
Negative
Responses
Acid
retardation
1
158
Carbon
treatment
(batch)
46
113
Carbon
treatment
(continuous)
40
119
Table
32.
Summary
of
Solution
Maintenance
Techniques
TECHNIQUE
#
of
Positive
Responses
#
of
Negative
Responses
September
1998
98
F006
Benchmarking
Study
Dummying
of
metal
contaminants
56
103
Electrodialysis
for
inorganic
56
155
contaminants
Carbonate
freezing
24
135
Filtration,
in­
tank
53
106
Filtration,
external
51
108
High
pH
treatment
16
143
Precipitation
20
139
Liquid/
Liquid
extraction
2
157
Microfiltration
1
158
Ultrafiltration
1
158
Other,
specify
0
1
September
1998
99
F006
Benchmarking
Study
Appendix
A:
Summary
of
the
10
Issue
Areas
Identified
for
the
Metal
Finishing
Sector
September
1998
100
F006
Benchmarking
Study
Issue
1.
Operational
Flexibility
Industry
performance
leaders
would
receive
operational
flexibility
(i.
e.,
less
burdensome
permitting,
monitoring,
and
reporting
requirements)
in
recognition
of
their
good
performance
and
as
an
incentive
to
seek
the
ambitious
performance
goals.

Issue
2:
Waste
Minimization
and
Recovery
The
first
phase
of
this
project
was
a
bench
marking
analysis
of
F006
constituents,
using
national
and
regional
sampling
data.
The
data
generated
in
the
bench
marking
study
will
be
used
by
the
RCRA
Project
Team
to
develop
and
assess
options
for
reducing
barriers
to
pollution
prevention
and
on­
site
and
off­
site
metal
recovery
requirements.

Issue
3:
Reporting
and
Right­
to­
Know
This
project
applies
business
process
reengineering
techniques
to
examine
federal,
state,
and
local
reporting
requirements
for
metal
finishers
across
all
environmental
media.

Issue
4:
Compliance
Tools
and
Assistance
This
project
is
designed
to
overcome
barriers
to
improved
compliance
and
pollution
prevention
by
combining
pollution
prevention
assistance
and
enforcement
relief
policies
as
an
incentive
for
improved
environmental
performance
by
metal
finishers.

Issue
5:
Research
and
Technology
The
National
Metal
Finishing
Environmental
R&
D
Plan
is
a
customer­
oriented
R&
D
strategy
for
risk
characterization,
exposure
assessment,
and
technology
transfer
for
metal
finishers,
communities,
and
other
stakeholders.

Issue
6:
Industrial
Pretreatment
The
POTW
Pretreatment
Project
is
designed
to
identify
ways
to
improve
the
capabilities
of
POTW
manage
their
industrial
users
by
reducing
mass
pollutant
loadings
without
limiting
industry
activity,
and
to
provide
the
most
effective
POTW
with
increased
managerial
flexibility
to
achieve
higher
environmental
quality
at
lower
cost.

Issue
7:
Environmentally
Responsible
Site
Transition
This
project
develops
a
government
sponsored
"exit
strategy"
for
metal
finishers
who
wish
to
get
out
of
the
business
that
reduces
future
contaminated
"orphan
industrial
sites."

Issue
8:
Enforcement
for
Chronic
Non­
Complier
This
project
develops
a
sector­
based,
targeted
enforcement
program
for
government
at
all
level
to
identify
chronic
non­
complier
and
take
appropriate
action
against
them.

Issue
9:
Access
to
Capital
This
project
focuses
on
developing
innovative
approaches
for
improving
access
to
capital
for
metal
finishers
and
electronics
firms.
September
1998
101
F006
Benchmarking
Study
Appendix
B:
F006
Management
Contained
in
EPA's
1995
Biennial
Report
Database
September
1998
102
F006
Benchmarking
Study
Waste
Management
Facilities:
This
appendix
lists
the
names
of
hazardous
waste
landfill
facilities
contained
in
EPA's
1995
Biennial
Report
that
reported
accepting
and
/or
managing
F006
waste.
The
table
includes
the
quantities
of
F006
waste
managed
by
each
facility,
the
facility's
EPA
ID,
and
the
number
of
shipments
the
facility
received.

Table
1:
F006
Waste
Managed
in
Landfills
Number
of
RCRA
large
quantity
generators
(greater
than
1000kg/
month)
who
sent
F006
waste
off­
site
to
a
RCRA
landfill
in
1995
=
283
Volume
of
F006
generated
on­
site
and
shipped
off­
site
to
a
landfill
=
80,298.370
tons
Volume
of
F006
generated
on­
site
and
managed
in
a
landfill
on­
site
=
18,782.832
tons
(2
facilities,
not
including
TSDs)

Total
volume
generated
and
managed
in
landfills
=
99,081.202
tons
Landfills
that
Accept/
Manage
F006
Waste,
by
State:

Number
EPA
ID
Company
Managed
On­
site
On­
site
Rcvd
Form
Qty
"Generated"
Qty
Rcvd
&
#
of
&
Managed
Shpmts
GM/
WR
1
ALD000622464
Chemical
Waste
Management,
Inc.
496.179
15
WR
2
CAD000633164
Laidlaw
Environmental
Services,
Inc.
94.800
4
WR
3
CAT000646117
Chemical
Waste
Management,
Inc.
260.000
GM
4
COD991300484
Highway
36
Land
Development
Co.
4,319.438
7
GM,
WR
5
IDD073114654
Envirosafe
Services
of
Idaho
138.955
20
WR
6
ILD000805812
Peoria
Disposal
Co.
5,208.628
GM
7
IND016584641
Midwest
Steel
Division
17,308.400
GM
8
IND078911146
Chemical
Waste
Management,
Inc.
118.300
3,015.950
34
GM,
WR
9
IND980503890
Heritage
Environmental
Services,
Inc.
68,213.625
1
WR
10
KSD057889313
Ashland
Chemical
Co.
1.800
1
WR
11
LAD000777201
Chemical
Waste
Management,
Inc.
44,939.950
45
WR
12
MID000724831
Michigan
Disposal
Waste
Treatment
43,259.000
GM
13
MID048090633
Wayne
Disposal
Site
#2
Landfill
45,070.380
9
WR
14
NJD002385730
E.
I.
DuPont
de
Nemours
&
Co.
Inc.
10,030.000
GM
15
NYD049836679
CWM
Chemical
Services
60.170
4
WR
16
OHD045243706
Envirosafe
Services
of
Ohio
Inc.
236.490
13,558.665
54
GM,
WR
17
OKD065438376
U.
S.
Pollution
Control
Inc.
3,403.746
17
WR
18
ORD089452353
Chemical
Waste
Management,
Inc.
121.602
3,810,086.0
20
GM,
WR
19
SCD070375985
Laidlaw
Env.
Svs.
of
SC
Inc.
0.530
2,843.1
491
GM,
WR
20
TND980847024
Excel
TSD
Inc.
1.310
GM
21
TXD069452340
Texas
Ecologists,
Inc.
1,800.2
3
WR
22
UTD982598898
Envirocare
of
Utah
4,431.8
7
WR
23
UTD991301748
USPCI
Grassy
Mountain
Facility
6,859.9
7
WR
24
WAD041337130
Boeing
­
Auburn
115,193.0
2
WR
25
WAD041585464
Boeing
Commercial
Airplane
Group
WR
Everett
Totals
78,018.7
47,026.0
2
GM
=
Reported
on
Biennial
Report
GM
form:
identifies
generators
who
manage
F006
in
an
onsite
landfill.

WR
=
Reported
on
WR
form:
identifies
off­
site
facilities
that
receive
and
manage
F006
in
a
landfill.
September
1998
103
F006
Benchmarking
Study
Table
2
lists
recycling
facilities
contained
in
EPA's
1995
Biennial
Report
that
reported
accepting
and/
or
managing
F006
waste
in
1995.
The
table
includes
the
quantities
of
F006
waste
managed
by
each
facility,
the
facility's
EPA
ID,
the
number
of
shipments
the
facility
received,
recovery
system
used,
and
a
system
description.

Table
2:
F006
Waste
Managed
by
Metals
Recovery
Number
of
generators
who
send
F006
waste
off­
site
to
metals
recovery
=
824
Volume
of
F006
generated
on­
site
and
shipped
off­
site
for
metals
recovery
=
64,670.462
tons
Volume
of
F006
generated
on­
site
and
managed
on­
site
by
metals
recovery
=
217,292.304
tons
(9
facilities)

Therefore,
total
volume
of
F006
generated
and
managed
by
metals
recovery
=
281,962.766
tons
Quantities
and
Number
of
Facilities/
Streams
that
Shipped
F006
Off­
site
for
Metals
Recovery
System
System
Description
Qty
Shipped
Off­
site
#
of
Facilities
#
of
Streams
M011
High
temperature
metals
recovery
18,252.113
159
179
M012
Retorting
295.301
4
12
M013
Secondary
smelting
11,958.071
74
89
M014
Other
metals
recovery
for
reuse
(iron
exchange,
etc.)
16,707.303
278
320
M019
Metals
recovery
­
type
unknown
17,457.674
309
370
Totals
64,670.462
824
970
September
1998
104
F006
Benchmarking
Study
Metals
Recovery
Facilities
that
Accept/
Manage
F006
Waste
Number
EPA
ID
Company
Managed
On­
site
Managed
On­
site
Shpmts
Rcvd
System
Description
Form
Qty
Generated
&
Qty
Rcvd
&
#
of
Recovery
System
GM/
WR
1
CAD981695729
Pacific
Circuit
Services
74.000
M014
Other
metals
recovery
for
reuse
GM
2
CAT000612150
Engelhard
West,
Inc.
25.314
M011
High
temp.
metals
recovery
GM
3
COD082657420
Schlage
Lock
Company
0.616
M014
Other
metals
recovery
for
reuse
GM
4
ILD005087630
United
Refining
&
Smelting
Co.
87.186
2
M011
High
temp.
metals
recovery
WR
5
ILD984766279
Hydromet
Environmental
Inc.
138.880
3
M014
Other
metals
recovery
for
reuse
WR
6
LAD058472721
Amax
Metals
Recovery
Inc.
27.300
3
M014
Other
metals
recovery
for
reuse
WR
7
MID047153077
Production
Plated
Plastics,
Inc.
192,351.977
M014
Other
metals
recovery
for
reuse
GM
8
MID981099435
Lacks
­
Airplane
24,603.837
M014
Other
metals
recovery
for
reuse
GM
9
NYD001325661
Lea
Ronal
Inc.
0.864
1
M011
High
temp.
metals
recovery
WR
10
NYD086225596
AT&
T
Nassau
Metals
0.741
4
M011
High
temp.
metals
recovery
WR
11
OHD061614673
Dayton
Water
Systems
57.700
17
M014
Other
metals
recovery
for
reuse
WR
12
PAD087561015
Inmetco
Inc.
4,839.448
97
M011
High
temp.
metals
recovery
WR
13
RID062309299
Hallmark
Healy
Group
Inc.
207.745
M013
Secondary
smelting
GM
14
RID063890214
Boliden
Metech
Inc.
95.120
3
M014
Other
metals
recovery
for
reuse
WR
15
RID981886104
Gannon
&
Scott
Inc.
1.455
4
M011
High
temp.
metals
recovery
WR
16
TXD008117186
Encycle/
Texas,
Inc.
7,938.630
244
M014
Other
metals
recovery
for
reuse
WR
17
TXD072181969
Metal
Coatings
Corp.
5.930
M011
High
temp.
metals
recovery
GM
18
TXD981514383
Alpha
Omega
Recycling
Inc.
15.460
1,028.440
67
M014
Other
metals
recovery
for
reuse
GM,
WR
19
WID006129522
Krueger
International
7.425
M014
Other
metals
recovery
for
reuse
GM
Totals
217,292.304
14,215.763
445
GM
=
Reported
on
Biennial
Report
GM
form:
identifies
generators
who
manage
F006
in
an
onsite
landfill.

WR
=
Reported
on
WR
form:
identifies
off­
site
facilities
that
receive
and
manage
F006
in
a
landfill.
September
1998
105
F006
Benchmarking
Study
Appendix
C:
Observed
F006
Handling
Practices
at
Metal
Finishing
Facilities
and
List
of
Worker
Health
and
Safety
Regulations
September
1998
106
F006
Benchmarking
Study
Description
of
F006
Generation
and
Handling
at
Metal
Finishing
Facilities
Diagram
1
presents
a
generic
F006
waste
generation
and
handling
process.
Electroplating
process
wastewaters
are
treated
through
multiple
processes
to
form
a
slurry/
precipitate.
The
slurry/
precipitate
is
sent
to
a
filter
press
where
excess
water
is
separated
by
the
filter
press.
The
moist
F006
drops
from
the
filter
press
to
a
cart,
supersack,
roll­
off
box
or
to
a
sludge
drier.
When
used
a
sludge
drier
reduces
the
amount
of
water
in
the
sludge
and
reduces
its
volume.
After
drying
or
in
the
moist
state,
the
F006
is
either
taken
away
by
a
recycler
or
hazardous
materials
handler
to
its
final
destination.
Diagram
1­
Generic
Flow
Diagram
of
F006
After
Wastewater
Treatment
to
Final
Storage*

Filter
Press
Luggerbox,
Cart
Superbag
or
Filterbag
Sludge
Drier
Roll­
off
Box
Sludge
Drier
Superbags
Hopper
Superbags
Drum
Superbags
Precipitator
Roll­
off
Box
Roll­
off
Box
*Flow
diagram
generated
from
Chicago
ESVs
conducted
during
CSI
Project
10/
97
Filter
Press
Superbags
Drum
Superbags
Superbags
Drum
Roll­
off
Box
(Plate/
Frame
or
Bag)

September
1998
107
F006
Benchmarking
Study
September
1998
108
F006
Benchmarking
Study
Health
and
Safety
Regulations
and
Guidelines
This
section
provides
a
list
of
worker
and
safety
regulations,
policies,
guides
and
operating
procedures
which
may
apply
to
on­
site
and
off­
site
management
of
F006
waste.
All
of
OSHA
General
Industry
Standards
are
applicable.
In
addition,
OSHA
Construction
Industry
Standards
would
be
applicable
to
construction
activities
at
these
facilities.

Table
1
­
List
of
Regulations,
Policies,
and
Guidelines
Agency/
Organization
Title
of
Regulation
Location
of
Regulation
EPA
Personnel
Training
40
CFR
§262.34(
a)(
4)
and
40
CFR
§265.16
Preparedness
and
Prevention
40
CFR
§265,
Subpart
C
Contingency
Plan
and
Emergency
Procedures
40
CFR
§265,
Subpart
D
Use
and
Management
of
Containers
40
CFR
§265,
Subpart
I
Best
Management
Practices
for
Pollutant
40
CFR
§125.104
Dischargers
OSHA
Walking­
Working
Surfaces
29
CFR
§1910.22
Guarding
floor
&
wall
openings
&
holes
29
CFR
§1910.23
Fixed
Industrial
Stairs
29
CFR
§1910.24
Fixed
Ladders
29
CFR
§1910.27
Scaffolds
29
CFR
§1910.28
Means
of
Egress
29
CFR
§1910.37
Emergency
Action
Plan
Implementation
29
CFR
§1910.38(
a)

Fire
Prevention
Plan
Implementation
29
CFR
§1910.38(
b)

Powered
Platform
Operation
29
CFR
§1910.66
Ventilation
29
CFR
§1910.94
Hearing
Conservation
29
CFR
§1910.95
Flammable
and
Combustible
Liquids
29
CFR
§1910.106
Dip
Tanks
Containing
Flammable
or
Combustible
29
CFR
§1910.108
Liquids
Process
Safety
Management
of
Highly
Hazardous
29
CFR
§1910.119
Chemicals
OSHA
(cont.)
Hazardous
Waste
Operations
(HAZWOPER)
29
CFR
§1910.120
Training
Personal
Protective
Equipment
29
CFR
§1910.132
Eye
&
Face
Protection
29
CFR
§1910.133
Respirator
Requirements
29
CFR
§1910.134
Table
1
­
List
of
Regulations,
Policies,
and
Guidelines
Agency/
Organization
Title
of
Regulation
Location
of
Regulation
September
1998
109
F006
Benchmarking
Study
Head
Protection
29
CFR
§1910.135
Electrical
Protective
Devices
29
CFR
§1910.137
Sanitation
29
CFR
§1910.141
Confined
Space
29
CFR
§1910.146
Lockout/
Tagout
29
CFR
§1910.147
Medical
Services
&
First
Aid
29
CFR
§1910.151
Fire
Extinguisher
Use
29
CFR
§1910.157
Fixed
Extinguishing
Systems
29
CFR
§1910.160
Air
Receivers
29
CFR
§1910.169
Materials
Handling
29
CFR
§1910.176
Powered
Industrial
Trucks
(Forklift
Operations)
29
CFR
§1910.178
Overhead
and
Gantry
Cranes
29
CFR
§1910.179
Machines,
General
Requirements
29
CFR
§1910.212
Mechanical
Power
Presses
29
CFR
§1910.217
Hand
and
Portable
Powered
Tools
and
Equipment,
29
CFR
§1910.242
General
Welding,
Cutting,
Brazing
­
Definitions
29
CFR
§1910.251
Welding,
Cutting,
Brazing
­
General
Requirements
29
CFR
§1910.252
Electrical
Systems
29
CFR
§1910.301
Air
Contaminants
(PELs)
29
CFR
§1910.1000
Inorganic
Arsenic
29
CFR
§1910.1018
Lead
29
CFR
§1910.1025
Cadmium
29
CFR
§1910.1027
Hazard
Communication
29
CFR
§1910.1200
OSHA
(cont.)
Occupational
Exposure
to
Hazardous
Chemicals
in
29
CFR
§1910.1450
Laboratories
DOT
HAZMAT
Transport
Training
49
CFR
§173
ACGIH*
Threshold
Limit
Values
(TLVs)
Guidelines
only
in
"1996
TLVs
and
BEIs"

*ACGIH
(TLVs)
are
not
legally
enforceable
F006
Handling
Practices
That
May
be
Used
to
Minimize
Potential
Hazards
September
1998
110
F006
Benchmarking
Study
Table
2
summarizes
F006
handling
practices
observed
at
Milwaukee,
Chicago,
and
Phoenix
metal
finishing
facilities.
This
table
represents
observed
practices
not
recommended
best
management
practices.

Table
2
­
F006
Handling
Activities
Observed
in
Regional
Benchmarking
Study
Work
Activity
Potential
Hazard
Hazard
Control
Method
Paddling
wet
F006
sludge
cake
Skin
exposure
to
sludge,
Personal
Protective
Equipment
(eye
from
the
filter
press
into
a
ingestion
hazard,
Physical
body
protection,
gloves,
respirator,
non
slip
boots),
lugger
box,
cart,
or
drum
damage,
slip
hazard,
possible
ergonomics
Training
dust
hazard
Replacing
worn
or
damaged
Skin
exposure
to
sludge,
Personal
Protective
Equipment
(eye
filter
cloths
in
the
filter
press.
ingestion
hazard,
Physical
protection,
gloves,
respirator),
Training,
damage
to
body
appendages
if
Means
of
locking
out
filter
press
press
is
activated
Shoveling
dried
F006
sludge
Inhalation
of
metal
dust
Personal
Protective
Equipment
(eye
into
supersacks,
luggerboxes,
particles,
Skin
exposure
to
dust,
protection,
gloves,
respirator),
Training
on
or
drums.
ingestion
hazard,
Physical
lifting
lifting
hazards,
confined
space
entry
Shoveling
dried
F006
sludge
Inhalation
of
metal
dust
Personal
Protective
Equipment
(eye
into
a
roll­
off
box
particles,
Skin
exposure
to
dust,
protection,
gloves,
respirator),
ergonomic
ingestion
hazard,
Physical
lifting
training
on
lifting
activities
hazards
Manually
moving
cart
or
Inhalation
of
metal
dust,
skin
Personal
Protective
Equipment
(eye
lugger
box
to
supersack
or
exposure,
ingestion
hazard,
protection,
gloves,
respirator),
ergonomic
roll­
off
box
Physical
hazard
training
Operation
of
overhead
crane
to
Physical
hazard
of
falling
objects,
Personal
Protective
Equipment
transport
cart
or
lugger
box
to
Crane
failure,
Inhalation
of
metal
Training
on
crane
operation,
crane
inspection
roll­
off
box
dust
program
Opening/
closing
a
roll­
off
box
Inhalation
of
metal
dust
particles,
Forklift
Training,
Personal
Protective
manually
or
with
a
forklift
Skin
exposure
to
dust,
ingestion
Equipment,
Standard
Operating
Procedures
hazard,
Forklift
operation
safety
(SOPs)
hazards,
Physical
lifting
damage
Changing
the
filter
to
the
sludge
Inhalation
of
metal
dust
particles,
Personal
Protective
Equipment
(eye
protection,
drier.
Skin
exposure
to
dust,
ingestion
gloves,
respirator),
Training,
means
of
locking
hazard,
drier
lock­
out
out
drier
to
prevent
accidental
operation
Any
work
activity
in
the
sludge
Inhalation
of
metal
dust
particles,
Personal
Protective
Equipment
(respirator,
eye
drier
room.
Skin
exposure
to
dust,
ingestion
protection,
hearing
protection)
hazard,
noise
exposure,
eye
hazard
Sampling
the
F006
sludge
(wet
Inhalation
of
metal
dust
particles,
Personal
Protective
Equipment
(eye
protection,
or
dry)
Skin
exposure
to
dust,
ingestion
gloves,
respirator)
hazard
Table
2
­
F006
Handling
Activities
Observed
in
Regional
Benchmarking
Study
Work
Activity
Potential
Hazard
Hazard
Control
Method
September
1998
111
F006
Benchmarking
Study
Housekeeping
Inhalation
of
metal
dust
particles,
Personal
Protective
Equipment
(eye
protection,
(i.
e.,
cleaning
roll­
off
box)
Skin
exposure
to
sludge
or
dust,
gloves,
respirator)
ingestion
hazard,
Physical
lifting
Means
of
locking­
out
Filter
press
hazards,
Slip/
trip/
fall
hazards,
Discharge
of
F006
while
cleaning
the
inside
of
the
roll­
off
box,
confined
space
entry
Any
work
activity
in
noisy
areas
Noise
exposure
Personal
Protective
Equipment
(hearing
(wastewater
treatment
pumps)
protection)

Forklift
operation
a
lugger
box,
Forklift
operation
safety
hazards
Forklift
Training,
Personal
Protective
drum,
or
bag.
Equipment
(respirator),
Standard
Operating
Procedures
(SOPs)

"Wet"
sludge
as
the
term
is
used
here
is
that
sludge
produced
after
the
filter
press
which
constitutes
about
25­
60
%
solids.
"Dry"
sludge
is
produced
by
the
sludge
drier
and
constitutes
about
90%
solids.

Personal
Protective
Equipment
Guidance
The
National
Institute
for
Occupational
Safety
and
Health
(NIOSH)
is
the
government
agency
responsible
for
performing
health
and
safety
studies
and
making
health
and
safety
recommendations.
NIOSH
has
recommended
personal
protective
equipment
and
sanitary
measures
for
handling
specific
chemicals
and
substances.
Table
3
is
extracted
from
the
NIOSH
"Pocket
Guide
to
Chemical
Hazards"
recommending
protective
equipment
and
sanitary
measures
for
specific
chemicals
and
substances
commonly
found
in
F006
waste.
This
is
not
an
all
inclusive
list,
for
example,
respirators
were
not
addressed.
These
recommendations
supplement
general
work
practices
(e.
g.,
no
eating,
drinking,
or
smoking
where
chemicals
are
used.)

Table
3
­
NIOSH
Recommended
Personal
Protection
and
Sanitation
Contaminant
Skin:
Eyes:
Wash
Skin:
Remove
Change
Provide:
Clothing:
Clothing:

Aluminum
N.
R.
N.
R.
N.
R.
N.
R.
N.
R.

Antimony
Prevent
skin
Prevent
eye
When
When
wet
or
Daily
contact
contact
contaminated
contaminated
Arsenic
Prevent
skin
Prevent
eye
When
When
wet
or
Daily
Eyewash,
contact
contact
contaminated
contaminated
Quickdrench
and
daily
Barium
Prevent
skin
Prevent
eye
When
When
wet
or
Daily
chloride/
nitrate
contact
contact
contaminated
contaminated
(ASRA)

Beryllium
Prevent
skin
Prevent
eye
Daily
When
wet
or
Daily
Eyewash
contact
contact
contaminated
Contaminant
Skin:
Eyes:
Wash
Skin:
Remove
Change
Provide:
Clothing:
Clothing:

September
1998
112
F006
Benchmarking
Study
Bismuth
as
Prevent
skin
Prevent
eye
When
When
wet
or
N.
R.
Eyewash,
telluride
doped
contact
contact
contaminated
contaminated
Quickdrench
with
selenium
sulfide
Cadmium
N.
R.
N.
R.
Daily
N.
R.
Daily
Chlorine
Frostbite
Frostbite
N.
R.
N.
R.
N.
R.
Frostbite
protection
Chromium
N.
R.
N.
R.
N.
R.
N.
R.
N.
R.

Chromium
III
Prevent
skin
Prevent
eye
When
When
wet
or
N.
R.
contact
contact
contaminated
contaminated
Cobalt
Prevent
skin
N.
R.
When
When
wet
or
Daily
contact
contaminated
contaminated
Copper
Prevent
skin
Prevent
eye
When
When
wet
or
Daily
contact
contact
contaminated
contaminated
Cyanide
Prevent
skin
Prevent
eye
When
When
wet
or
Daily
contact
contact
contaminated
contaminated
Iron
N.
R.
N.
R.
N.
R.
N.
R.
N.
R.

Lead
Prevent
skin
Prevent
eye
Daily
When
wet
or
Daily
contact
contact
contaminated
Manganese
N.
R.
N.
R.
N.
R.
N.
R.
N.
R.

Mercury
Prevent
skin
N.
R.
When
When
wet
or
Daily
contact
contaminated
contaminated
Nickel
Preven
skin
N.
R.
When
When
wet
or
Daily
contact
contaminated/
contaminated
daily
Platinum
N.
R.
N.
R.
N.
R.
N.
R.
Daily
Platinum
Prevent
skin
Prevent
eye
When
When
wet
or
Daily
(soluble
salts)
contact
contact
contaminated
contaminated
Selenium
Prevent
skin
N.
R.
When
When
wet
or
N.
R.
contact
contaminated
contaminated
Silver
Prevent
skin
Prevent
eye
When
When
wet
or
Daily
contact
contact
contaminated
contaminated
Sodium
Prevent
skin
Prevent
eye
When
When
wet
or
Daily
Eyewash,
hydroxide
contact
contact
contaminated
contaminated
Quickdrench
Sulfur
dioxide
Frostbite
Frostbite
N.
R.
When
wet
or
N.
R.
Frostbite
contaminated
protection
Tin
N.
R.
N.
R.
N.
R.
N.
R.
N.
R.
Contaminant
Skin:
Eyes:
Wash
Skin:
Remove
Change
Provide:
Clothing:
Clothing:

September
1998
113
F006
Benchmarking
Study
Vanadium
Prevent
skin
Prevent
eye
When
When
wet
or
Daily
contact
contact
contaminated
contaminated
Zinc
N.
R.
N.
R.
N.
R.
N.
R.
N.
R.

Notes:
Skin
­
Recommends
the
need
for
personal
protective
equipment
Eyes
­
Recommends
the
need
for
eye
protection.
Wash
skin
­
Recommends
when
workers
should
wash
the
spilled
chemical
from
the
body
in
addition
to
normal
washing.
Remove
­
Advises
workers
when
to
remove
clothing
that
has
accidentally
become
wet
or
significantly
contaminated.
Change
­
Recommends
whether
the
routine
changing
of
clothing
is
needed.
Provide
­
Recommends
the
need
for
eyewash
fountains
and/
or
quick
drench
facilities.
These
recommendations
supplement
general
work
practices
(e.
g.,
no
eating,
drinking,
or
smoking
where
chemicals
are
used.)
N.
R.
­
No
recommendation
specified
References
ACGIH.
1996
Threshold
Limit
Values
and
Biological
Exposure
Indices
for
Chemical
Substances
and
Physical
Agents.
Cincinnati,
OH:
American
Conference
of
Governmental
Industrial
Hygienists,
1996.

Cushnie,
Jr.,
George.
Pollution
Prevention
and
Control
Technology
for
Plating
Operations.
Ann
Arbor,
MI:
National
Center
for
Manufacturing
Sciences,
1994.

EPA.
Development
Document
for
Existing
Source
Pretreatment
Standards
for
the
Electroplating
Point
Source
Category.
EPA
440/
1­
79/
003,
Washington,
D.
C.:
Environmental
Protection
Agency,
August
1979.

NIOSH.
NIOSH
Pocket
Guide
to
Chemical
Hazards.
DHHS
(NIOSH)
Publication
No.
94­
116.
Washington,
D.
C.:
U.
S.
Government
Printing
Office,
1997.

OSHA
Regulations
(Standards
­
29
CFR)
­
Part
1910
Occupational
Safety
and
Health
Standards,
http://
www.
osha­
slc.
gov/
OshStd_
toc/
OSHA_
Std_
toc_
1910.
html
September
1998
114
F006
Benchmarking
Study
Appendix
D:
Checklist
Used
to
Identify
Pollution
Prevention
Technologiesat
Metal
Finishing
Facilities
September
1998
115
F006
Benchmarking
Study
P2
Technology
T
T
Comment
1.
SPENT
PLATING
SOLUTIONS
General
Bath
Life
Extension
C
C
Filtration
C
C
Carbon
Treatment
C
C
Replenishment
C
C
Purified
Water
C
C
Electrolytic
Dummying
C
C
Cyanide
Bath
Carbonate
Freezing
C
C
Precipitation
C
C
Monitoring
C
C
Housekeeping
C
C
Drag­
in
Reduction
C
C
Purer
Anodes
and
Bags
C
C
Ventilation/
Exhaust
Systems
Hexavalent
Chrome
Alternatives
Trivalent
chrome
Non­
chrome
conversion
coatings
Nonchelated
Process
Chemistries
Continuous
filtration
Non­
cyanide
Process
Chemicals
Solvent
Degreasing
Alternatives
Hot
alkaline
cleaning
Electrocurrent
Ultrasonic
Alkaline
Cleaners
Filtration
(Micro/
Ultra)
Skimming
Coalescer
Caustic
Etch
Solution
Regeneration
Acid
Purification
Ion
Exchange
2.
DRAG­
OUT
REDUCTION
C
C
Process
Bath
Operating
Concentration
and
Temperature
C
C
Wetting
Agents
P2
Technology
T
T
Comment
September
1998
116
F006
Benchmarking
Study
C
C
Workpiece
Positioning
C
C
Withdrawal
and
Drainage
Time
C
C
Air
Knives
C
C
Spray
or
Fog
Rinses
C
C
Plating
Baths
C
C
Drainage
Boards
C
C
Drag­
Out
Tanks
3.
DRAG­
OUT
RECOVERY
C
C
Evaporation
C
C
Ion
Exchange
C
C
Electrowinning
C
C
Electrodialysis
C
C
Reverse
Osmosis
C
C
Meshpad
Mist
Eliminators
4.
RINSE
WATER
Improved
Rinsing
Efficiency
C
C
Spray
Rinse/
Rinse
Water
Agitation
C
C
Increased
Contact
Time/
Multiple
Rinses
C
C
Countercurrent
Rinsing
Flow
Controls
C
C
Flow
Restrictors
C
C
Conductivity­
Actuated
Flow
Control
Recycling/
Recovery
C
C
Rinse
Water
C
C
Spent
Process
Baths
C
C
Solvents
September
1998
117
F006
Benchmarking
Study
Appendix
E:
Laboratory
Analysis
Information:
Constituents,
Methods,
and
Detection
Limits
Used
in
the
Benchmarking
Studies
September
1998
118
F006
Benchmarking
Study
Table
1.
Volatile
Organic
Target
Analytes
Method
8260A
CONSTITUENT
TARGET
DETECTION
LIMIT
(F
Fg/
Kg)

Chloromethane
5
Vinyl
Chloride
5
Bromomethane
5
Chloroethane
10
Trichlorofluoromethane
5
Acetone
10
2­
Chloroethyl
vinyl
ether
20
1,1­
Dichloroethene
5
Methylene
Chloride
5
Carbon
Disulfide
5
Vinyl
Acetate
10
1,1­
Dichloroethane
5
2­
Butanone
10
trans­
1,2­
Dichloroethene
5
cis­
1,2­
Dichloroethene
5
Chloroform
5
1,1,1­
Trichloroethane
5
Carbon
Tetrachloride
5
1,2­
Dichloroethane
5
Benzene
5
Trichloroethene
(TCE)
5
1,2­
Dichloropropane
5
Bromodichloromethane
5
4­
Methyl­
2­
pentanone
10
2­
Hexanone
10
cis­
1,3­
Dichloropropene
5
trans­
1,3­
Dichloropropene
5
1,1,2­
Trichloroethane
5
Toluene
5
Table
1.
Volatile
Organic
Target
Analytes
Method
8260A
CONSTITUENT
TARGET
DETECTION
LIMIT
(F
Fg/
Kg)

September
1998
119
F006
Benchmarking
Study
Dibromochloromethane
5
Tetrachloroethene
(PCE)
5
Chlorobenzene
5
Ethylbenzene
5
m,
p­
Xylenes
5
o­
Xylene
5
Styrene
5
Bromoform
5
1,1,2,2­
Tetrachloroethane
5
1,3­
Dichlorobenzene
5
1,4­
Dichlorobenzene
5
1,2­
Dichlorobenzene
5
September
1998
120
F006
Benchmarking
Study
Table
2.
Semivolatile
Organic
Target
Analytes
Method
8270B
­
Solid
Samples
CONSTITUENT
TARGET
DETECTION
LIMIT
(F
Fg/
Kg)

Phenol
660
bis(
2­
Chloroethyl)
ether
660
2­
Chlorophenol
660
2,3­
Dichlorobenzene
660
1,4­
Dichlorobenzene
660
Benzyl
alcohol
1300
1,2­
Dichlorobenzene
660
2­
Methylphanol
660
bis((
2­
Chloroisopropyl)
ether
660
4­
Methyphenol
660
N­
Nitroso­
di­
n­
propylamine
660
Hexachloroethane
660
Nitrobenzene
660
Isophorone
660
2­
Nitrophenol
660
2,4­
Dimethylphenol
660
bis(
2­
Chloroethoxy)
methane
660
Benzoic
acid
3300
2,4­
Dichlorophenol
660
1,2,4­
Trichlorobenzene
660
Naphthalene
660
4­
Chloroaniline
1300
Hexachlorobutadiene
660
4­
Chloro­
3­
methylphenol
1300
2­
Methylnaphthalene
660
Hexachlorocyclopentadiene
660
2,4,6­
Trichlorophenol
660
2,4,5­
Trichlorophenol
660
2­
Chloronaphthalene
660
Table
2.
Semivolatile
Organic
Target
Analytes
Method
8270B
­
Solid
Samples
CONSTITUENT
TARGET
DETECTION
LIMIT
(F
Fg/
Kg)

September
1998
121
F006
Benchmarking
Study
2­
Nitroaniline
3300
Dimethylphthalate
660
Acenaphthylene
660
2,6­
Dinitrotoluene
3300
3­
Nitroaniline
3300
Acenaphthene
660
2,4­
Dinitrophenol
3300
4­
Nitrophanol
3300
4­
Nitrophenol
660
Dibenzofuran
660
2,4­
Dinitrotoluene
660
Diethyphthalate
660
4­
Chlorophenyl­
phenylether
660
Fluorene
660
4­
Nitroaniline
3300
4,6­
Dinitro­
2­
methylphenol
3300
N­
Nitrosodiphenylamine
660
4­
Bromophenyl­
phenylether
660
Hexachlorobenzene
660
Pentachlorophenol
3300
Phenanthrene
660
Anthraoene
660
Carbazole
660
Di­
n­
butylphthalate
660
Fluoranthene
660
Pyrene
660
Butylbenzylphthalate
660
3,3'­
Dichlorobenzidine
1300
Benzo(
a)
anthracene
660
Table
2.
Semivolatile
Organic
Target
Analytes
Method
8270B
­
Solid
Samples
CONSTITUENT
TARGET
DETECTION
LIMIT
(F
Fg/
Kg)

September
1998
122
F006
Benchmarking
Study
bis(
2­
Ethylhexyl)
phthalate
660
Chrysene
660
Din­
octylphthalate
660
Benzo(
b)
fluoranthene
660
Benzo(
k)
fluoranthene
660
Benzo(
a)
pyrene
660
Indeno(
1,2,3­
cd)
pyrene
660
Dibenz(
a,
h)
anthracene
660
Benzo(
g,
h,
f)
perylene
660
September
1998
123
F006
Benchmarking
Study
Table
3.
Target
Analytes:
Metals
and
other
Inorganics
SW­
846
Target
Detection
Limits
1
Analyte
Method(
s)
Solid
mg/
kg
Aluminum
6020
10
Antimony
6020
1
Arsenic
6020
2
Barium
6020
10
Beryllium
6020
1
Bismuth
6020
1
Cadmium
6020
1
Calcium
6020
100
Chromium
6020
2
Copper
6020
1
Iron
6020
10
Lead
6020
0.6
Magnesium
6020
100
Manganese
6020
3
Mercury
7471
0.1
Nickel
6020
1
Selenium
6020
1
Silver
6020
1
Sodium
6020
100
Tin
6020
1
Zinc
6020
4
Chloride
SM
300.0
NR
Fluoride
SM
340.2
NR
Cyanide
(total
and
amenable)
9010
NR
Hexavalent
chromium
3060A/
7196A
NR
S)))))))))))))))))))))))))))))))))))))
Notes:

1
The
target
detection
limits
provided
are
for
reference
purposes.
The
actual
method
detection
limits
are
sample
dependent
and
may
vary
as
the
sample
matrix
varies.
NR
­
Not
required,
best
achievable
limit
by
laboratory
to
be
used.
September
1998
124
F006
Benchmarking
Study
Table
4.
TCLP
Compliance
Criteria
Analyte
Methods
Target
Quantitation
Limits
mg/
L
1
Metals
Arsenic
6020
5.0
Barium
6020
100.
Cadmium
6020
1.0
Chromium
6020
5.0
Lead
6020
5.0
Mercury
7470
0.2
Selenium
6020
1.0
Silver
6020
5.0
S)))))))))))))))))))))))))))))))))))))))))))))))
Q
Notes:

1.
All
methods
are
SW­
846
3rd
Ed.
September
1998
125
F006
Benchmarking
Study
Appendix
F:
Regional
Benchmarking
Survey
September
1998
126
F006
Benchmarking
Study
EPA's
CSI
Survey
of
10
Milwaukee
Platers
Instructions
The
National
Association
of
Metal
Finishers
(NAMF)
is
member
of
Environmental
Protection
Agency's
Common
Sense
Initiative
(CSI)
metal
finishing
sector
workgroup
and
is
participating
in
the
data
gather
effort
focusing
on
hazardous
waste
regulatory
issues
has
identified
the
need
to
compare
the
characteristics
of
F006
wastes
generated
today
with
F006
wastes
generated
at
the
time
of
the
listing
under
RCRA
(1980).
The
following
survey
will
be
used
to
evaluate
the
chemical
content
of
F006
generated
by
10
metal
finishing
facilities
from
Milwaukee.
This
information
will
be
used
to
characterize
F006,
evaluate
the
processes
generating
F006
and
the
level
of
pollution
prevention
practiced,
and
determine
the
recyclability
of
F006.
Please
note
that
this
survey
should
be
completed
using
available
information
or
best
engineering
judgement
and
that
you
are
not
required
to
generate
any
new
data.

Confidentiality:
If
you
believe
that
some
parts
of
the
information
supplied
by
your
are
commercially
sensitive,
you
may
claim
protection
for
your
data.
However
it
will
be
extremely
difficult
for
the
workgroup
to
use
any
data
that
is
considered
confidential
in
determining
the
F006
recyclability.
If
you
believe
your
information
to
be
sensitive,
it
may
be
blinded
in
order
for
the
workgroup
to
develop
a
final
report.

Return
the
completed
survey
within
10
days
from
date
of
receipt
to:

William
(Bill)
Sonntag
NAMF
2600
Virginia
Ave.
NW,
Suite
408
Washington,
DC
20037
Phone:
(202)
965­
5190
Fax:
(202)
965­
4037
The
survey
may
also
be
submitted
to
the
EPA
contractor
during
the
engineering
site
visit
and
sampling
effort.

For
technical
assistance,
call
Kristy
Allman,
SAIC
at
(703)
318­
4766.

Response
may
be
typed
or
handwritten
neatly.
Use
additional
paper
as
needed.

A.
Corporate
and
Facility
Information
Parent
Corporation
Name
of
Company/
Affiliate
Address
of
Corporation
Headquarters
Street
City
State
Zip
Name
of
Facility
Address
of
Facility
(if
different
from
above)

Street
City
State
Zip
RCRA
Hazardous
Waste
Generator
ID
Number:

POTW/
NPDES
Permit
Number:

PSD
Permit
Number:

Name(
s)
of
personnel
to
be
contacted
for
additional
information
pertaining
to
this
questionnaire
Name
Title
Telephone
September
1998
127
F006
Benchmarking
Study
Type
of
Facility:
Job
shop
Captive
shop
Number
of
Employees:

B.
Process
Flow
Diagram
The
purpose
of
this
question
is
to
provide
the
workgroup
with
an
overview
of
the
plating
operations
and
understanding
of
how
the
various
plating
operations
are
linked
together,
and
the
flow
of
wastewaters
to
the
waste
water
treatment
plant
(WWTP)
generating
the
F006
sludge.

The
workgroup
is
most
interested
in
the
following
commonly
used
processes:

C
zinc
plating
on
steel
C
nickel/
chromium
plating
on
steel
C
copper/
nickel/
chromium
plating
on
non­
ferrous
substrates
(zinc,
brass,
ABS)
C
copper
plating/
stripping
in
the
printed
circuit
industry
C
hard
chromium
plating
on
steel
C
cadmium
plating
Please
provide
a
general
process
block
flow
diagram
for
each
these
plating
processes
that
identifies
basic
plating
operation.
This
should
contain
general
information
on
feedstocks,
plating
solutions,
waste
generation,
etc.

Please
provide
a
brief
written
description
of
the
plating
process.
This
should
include:

C
Feed
stock,
intermediate,
or
product
storage
C
Waste
management
units
C
Waste
storage
and
shipping
equipment
C
Production
output
C
Waste
generation
C
Plating
sequence,
solutions,
and
substrates
C.
Wastewater
Treatment
Plant
Flow
Diagram
Please
provide
a
brief
description
of
the
treatment
process
wastewaters
go
through
to
remove
metals
and
other
toxic
substances
prior
to
discharge.
Please
discuss
the
following
steps
and
equipment
used
(as
applicable):

C
waste
stream
segregation
C
hexavalent
chrome
reduction
C
cyanide
oxidation
C
neutralization,
flocculation,
clarification,
effluent
polishing
C
sludge
dewatering
and
drying
C
sludge
blending
to
achieve
desired
concentration
C
sludge
storage
and
duration
D.
F006
Quantity
Generated
and
Management
Methods
D.
1.
What
was
the
total
product
weight
produced
by
your
facility
in
1995?
Long
Tons
or
Surface
area
(Circle
one)

D.
2.
Is
the
F006
generated
at
your
facility
process­
specific
or
is
it
combined
in
the
wastewater
treatment
plant?

D.
3.
What
was
the
total
quantity
of
F006
generated
in
1995?
Dry
tons
D.
4.
Estimate
the
quantity
of
F006
generated
from
each
process
in
1995?

Process
Quantity
(dry
tons)
September
1998
128
F006
Benchmarking
Study
D.
5.
Please
provide
a
description
of
any
onsite
recycling
of
your
F006.
Please
estimate
the
quantities
(dry
tons)
recycled
or
recovered.

D.
6.
Please
provide
the
name,
location,
brief
process
description
(e.
g.,
pyrometallurgical)
and
quantity
(dry
tons)
for
all
F006
sludge
that
is
sent
offsite
for
recycling/
metals
recovery.

D.
7.
Please
provide
the
name,
location,
management
method
(e.
g.,
Subtitle
C
landfill)
and
quantity
(dry
tons)
for
all
F006
sludge
that
is
sent
offsite
for
disposal.

D.
8.
What
is
the
quantity
of
F006
sludge
disposed
of
onsite?
Dry
tons
D.
9.
What
was
the
quantity
exported
outside
the
U.
S.
in
1995?
Dry
tons
E.
F006
Waste
Characterization
Please
provide
waste
characterization
analytical
data
sheets
for
your
F006
sludge.
Submit
both
Toxicity
Characteristic
Leaching
Procedure
(TCLP)
and
total
compositional
data
when
possible.
Please
provide
characterization
information
(if
available)
for
pH,
reactive
cyanide,
specific
gravity,
and
phase
distribution.
Please
be
sure
your
facility
name
and
F006
sludge
sample
identification
is
clearly
marked
on
each
page
or
provide
it
in
the
top
right
hand
corner
of
the
analytical
data
sheet
with
any
additional
information
you
may
wish
to
provide.
Please
provide
any
specifications
required
by
recyclers.

F.
Pollution
Prevention/
Waste
Minimization
Activities
Briefly
please
respond
to
each
of
the
following
questions
concerning
your
present
or
past
pollution
prevention/
waste
minimization
(P2)
activities.
Please
remember
it
is
just
as
important
to
document
your
failures
as
well
as
your
successes
in
conducting
P2.

F.
1.
What
types
of
equipment
changes
or
equipment
layouts
have
you
implement
in
conducting
P2?

F.
2.
Describe
how
you
have
improved
operating
practices
including
operator
training.

F.
3.
Describe
any
material
substitution
or
elimination
you
have
implemented
to
make
your
F006
less
toxic
or
more
recyclable.

F.
4.
Describe
your
water­
use
(e.
g.,
flow
restriction,
drag
out)
reduction
program
or
policy
and
any
addition
P2
measures
conducted
at
your
facility
not
mentioned
before.
September
1998
129
F006
Benchmarking
Study
F.
5.
Describe
any
closed­
loop
recycling
conducted
by
your
plating
operation.

F.
6.
Please
describe
how
your
facility's
use
of
pollution
prevention
has
(or
has
not)
affected
the
quantities
and/
or
quality
of
F006
sludge
generated
at
your
facility.

F.
7.
Do
you
have
any
documentation
where
P2
was
implemented
and
subsequently
partially
or
completely
abandoned
in
favor
of
reclamation.
If
so
can
you
provide
EPA
with
a
copy
of
the
documentation
and
briefly
describe
it
below.

F.
8.
Please
describe
any
industrial
trends
affecting
your
metal
finishing
facility
or
the
metal
finishing
industry
as
a
whole
and/
or
the
generation
of
F006
sludge.

F.
9.
Please
describe
any
economic
barriers
and/
or
incentives
to
conducting
P2.
Please
describe
the
principle
economic
factors
that
have
lead
to
your
facility's
current
practices.

F.
10.
Please
describe
any
regulations
that
affect
P2,
recycling
and
sludge
treatment/
management
decisions.
September
1998
130
F006
Benchmarking
Study
September
1998
131
F006
Benchmarking
Study
September
1998
132
F006
Benchmarking
Study
Appendix
G:
National
Benchmarking
Survey
and
Instructions
September
1998
133
F006
Benchmarking
Study
Call
for
Data
as
Part
of
EPA's
CSI
Instructions
The
National
Association
of
Metal
Finishers
(NAMF),
American
Electroplaters
and
Surface
Finishers
(AESF),
and
Metal
Finishing
Sciences
Association
(MFSA)
are
members
of
the
Environmental
Protection
Agency's
Common
Sense
Initiative
(CSI)
metal
finishing
sector
workgroup
and
are
participating
in
the
data
gathering
effort
focusing
on
hazardous
waste
regulatory
issues
and
has
identified
the
need
to
compare
the
characteristics
of
F006
wastes
generated
today
with
F006
wastes
generated
at
the
time
of
the
listing
under
RCRA
(1980).
The
following
survey
will
be
used
to
characterize
F006,
evaluate
the
processes
generating
F006
and
the
level
of
pollution
prevention
practiced,
and
determine
the
recyclability
of
F006.
Please
note
that
this
survey
should
be
completed
using
available
information
or
best
engineering
judgement
and
that
you
are
not
required
to
generate
any
new
data.

F006
is
defined
as
"Wastewater
treatment
sludges
from
electroplating
operations
except
from
the
following
processes:
(1)
Sulfuric
acid
anodizing
of
aluminum;
(2)
tin
plating
on
carbon
steel;
(3)
zinc
plating
(segregated
basis)
on
carbon
steel;
(4)
aluminum
or
zinc­
aluminum
plating
on
carbon
steel;
(5)
cleaning/
stripping
associated
with
tin,
zinc,
and
aluminum
plating
on
carbon
steel;
and
(6)
chemical
etching
and
milling
of
aluminum."
(40
CFR
§261.31)

Return
the
completed
survey
as
soon
as
possible
but
not
later
than
30
days
after
receipt
of
this
survey
to:

Christian
Richter
NAMF/
AESF/
MFSA
2600
Virginia
Ave.
NW,
Suite
408
Washington,
DC
20037
Phone:
(202)
965­
5190
Fax:
(202)
965­
4037
Response
may
be
typed
or
handwritten
neatly.

A.
CORPORATE
AND
FACILITY
INFORMATION
Parent
Corporation
Name
of
Company/
Affiliate
Address
of
Corporation
Headquarters
Street
City
State
Zip
Name
of
Facility
Address
of
Facility
(if
different
from
above)

Street
City
State
Zip
RCRA
Hazardous
Waste
Generator
ID
Number:

POTW/
NPDES
Permit
Number:

PSD
Permit
Number:

State
or
Local
environmental
permits:

Name(
s)
of
personnel
to
be
contacted
for
additional
information
pertaining
to
this
data
Name
Title
Telephone
Type
of
Facility:
Job
shop
Captive
shop
September
1998
134
F006
Benchmarking
Study
Number
of
Employees:

B.
METAL
FINISHING
OPERATIONS
What
type
of
plating
operations
are
conducted
by
your
facility?
Specify
cyanide­
versus
non­
cyanide­
based
plating.

zinc
plating
on
steel
CN
Non­
CN
nickel/
chromium
plating
on
steel
copper/
nickel/
chromium
plating
on
non­
ferrous
substrates
(zinc,
brass,
ABS)

copper
plating/
stripping
in
the
printed
circuit
industry
hard
chromium
plating
on
steel
Copper
plating
tin
(acid)
plating
cadmium
plating
sulfuric
acid
anodizing
silver
plating
gold
plating
bright
dip
of
copper/
alloy
Other,(
specify):

C.
F006
QUANTITY
GENERATED
AND
MANAGEMENT
METHODS
C1.
What
was
the
total
product
weight
produced
by
your
facility
in
1996?
(Long
Tons/
Cubic
yards/
Cubic
feet)
Please
circle
appropriate
units.

C2.
Is
the
F006
generated
at
your
facility
process­
specific
or
is
it
combined
in
the
wastewater
treatment
plant?

C3.
Are
cyanide­
bearing
F006
sludges
segregated
from
non­
cyanide
F006?
Yes
/
No
C4.
What
was
the
total
quantity
of
F006
generated
in
1996?
(Dry
Tons/
Cubic
yards/
Cubic
feet)
Please
circle
appropriate
units.

C5.
Estimate
the
quantity
of
F006
generated
from
each
process
in
1996?

Process
Quantity
(Specify
units)

C6.
Please
provide
a
description
of
any
onsite
recycling
of
your
metals
prior
to
discharge
to
wastewater
treatment.
Please
estimate
the
quantities
(Dry
Tons/
Cubic
yards/
Cubic
feet)
recycled
or
recovered.
September
1998
135
F006
Benchmarking
Study
Description
of
any
onsite
recycling
Quantity
recycled
or
recovered
C7.
Please
provide
the
name,
location,
and
quantity
(Dry
Tons/
Cubic
yards/
Cubic
feet)
for
all
F006
sludge
that
is
sent
offsite
for
recycling/
metals
recovery.

Name
Location
Quantity
C8.
Please
provide
the
name,
location,
management
method
(e.
g.,
Subtitle
C
landfill)
and
quantity
(dry
tons)
for
all
F006
sludge
that
is
sent
offsite
for
disposal.

Name
Location
Management
Quantity
Method
C9.
What
was
the
quantity
exported
outside
the
U.
S.
in
1996?
Dry
tons
C10.
Please
check
any
of
the
wastewater
treatment
process
used
to
remove
metals
and
other
toxic
substances
prior
to
discharge.
Please
discuss
the
following
steps
and
equipment
used
(as
applicable):

waste
stream
segregation
hexavalent
chrome
reduction
cyanide
oxidation
neutralization,
flocculation,
clarification,
effluent
polishing
sludge
blending
to
achieve
desired
concentration
D.
F006
WASTE
CHARACTERIZATION
Please
provide
waste
characterization
analytical
data
sheets
for
your
F006
sludge.
Submit
both
Toxicity
Characteristic
Leaching
Procedure
(TCLP)
and
total
compositional
data
when
possible.
Please
provide
characterization
information
(if
available)
for
pH,
reactive
cyanide,
specific
gravity,
and
phase
distribution.
Please
be
sure
your
facility
name
and
F006
sludge
sample
identification
is
clearly
marked
on
each
page
or
provide
it
in
the
top
right
hand
corner
of
the
analytical
data
sheet
with
any
additional
information
you
may
wish
to
provide.
Please
provide
any
specifications
required
by
recyclers.

E.
POLLUTION
PREVENTION/
WASTE
MINIMIZATION
ACTIVITIES
E1.
Check
the
techniques
used
at
your
site.
If
requested,
indicate
whether
the
technique
is
automated
or
manual.
The
pollution
prevention
benefits
from
the
techniques
you
use
(1=
low
success,
5=
high
success).
If
the
rating
is
1
or
2,
September
1998
136
F006
Benchmarking
Study
indicate
below
what
problems
were
encountered.
Also,
use
the
space
below
or
other
sheets
to
describe
any
innovative
methods
or
to
provide
additional
information.

Reduce
Drag­
Out
Losses
By:
P2
Benefit
Using
drag­
out
rinse
tanks
and
returning
chemicals
to
the
process
bath
9
Manual
or
9
Automatic
Using
drip
tanks
and
returning
chemicals
to
the
process
bath
9
Manual
or
9
Automatic
Reducing
speed
of
rack/
part
withdrawal
9
Manual
or
9
Automatic
Allowing
rack/
part
to
drip
over
plating
tank
9
Manual
or
9
Automatic
Using
a
drag­
in/
drag­
out
arrangement
(i.
e.,
use
of
same
rinse
tank
before
and
after
plating
also
referred
to
as
a
double­
dip
or
double­
use
rinse)
9
Manual
or
9
Automatic
Fog
or
spray
rinses
installed
over
process
bath
9
Manual
or
9
Automatic
Air
knives
that
blow
off
drag­
out
9
Manual
or
9
Automatic
Drip
shields
between
tanks
9
Manual
or
9
Automatic
Lower
bath
concentration
Increasing
solution
temperature
(reduces
viscosity)

Using
a
wetting
agent
(reduces
viscosity)

Positioning
work
piece
to
minimize
solution
holdup
Other,
specify
Reduce
Rinse
Water
Use
By:
P2
Benefit
Manually
turning
off
rinse
water
when
not
in
use
Conductivity
or
pH
rinse
controls
Timer
rinse
controls
Flow
restrictors
Countercurrent
rinses
Spray
rinses
Air
agitation
in
rinse
tanks
Use
flow
meters/
accumulators
to
track
water
use
at
each
rinse
tank
or
plating
line
Reactive
rinsing
or
cascade
rinsing
Other,
specify
September
1998
137
F006
Benchmarking
Study
Various
Operating
Practices:
P2
Benefit
Training
and
Programs:

Established
a
formal
policy
statement
with
regard
to
pollution
prevention
and
control
Established
a
formal
pollution
prevention
program
Conduct
employee
education
for
pollution
prevention
Establish
a
preventative
maintenance
program
for
tanks
Use
specifically
assigned
personnel
for
chemical
additions
Procedures:

Stricter
conformance
w/
Line
Preventive
Maintenance
Schedule
Stricter
conformance
w/
SPC
Procedures
Waste
stream
segregation
of
contact
and
noncontact
wastewater
Strict
chemical
inventory
control
Perform
routine
bath
analyses
Maintain
bath
analyses/
addition
logs
Have
written
procedures
for
bath
make­
up
and
additions
Use
process
baths
to
maximum
extent
possible
(no
dump
schedule)

Remove
anodes
from
bath
when
they
are
idle
(e.
g.,
cadmium,
zinc)

Regularly
retrieve
fallen
parts/
racks
from
tanks
F006
Volume
Reduction
methods:

Closed­
loop
recycling
Use
control
method
for
adding
water
to
process
tanks
Sludge
Dewatering­
(Vacuum
filter,
Solid
bowl
centrifuge,
Imperforate
basket
centrifuge,
belt
filter
press,
Recessed
plate
filter
press,
sludge
drying
beds,
sludge
lagoons,
sludge
dryers,
etc.)

Install
overflow
alarms
on
process
tanks
Install
other
spill/
leak
detection
system,
specify
_________________________________

Inspections/
Maintenance:

Perform
regular
maintenance
of
racks/
barrels
Pre­
inspect
parts
to
prevent
processing
of
obvious
rejects
Waste
Reduction
Study
conducted
Research/
Evaluations:

Evaluation
of
recycling
alternatives
Increasing
drain
time
over
process
tanks
Various
Operating
Practices:
P2
Benefit
September
1998
138
F006
Benchmarking
Study
Research
of
alternative
plating
technologies
Development
of
tracking
system
for
monitoring
flow
from
different
areas
Monitoring
of
incoming
water
with
strict
control
program
Two
separate
labs
for
process
chemistry
and
wastewater
treatment
Elimination/
Replacement/
Substitutions:

Eliminate
obsolete
processes
and/
or
unused
or
infrequently
used
processes
Replace
cyanide
based
plating
solution
with
alkaline­
based
solutions
Elimination
of
rinse
waters
to
waste
treatment
(nickel,
chrome)

Substitution
of
chromate
and
dichromate
seal
with
non
chrome
sealer
Elimination
of
plating
services
(cadmium,
tin,
nickel,
copper,
brass
and
hard
chrome)

Elimination
of
vapor
degreasing
Implementation
of
a
multi­
stage
cyanide
destruct
system
Elimination
of
chelated
cleaners
Other,
specify
Other,
specify
Additional
Information
(attach
other
sheets,
if
necessary):
______________________________________

E.
2.
Has
the
implementation
of
pollution
prevention
reduced
your
wastewater
discharge
rate?
9
Yes
9
No
If
yes,
approximately
how
many
gallons
per
day
average
have
you
reduced
your
flow
by
using
pollution
prevention?
______________________
gpd
eliminated
(base
year
=
19__)

E.
3.
Recycle
and
Recovery
Technologies
­
Check
each
technology
that
you
have
used
in
the
past
or
currently
use,
indicate
the
type
of
process
bath
to
which
the
technology
is
applied.

Technology
Process
Bath
Technology
is
Applied
to
Electrodialysis
Electrowinning
Evaporator
Ion
flotation
Ion
exchange
Mesh
pad
mist
eliminator/
recycle
Reverse
osmosis
Ultrafiltration
Technology
Process
Bath
Technology
is
Applied
to
September
1998
139
F006
Benchmarking
Study
Other*

E.
4.
Solution
Maintenance
Techniques
Check
the
techniques
that
you
presently
use
and
indicate
the
type
of
process
bath
to
which
the
techniques
applied.
Use
the
space
below
to
describe
any
innovative
methods
or
to
provide
additional
information.

Technology
Process
Bath
Technology
is
Applied
to
Acid
retardation
Carbon
treatment
(batch)

Carbon
treatment
(continuous)

Dummying
of
metal
contaminants
Electrodialysis
for
inorganic
contaminants
Carbonate
freezing
Filtration,
in­
tank
Filtration,
external
High
pH
treatment
Precipitation
Liquid/
Liquid
extraction
Microfiltration
Ultrafiltration
Other,
specify
Other,
specify
Other,
specify
Additional
Information:________________________________________________________________________
September
1998
140
F006
Benchmarking
Study
Appendix
H:
National
Benchmarking
Commercial
Recyclers
Survey
September
1998
141
F006
Benchmarking
Study
EPA's
CSI
Survey
of
Recyclers
of
F006
Instructions
The
National
Association
of
Metal
Finishers
(NAMF),
American
Electroplaters
and
Surface
Finishers
(AESF),
and
Metal
Finishing
Sciences
Association
(MFSA)
are
members
of
Environmental
Protection
Agency's
Common
Sense
Initiative
(CSI)
metal
finishing
sector
workgroup
and
are
participating
in
the
data
gathering
effort
focusing
on
hazardous
waste
regulatory
issues.
The
workgroup
has
identified
the
need
to
compare
the
characteristics
of
F006
wastes
generated
today
with
F006
wastes
generated
at
the
time
of
the
listing
under
RCRA
(1980).
The
following
survey
will
be
used
to
characterize
F006,
evaluate
the
F006
recycling
processes,
and
determine
the
recyclability
of
F006.
Please
note
that
this
survey
should
be
completed
using
available
information
or
best
engineering
judgement
and
that
you
are
not
required
to
generate
any
new
data.

Return
the
completed
survey
within
30
days
from
date
of
receipt
to:

William
(Bill)
Sonntag
NAMF/
AESF/
MFSA
2600
Virginia
Ave.
NW,
Suite
408
Washington,
DC
20037
Phone:
(202)
965­
5190
Fax:
(202)
965­
4037
For
technical
assistance,
please
call
Kristy
Allman
at
(703)
318­
4766.

Response
may
be
typed
or
handwritten
neatly.
Use
additional
paper,
as
needed.

A.
CORPORATE
AND
FACILITY
INFORMATION
Parent
Corporation
Name
of
Recycling
Company/
Affiliate
Address
of
Recycling
Company
Headquarters
Street
City
State
Zip
Address
of
Facility
(if
different
from
above)

Street
City
State
Zip
RCRA
Hazardous
Waste
Generator
ID
Number:

POTW/
NPDES
Permit
Number:

PSD
Permit
Number:

State
and
local
environmental
permits:

Name
of
person
to
be
contacted
for
additional
information
pertaining
to
this
questionnaire
Name
Title
Telephone
Manner
of
Handling
F006:
Hydrometallugical
%

Pyrometallurgical
%

Blender/
Broker
%

Other,
specify
(%)

Number
of
Employees:
The
CSI
workgroup
is
attempting
to
characterize
the
F006
sludge
based
on
1995
data.
If
data
for
1995
is
15
not
available,
other
recent
time
frames
will
be
useful.
Please
clearly
mark
the
date
or
time
frame
on
the
data
sheets.

September
1998
142
F006
Benchmarking
Study
B.
PROCESS
FLOW
DIAGRAM
B.
1
On
a
separate
sheet
of
paper,
please
provide
brief
description
of
your
process
and,
if
possible,
a
process
flow
diagram
that
identifies
basic
metal
recovery
methods.
This
should
include
general
information
including
process
steps,
feeds,
products,
and
the
emissions
and
wastes
from
the
recycling
process.
This
should
include:

C
Feed
stocks,
intermediates,
and/
or
products
C
Process
steps
C
Waste
management
units
C
production
output
C
emissions
and
waste
generation
points
C.
F006
QUANTITIES
C.
1.
What
was
the
volume
of
all
the
materials
processed
by
your
facility
in
1995?
Long
tons
15
C.
2.
What
was
the
volume
of
F006
sludge
processed
by
your
facility
in
1995?
Dry
tons
1
D.
F006
CHARACTERIZATION
D.
1.
Please
provide
analytical
data
for
F006
evaluated
in
1995
.
If
this
represents
a
large
quantity
of
data,
you
may
1
present
a
subset
focusing
on
either
more
complete
analytical
scans
or
on
a
more
recent
time
period
(i.
e.,
the
last
month).
If
the
data
is
confidential,
you
may
present
a
range,
with
the
average
and
number
of
data
points.
If
available,
please
provide
the
broader
pre­
approval
scans,
typically
examining
a
broader
spectrum
of
constituents,
rather
than
the
more
cursory
screening
analyses
typically
performed
on
each
load
of
newly
received
F006.
When
available,
submit
both
Toxicity
Characteristic
Leaching
Procedure
(TCLP)
and
total
concentration
data.
Please
be
sure
your
facility
name,
and
F006
sludge
sample
is
clearly
identified
on
each
page
or
provide
it
in
the
top
right
hand
corner
of
the
analytical
data
sheet
with
any
additional
characteristic
information
you
may
wish
to
provide.
If
you
have
any
questions,
you
may
call
the
technical
assistance
line.

D.
2.
Please
provide
a
copy
or
descriptions
of
the
specification
for
the
F006
sludge
must
meet
for
your
facility
to
accept
it
for
recycle.
Use
additional
paper
if
necessary.

D.
3.
Explain
any
undesirable
physical
or
chemical
characteristics
F006
might
possess
making
it
unacceptable
to
you
facility.
Use
additional
paper
if
necessary.

EVALUATION
OF
F006
E.
1.
How
does
your
facility
establish
the
value
of
F006
(i.
e.,
how
do
you
determine
what
your
company
will
charge
or
pay
for
F006)?
Please
list
the
specific
metals
or
combination
of
metals,
or
contaminants
which
affect
your
valuations.
(Please
respond
in
less
specific
terms
if
specific
termination
is
considered
proprietary.)
Use
additional
paper
if
necessary.
September
1998
143
F006
Benchmarking
Study
Appendix
I:
Responses
to
Citizen
Group
Phone
Survey
September
1998
144
F006
Benchmarking
Study
Individual
responses
are
summarized
below.

Question
#1:
Is
the
Group
Aware
of
Environmental
Impacts
from
the
Recycling
Facility?

NO
NO.
"Not
in
the
past
6
years.
No
known
violations.
Involved
in
moving
waste
from
one
state
to
another­­
some
question
concerning
whether
it
is
"sham
recycling"
or
not."

NO
NO
COMMENT.
The
environmental
group
technically
no
longer
exists.

NO
NO.
"They
generally
try
to
make
env.
laws
easier,
through
political
influence.
They
also
operate
a
superfund
site."

NO
NO
UNKNOWN.
"Never
heard
of
the
company."

Question
#2:
Is
the
Group
Aware
of
Economic
Impacts
from
the
Recycling
Facility?

NO
NO.
"They
are
the
largest
waste
recycler
in
this
state,
but
mostly
imported
from
other
states."

NO
NO
COMMENT.
The
environmental
group
technically
no
longer
exists.

YES.
"Positive
impact,
always
in
the
business
pages
of
the
newspaper."

NO
NO.
"Provides
a
good
service
for
local
companies."

NO
UNKNOWN.
"Never
Heard
of
the
company."

Question
#3:
Is
the
facility
considered
a
"Good
Neighbor?"

UNKNOWN
NO.
"They
spread
the
waste
on
the
ground
to
dry
it."

UNKNOWN.
"Have
heard
little
about
this
facility,
it
is
50
miles
away."

NO
COMMENT.
The
environmental
group
technically
no
longer
exists.

YES.
"Have
no
information
to
say
they
are
a
bad
neighbor."

NO.
"Don't
trust
them."

YES.
"They
make
an
effort
to
get
involved
in
informing
the
community
on
what
they
do."
Question
#3:
Is
the
facility
considered
a
"Good
Neighbor?"

September
1998
145
F006
Benchmarking
Study
YES.
"They
received
an
environmental
award
and,
we
have
participated
with
them
on
voluntary
P2
committees
and
projects."

UNKNOWN.
"Never
heard
of
the
company."
September
1998
146
F006
Benchmarking
Study
Appendix
J:
Statistical
"Representativeness"
of
the
National
Benchmarking
Study
¯
Y
j
'
1
N
j
j
k
Y
jk
,
S
j
'
1
N
j
j
k
(Y
jk
&
¯
Y
j
)
2
September
1998
147
F006
Benchmarking
Study
Statistical
"Representativeness"
of
the
National
Benchmarking
Study
A
chi­
square
analysis
was
performed
to
determine
whether
there
is
a
difference
in
the
distribution
of
sample
proportions
for
D&
B,
BRS
and
"national"
databases
over
the
different
regions.

C
Summary
of
results
of
comparison
of
the
National
sample
with
the
Dun
&
Bradstreet
extract
A
chi­
square
analysis
was
performed
to
compare
the
National
sample
and
the
D
&
B
extract
(Primary
SIC
code
of
3471)
on
the
number
of
data
points
for
each
of
the
ten
EPA
regions.

Results
of
the
test
showed
that
they
are
statistically
different
(
p­
value
­
0.003.
Please
refer
to
Table
1
of
Attachment
1
).
The
difference
can
be
attributed
to
the
difference
in
percentages
of
the
number
of
facilities
in
the
National
sample
and
the
D
&
B
extract
for
EPA
regions
4,
5,
and
6.
The
D
&
B
extract
had
nearly
30%
of
the
data
points
as
against
42%
in
the
National
sample
for
region
5.
The
National
sample
had
5.78
%
(region
4),
1.16%
(region
6)
of
the
data
points
as
against
9.84%
(region
4)
and
7.43%
(region
6)
in
the
D
&
B.
The
difference
in
size
of
the
National
sample
(173)
and
the
D
&
B
(4147)
was
an
important
issue
for
the
significant
p­
value
of
0.03%.
If
the
National
sample
is
used
to
produce
any
national
estimate,
there
should
be
caveats
for
the
differences
mentioned
above
for
EPA
region
4,
5,
and
6.

The
National
and
the
D&
B
extract
were
also
compared
on
the
basis
of
mean
number
of
employees
per
facility.
It
was
found
that
the
means
for
the
National
sample
were
consistently
higher
than
the
corresponding
means
in
the
D
&
B
(
Please
refer
to
table
2
of
Attachment
1).
This
shows
that
relatively
larger
facilities
in
terms
of
manpower
volunteered
for
the
National
sample.
Hence,
any
national
estimate
from
this
sample
must
come
with
a
caveat
indicating
a
potential
bias
problem.

For
9
degrees
of
freedom,
the
P
value
of
25.22
is
significant
beyond
both
5%
and
1%
levels.
2
Therefore,
we
reject
the
null
hypothesis
that
there
is
no
difference
in
the
sample
proportions
for
D&
B
and
"national'
databases.
Note,
however,
that
due
to
small
sample
sizes
in
the
"national"
database,
the
results
could
be
more
informative
after
collapsing
several
regions
in
larger
strata.

2.
In
this
section,
a
statistical
method
for
testing
the
difference
between
average
number
of
employees
from
the
D&
B
and
"national"
databases
is
described.
Histograms
and
normal
probability
plots
applied
to
the
total
number
of
employees
suggest
that
the
characteristic
of
interest
(#
of
employees)
is
distributed
more
lognormally
than
normally.
Therefore,
the
log­
transformed
version
was
used
in
all
calculations.
Assuming
that
the
D&
B
database
covers
almost
all
facilities
of
interest,
the
true
mean
and
true
standard
deviation
for
each
region
can
be
approximated
by
Since
N
is
large
enough
and
S
is
known,
we
can
use
normal
approximation
to
test
the
differences
j
j
between
the
true
(D&
B)
mean,
Y,
and
the
sample
("
national")
mean,
y
.
In
this
case
the
test
statistic
j
j
is
given
by
z
j
'
|
¯
y
j
&
¯
Y
j
|

S
j
,
j
'
1,
2,
ÿ,
10
September
1998
148
F006
Benchmarking
Study
C
Summary
of
results
of
comparison
of
the
National
sample
with
the
BRS
sample
Results
of
the
chi­
square
test
performed
to
compare
the
National
sample
and
the
BRS
sample
are
similar
to
the
results
of
comparison
of
the
National
sample
and
the
D
&
B
extract.
In
fact,
with
a
precision
of
0.1%,
we
conclude
that
the
distribution
of
sample
points
by
region
in
the
National
sample
is
significantly
different
from
the
distribution
of
sample
points
by
region
in
the
BRS
sample.
The
difference
can
be
attributed
to
the
difference
in
percentages
of
the
number
of
facilities
in
the
national
sample
and
the
BRS
sample
for
EPA
regions
3,
4,
5,
6,
and
9.

Comparing
the
average
F006
discharge
for
each
region
in
the
national
sample
and
in
the
BRS
sample,
we
found
that,
in
general,
there
are
no
significant
differences
for
most
regions
in
these
two
samples.
Only
two
regions
(region
1
and
region
5)
out
of
ten
in
the
National
sample
discharged
significantly
more
F006
than
the
corresponding
regions
in
the
BRS
sample.
Note
also
that
there
were
no
samples
taken
from
region
8
in
the
National
survey.

C
Comparison
of
the
Regional
Benchmarking
Sampling
data
to
the
National
Survey
data
The
results
of
the
test
for
all
10
groups
along
with
the
corresponding
p­
values
are
attached.
In
order
to
compare
the
responses
from
the
ALLDATA
sample
and
the
NATIONAL
sample,
we
examine
how
much
the
mean
and
distribution
of
each
analyte
from
the
ALLDATA
sample
differ
from
those
from
the
NATIONAL
sample.
The
table
below
summarizes
the
results
of
statistical
tests
performed
to
compare
the
two
samples.
It
contains
p­
values
for
the
analytes
that
are
in
both
ALLDATA
and
NATIONAL
samples.
P­
values
less
than
0.05
indicate
a
statistically
significant
difference
between
the
responses
from
the
ALLDATA
sample
and
the
NATIONAL
sample
for
a
particular
analyte.

From
this
table
we
conclude
that
the
reported
values
are
significantly
different
for
Amenable
Cyanide,
Magnesium,
Selenium,
Total
Cyanide,
and
Zinc
from
the
TOTAL
group.
The
results
for
other
analytes
do
not
show
significant
differences
between
the
two
samples
under
study.
September
1998
149
F006
Benchmarking
Study
TCLP
METALS
TOTAL
METALS
ANALYTE
P­
VALUE
ANALYTE
P­
VALUE
BARIUM
0.0691
ALUMINUM
0.1407
CADMIUM
0.5960
AMENABLE
CYANIDE
0.0084
CHROMIUM
0.0517
ANTIMONY
0.3772
LEAD
0.3126
ARSENIC
0.2715
MERCURY
0.1071
BARIUM
0.6320
SILVER
0.4097
BERYLLIUM
0.3729
BISMUTH
0.2239
CADMIUM
0.3766
CALCIUM
0.1183
CHLORIDE
0.4763
CHROMIUM
0.1502
CHROMIUM,
HEXA
0.2812
COPPER
0.1159
FLUORIDE
0.1477
IRON
04179
LEAD
0.6072
MAGNESIUM
0.0044
MANGANESE
0.3262
MERCURY
0.2802
NICKEL
0.2023
SELENIUM
0.0365
SILVER
0.2741
SODIUM
0.6743
TIN
0.2546
TOTAL
CYANIDE
0.0319
ZINC
0.0146
