United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5305W)
September 1998
xvEPA
Metal Finishing F006
/
Benchmark Study
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
EPA
530/
1998.2
Printed on paper that contains at least 30 percent postconsumer fiber
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510
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
OCT 7 1998
MEMORANDUM
Subject:
From:
To:
Metal Finishing F006 Benchmarking Study
HrU^*1 ---
A
CSI Metal Finishing Subcommittee
Michael
EPA/OSW
On behalf of the RCRA workgroup, I am pleased to transmit the Metal Finishing
F006 Benchmarking Study. This report is the culmination of a two year effort and
represents a lot of hard work by many workgroup participants. In particular, I'd like to
give special thanks to John Lindstedt'(Artistic Plating, Inc.) who was instrumental in
both the project design and implementation and, to Jim Lounsbury (US EPA) who
coordinated the data collection efforts.
This study was designed to answer the following questions:
•> what are the characteristics of F006?
»• 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?
»• what are the environmental impacts of F006 recycling?
The attached report presents the results of this effort. These results will be used
to inform upcoming discussions regarding potential modifications to RCRA regulations
that relate to F006 (Phase II). If you have any questions regarding the report please
contact Kristina Meson (US EPA 703/308-8488) or one of the RCRA workgroup
members.
Recycled/Recyclable •Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)
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Common Sense Initiative
Metal Finishing Sector
WORKGROUP REPORT: F006 BENCHMARKING STUDY
September 1998
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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
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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
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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 1-994 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.1 The total number of plating shops has decreased significantly
since 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
1 Borst, Paul A. U.S. EPA, Office of Solid Waste. Recycling of Wastewater Treatment Sludges from
Electroplating Operations. F006. 1997.
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(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
2 Borst, Paul A. U.S. EPA, Office of Solid Waste. Recycling of Wastewater Treatment Sludges from
Electroplating Operations. F006. 1997.
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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;
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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;
i
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.
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The Appendices of this report contain further details supporting various aspects of the 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),
JeffHannapel(USEPA)
John Lingelbach (facilitator, Decisions and Agreements, LLC) and,
the SAIC Contractor Support Team.
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L 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
commerciaily valuable metals (contained in F006) than they currently recover, and
simultaneously decrease the amount of metal finishing wastes disposed of in regulated landfills.
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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
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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.3 Of the total, approximately 10,000 metal finishing facilities are estimated to
be "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.4 The total number of plating shops has decreased since the 1970's, mainly as a
result of 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
3 USEPA, Office of Policy, Planning and Evaluation. SUSTAINABLE INDUSTRY: Promoting
Environmental Protection in the Industrial Sector, Phase 1 Report. June 1994.
cT
4 Borst, Paul A. U.S. EPA, Office of Solid Waste. Recycling of Wastewater Treatment Sludges from
Electroplating Operations. F006. 1997.
5 Kirk-Othmer. Encyclopedia of Chemical Technology (4th ed.), 199-888, v.9
6 USEPA, Office of Solid Waste, Hazardous Waste F006 Listing Background Document p. 107.
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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
Decorative
Corrosion resistance
Wear, lubricity, hardness
Bearings
Joining, soldering, brazing, electrical
contact resistance, conductivity
Barrier coatings, anti-diffusion, heat-
treatment
Electromagnetic shielding
Paint/lacquer base, rubber bonding
Electroforming manufacturing
Electronics manufacturing
Dimensional buildup, salvage of worn
parts
Principal Plating Metals
Chromium, copper, nickel, brass, bronze, gold, silver, platinum, zinc
Nickel, chromium, electroless nickel, zinc, cadmium, copper, copper
alloys, silver, tin, gold
Chromium, electroless nickel, bronze, nickel, cadmium, silver, tin,
metal composites
Copper, bronze, silver, silver alloys, lead-tin
Nickel, electroless nickel, electroless copper, copper, cadmium, gold,
silver, lead-tin, tin, cobalt
Nickel, cobalt, iron, copper, bronze, tin-nickel, palladium
Copper, electroless copper, nickel, electroless nickel, zinc
Zinc, tin, chromium; brass
Copper, nickel
Electroless copper, copper, electroless nickel, nickel, gold, palladium
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
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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.7 In 1993, the National Association of Metal Finishers estimated that approximately 15
to 20 percent of F006 is recycled for metal recovery.8 EPA's Biennial Reporting System (BRS)
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 treated9 and disposed of 99,000 tons of F006 in RCRA regulated landfills
per 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
7 Borst, Paul A. U.S. EPA, Office of Solid Waste. Recycling of Wastewater Treatment Sludges from
Electroplating Operations. F006. 1997.
8 op. cit.
Prior to land disposal, F006 must be treated to meet the treatment standards specified in EPA's Land
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.
10 The Biennial Reporting System is not designed to provide "treatment train" (e.g., stabilization followed
by 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.
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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 RCRA11 in 1980 based on a
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/1, cadmium levels of non-detectable to 268 mg/1, and chromium
levels of 0.12 to 400 mg/1.
»
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.
" A solid waste may be classified as a hazardous wastes if: 1) it exhibits a characteristic for ignitability,
corrosivity, reactivity, or toxicity (40 CFR Part 261 Subpart C), or 2) if, classified as a listed waste (40 CFR Subpart
D),
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Tables 3a and 3b are taken from EPA's F006 listing regulatory support documents
(1980). Table 3 a summarizes the chemical composition of typical electroplating baths used in
the 1970's. Table 3b summarizes information on heavy metal concentrations in sludges.
Table 3a: Typical Electroplating Baths and Their Chemical Composition
Plating Compound
1 . Cadmium Cyanide
2. Cadmium Fluoborate
3. Chromium Electroplate
4. Copper Cyanide •
5. Electroless Copper
6. Gold Cyanide
7. Acid Nickel
8. Silver Cyanide
9. ZincSulfate
Constituents
Cadmium oxide
Cadmium
Sodium cyanide
Sodium hydroxide
Cadmium fluoborate
Cadmium (metal)
Ammonium fluoborate
Boric acid
Licorice
Chromic acid
Sulfate
Fluoride
Copper cyanide
Free sodium cyanide
Sodium carbonate
Rochelle salt
Copper nitrate
Sodium bicarbonate
Rochelle salt
Sodium hydroxide
Formaldehyde (3 7%)
Gold (as potassium gold cyanide)
Potassium cyanide
Potassium carbonate
Depotassium phosphate
Nickel sulfate
Nickel chloride
Boric acid
Silver cyanide
Potassium cyanide
Potassium carbonate
Metallic silver
Free cyanide
Zinc sulfate
Sodium sulfate
Magnesium sulfate
Concentration (g/I)
22.5
19.5
77.9
14.2
251.2
94.4 '
. 59.0
27.0
1.1
172.3
1.3
0.7
26.2
5.6
37.4
44.9
15
' 10
30
20
100 ml/1
8
30
30
30
330
45
37
35.9
• 59.9
15.0
23.8
•41.2
374.5
71.5
59.9-
Source: EPA F006 Listing Background Document, 1980
September 1998
14
F006 Benchmarking Study
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Table 3b: Heavy Metal Content for Chromium and Cadmium in Electroplating Sludges (Dry Weight ppm) |
Primary Plating Process
Segregated Zinc
Segregated Cadmium
Zinc Plating and Chromating
Copper-Nickel-Chromium on Zinc
Aluminum anodizing (chromic process)
Nickel-Chromium on steel
Multi-process job
Electroless Copper on Plastic, Acid Copper, Nickel Chromium
Multi-process with Barrel or Vibratory Finish
Printed Circuits
Nickel-Chromium on Steel
Cadmium-Nickel-Copper on Brass and Steel
Chromium
200
62,000
.65,000
500
1,700
14,000
25,000
137,000
570
3,500
79,200
48,900
Cadmium
<100
22,000
1,100
ND
ND
-
1,500
ND
-
<100
<100
. . 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:
Waste-water 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
September 1998
15
F006 Benchmarking Study
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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.
12 Borst, Paul A. U.S. EPA, Office of Solid Waste. Recycling of Wastewater Treatment Sludges from
Electroplating Operations. F006. 1997.
September 1998
16
F006 Benchmarking Study
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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 (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
13
NCMS/NAMF. Pollution Prevention and Control Technology for Plating Operations. 1994.
September 1998
17
F006 Benchmarking Study
-------
Table 4: Examples of Pollution Prevention Measures
Method
Remove cadmium and zinc anodes from bath
when it is idle. Anodes baskets can be placed
on removable anode bars that are lifted from
tank by an overhead hoist
Eliminate obsolete processes and/or unused or
infrequently used processes
a
Waste stream segregation of contact and non-
contact wastewaters
Establish written procedures for bath make-up
and additions. Limit chemical handling to
trained personnel. Keep tank addition logs
Install overflow alarms on all process tanks to
prevent tank overflow when adding water to
make up for evaporative losses
Conductivity and pH measurement instruments
and alarm system for detecting significant
chemical losses
Control materialpurchases to minimize obsolete
material disposal
Use process baths to maximum extent possible
before discarding. Eliminate dump schedules.
Perform more frequent chemical analysis
Reduce bath dumps by using filtration to
remove suspended solids contamination
Deburring containment
Ultrafiltration, oil removal
Pollution Prevention Benefits
• Eliminates cadmium/zinc buildup causing decanting of
solution due to galvanic cell set up between steel anode
basket and cadmium/zinc anodes
• Maintains bath within narrow Cd/Zn concentration
providing more predictable plating results
• Reduces risks associated with hazardous chemicals
• Creates floor space to add countercurrent rinses or other P2
methods
• Creates safer and cleaner working environment
• Eliminates dilution of process water prior to treatment
which can increase treatment efficiency
• Reduces treatment reagent usage and operating costs
• Prevents discarding process solutions due to incorrect
formulations or contamination
• Improves plating solution and work quality consistency
•Improves shop safety
• Minimizes potential for catastrophic loss of process solution
via overflow
• Prevents loss of expensive chemicals
* Identifies process solution overflows and leaks before total
loss occurs
* Alerts treatment operators to potential upset condition
• Reduces losses of expensive plating solutions
• Reduces hazardous waste generation
• Reduces chemical purchases
• Prevents discarding of solutions prematurely
• Reduces chemical costs
• Chemical adjustments of baths will improve work quality
• Extends bath life
• Reusable filter cartridges reduce solid waste generation
• Improves bath performance
• Segregates waste
• Removes contaminants from cleaning wastes, promotes
recycling
Process/Chemical Substitution
Substitute cyanide baths with alkaline baths
when possible
Substitute trivalent chromium for hexavalent
chromium when product specifications allow.
• Eliminates use of CN
• Reduces/eliminates use of hexavalent chromium
September 1998
18
F006 Benchmarking Study
-------
Table 4: Examples of Pollution Prevention Measures
Method
Eliminate use of cadmium plating if product
specifications allow
Eliminate cyanide copper
Introduce deposit substitutes: e.g., Zn-Ni alloy
replaces cadmium
Pollution Prevention Benefits
• Eliminates the use of cadmium
• Eliminates use of CN
• Eliminates use of Cd
Drag-Out Reduction Methods that Reduce Waste Generation
Install fog rinses or sprays over process tanks to
remove drag out as rack/part exits bath
Minimize the formation of drag out by:
redesigning parts and racks/barrels to avoid cup
shapes, etc. that hold solution; properly racking
parts; and reducing rack/part withdraw speed
Introduction of barrel spray rinsing
Automation control
• Can inexpensively recover a substantial portion of drag out
and does not require additional tankage
•Reduces pollutant mass loading on treatment processes,
treatment reagent usage, and resultant sludge generation
• May improve treatment operation/removal efficiency
• Reduces chemical purchases and overall operating costs
• Reduces pollutant mass loading on treatment processes,
treatment reagent usage, and resultant sludge generation
• Reduces process error and process waste
Rinse Water Reduction Methods. that Reduce Waste Generation . . ...
Install flow restrictors to control the flow rate of
water
Install conductivity or timer rinse controls to
match rinse water needs with use
Use counter-current rinse arrangement with two
to four tanks in series depending on drag out
rate
Track water use with flow meters and
accumulators. Keep logs on water use for
individual operations /*-• /
Ml
tr~-
Install pulsed spray rinsing
• Reduces water use and aids in reducing variability in
wastewater flow
• Very inexpensive to purchase and install
• Coordinates water use and production when properly
implemented
• Provides automatic control of water use
• Major water reduction can be achieved
• High impact on water bills
• May reduce the size of needed recovery/treatment
equipment
• Identifies problem areas including inefficient processes or
personnel • "
-• Helps management to determine cost for individual plating
processes.
• Reduced wastewater generation
Source: NCMS/NAMF: Pollution Prevention and Control Technology for Plating Operations. 1994
September 1998
19
F006 Benchmarking Study
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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 report14. The five portions of the study are
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;
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;
14USEPA, Office of Solid Waste. Quality Assurance Project Plan For the Metal Finishing
Industry. October, 1997.
September 1998
20
F006 Benchmarking Study
-------
• An analysis which evaluates the extent to which the regional and national
benchmarking studies represent the universe of metal finishers.
• 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
• 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:
• Type of shop: captive/job,
• Size: number of employees,
• Type of deposition process in use,
• Pollution prevention technologies in use,
• In-house metal recovery technologies:
-- counterflow rinse,
— ultrafiltration/microfiltration,
— other ion exchanges,
— electrolytic metal recovery,
— electrodialysis, or
-- reverse osmosis; and
• 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
21
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 Fl, F4, Fl 1, 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
September 1998
22
F006 Benchmarking Study
-------
practices, 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
23
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:
• Is the group aware of environmental impacts from the recycling facility?
• Is the group aware of economic impacts from the recycling facility?
• 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
24
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
25
F006 Benchmarking Study
-------
-------
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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
Detections
Minimum
Mean
Median
Maximum
Tola) Metals (mg/kg)
Aluminum (Al)
Antimony (Sb)
Arsenic (As)
Barium (Ba)
Beryllium (Be)
Bismuth (Bi)
Cadmium (Cd)
Calcium (Ca)
Chromium (Cr)
Copper (Cu)
Iron (Fe)
Lead (Pb)
Magnesium (Mg)
Manganese (Mn)
Mercury (Hg)
Nickel (Ni)
Selenium (Se)
Silver (Ag)
Sodium (Na)
Tin (Sn)
Zinc (Zn)
34
22
35
38
20
7
39
28
60
51
38
47
14
28
30
44
35
30
9
28
48
0.59
1.80
2.00
6.00
0.59
2.10
2.10
682.00
10.00
33.60
364.00
5.00
187.00
13.00
0.05
51.00
1.900
1.50
25.00
9.00
57.00
13,387.89
2,188.23
489.67
199.27
12.55
50.86
6,122.32
37,239.28
39,601.20
55,474.35
82,420.74
5,754.10
48,798.09
830.91
0.39
23,456.33
7.86
169.64
18,458.37
20,906.06
88,692.44
1,725.00
67.40
10.00
73.70
8.50
29.00
22,00
17,250.00
13,900.00
10,620.00
48,950.00
346.00
10,800.00
563.00
0.30
5,935.00
6.50
87.50
11,000.00
1,100.00
24,600.00
76,100.00
34,800.00
8,780.00
1,080.00
37.00
398.00
71,300.00
143,000.00
206,000.00
631,000.00
560,000.00
175,000.00
336,000.00
3,300.00
2.00
180,000.00
16.60
1,190.00
89,200.00
467,000.00
460,000.00
TCLP(mg/l) ' .
Arsenic (As)
Barium (Ba)
Cadmium (Cd)
Chromium (Cr)
Lead (Pb)
Mercury (Hg)
Selenium (Se)
Silver (Ag)
17
16
18.
20
IS
15
16
17
ND
0.26
0.02
0.02
0.06
0.001
0.08
0.01
ND
1.29
8.36
9.48
113.97
0.005
0.08
0.67
ND
1.45
0.11
0.92
0.13
0.005
0.08
0.06
ND
2.20
144.00
56.20
1,630.00
0.011
0.08
3.80
General Chemistry (mg/kg)
Chloride (Cl)
Fluoride (F)
Chromium, hex
Cyanide, Total (CM)
Cyanide, Am (CN)
Percent Solids
20
13
15
25
11
64
1.2
0.1
0.8
2.6
13.5
8,035.09
719.06
108.89
692.47
609.56
37.65
2,225.00
161.00
11.00
114.50
51.00
30.80
70,100.00
4,240.00
1,190.00
3,920.00
5,340.00
94.10
September 1998
28
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
29
F006 Benchmarking Study
-------
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-------
Table 9: Facility-Specific Information for Milwaukee Facilities
Facility F4
Platiag Process -' F606 Quantity and Management
Nickel-chrome on Aluminum 146 tons/yr
Zinc (non-CN) on Steel
Decorative nickel-chrome on Steel Landfill
Pollution Prevention Practices
SPENT PLATING SOLUTIONS
Implementation of high temperature zinc baths to eliminate partial bath
dumps
Replaced hexavalent Cr with Trivalent Cr on decorative Cr line
Elimination of all cyanide plating baths
Substitution of chromate and dichromate seal with non-chrome sealer
Constant development of alternative plating technologies
Filtration on nickel recovery unit
Electrolytic dummying
Precipitation and monitoring of spent plating solutions
Uses purer anodes and bags
Tooling attention/maintenance on scrubbers
Evaporation techniques on nickel portion of chrome line
Chemical usage reduction through substitution - replaced hard chrome
with decorative chrome
Oil removal techniques
DRAG-OUT REDUCTION
Enhanced product hang times
Uses wetting agents occasionally
Drainage boards
Strategic workpiece positioning
Withdrawal and drainage time
Diking
RINSEWATER
Counter-current flow rinse systems for 1 plating line
Flow restrictors done with weirs
Use conductivity meters to monitor the quality of final rinses
Reuse electrocleaner rinse water as dilute plating bath solution
Reuse acid rinse waters for rinsing racks exiting soak cleaner
Evaporative recovery of Ni rinse waters
Closed-loop wastewater systems on Ni and Hex. Cr lines
OTHER
Chemical inventory and control
Conducts annual plant assessments and housekeeping
Preventive maintenance systems
Increased temperature of bath
Product longevity through specification alteration
Sample Description
Fl-01 - Sludge sample collected
directly from drop bin
F 1-02 - Sludee collected from
supersack dated the previous month
Sample Characteristics (Dry wt)
Fl - 01 Fl - 02
Total (ma/kg) Total (ma/kg)
Al- 3 1,200 Al- 17,300
Sb-5.5 Sb-1.8
As - 9.9 As - 9.3
Ba-41.9 Ba-34.3
Be-ND Be-ND
Bi - 2.7 Bi - 3.3
Cd - 7.5 Cd - 9.6
Ca- 24,800 Ca- 17,500
Cr- 59,500 Cr- 64,900
Hex. Cr - 0.6 Hex. Cr - 0.6
Cu-130 Cu- 1,480
Fe - 25,000 Fe - 27,700
Pb - 297 Pb - 366
Mg- 15,800 Mg- 17,400
Mn- 1,710 Mn-399
Hg-2 Hg-ND
Ni- 19,900 Ni- 18,200
Se-16.6 Se-16
Ag - 267 Ag - 97.9
Na- 8,360 Na- 2 1,700
Sn - 404 Sn - 582
Zn - 336,000 Zn - 335,000
CN-ND CN-ND
TCLP(mg/l) TCLP fme/H
As - ND As - ND
Ba-0.3 Ba-1.4
Cd-0.04 Cd-0.1
Cr-40.6 Cr-56.2
Pb-ND Pb-0.1
Hg - ND Hg - ND
Se-ND Se-ND
Ag - 0.05 Ag - ND
September 1998
32
F006 Benchmarking Study
-------
Table 9 (cont'd): Facility-Specific Information for Milwaukee Facilities
Facility F5
Plating Process FOQ6 Quantity aad Management
Zinc (non-CN) on steel 42.5 tons/yr
Cu/Ni/Cr on steel
Nickel chrome on steel Recycle (Horsehead)
Nickel plating
Hard chrome on steel
Pollution Prevention Practices
SPENT PLATING SOLUTION
Copper and nickel strips are sent out in liquid form for recycling reducing
quantity of F006
Filtration, carbon treatment, replenishment, and electrolytic dummying for
bath life extension
Replaced cyanide zinc plating with zinc alkaline plating
Planning to change to non-cyanide copper plating in 1997.
Oil removal techniques on pre-cleaning line
Chemical usage reduction through automated addition of brightener
Product longevity dirough specification alteration
Alternate stripping methodologies - replaced cyanide solution with non-
cyanide solution to strip nickel
DRAG OUT REDUCTION/RECOVERY
Mesh pad Mist eliminators on 2 of 3 chrome lines for drag-out recovery
Enhanced product hang times
New plating barrel reduces drag out
Increase drain time over process tanks
Drag out tanks and counter-current flow used where feasible.
Increased withdrawal and drainage time
. Uses wetting agents
Strategic workpiece positioning
Spray rinses
RINSEWATER
Flow restrictors
Spray rinsing on 1 line
OTHER
Tooling attention/maintenance
Waste collection plumbing alterations or improvements
Diking
Energy savings techniques
Conducts annual plant assessments and plant housekeeping
\ •' •" , •' ..
Sample Description
F5-01 - Collected from sludge drier
F5-02 - Collected from rolloff bin
accumulated ~1 month previously
1 Sample Characteristics {Dry wt)
F5 - 01 F5 - 02
Total (mg/kg) Total (mg/kg)
Al- 3,690 Al- 1,710
Sb-67.4 " Sb-45
As -15.4 As -18.3
Ba-843 Ba-157
Be - 0.6 Be - 0.7
Bi-2.1 Bi-3.2
Cd-9.6 Cd-13.4
Ca- 2 1,400 Ca- 23,200
Cr- 92,000 Cr- '7 1,000
Hex. Cr- 0.6 Hex. Cr- 0.1
Cu- 39,900 Cu- 4 1,500
Fe-92,100 Fe- 105,000
Pb - 976 Pb - 556
Mg- 13,000 Mg- 12,500
Mn- 1,200 Mn- 1,340
Hg - 0.3 Hg - 0.26
Ni- 104,000 Ni- 105,000
Se-!0.6 Se-11.5
Ag - 8.7 Ag - 3.4
Na - 5,950 Na - 6,830
Sn - 429 Sn - 337
Zn- 126,000 Zn- 158,000
CN - 700 CN - 900
TCLPfme/1) TCLPfma/l)
Ar - ND As - ND
Ba-1.7 Ba-2.2
Cd-0.05 Cd-0.1
Cr-27.2 Cr-12.1
Pb-ND Pb-ND
Hg-ND Hg-ND
Se - ND Se - ND
Ag - ND Ag - ND
September 1998
33
F006 Benchmarking Study
-------
1 Table 9 (cont'd): Facility-Specific Information for Milwaukee Facilities
Plating Process
Hard Chrome on Steel
Pollution Prevention Practices
SPENT PLATING SOLUTION
Ion exchange resin system - echo-tec
Facility F8
FOQ6 Quantity and Management
unreported
Landfill
••
DRAG OUT REDUCTION/RECOVERY
Strategic workpiece positioning
OTHER
Annual plant assessments
Diked tanks
High efficiency lighting
Plant Housekeeping
Preventive Maintenance systems
Installed waste collection hard piping to control chemicals
Tooling maintenance once per year
Sample Description
F8-01 - Collected from supersack
dated that week
F8-02 - Collected from suoersack
dated the previous month
Sample Characteristics (Dry wt)
F8-01 F8-02
Total (mg/kg) Total (me/kg)
At- 19,300 Al- 8,560
Sb-I61 Sb-110
As-5.5 As- 11.8
Ba - 83.4 Ba - 33.3
Be-ND Be-ND
Bi - ND Bi - ND
Cd-10.1 Cd-42.7
Ca - 67,400 Ca - 50,800
Cr- 193,000 Cr- 9 1,500
Hex. Cr - 0.4 Hex. Cr - 0.2
Cu- 24,500 Cu-41,100
Fe- 110,000 Fe- 279,000
Pb-858 Pb-231
Mg- 9,710 Mg-1 1,100
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-ND Hg- 0.005
Se - ND Se - ND
Ag-ND Ag-ND
September 1998
34
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
Bright dip on brass
Copper, nickel, chrome on steel
Hard chrome on steel
Nickel chrome on nonferrous
Zinc (non-CN) on steel
150tons/yr
Recycle (Encycle/Horsehead 97%)
Landfill (3%)
F9-01 - Collected from supersack
loaded that day
F9-02 - Collected by facility about
2 weeks later
Pollution Prevention Practices
Sample Characteristics (Dry i*t>
SPENT PLATING SOLUTION
Eliminated cadmium plating line
Replace some hexavalent chrome lines with trivalent chrome
Utilizes filtration carbon treatment, replenishment, and electrolytic
dummying for general bath life extension
Uses precipitation, monitoring, carbonate agitation, and electrowinning on
spent solutions
Uses evaporative techniques on nickel plating bath
Chemical usage reduction through automation and substitution
Increased temperature of bath
DRAG OUT REDUCTION/RECOVERY
Drag out and counter-current flow rinse systems
Ion exchange systems
Evaporation and Mesh pad mist eliminators for drag-out recovery
Spray rinsing and drag-out tankage
Enhanced product hang times
Withdrawal and drainage time
Uses wetting agents and drainage boards
Spray rinses only on nickel boards
Utilizes strategic workpiece positioning
RINSEWATER
Implemented a strict control program for monitoring incoming water to
each separate production line
Company-wide water conservation program (e.g., spray rinses, flow
restrictors water meters, etc.)
Use spent acid bath for pH adjustment in WWT
Reuse treated wastewater in production lines
Replaced solvent-based washers with aqueous systems (increasing sludge
generation)
Flow restrictors
OTHER
Use sludge dryer to reduce sludge volume and transportation costs
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
Total (mg/kg)
Al - 27,000
Sb - 5.4
As-4.8
Ba- 298
Be-ND
Bi - 72.5
Cd-2.l
Ca - 87,000
Cr-28,200
Hex. Cr - 29
Cu - 20,700
Fe - 105,000
Pb - 439
Mg - 44,300
Mn-1,070
Hg - 0.35
Ni - 14,800
Se-1.9
Ag-65
Na- 15,900
Sn-1,100
Zn - 67,200
CN-46
TCLP (mg/n
As-ND
Ba-1.1
Cd-ND
Cr - 0.9
Pb-ND
Hg-ND
Se-ND
Ag-ND
F9-02
Total (mg/kg)
Al-13,200
Sb-13.5
As-3.1
Ba-257
Be-ND
Bi-31.5
Cd - 17.3
Ca - 70,000
Cr-94,000
Hex. Cr-1,000
Cu-15,000
Fe - 80,800
Pb-410
Mg - 30,300
Mn-1,170
Hg - 0.6
Ni-18,700
Se-ND
Ag - 230
Na - 39,000
Sn-681
Zn - 83,900
CN-74
TCLP (mg/n
As-ND
Ba-0.8
Cd-ND
Cr-13.1
Pb-ND
Hg-ND
Se - 0.04
Ag-ND
September 1998
35
F006 Benchmarking Study
-------
Table 9 (cont'd): Facility-Specific Information for Milwaukee Facilities
Facility Fll •
Plating Process
MQ6 Quantity and Management
Zinc (non-CN) on steel
Tin on non-ferrous and steel
Nickel-chrome plating
Copper-nickel on steel
unreported
Recycle (Encycle)
Fll-OI - Collected from sludge
drier
Fl 1-02 - Collected from supersack
dated the previous month
Pollution Prevention Practices
Sample Characteristics (Dry wt.)
SPENT PLATING SOLUTION
Eliminated cyanide cadmium plating
Replaced zinc cyanide plating with zinc alkaline plating
Spent alkaline baths are used for pH adjustment
Oil removal techniques
Chemical usage reduction through substitution
Utilizes filtration, carbon treatment, replenishment, and electrolytic
dummying
DRAG OUT REDUCTION/RECOVERY
Drag out recovery on chrome and nickel lines
Enhanced product hang times
Installed atmospheric evaporators on automatic chrome line for drag out
recovery
Wetting agents and drainage boards
Strategic workpiece positioning
Increase in withdrawal and drainage time
RINSEWATER
Counter-current flow rinse systems
Monitors solutions and uses purer anodes and bags
Utilizes exit spray rinse
Uses atmospheric and simple evaporation techniques
Flow restrictors
Conductivity controls
OTHER
Installed sludge drier to reduce sludge volume
Train staff on causes of increase in hazardous waste production
Tooling attention/maintenance
Chemical inventory and control
Waste collection alterations or improvements
Diking
Product longevity through specification alteration
Energy saving techniques
Plant housekeeping and annual plant assessment
Automatic leak detection system
Preventive maintenance system
Fll-01
Total (mg/kg)
Al-1,800
Sb-14.2
As-13
Ba - 227
Be-ND
Bi-1.7
Cd-12.5
Ca-16,100
Cr-31,100
Hex. Cr-26
Cu - 8,980
Fe - 58,800
Pb - 527
Mg-13,500
Mn - 557
Hg-ND
Ni-180,000
Se - 7,3
Ag - 163
Na - 22,700
Sn - 3,550
Zn - 129,000
CN-16
TCLP(mg/l)
As-ND
Ba-1.3
Cd-0.1
Cr-3.1
Pb-ND
Hg-ND
Se-ND
Ag-ND
Fll-02
Total (mg/kg)
Al - 1,650
Sb-11.1
As - 6.5
Ba-159
Be-ND
Bi-1.8
Cd - 7.3
Ca - 14,800
Cr-48,100
Hex. Cr - 0.4
Cu-11,300
Fe - 69,300
Pb - 230
Mg-13,700
Mn - 707
Hg-0.3
Ni - 84,600
Se-5
Ag-657
Na-84,300
Sn - 8,070
Zn - 94,400
CN - 6.6
TCLP (mg/1)
As-ND
Ba-0.11
Cd - 0.64
Cr-ND
Pb-ND
Hg-ND
Se-ND
Ag - 0.08
September 1998
36
F006 Benchmarking Study
-------
Table 9 (cont'd): Facility-Specific Information for Milwaukee Facilities
Facility F13
Plating Process
F606 Quantity and Management
Sample Description
Nickel chrome on steel
15 tons/yr
Recycle (Inmetco)
F13-01 - did not meet the
regulatory definition of F006
F13-02 - Collected from sludge
supersack
Sample Cnaracter
SPENT PLATING SOLUTION
Oil removal and filtration techniques
Promote product longevity through specification alteration
Uses alternate stripping methodologies - switched from cyanide to non-
cyanide stripping
Evaporation to concentrate plating by-products
Substituted hexavalent chrome with trivalent chrome
Set up pilot line to evaluate a liquid addition agent for cleaning
Require operators to log plating parameters daily which improves their
control
Uses purer anodes and bags and fume suppressors
DRAG OUT REDUCTION/RECOVERY
Enhanced product hang times
Wetting agents
Air knives
Spray or fog rinses
Drainage boards
Increased withdrawal and drainage time
Strategic workpiece positioning
RINSEWATER
Other than cooling water and water used to process incoming water, this is
a zero discharge facility (from the process units)
Rinse water is recycled through filtration, carbon absorption in waste
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
FI3-02
Total (mg/kg)
AI-311
Sb - 0.6
As - 2.3
Ba-6
Be-ND
Bi-ND
Cd-ND
Ca - 855
Cr - 193
Hex. Cr-0.5
Cu - 33.6
Fe - 3,350
Pb - 0.6
Mg - 355
Mn-3.8
Hg-ND
Ni - 76,000
Se-ND
Ag-ND
Na- 16,400
Sn - 9.0
Zn-6.1
CN - 2.0
September 1998
37
F006 Benchmarking Study
-------
Table 9 (cont'd): Facility-Specific Information for Milwaukee Facilities
Facility F14
Plating Process
FOQ& Quantity and Management
Sample Description
Zinc (CN) on Steel
196 tons/yr
Recycle (Horsehead 58%)
Landfill (42%)
F14-01 - Sludge from drier output
Pollution Prevent&n Practices
SPENT PLATING SOLUTIONS
Separated the process chemistry and wastewater treatment departments
Cyanide bath carbonate freezing to prolong life
Utilize bags on 1 chloride bath
Oil removal techniques on 1 barrel
DRAG-OUT REDUCTION
Workpiece positioning
Increase dwell (rinse) cycles
Wetting Agents
Prolonged withdrawal and drainage time
Drainage boards
RINSEWATER
Counter-current flow rinse systems
Flow restrictors
Spray rinse and multiple rinses
Evaporators and filters on 3 of 4 baths
Larger hole barrels
Use alkaline cleaner baths for wastewater pH adjustment
Sludge dryer reduces volume by 65%.
Assessed source by source water use to eliminate major changes in flow
which upsets WWT performance
Employed an environmental engineering company to assist in water
control and reduction.
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
Total (mg/kg)
Al -2,320
Sb-2
As-13.4
Ba-29.2
Be-ND
Bi-ND
Cd - 3.9
Ca-18,000
Cr -26,900
Hex. Cr - 2.6
Cu - 54.6
Fe- 194,000
Pb - 64.8
Mg - 9,990
Mn-979
Hg-ND
Ni-57.1
Se-5.7
Ag - 4.4
Na - 3,830
Sn-19.5
Zn - 277,000
CN - 200
TCLP fmg/1)
As-ND
Ba-1.3
Cd - 0.03
Cr - 0.2
Pb-ND
Hg-ND
Se-ND
Ag-ND
September 1998
38
F006 Benchmarking Study
-------
Table 9 (cont'd): Facility-Specific Information for Milwaukee Facilities
Facility F16
Pbting Process Fd06 Quantity and Management
Nickel chrome on non- ferrous 41 tons/yr
Gold plating
Landfill
PeltotiOH Prevention Practices
SPENT PLATING SOLUTION
Filtration
Improved SOPs by tracking water flow reducing the level of chrome in the
hot rinse >90%
Leak detection systems on plating bath
Metals recovery system via ion exchange reclaims Cr and Ni from rinse
waters
Oil removal techniques on pre-cleaning line
DRAG OUT REDUCTION/RECOVERY
Conductivity meters
Rack design eliminates drag out
Enhanced product hang times on pre-cleaning line
Wetting agents on chrome line
Spray rinses and drainage boards
RINSEWATER
Counter-current flow rinsing on plating and pre-cleaning lines
Flow restrictors
Spray rinsing on some pre-cleaning lines
Replaced solvent-based washers with aqueous systems (increasing sludge
generation)
Continually searching for new environmentally safe cleaners
Operators are certified and receive on-going training
Tooling attention/maintenance
Chemical inventory and control
Diking
Utilize high efficiency motors
Conduct annual plan assessments
Ongoing plant housekeeping and chemical usage reduction
Preventive maintenance systems
Employ monitoring and utilize bags
Sample Description
F16-01 - Collected from supersack
dated that day
F 16-02 - Collected by facility about
2 weeks later
Sample Characterises (Djy>vi.>
F16-01 F16-02
Total fma/ke) Total (mg/ke)
Al- 3,940 Al- 1,210
Sb - 3.5 Sb - 2.7
As - 9.4 As - 7
Ba - 73.7 Ba - 24.5
Be - ND Be - ND
Bi - 5.4 Bi - 2.2
Cd-1.3 Cd-1.3
Ca - 97,300 Ca - 105,000
Cr- 13,800 Cr- 5,520
Hex. Cr- 0.2 Hex. Cr- 0.1
Cu- 13,600 Cu- 5,520
Fe- 11 4,000 Fe- 189,000
Pb - 2,870 Pb - 778
Mg- 10,400 Mg- 4,250
Mn - 671 Mn - 950
Hg - 0.4 Hg - ND
Ni - ND Ni - ND
Se - 30,700 Se - 16,800
Ag - 47.4 Ag - 20.2
Na - 5,490 Na - 7,900
Sn - 497 Sn - 50.8
Zn - 14,200 Zn - 5,790
CN - ND CN - ND
TCLPfmaT) TCLPfme/1)
As - ND As - ND
Ba - 0.9 Ba - 0.2
Cd - 0.03 Cd - ND
Cr-14.5 Cr-I2.7
Pb-0.3 Pb-1.3
Hg- 0.005 Hg-0.01
Se - ND Se - ND
Ag-ND Ag-0.04
September 1998
39
F006 Benchmarking Study
-------
Table 9 (cont'd): Facility-Specific Information for Milwaukee Facilities
Facility F17
Plating Process ld®$ Quantity and Management
Zn (non-CN) on steel unreported
Chrome on nonferrous
Copper-nickel on nonferrous Landfill
Copper-nickel on steel
Cadmium on steel
P&H«ti«rti Prevention Practices
SPENT PLATING SOLUTION
Uses vapor recompression evaporation and carbonate removal system for
recovery
Employs filtration, carbon treatment, replenishment, and electrolytic
dummying
Utilizes cyanide bath carbonate freezing to extend life of solution
Reduced 50% of cadmium to zinc
Oil removal techniques on pre-cleaning line
Alternate stripping methodologies - formerly used cyanide based stripper;
but now outsourced
DRAG OUT REDUCTION/RECOVERY
Uses stagnant rinse tanks or drag out tanks
Drag out waters replace drag in waters or added back to plating bath
Spray rinses and diking
Enhanced product hang times
Utilizes wetting agents and drainage boards
Increased temperature bath, withdrawal and drainage time
RINSEWATER
Segregate wastewater streams
Counter-current flow rinse systems
Flow restrictors
Conductivity meters
Uses reverse osmosis (3 units) and atmospheric and vacuum distillation
evaporation to recycle rinse waters
Ion exchange for water delivered to plating baths
OTHER
Planning to re-engineer the WWT to segregate the nickel sludge from the
cadmium sludge to enable recycling of the nickel sludge to Encycle.
Cadmium sludge will be landfilled.
Chemical inventory and control
Redesigned waste plumbing
Utilizes energy saving techniques
Conducts annual plant assessments and weekly plant housekeeping
Preventive maintenance systems and leak detection on reverse osmosis
equipment
Sample Description . <•"
F 17-01 - Collected from sludge
drier
F 17-02 - Collected from supersack
dated the previous month
Sample Characteristics (Dry \vt,)
F17-01 F17-02
Total (me/kg) Total (me/kg)
Al- 1,260 Al- 1,360
Sb - 0.6 Sb - 0.6
As -3.8 As -4.1
Ba-29.4 Ba-43.5
Be - ND Be - ND
Bi - ND Bi - ND
Cd- 39,300 Cd-21,600
Ca- 14 1,000 Ca- 140,000
Cr- 14,000 Cr- 9,250
Hex. Cr-19 Hex. Cr- 3.7
Cu- 2 1,900 Cu- 18,600
Fe- 24,300 Fe - 17,400
Pb-221 Pb-237
Mg- 12,900 Mg- 12,300
Mn-244 Mn-199
Hg-ND Hg-0.12
Ni- 83,000 Ni-35,100
Se-2.1 Se-2.1
Ag-0.5 Ag-1.5
Na-1 1,700 Na- 17,700
Sn-11.2 Sn-13.8
Zn - 35,500 Zn - 44,600
CN - 380 CN - 99
TCLP fme/n TCLP fog/D
As - ND As - ND
Ba-1.3 Ba-1.1
Cd-13.3 Cd-5.7
Cr-ND Cr-ND
Pb - ND Pb - ND
Hg - ND Hg-ND
Se-0.01 Se-ND
Ag - ND Ag - ND
September 1998
40
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
Detects
# Samples
Above Instrument
Detection, Below
Method Quantitation
# Samples Above Method
Quantitation Limit
Total Metals Concentration (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Bismuth
Cadmium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Selenium
Silver
Sodium
Tin
Zinc
16
16
16
16
16
16
16
, 16
16
16
16
16
16
16
16
16
16
16
16
16
16
0(0%)
0(0%)
0(0%)
0(0%) .
14(87%)
6(37%)
1(6%)
0(0%)
0(0%)
0(0%)
0(0%)
0(0%)
0(0%)
0(0%)
6(37%)
2(12%)
2(12%)
3(37%)
0(0%)
0(0%)
0(0%)
0(0%)
6(37%)
2(12%)
3(19%)
0(0%)
3(19%)
2(12%)
0(0%)
0(0%)
0(0%)
0(0%)
1(6%)
0(0%)
1(6%)
4(25%)
0(0%)
0(0%)
1(6%)
0(0%)
0(0%)
1(6%)
16(100%)
10(63%)
14(88%)
13(81%)
2(13%)
7(44%)
13(82%)
16(100%)
16(100%)
16(100%)
16(100%)
15(94%)
16(100%)
15(94%)
6(37%)
14(88%)
12(75%)
12(75%)
16(100%)
16(100%)
15(94%)
TCLP (mg/l)
Arsenic
Sarium
Cadmium
Chromium
Lead
vlercury
Selenium
Silver
16
16
16
16
16
16
16
16
16(100%)
0(0%)
4(25%)
2(12%)
12(75%)
13(81%)
14(87%)
12(75%)
0(0%)
12(75%)
4(25%)
0(0%)
0(0%)
0(0%)
1(6%)
3(19%)
0(0%)
4(25%)
8(50%)
14(88%)
4(25%)
3(19%)
1(6%)
1(6%)
Genera) Chemistry (mg/kg)
Chloride
Fluoride
Chromium, hexavalent
Total Cyanide
Amenable Cyanide
Jercent Solids
16
16 •
16
16
16
"16
0(0%)
0(0%)
0(0%)
4(25%)
4(25%)
" 0(0%)
0(0%)
1(6%)
0(0%)
0(0%)
0(0%)
0(0%) ft
16(100%)
15(94%)
16(100%)
12(75%)
12(75%)
16(100%)
September 1998
41
F006 Benchmarking Study
-------
II Table 11: Analytical Data for the Milwaukee Facilities.
L . '" "
|nonstitiient
CAS No
F1-011
FQ-01
F1rt-f)1
F17-01
Volatile Organics - Method 8260A ug/kg
Acetone
2-Butanone
2-Hexanone
Benzene
Chloroform
Chlorobenzene
Trichloroethene
4-Methyl-2-pentanone
Toluene
Ethylbenzene
m,p-Xylenes
o-Xylene
67641
78933
591786
71432
67663
108907
79016
108101
108883
100414
108383 / 106423
95476
210
J
ND
ND
J
ND
ND
ND
J
ND
ND
ND
B 7,500
B 58
ND
53
6
J
ND
16
J
ND
ND
ND
B 290
B 69
JB
J
ND
ND
J
64
20
J
.J
J
24
J
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Semivolatile Organics - Method 8270B ug/kg
bis(2-Ethylhexyl)phthalate
Di-n-octylphthalate
Fluoranthene
Phenanthrene
Pyrene
Phenol
Benzyl alcohol
117817
117840
206440
85018
129000
108952
100516
59,000
J
4,900
4,600
J
3,600
7,900
55,000
ND
ND
ND
ND
3,600
7,900
180,000
ND
ND
ND
ND
ND
ND
28,000
ND
ND
ND
ND
ND
ND
Notes: All results reported on a dry-weight basis.
1 . Facility F4's F006 samples were designated as F 1 .
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-l,2-Dichloroethene, 1,1,1-Trichloroethane,
Carbon Tetrachloride, 1,2-Dichloroethane, Benzene, 1 ,2-Dichloropropane, Bromodichloromethane, cis-1,3-
Dichloropropene, trans-l,3-Dichloropropene, 1,1,2-Trichloroethane, Dibromochloromethane, Tetrachloroethene
(PCE), Styrene, Bromoform, 1,1,2,2-Tetrachloroethane, 1,3-Dichlorobenzene, 1,4-DichIorobenzene, 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, N-Nitroso-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,! Anthracene, Carbazole, Di-n-butylphthalate, Butylbenzylphthalate, 3,3'-
Dichlorobenzidine, Benzo(a)anthracene, Chrysene, Din-octylphthalate, Benzo(b)fluoranthene,
Benzo(k)fluoranthene, Benzo("a)pvrene, Indenon,2,3-cd)pyrene, Dibenz(a,h)anthracene, and Benzofe.h.ftoerylene
September 1998
42
F006 Benchmarking Study
-------
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