Reassessment of the F006 Listing Sample Clauses

Reassessment of the F006 Listing. IBM is seeking a site specific reassessment of the application of the F006 RCRA listing, as defined in 40CFR261.31, to the rinsewaters generated by the semiconductor wafer copper plating process. The F006 RCRA listing states, “Wastewater treatment sludges from electroplating operations except from the following processes: (1) sulfuric acid anodizing of aluminum; (2) tin plating on carbon steel; (3) zinc plating (segregated basis) on carbon steel; (4) aluminum or zinc- aluminum plating on carbon steel; (5) cleaning/stripping associated with tin, zinc, and aluminum plating on carbon steel; and (6) chemical etching and milling of aluminum.” are F006 wastes. The documented hotline and compendium rulings. The F006 listing, as promulgated, was primarily focused on large scale plating operations used to plate large metal parts for the finished goods industry. These operations utilized plating and rinse baths consisting of hundreds or thousands of gallons of plating and rinsing solutions which typically processed large parts with extensive geometries. As parts moved from the plating bath to the rinse bath, they carried over significant quantities of plating solution into the rinsewaters, resulting in significant levels of metals in the wastewater treatment sludges. The copper plating process discussed in this application is very different than the electroplating that was performed twenty years ago. Perhaps most importantly, the chemicals used in IBM’s process do not contain the heavy metals, listed in Appendix VII to Part 261 (Basis for Listing Hazardous Waste) which were the focus of the original F006 definition. The plating process and equipment have also been engineered with negligible environmental impact in mind. The process has been designed to minimize the use of the chemical in the plating process and the quantity of chemical dragged out from the plating process to the rinse step. The quantity of copper released through the discharge of the rinsewaters (which is further discussed in this application) is negligible. The process has been developed to maximize the efficient use of the copper metal and minimize the release of the materials into the wastewater system.
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