Background Document June 2011 Providing Context
– The Example of F006 Electroplating Sludges F006 electroplating sludges represents a common example in industry where partial reclamation occurs prior to final reclamation at a primary mineral processing smelter. F006 sludges are generated as part of an electroplater’s on
- site wastewater treatment sy stem, and upon generation, often contain 8 to 12 percent concentrations of recoverable metals, such as copper, zinc, tin and nickel. The wastewater treatment p rocesses used b y facilities generating F006 sludges are designed to separate out contaminants and solids prior to discharge to a surface water body or publicl y owned treatment works (POTW). Most generators of F006 use an on
- site filter press to dewater 1 th eir newly generated wastes. These dewatered materials are indifferentiated because they

could either be disposed of, or sent to a facility for further processing (e.g., partial reclamation) and subsequent recycling. Whether sent off to be landfilled or sub sequently recycled, the dewatering of the sludges is meant to reduce the weight of the material, making it less expensive to transport and subsequentl y manage. Even after the F006 sludges have been dewatered b y the generator, they still contain approximat ely 60 - 75 percent water unsuitable for final reclamation. Because of the composition of F006 sludges at electroplater facilities , further processing is required before they

can become commodity - like and subsequentl y sent to a primary mineral processing fa cility

where the metals contained in them can be recovered or r eclaimed. Partial reclamation facilities ty

pically represent the facilitator or intersecting entity between generators

1 Dewatering is a form of reclamation.producing electroplating residuals, and primary mineral processing facili ties recycling commodity
- like, smelter ready F006 materials. Partial reclamation facilities seek out generators of F006 wastewater treatment sludges containing specific characteristics, particularly high metal content or precious metals that have the pote ntial to meet the contract specifications of primary mineral processing facilities and produce commodity - like, smelter ready m aterials. Generators of electroplating residuals or F006 sludges very

often pay the partial reclamation facility for its services, predicated on the amount of recoverable metals contained in the electroplating residuals. Once generators of F006 sludges are found and contractual arrangements are finalized, the partial reclamation facility will pick up the generator’s shipment and transport it to its facility where the electroplating sludges are processed (e.g., partially reclaimed) to produce a commodity
- like material . The processing steps include: (1) sampling and analyzing the shipment to determine the concentration of desirable, and possibly undesirable constituents that could adversel y impact the efficiency of the smelting process, (2) dewatering the residuals through thermal treatment (e.g., through use of a rotary kiln, roaster, or calcination process), and (3) blending the sh ipment with shipments from other generators in such a way as to meet the contract specifications of the primary mineral processing facility and produce a smelter
- ready material that will maximize potential metal recovery . By meeting the contract specifications of its customer, the partial reclamation facility is paid a fee b y the primary mineral processing facility u sually

predicated upon the price the smelter is paid for delivery of their finished product
. Primary

mineral processing facilities represent the end market where commodity
- like F006 sludges are sent for final recovery . These facilities produce metal products from virgin ore containing particular metals, such as copper. As an example, copper ore when mined usuallycontains between 0.5 percent an d 0.7 percent copper. Once extracted, the copper ore undergoes

a series of beneficiation steps ( e.g., crushing, grinding, and flotation) that produces a virgin ore concentrate of between 28
- 30 percent copper. This concentrate then enters the smelting p rocess to produce a copper anode with a concentration of at least 99 percent copper. This anode is then sent to the electrol yt ic copper process where products, such as billets or wire rod, are produced. The commodity
- like F006 sludges represent a viable su bstitute for virgin ore concentrate that both reduces processing costs and increases smelter utilization. Applying the Revised Criteria to F006 S ludges P artially R eclaimed to Produce a Commodity - like Material 1) Whether the degree of partial reclamation the ma terial has undergone is substantial.

In the case of F006 sludges, the process ing required by a partial reclamation facility to produce a commodity
- like material first involves sampling and analysis of incoming waste shipments to prescreen for constit uents or material characteristics that could adversely impact the smelter process, and to measure the concentration of recoverable metals. Once screened and accepted, the F006 sludges are thermally dried, and blended with other shipments of F006 sludges t o produce a commodity
- like metal concentrate that is smelter
- ready for final processing and recovery by a primary mineral processing facility. This processing occurs at a partial reclamation facility. Conversely, F006 sludges generated by an electroplat er and subsequently shipped to a partial reclamation facility can never be commodity
- like or smelter ready if the only processing involved by the electroplater involves dewatering with a filter press. As des cribed above, t hese sludges still contain 60
- 75% water – unacceptable to a smelter , and often do not contain a sufficient concentration of recoverable metals that a primary mineral processing facility willpurchase . These filter press processes are not designed to partially reclaim the residual from the

electroplating operation into a commodity
- like material. Additional processing steps after the filter press are required before the material can be considered commodity
- like. 2) Whether the partially - reclaimed material has sufficient economic value that it will be purchased for final reclamation . An F006 sludge that has been partially reclaimed to produce a commodity
- like material will have sufficient economic value that a final reclaimer (e.g., primary mineral processing facility) will enter into a contra ct with the partial reclamation facility to purchase th is material. Evidence to support this criterion may

include sales information, business contracts, including quantities of the material sold, additional demand for the material (if any), and the price paid for the material by purchasers. However, an F006 sludge, as generated, very often will not contain a concentration of recoverable metal that will be purchased b y a primary mineral processing facility
. And, as stated above, a newl y generated F006 wast e will contain significant amounts of water

– thus severel y limiting the metal recovery process by

the smelter. Ineffect, the value of the material produced by the electroplater will have no positive economic value, nor will incoming shipments to partial reclamation facilities. Hence, generators pay partial reclamation facilities to process their wastes (e.g., F006 sludges). Therefore, only when the F006 sludge has been thermally dried, and blended with other shipments to produce a metal concentrate with high concentrations of recoverable metal will a commodity
- like material have been produced that a primary mineral processing facility

will purchase. 3) Whether the partially - reclaimed material is a viable substitute for a product or intermediate produced fro m virgin or raw materials which feeds subsequent production steps.In the context of F006 sludges, this criterion would be met when a commodity
- like, smelter

ready material can be substituted for a virgin ore concentrate that is fed into the smelting pr ocess. For example, virgin ore copper concentrate usually contains 28 to 30 percent copper. A partially reclaimed or commodity
- like F006 sludge may not contain that high a concentration of copper, but other valuable metals contained in the material, such as precious metals , may more than offset the economic difference in lower copper concentrations . Data collected by EPA have found a copper primary mineral processing facility willing to pay for concentrations of 18 percent or higher, provided the incomin g material satisfies the other minimum or maximum concentrations for specified constituents identified in business contracts. Although lower than normal virgin ore concentrate, these incoming materials represent levels that can be processed at a profit by the mineral processing facility. Conversely, comparing the concentration of an incoming shipment of F006 waste to a partial reclamation facility (8
- 12% copper on average) with virgin ore (i.e., greater than 0.5% for nickel and 0.7% for copper) would not sa tisfy this criterion. Neither the incoming F006 to the partial reclamation facility nor the virgin ore represent a viable substitute for virgin ore concentrate (28 to 30%) which is fed into the smelting process because n either of these material are commodi ty - like. 4) Whether there is a guarante ed end market for the partially - reclaimed material. T he end market for partially reclaimed F006 that is also commodity
- like would be a primary mineral processing facility . Conversely, the end market would not be a nother intermediate processing or partial reclamation facility. Almost all F006 sludges generated must undergo additional processing steps (e.g., additional de
- watering and blending) by a intermediate processing facility to derive a commodity
like material that a primary mineral processing facility will purchase and recycle. 5 ) Whether the partially - reclaimed material is handled to minimize loss.F006 wastes sent to a partial reclamation facility must be managed in compliance with all

applicable RCRA S ubtitle C regulations , including RCRA Part B storage and treatment permits and financial assurance. The majority of F006 wastewater treatment sludges are stored and transported in closed containers such as drums, cinched super
- sacks (large synthetic bags generally moved by fork
- lift) on pallets, and roll
- on/roll
- off containers. Wastewater treatment sludges are generally a moist cake
- like particulate material that is relatively non
- dispersible and with care is easy to manage in a way that minimizes loss by using these non
- leaking closed containers. Similarly, we would expect a partial reclamation facility to manage any commodity
- like materials produced from their operations so as to eliminate, if not, minimize any releases to the environment because of t he economic value attached to them. Failure to do so suggests the materials are not valuable or commodity
- like.