Background Document 

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 system, and upon 

generation, often contain 8 to 12 percent concentrations of recoverable metals, such as copper, 

zinc, tin and nickel. The wastewater treatment processes used by facilities generating F006 

sludges are designed to separate out contaminants and solids prior to discharge to a surface water 

body or publicly owned treatment works (POTW). Most generators of F006 use an on-site filter 

press to dewater1their 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 subsequently 

recycled, the dewatering of the sludges is meant to reduce the weight of the material, making it 

less expensive to transport and subsequently manage. Even after the F006 sludges have been 

dewatered by the generator, they still contain approximately 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 subsequently sent to a primary mineral 

processing facility where the metals contained in them can be recovered or reclaimed. Partial 

reclamation facilities typically represent the facilitator or intersecting entity between generators 

 

1 Dewatering is a form of reclamation.
producing electroplating residuals, and primary mineral processing facilities 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 potential to meet the contract specifications of primary mineral processing facilities and 

produce commodity-like, smelter ready materials. 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 

adversely 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 shipment 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 by the primary mineral processing facility usually 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 usually contains between 0.5 percent and 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 process to produce a copper anode with a concentration 

of at least 99 percent copper. This anode is then sent to the electrolytic copper process where 

products, such as billets or wire rod, are produced. The commodity-like F006 sludges represent a 

viable substitute for virgin ore concentrate that both reduces processing costs and increases 

smelter utilization. 

Applying the Revised Criteria to F006 Sludges Partially Reclaimed to Produce a 

Commodity-like Material

1) Whether the partial reclamation of the material is substantial to produce a 

commodity-like material. 

In the case of F006 sludges, the processing required by a partial reclamation facility to 

produce a commodity-like material first involves sampling and analysis of incoming waste 

shipments to prescreen for constituents 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 

to 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 electroplater 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 described above, these 

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 will 

purchase. These filter press processes are notdesigned to partially reclaim the residual from the 

electroplating operation into a commodity-like material. Additionalprocessing 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 

generally be purchased.

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 

contract with the partial reclamation facility to purchase this 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 by a primary mineral processing facility. And, as stated 

above, a newly generated F006 waste will contain significant amounts of water – thus severely 

limiting the metal recovery process by the smelter. In effect, 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 from virgin or raw materials that 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 process. 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 incoming 

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 satisfy 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 neitherof these materialare commodity-like. 

4) Whether there is a guaranteed end market for the partially reclaimed material.

The 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 another 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 commoditylike 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 Subtitle 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 the economic value attached to them. Failure to do so suggests the materials are not 

valuable or commodity-like.