As a Large Quantity Generator (LQG) of hazardous waste, you are aware that hazardous waste may not accumulate at your site for longer than 90 days unless it is managed in a satellite accumulation area pursuant to 40 CFR 262.34(c)(1).  However, did you know that an extension of the on-site accumulation time limit from ≤90 days to≤180 days exists for a specific type of hazardous waste?   F006 electroplating wastewater treatment sludge destined for recycling may be accumulated on-site for up to 180 days without a permit or interim status pursuant to 40 CFR 262.34(g-I).  This extension is not granted to any other hazardous waste the facility may generate.  Nor is the extension allowed if the F006 waste is destined for any disposal option other than “legitimately recycled through metals recovery” per 40 CFR 262.34(g)(2).

The one great restriction on the use of this extension is the requirement that the F006 hazardous waste be “legitimately recycled through metals recovery”.  If the wastewater treatment sludge from your electroplating operations is destined for landfill or other treatment instead of metals recovery recycling, you will not be able to take advantage of this extension.  The limiting factors in recycling this type of waste are the value of the metals to be recovered and their concentration in the sludge.  Sludge with low-value metals such as zinc or tin will have a harder time finding recycling options than a sludge containing higher concentrations of copper, nickel, or chrome.  This is something every generator must determine for itself.

If you are able to take advantage of the extension, the requirements of the US EPA are relatively simple; they include:

1. Implement pollution prevention practices to reduce the hazards of the F006 waste [40 CFR 262.34(g)(1)].
2. Ensure the F006 waste is legitimately recycled through metals recovery [40 CFR 262.34(g)(2)].
3. Accumulate no more than 20,000 kg of F006 waste on-site at any one time [40 CFR 262.34(g)(3)].
4. Comply with the regulations applicable to LQG’s who manage hazardous waste in containers, tanks, or containment buildings [40 CFR 262.34(g)(4)(i-v)].

If the recycling facility to which you ship the F006 waste is at a distance of ≥200 miles, then you may accumulate the waste on-site for up to 270 days without a permit and without special permission from US EPA [40 CFR 262.34(h)].

Unless an extension to the 180/270 day time limit or an exception to the 20,000 kg on-site accumulation limit has been granted by the Regional Administrator of the US EPA, an exceedence of either of these limits subjects the facility to the US EPA regulations of a storage facility and the requirements of 40 CFR 264,265, and 267 and the permit requirements of 40 CFR 270.

Unless you generate an F006 listed hazardous waste from the on-site treatment of electroplating wastewaters, this extension in on-site accumulation times will not be of any benefit to you.  Further, if you generate this type of waste but do not have a recycling disposal option available, you will not be able to avail yourself of the increased on-site accumulation time limits.  However, if you meet the required criteria, it may be of great benefit to you to take advantage of this limited extension of the on-site accumulation limits.