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International Business Machines Corporation (IBM) East Fishkill

The International Business Machines Corporation (IBM) East Fishkill facility in Hopewell Junction, New York has proposed to use specific electroplating wastewater treatment sludges (designated as F006 hazardous wastes) as an ingredient in the production of cement. IBM's specific F006 wastes contain high concentrations of calcium (a necessary ingredient in cement production) and very low levels of hazardous contaminants, comparable to levels found in analogous raw materials used to produce cement. The Resource Conservation and Recovery Act (RCRA) regulates the use of hazardous secondary materials (e.g., wastes) when they are used to produce a product that is in turn used in a manner constituting disposal (e.g., placement on the land). Cement manufacturers that would otherwise accept the sludge for recycling decline to use it because they would be required to get RCRA permits, and because the cement produced using the sludge would be considered a hazardous waste-derived product. Thus for IBM, the most practical option under the current regulatory system is simply to treat and dispose of the sludge, rather than realizing its recycling potential. EPA has agreed to provide site-specific regulatory flexibility to the IBM East Fishkill facility sludge in order to implement this recycling scenario.

Rather than using up valuable landfill space, the waste will be reused, and will substitute for raw materials that would otherwise have to be mined. However, the immediate environmental benefits are relatively minor compared to the more long-term benefits. During the first phase of action, conservation of natural resources normally used by the cement manufacturer will be less than 1% (approximately 300 tons/year). However, F006 is a very large wastestream (an estimated 360,000 to 500,000 tons of dry weight equivalent generated per year nationally), so that even if only a small portion of the entire volume of F006 wastes generated is amenable to this type of recycling, the environmental benefit could be significant.

IBM has proposed that EPA provide an exclusion to the definition of solid waste for a hazardous secondary material that is used as an ingredient to produce a product (cement) that will be used directly on the land. It is expected that the EPA will negotiate and set parameters regarding the constituent concentrations in the sludge, management conditions to ensure that the sludge is not released to the environment, and a means of assessing the effectiveness and safety of using the sludge as an ingredient in cement. This information will contribute to an overall approach towards addressing the environmentally sound recycling of F006 sludges.

IBM has actively solicited the participation of many stakeholders in this project. For example, the Common Sense Initiative/Metal Finishing Subcommittee and the Atlantic States Legal Foundation are two groups being kept involved by mailings from IBM. Local community groups and national environmental groups have also been contacted for their input

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