Sludge Impacts. IBM has based its request for a site specific process exemption from the F006 regulations on the evaluation of the impact of the copper plating rinsewaters on the IBM wastewater treatment plant influent and sludge. It is IBM’s belief that the F006 listing as originally promulgated was not intended to capture the operations performed at the IBM Burlington facility and should not be applicable to the proposed copper plating semiconductor manufacturing process for the following reasons: @ the guidance documentation dated August 1979. Appendix VII of Part 261 does not identify copper as a reason for the F006 listing. Copper metal is also not regulated under the Land Disposal Restriction (LDR) standards for wastewaters or non-wastewaters. The LDRs do not set standards for copper, as the metal does not represent a significant environmental threat when materials are land disposed. The TCLP results, provided in Appendix A, demonstrate that the sludge is not hazardous for characteristics. As described above, the total mass of copper projected to be introduced into the plating rinsewaters for the copper metallization process at full production is 5.7 grams per day and the total volume of rinsewater generated from the process is projected to be 5500 gallons per day. The impact of this wastestream on the composition of the wastewater treatment sludges is inconsequential. @ After the copper metallization step, the wafer is subjected to mechanical polishing. This operation results in the generation of 99.4% of the copper mass (2004 grams in the year 2001) generated from the introduction of the copper plating process. Under the F006 definition, this process wastestream does not result in the generation of a regulated hazardous treatment sludge as the polishing process is not in-line or directly associated with the copper plating process. The impacts of the copper plating and mechanical polishing processes on the wastewater treatment sludge are minimal. At full deployment of the two, distinct processes, the mass of copper transferred to the sludge will increase from approximately 170 grams per day (baseline) to 1102 grams per day, resulting in an increase in the sludge concentration from 34 mg/kg to 180 mg/kg. Again, 99.4% of the increase results from the unregulated mechanical polishing process. The sludge would also not come under regulation under the RCRA Toxic Characteristic test, as copper is not a regulated material.
