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RCRA/SUPERFUND HOTLINE SUMMARY
Company A etches semiconductor silicon wafers. Company b use the wafers to manufacture printed circuit boards. The two companies are totally separate. Is company As wastewater treatment sludge from the etching process classified as a F006 waste?
Yes, the wastewater treatment sludge is regulated as F006. The chemical etching is viewed as electroplating, even though the Background Document on electroplating did not include the etching process. The Background Document was overly narrow in including only the manufacture of printed circuit boards and excluding etching.
Source: Bill Sproat and Myles Morse