Environmental Benefits, Copper Plating Process a. Copper Additions to the Wastewater Influent, Effluent and Treatment Sludge As discussed in the Project Summary, regulation of the copper plating rinsewaters and the resulting treatment residuals is an environmentally neutral activity. Revising the regulatory regime does not change the environmental impact of the implementation of the copper plating and mechanical polishing process at IBM Burlington. Table 1 (p.16) details the impacts of the copper plating and mechanical polishing process on the influent to the wastewater treatment plant and the discharge effluent. The baseline loading increases with time, because production increases on the baseline process increase wastewater flows and the mass of copper discharged from the base process. Increases in copper loading are relatively moderate through 1998, with numbers increasing more dramatically from 1998 to 2001 as the copper plating process is fully deployed into the facility product line. Even with the additional process loadings, the copper discharge levels will only be 28% of the water quality limits for the Winooski River. The additional loadings do not represent a significant environmental impact to the receiving stream. The table below summarizes the increased copper loading data. Table 1 PROJECTED COPPER LOADINGS: BASELINE & WITH NEW COPPER PLATING AND MECHANICAL POLISHING PROCESSES All Values in grams per day YE 1995 YE 1997 YE 1998 YE 1999 YE 2000 YE 2001 Baseline Influent Cu 235 309 329 378 378 378 Cu Plating Influent Cu 0 0.06 0.7 2.0 5.4 5.7 Cu Mechanical Polishing Influent Cu 0 18 208 558 1536 1620 Total Cu Influent 000 000 000 938 1919 2004 Total Cu Effluent 139 147 242 422 863 902 Table 2 details the impact of the increased copper loading on the wastewater treatment plan sludge. Table 2 details daily mass loadings of copper to the sludge (in grams per day) and the final sludge copper concentration (in milligrams per kilogram). As was discussed earlier, copper is not regulated as a specified material in the F006 listing or in the TC test. In fact, if IBM was to attempt to delist the sludge, the concentration of copper in the sludge matrix would not even be part of the evaluation and decision process. The copper is bound up in the sludge matrix and processing of the sludge at the Stablex facility results in further stablization of the sludge in a concrete matrix for ultimate disposal in a clay lined landfill cell. This increase in copper concentration does not measurably increase the envir...
