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HADCO to Stakeholders RE: Project XL

29 October 1996
Richard deSeve, Esq. Ralph Goodno, President
Baldwin & deSeve Merrimack River Watershed Council
101 North Main St. POB 1377
Concord, NH 03301 Lawrence, MA 01842

Bruce Hill, Staff Scientist Tom Kiernan, President
Appalachian Mountain club Audubon Society of NH
POB 298 3 Silk Farm Road
Gorham, NH 03581 Concord, NH 03301-8200

Pilar Olivo Jeanne Sole, Staff Attorney
NH Citizen Action Conservation Law Foundation
10 Ferry Street, Unit 319 62 Summer Street
Concord, NH 03001 Boston, MA 02110-1008

RE: Project XL

Ladies and Gentlemen:

As you may know, HADCO Corporation has submitted a proposal for consideration under EPA's project XL initiative. Our proposal's goal is to enhance the recycling of copper bearing wastes from our printed wiring board manufacturing facilities. Once achieved, our goal will result in both reduced mobile air emissions and reduced material landfilled. A copy of our proposal is enclosed for your review, along with comments from NH DES Waste Management Div.

Essentially, our proposal seeks an expedited delisting of our wastewater treatment (WWT) sludge so that direct recycling of this material (our intent is to directly ship to a major copper smelter in Quebec province) without the cost and administrative burden of exporting a "hazardous waste". This smelter (Noranda) has determined by testing that these materials are NOT a hazardous waste in Canada, which confirms our tests using EPA's criteria and protocols for characteristics of hazardous waste. Our understanding is that the typical delisting process takes 3-4 years, with several taking 5-6 years. With confirmation that our WWT sludges are not characteristic hazardous wastes coupled with recycling agreement with this Canadian smelter (there aren't too many in North America), we hope to see a reduction in our recycling costs for our WWT sludge (we've been recycling this material through a processor in Pennsylvania for over five years). We then plan to invest any savings into sludge drying equipment to further reduce the volume of what is directly shipped to the smelter, and to commence recycling of our copper bearing dusts (generated by sawing, drilling and edging PWB copper laminate stock), currently landfilled.


While our proposal was submitted only three months ago, I have not had the time to involve other stakeholders in our proposal, although Ralph and I discussed it briefly. Hence this letter seeking your review, comments and suggestions on our proposal. I would have liked to discuss this with you at our upcoming meeting of the Public Advisory Group of the NH Comparative Risk Project on 31 October, but unfortunately I have a prior commitment. I would however, appreciate your calling (617/565-9125) or faxing (617/565-3415) George Hawkins, Special Assistant to John DeVillars, Regional Administrator for EPA New England as soon as you can with your comments. To the extent that your organization is impacted by our proposal, we would both appreciate your comments.

I am also enclosing a graph showing the results of our waste minimization efforts on WWT sludge at our Salem, NH facility. This achievement of 72% reduction in sludge generated over four years, WITHOUT ANY INCREASE IN HEAVY METALS DISCHARGED, was accomplished by changing wastewater treatment chemistry only. The current chemistry was developed by a startup company here in New England (Romar Technology, Danvers, MA) and has not only achieved the results shown, but also has given us the ability to meet the proposed heavy metal limitations as proposed recently in EPA's Metal Products and Machinery guidelines.

We are willing to share information such as the enclosed group data with you, as well as other companies who generate wastewater containing heavy metals, and the associated WWT sludge from its treatment. Please note that even if our (or our industry's) WWT sludge is delisted as a listed hazardous waste, that proper management of this recyclable streams is guided by the sewer sludge rules promulgated under 40 CFR 503, as the concentration of the very constituent which makes this material excellent for recycling (copper), also prohibits it from land disposal.

Please contact me at 603/898-8010, or by fax at 603/890-1298, or by email at lwilmot@hadco.com with any questions you might have on our proposal.


Lee R. Wilmot
Manager, Corporate SAFETY
Health & Environmental Affairs

cc: George Hawkins, Esq.
Dick Saporito

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