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HADCO
Stakeholder's Meeting
HADCO
HADCO's Project XL
Stakeholders Meeting
March 18, 1996
Salem, New Hampshire
2:00 Welcome and Introductions
2:10 Overview of Project XL
2:30 Review of HADCO's XL Proposal
3:00 Review of Draft Final Project Agreement (FPA)
3:30 Process to Complete FPA
- Future Meetings
- Dates to submit input
4:00 Adjournment
HADCO CORPORATION 12A MANOR PARKWAY SALEM, NEW HAMPSHIRE 03079 603/ 898-8000
HADCO's Project XL Proposal
Project XL is an EPA regulatory reinvention initiative announced in May, 1995 (60 FR 27282)
"... to give regulated sources the flexibility to develop alternative strategies that will replace or modify specific regulatory requirements on the condition that they produce greater environmental benefits."
Project XL proposals will/are evaluated in the following criteria:
1. Environmental results
"... environmental performance that is superior to what would be achieved through current regulation..." Explicit definitions and measures are required.
2. Cost savings and paperwork
"... should produce cost savings or economic opportunity, and/or result in a decrease in paperwork burden."
3. Stakeholder support
"...support of parties that have a stake in the environmental impacts of the project"
4. Innovation/Multi-media Pollution Prevention
"Projects should embody a systematic approach to environmental protection that... affects more than one environmental medium."
5. Transferability
"... test new approaches that could conceivably be incorporated into the Agency's programs, or ... OTHER FACILITIES IN THE SAME INDUSTRY."
6. Feasibility
"... should be technically and administratively feasible..."
7. Monitoring, reporting and evaluation
"... identify how to make information... available to stakeholders... clear objectives and requirements that will be measureable..."
8. Shifting of risk burden
"... consistent with Executive Order 12898 ... protect worker safety and ensure that no one is subjected to unjust or disproportionate environmental impacts."
HADCO
________________________________________________
Project XL Stakeholders Meeting
Salem, NH
Minutes of 3/18/96 Meeting
The first meeting of HADCO's Project XL stakeholders was held on March 18, 1996 starting at 2:00 at HADCO's offices located at 12A Manor Parkway, Salem, NH. Meeting attendees included
Ron Blanchette HADCO - Derry Pearly Deneault PDL Industrial Products Richard deSeve NH Chapter of Sierra Club Joe Dufresne Teradyne Marc Duquette HADCO - Tech Center 1, Salem Elaine Eakes NH Chapter of Sierra Club Will Gotschall World Resources Company Joan Jouzaitis EPA New England David Marshall Orr & Reno/HADCO Ken Merschner NH DES Steve Raper HADCO - Hudson Russ Tremblay M/A COM & IPC Lee Wilmot HADCO - Salem
Attendees introduced themselves, and Lee Wilmot stated that other stakeholders who indicated they would attend were Ralph Goodno from Merrimack River Watershed Council, and Health Officers James Doolin and Bill Oleksak from Derry and Hudson respectively. Others invited but who could not attend included Tom Kiernan with Audubon Society of NH, Barbara Bernstein of Wastecap of NH, and Suzanne Doucette - Salem Health Officer. Also, Hillary Nelson and Ruth Holmes of Canterbury, NH had faxed in a letter as they could not attend.
Lee Wilmot introduced Andy Lietz, President and CEO of HADCO Corporation, who spoke about HADCO's commitment to both being a good corporate citizen and HADCO's support of Project XL. Lee then reviewed the meeting agenda, and the eight Project XL criteria. (See attached)
An overview of the printed wiring board (PWB) process was given, including which process steps generated wastewater that generated the metal bearing sludge after on-site treatment. The major points of HADCO's project XL proposal was reviewed, including annual shipment volumes from HADCO's three NH sites and annual analyses of pertinent metals from the sludge from these sites. Both total metals and leachable metals analyses were reviewed. (See attached)
Finally, a seven page draft of a final project agreement (FPA) was distributed. Although this draft was intended to spur discussion on the delisting process, stakeholders requested that the next revision be in the format suggested by EPA's guidelines. EPA Washington has suggested completion of the FPA by May 3rd. Most attendees felt this time target was not realistic, but 6/3/96 was.
Questions/comments regarding the project XL proposal were as follows:
1. What happens to metals from the copper smelters?
2. Will other states and EPA regional offices get to review the NH drafts? (Answer = yes)
3. FPA needs to include the term of the project, project evaluation criteria, administrative & legal mechanisms, termination conditions, and applicable regulations.
4. Suggestion to add the definition of F006 waste to draft paragraph B.11.
5. Can copper smelters like Noranda be stakeholders?
6. Is the Province of Quebec interested in being a stakeholder?
7. The NH Chapter of the Sierra Club will advise after March 31st whether it intends to be a stakeholder.
8. How many PWB manufacturers landfill their F006 sludge now?
It was agreed that attendees would submit comments on the draft FPA by Friday, 4/5/96. Further, it was agreed to meet again on Wednesday afternoon, 4/17/96 at 2:00. The meeting will be at HADCO's offices located at 12B Manor Parkway (next door). See attached directions. HADCO agreed to revise the draft FPA for distribution at the next stakeholders meeting on 4/17 and at a New York stakeholders meeting to be held before 4/17.
Respectfully submitted by Lee Wilmot
HADCO's Project XL Proposal
(Major points)
1. Expedited delisting of F006 sludge.
2. Delisting will permit unburdened direct shipment of sludge to copper smelter (s).
Accordingly,
- mobile emissions will decrease
3. Savings from direct recycling of F006 sludge will be invested in sludge dryers thereby
- minimizing volume shipped AND mobile emissions from same
4. Direct recycling sludge savings will also be directed toward recycling copper dusts, thereby
- eliminating landfilling of same
F006 Background
F006 "Wastewater treatment sludges from electroplating operations except from the following processes:...
(5) cleaning/stripping associated with tin, zinc and aluminum plating on carbon steel; "
Further clarified 12/2/86 in 51 FR 43350 to exclude electroless plating and printed circuit board manufacturing (except processes within the scope of the listing).
Basis for listing
Wastewater treatment sludges from listed electroplating operations contain significant concentrations of toxic metals
Printed circuit
dry weight conc.*
cadmium 100
chromium 3500
nickel
and cyanides (complexed)
Leaching tests show that these metals leach out in significant concentrations to pose a risk to groundwater contamination from improper disposal
Comparison of Sludge Concentrations
Listing document HADCO Data (ppm)
measured/projected Derry Hudson Salem
(ppm) / (mg/1*) 1993
1994
1995
Cadmium 100 / 162.5 0.43 0.44
0.49 0.44 0.49 0.970.49
0.48
Chromium (Total) 3500 / 18485 1.06 48
1.22 82.6 59
109 156 47.6
Cyanide (Total) / 2146 4.4 N.D.
69.8 0.83 5.63
9.25 1.61 6.83
3.1 (1996)
Nickel / 24310 447 40
277 26.6 117
444 55.5 283
* Source - Development document for existing source pretreatment standards for the electro-plating point source category. EPA 440/1-78-085. February, 1978
Extract Concentrations of Metals
from Electroplating WWT Sludge
(mg/1)
Listing document HADCO Characteristic
(EP Toxicity)* EPTox (TCLP) HazWaste
1990 1995 Min.Conc.
Printed Circuits 1996
Plating Process
Cadmium 0.01 0.02 1.0
0.10
Chromium 0.12 ND 0.091 5.0
0.15
"The Agency believes that there are factors in addition to metal concentrations in leachates which justify the T listing. Some of these... namely that present industry disposal practices have proven inadequate; the presence of nickel and cyanide, often in high concentrations, two constituents not caught by the (E) characteristic; ..." (p.123)
* Source - American Electroplating Society. Interim Phase I Report: Electroplating wastewater sludge characterization. August 24, 1979; revised September 12, 1979
Comparison of HADCO WWT Sludges
Metal Listing document HADCO
Measured/projected (91-95)
(ppm - dry weight basis)
Cadmium 100/162 0.2 - 2.5
Chromium (Total) 3500/18485 1.06 - 204
Cyanide (Total) /2146 N.D.-69.8
Nickel /24310 26.6 - 1696
Sewage Sludge Criteria
30 day avg/maximum
40 CFR 503.13
Arsenic 41/75 11-278
Cadmium 39/85 0.2-2.5
Chromium 1200/3000 1.06 - 204
Copper 1500/4300 46K - 179K
Lead 300/840 47-28058
Nickel 420/420 ND - 1696
Zinc 2800/7500 1-1009