HADCO

State of NH to Lee Wilmot RE

State of New Hampshire
DEPARTMENT OF ENVIRONMENTAL SERVICES
6 Hazen Drive, P.O. Box 95, Concord, NH 03302-0095
603-271-3503 FAX 603-271-2867
TDD Access: Relay NH 1-800-735-2964

April 5, 1996

Mr. Lee R. Wilmot, Manager
Corporate Safety
Health & Environmental Affairs
HADCO Corporation
12A Manor Parkway
Salem, New Hampshire 03079

RE: EPA Project XL - Final Project Agreement with revisions

Dear Mr. Wilmot:

We are pleased to submit for your review, the Department of Environmental Services (DES) comments pertaining to HADCO's Project XL draft Final Project Agreement (FPA). The recent National Governor's Association Project XL meeting we attended in Atlanta was helpful in assessing what pertinent elements should be included in a FPA. Unfortunately, none of the participants selected for the XL initiative had an approved FPA to present for our perusal. Our preliminary comments on your FPA address concerns related to completeness and clarity of technical issues:

We have separated our review of the FPA into four components as listed below:

I. HADCO Facility Summary

· HADCO Corporation is a leading manufacturer of printed wiring boards (PWB) and electronic interconnection products. HADCO sales were approximately $265 million in 1995.

· HADCO operates five manufacturing facilities nationwide:

a. New Hampshire (Derry, Hudson and Salem)
b. New York (Owego)
c. California (Watsonville)

· Total employment at HADCO is approximately 2400 with a proposed expansion of 300 additional employees in Derry, New Hampshire.

· HADCO facilities generate approximately 600 tons of F006 sludge per year.

II. HADCO's XL Proposal

· On July 21, 1995, HADCO submitted a proposal to EPA for enhancing the direct recycling of a metal bearing waste sludge from its PWB manufacturing operations.

· HADCO proposed removing from RCRA-C regulation, its listed F006 wastewater treatment sludge generated within its PWB facilities utilizing an expedited delisting process.

· The reason for HADCO submitting the proposal was due to the current delisting process being too costly, time consuming and complex for EPA, the States and the applicant.

· HADCO's PWB plating chemistry changed substantially since the F006 sludge was originally listed in the late 1970s. Chromic/Sulfuric acid are not longer used as etchant reagents, thereby not creating the hazard which listed the wastewater treatment sludge years ago.

· HADCO's proposal intends to install a sludge dryer at one of their New Hampshire facilities to start the F006 sludge reclamation process. Upon analytical testing and drying the sludge to a predetermined moisture level, HADCO would ship the resulting sludge directly to a smeltering operation or another reclamation facility. The shipment would be done without having to first transport the sludge to a permitted Treatment, Storage, Disposal (TSD) facility.

III. Predicted Project Benefits of HADCO's XL Proposal:

Environmental Results:

· The project would promote the recycling of PWB F006 sludges thereby saving natural resources (ore 4-5% vs. sludge 7-11% copper content). Considering the copper content within the sludge, the material upon processing is a valuable commodity.

· The project would increase waste minimization efforts by drying the sludges before shipment thereby reducing the volume shipped.

· The project would reduce air pollution by reducing the transportation miles via shipping directly to a smelter.

Cost Savings and Paperwork Reductions:

· The savings from not managing the sludge as a hazardous waste is estimated at approximately $200,000/year.

· There would be no need to process a hazardous waste manifest.

· If a successful delisting can occur for this particular PWB F006 sludge and subsequently applied to the other 750 PWB manufacturers, then the cost savings would be very significant.

· There is the possible realization of revenue to HADCO from reclamation of the sludge.

Stakeholder Support:

· Conservation groups should be supportive of saving natural resources via less mining.

· Environmental groups should be supportive due to recycling efforts.

· Positive support should be received from communities where the formerly landfilled sludge no longer occurs.

· This is not a project which increases the risk to the public at large.

Innovation/Multi-Media Pollution Prevention:

· An expedited delisting would promote greater flexibility from a procedural requirement that normally is costly and complex. Conceivably, the project may assist EPA in developing a more streamlined delisting process for use in certain other listed waste streams.

· In the area of multi-media pollution prevention: solid waste minimization and recycling, mobile air emission reduction, and raw material use reduction would increase.

Transferability:

· If the HADCO pilot is successful, then many similar PWB companies may benefit from an expedited delisting process.

· If the expedited delisting is approved, the potential for establishing a trading system with other PWB manufacturers to take their non-hazardous F006 sludge to a facility with a sludge dryer becomes a strong possibility. Upon drying the sludge at a centralized location, all the sludge could be directly shipped to a smelter, thereby saving additional costs and air pollution emissions.

Feasibility:

· The proposed project is very feasible because it is not conceptually or technically difficult to implement.

· The cost to initiate the proposal is relatively low.

· Some clarification with Canada may be necessary on the classification of the listed waste stream, but this is not insurmountable.

Monitoring, Report and Evaluation:

· The project will be easy to monitor before and after delisting:

a. Technical analysis of sludge samples will be done regularly to demonstrate the sludge is meeting the criteria for delisting.
b. Number of shipments to the processing facility and cost will be kept.
c. Average tons/shipment will be logged.
d. Miles traveled by transporting trucks will be recorded.
e. Estimate of truck fuel consumed will be tallied.
f. Revenue realized due to direct recycling will be monitored.

Shifting the Risk Burden:

· No shifting of the risk burden is expected, nor are there any environmental justice issues involved.

IV. Review Comments from the March 18, 1996 Draft FPA Format:

A. Facility and Industry

· A summary of HADCO Corporation and the printed wiring board industry should be included as an FPA "opening" section to familiarize the reader with the project
participant and its industry.

· The inclusion of PWB industry F006 sludge figures generated per year would be helpful to understand the magnitude of F006 sludge produced nationally, and how much is potentially eligible for direct recycling.

B. Project Description

· The language used in describing the project should be reviewed to ensure clarity of understanding for all stakeholders and the public. The use of acronyms or EPA jargon, especially found in the second paragraph, page 1, should be revised or avoided. Examples of the above would include such terms as: EP, TCLP, amenable cyanide, landban and 40 CFR 261.41.

C. Description of the Project's Basic Provisions

· If the intent of the project is ultimately to craft an expedited delisting process that many others could follow, then a detailed "delisting process procedure" should be incorporated into this section. For example, 40 CFR 260.22 establishes a procedure for delisting a listed hazardous waste. HADCO's proposal ought to validate a process, by steps, for what must be done to convince EPA and the State that the PWB F006 sludge should receive an expedited "conditional" or "unconditional" delisting.

· With respect to the sampling protocols, the frequency of testing the various composite samples from the HADCO facilities must be explicitly determined to arrive at a statistically significant set of data over the three month period of intensive sampling. Consideration must be given to ensure that three months of sampling are truly representative of the sludge quality.

· Under #3, page 2, "Other constituents of interest" in the sludge, an analysis for "sulfides" from the treatment process should be included to ensure the receiving facility reclaiming the sludge materials is fully aware of the sulfur content.

· Under #4, page 2, HADCO should research the formerly delisted F006 sludge levels in the Federal Register and present to the EPA and the State a summary of HADCO's comparison findings.

D. Project XL Criteria

Environmental Results:

· An explanation of sludge residuals not reclaimed at a smelter should be described and an accounting made as to their final disposition.

· A more complete explanation is needed to describe how the edging dust and drilling fines will fit into the reclamation process.

Cost Savings and Paperwork Reduction:

· In the cost savings paragraph, it appears that the sludge dryer purchase is contingent upon receiving revenue from the recycling of the sludge. Purchasing the dryer in advance of final FPA approval may be an appropriate strategy for HADCO to consider. HADCO is unique in the XL process because the corporation may seek an EPA and State variance during the project's implementation state. See the "general comments" section at the end of this review for further discussion on this topic.

Stakeholder Support:

· HADCO has made a valiant effort to enlist the support of potentially interested stakeholders for this project, but the corporation should attempt to include the future reclamation facilities in the stakeholders group.

Innovation/Multimedia Pollution Prevention:

· No comments.

Transferability:

· The creation of an expedited delisting process for similar PWB F006 sludges is a crucial element in the success of this project. The "expedited delisting process" created will have carryover value to other listed waste streams which are truly nonhazardous. Some listed waste streams may be vestiges of regulations created in the 1970s and may no longer be applicable with today's changing process technology.

Mr. Lee R. Wilmot, Manager
Corporate Safety
HADCO Corporation
April 5, 1996
page 7

Feasibility:

· This project has an extremely high potential for success due to is relative simplicity.

· A detailed review of Canadian rules must be accomplished to ensure the project's international compatibility.

Monitoring, Report and Evaluation:

· Monthly data reporting to EPA and the State is requested for the first three months of the project's implementation. The data should be in a graphical format if possible.

· Data should also include the percent of solids before and after sludge drying.

Shifting of Risk Burden:

· A demonstration should be made that the smeltering operation has appropriate air permits to accept HADCO's sludge.

· Slag disposition from the sludge reclamation must be done in an environmentally sound manner.

· Proof will be required to ascertain that any gases omitted from the sludge dryer operation are adequately treated before release.

· Documentation is necessary to ensure that sludge stored at HADCO is managed in a manner that does not pose any risks to health and environment.

· Certification will be needed to document an end market on the "smelted" sludge to ensure the copper is sold from the smelter.

General Comments:

· HADCO should consider advancing the reclamation process of the F006 sludge at their facilities through the purchase of a sludge dryer. The solid waste variance provision at 40 CFR 260.31(c) may provide HADCO the opportunity to pursue this project with a "legal shield" not easily found for other Project XL participants. Please see the attached April 6, 1988 letter from Sylvia K. Lowrance, Director of EPA's Office of Solid Waste.

Mr. Lee R. Wilmot, Manager
Corporate Safety
HADCO Corporation
April 5, 1996
page 7

· A statement of project termination should be included in the FPA in case the signatories can not agree to sustain the project.

We thank you for the opportunity to comment on the draft FPA. Please be assured that the Department of Environmental Services is enthusiastic about the potential success of HADCO's Project XL proposal and the relief the project may bring to the PWB industry as a whole. The elements of environmental benefit, cost savings and regulatory relief are prominent in this proposal and the DES will work diligently with HADCO to see the project through to a successful conclusion.

I look forward to our second meeting with the stakeholders on April 17, 1996 and a review of their comments to the FPA. Good luck with your other stakeholder meetings in New York and California!

Sincerely,

/s/ Kenneth W. Marschner
Kenneth W. Marschner
Administrator
Waste Management Compliance Bureau
Waste Management Division

Attch.

cc: Joan Jouzaitis, EPA - New England
Philip J. O'Brien, Ph.D., Director WMD
Anne Renner, Esq., NHDOJ

HADCO

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