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Stakeholder's Meeting Minutes

HADCO Project XL
Minutes of 6/19/96 Stakeholder Meeting
A video conference meeting was held on 6/19/96 with the following attendees at the four sites connected:

Salem, NH
Derry, NH
Marc Duquette HADCO Salem TC1 Ron BlanchetteHADCO Derry
Suzanne Orenstein Resolve Steve RaperHADCO Hudson
Lee Rice World Resources
Will Gotschall World Resources
Tom Kiernan Audubon Society Kate DonnellyEPA Reg II
Paul Mercier Wastecap of NH Perry WalterHADCO Owego
Joan Jouzaitis EPA New England
Joshua Secunda EPA New England
Watsonville, CA
David Marshall Orr & Reno, PA Mostafa PournejatZycon
Lee Wilmot HADCO Salem Larry Bush Watsonville POTW
Ken Marschener NH DES Mike Dwan West Coast Circuits
Ken Rota EPA New England Vic Marani Indep. Consultant
Steven Linder EPA Region IX Gary MurchisonCA DTSC
Lisa Hunter EPA Washington Mike CruddasHADCO TC2
Ralph Goodno MerrRiver W Cncl Robert PunoHADCO TC2
Bill Oleksak Town of Hudson  

After introductions by all attending, the meeting started with a review of the 5/31/96 discussion draft 3 of the final project agreement (FPA).

First reviewed was the environmental results of the XL criteria. The commitment to install sludge dryers v economic viability was discussed, along with allowable moisture content of dried sludge. The separation of copper bearing dusts was raised regarding economics of recycling these dusts. Depending on facility, this has limited ability.
Mobile emissions was discussed, and it was agreed to not restrict emissions to haul trucks, as rail shipments of a delisted sludge are possible. It was also requested to have a before and after comparison of air emissions and water discharges at each facility to determine what if any difference sludge drying makes.

Cost Savings Issues discussed included # of haul trips, maximum loading per shipment, processing fees (at receiving facility), haz waste tax and manifest fees.

Stakeholder Meetings Gary Murchison and Mark Moroukian (NY DEC) reported not receiving meeting packages. Over 40 were sent out.

Transferability WRC believes that this project is not transferable to most PWB manufacturers due to the small size of many PWB shops. They reported that totals for SIC code 3672 are about 16000 tons of F006 sludge generated, of which 12,500 was recycled. WRC recycled about 11000 tons from 130 generators. The concept of consortiums was discussed.
Smelter specifications for incoming material was discussed. Gary M asked what are we doing to encourage recycling? The issue of smelter specs to avoid BIF rules was made by Ken Rota, and that leachable


concentrations are on smelter slag, not incoming raw materials. p.2

Monitoring Analyses of samples for TCLP organics on first weekly composite (except of herbicides and insecticides) was confirmed, as was TOC analyses on remaining weekly composites.
It was agreed to combine transportation method and fuel usage for reporting. Also, reporting should be on a calendar year basis.
Critique of HADCO's final report was discussed, and generally felt that Agencies should comment on this final report. A followup meeting of stakeholders was also discussed.

Risk of Burden HADCO and smelter worker exposure to sludge dust was an area of concern, as was this exposure to truck drivers.

The timeframe and next steps regarding this project were then discussed. The economic viability of the combined project (both sludge and copper dust) will be the major factors determining viability. If economic viability is good, then there would be a desire to transfer this to other facilities as soon as possible. Whether EPA would entertain a change in RCRA listing rules would depend on a number of factors.
WRC expressed concern about EPA giving up its discretion. Several EPA personnel responded saying that they are giving up no discretion, and are viewing the analytical requirements in the FPA as a screening tool to determine how best to proceed i.e. conditional delisting, or solid waste variance.
A discussion then ensued regarding the legal status of an FPA. It was emphasized that an FPA is NOT a legally enforceable document, but rather a statement of work plan.

Implementation Mechanisms - State
Gary Murchison stated that California can only sign for what it has authority over. If HADCO's sludge is delisted by EPA, then it would be exempt under CA law provided it is recycled at a copper smelter. Gary will provide language regarding CA's signatory caveat, and the name of the person signing for CA DTSC.

Discussion was held on replacing the list of smelters willing to accept delisted sludge with letters of intent from those smelters along with the material specifications that they would require.

Future Action
It was agreed that one more meeting would be necessary in order to view the changes in the WPA (work plan agreement) discussed above. HADCO will target mailing this out on 7/1/96 so that attendees would have the revision by the next meeting scheduled for Wed. 7/17/96.
Respectfully submitted by Lee Wilmot on 7/3/96.
/initialed/ JLW

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