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Letter from NGA to Conference Call Participants RE: 6/26/96 Conference Call.

NATIONAL
GOVERNORS
ASSOCIATION
Hall of the States
444 North Capitol Street
Washington, D.C. 20001-1512
Telephone (202) 624-5300


June 24, 1996

      F A X C O V E R S H E E T

      To: Gary Murchison, Cal-EPA 916/327-4495
      Steve Linder, EPA Region 9 415/744-1044
      Linda Powell, EPA Region I 415/744-2499
      Ken Marschner, NH DES 603/271-2456
      George Hawkins, EPA Region 1 617/565-3415
      Joan Jouzaitis, EPA Region 1 617/565-3415
      Mark Moroukian, NY DEC 518/457-2570
      Larry Nadler, NY DEC 518/457-2570
      Sherry Bishko, EPA Region 2 212/637-5045
      Kate Donnelly, EPA Region 2 212/637-3199
      Jim Sullivan, EPA Region 2 212/637-4949
      Lisa Hunder, U.S. EPA 202/401-6637

      From: Barbara Wells, Allyn Finegold

      Fax Number: 202/624-5313

      Number of Pages (including this page): 7

      If you had any problems receiving this transmission, please call Barbara Wells, at (202) 624-5822.
      REMINDER

      Conference Call of Participants in HADCO Project XL Pilot
      Wednesday, June 26, from 2:00 to 3:00 Eastern time

      The access number for the call is 703/736-7324
      Attached for your attention is a brief agenda; the June 7, 1996, letter from Norman Nosenchuck of the New York State Department of Environmental Conservation to Michael Shapiro at U.S. EPA; and a list of state and EPA staff involved in the HADCO pilot. If you have any questions or comments, please call Barbara Wells at 202/624-5822.

      CONFERENCE CALL OF PARTICIPANTS IN THE HADCO PROJECT XL PROJECT

      AGENDA

      JUNE 26, 1996

      2:00 - 3:00 PM (EASTERN TIME)

      CALL ACCESS NUMBER: 703/736-7324

      2:00 INTRODUCTIONS

      2:10 DISCUSSION OF NEW YORK DEC LETTER TO U.S. EPA
Summary of the Issue: Larry Nadler, New York DEC
Status of EPA Response: Lisa Hunter, U.S. EPA
Follow Up Activities
      2:30 STATUS OF STAKEHOLDER MEETINGS
Discussion of June 19 Stakeholder Meeting: Gary Murchison, Cal-EPA
Other Stakeholder Issues
      2:45 MEASURES TO FACILITATE COMMUNICATION
Suggested documents to be distributed to the group by NGA
Additional conference calls and agenda topics
Other necessary interaction among the group


NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Division of Solid & Hazardous Materials
50 Wolf Road, Albany, New York 12233-7250
(518) 457-6934 FAX (518) 457-0629
      Mr. Michael Shapiro MAY 07, 1996
      Director
      Office of Solid Waste (MC5301)
      U. S. Environmental Protection Agency
      401 M Street, S.W.
      Washington, D.C. 20460

      Dear Mr. Shapiro:

      Re: Jurisdictional Status of Metal-Rich Sludges

      The New York State Department of Environmental Conservation is seeking input from the United States Environmental Protection Agency (EPA) on an issue which has been considered previously by the EPA Office of Solid Waste, but perhaps not in the context in which it is addressed herein.

      Here's the background on this issue.

      A company manufactures printed wire boards at facilities located in three different states. One facility is located in New York State. These facilities are engaged in metal finishing and each produces a wastewater treatment sludge that current meets the definition of F006. These sludges are very rich in copper, ranging up to 25% (i.e., 250,000 ppm) copper by weight. Significant hazardous constituent metals, including arsenic, chromium, lead, and nickel, are also present, but at levels ranging from 0.01 - 0.1% (100-1,000 ppm).

      The company wishes to send these sludges to a primary copper smelter for extraction of the copper after the sludge has been dewatered further by adding sludge dryers to the company's existing wastewater treatment systems. The copper content of the sludge is comparable to, and probably exceeds, most virgin copper-bearing ores that are currently processed by primary copper smelters. With regard to toxics "along for the ride" (TAR), the levels of arsenic, chromium, lead, and nickel in the sludges will be compared to the ranges found for these metals in virgin copper-bearing ores.

      The issue here is whether it is possible for the extraction of metals from these sludges to rise beyond mere "reclamation" to legitimate "use/reuse" as a feedstock substitute for primary smelters. The "use/reuse" exclusion of 40 CFR 261.2 (e)(1)(i) would, of course, exclude the material from being a solid waste under Subtitle C of RCRA.

      If a F006 sludge is sent to a primary (not secondary) metal smelter, would EPA agree that the material could be considered a legitimate feedstock substitute and could qualify for the "use/reuse" exclusion if the following conditions are met:

        1. That the levels of the metal or metals to be extracted for production purposes must be comparable to or exceed what would be found in virgin raw materials that the primary smelter would otherwise be processing; and

        2. That the levels of all significant hazardous constituents present that are not targeted for extraction must be comparable to or lower than those which would normally be found in virgin ores that the primary smelter would otherwise be processing for extraction of the target metals.

      If EPA would not concur with the application of the use/reuse exclusion to F006 sludges that meet these conditions and are processed by primary smelters, would EPA alternatively consider applying the use/reuse exclusion on a pilot basis, in accordance with a Project XL proposal?

      We look forward to your reply. Thank you in advance for your assistance. If any further information is needed, please have your staff contact Mr. Lawrence J. Nadler.

      Sincerely,

      /s/ Norman H. Nosenchuck
      Norman H. Nosenchuck, P.E.
      Division of Solid & Hazardous Materials

      cc: C. Simon - EPA Region II
bcc: N. Nosenchuck (2)
      N. Mitray
      J. Willson
      P. Counterman
      J. Iannotti
      L. Nadler
      W. Eberle
      W. Yeman

LJN:NHN:z
mshapiro.doc

NGA CONTACTS OF PROJECT XL FOR FACILITIES
22-Jun 96

Contact Agency and Address Phone/Fax Affiliation XL Pilot Projects


Lisa Hunter Office of Policy, Planning and Evaluation Phone: (202) 260-4744 Federal HADCO
U.S. Environmental Protection Agency Fax: (202) 401-6637
401 M Street, SW, Room
Washington DC, 20460


CA

Steve Linder U.S. Environmental Protection Agency Phone: (415) 744-2036 Federal HADCO
75 Hawthorne Street Fax: (415) 744-1044
San Francisco, CA 94105


Gary Murchison Department of Toxic Substance Control Phone: (916) 322-0807 State HADCO Corporation
Sr. Policy Advisor California Environmental Protection Agency Fax: (916) 327-4495
P. O. Box 806 E-Mail: murch@ bx.netoom.com
Sacramento, CA 958120806


Linda Powell Region 9 Phone: (415) 744-1629 Federal HADCO Corporation
U.S. Environmental Protection Agency Fax: (415) 744-2499 3M Corporation
75 Hawthorne Street South Coast Air Quality
San Francisco, CA 94105 Management District
Intel Corporation

MA

George Hawkins Region 1 Phone: (617) 565-9125 Federal HADCO Corporation
U.S. Environmental Protection Agency Fax: (617) 565-3415 IBM Corporation
John F. Kennedy Federal Building
Boston, MA 02203


Joan Jouzaitis EPA New England Phone: (617) 565-9009 Federal HADCO Corporation
U.S. Environmental Protection Agency Fax: (617) 565-3415
John F. Kennedy Federal Building
Boston, MA 02203


NH

Heather Lane Office of the Governor Phone: (603) 271-2121 Governor HADCO Corporation
Legislative Assistant State Capitol, Room 208 Fax: (603) 271-2130
Concord, NH 03301


Ken Marschner Waste Management Division Phone: (603) 271-2943 State HADCO Corporation
Administrator, Waste New Hampshire Department of Fax: (603) 271-2458
Management Compliance Environmental Services
Bureau 6 Hazen Drive
Concord, NH 033010095


Lee Wilmot Health & Environmental Affairs Phone: (603) 898-8010 Facility HADCO Corporation
Corporate Safety, Health, HADCO Corporation Fax: (603) 890-1298
and Environment 12A Manor Parkway E-Mail: Lwilmot@hadco.com
Manager Salem, NH 03079



NY

Sherry Bishko Region 2 Phone: (212) 637-3571 Federal HADCO Corporation
U.S. Environmental Protection Agency Fax: (212) 637-5045 LUCENT Technologies
26 Federal Plaza
New York, NY 10278


Kate Donnelly U.S. Environmental Protection Agency Phone: (212) 637-3205 Federal HADCO
Assistant Regional Counsel 290 Broadway Fax: (212) 637-3199
New York, NY 100071866

Mark Moroukian New York State Dept. of Environmental Phone: (518) 457-6072 State HADCO Corporation
Environmental Engineer Conservation Fax: (518) 457-2570
50 Wolf Road
Albany, NY 122338010


Contact Agency and Address Phone/Fax Affiliation XL Pilot Projects

Lawrence Nadler New York Department of Environmental State HADCO Conservation Fax: (518) 457-2570
50 Wolf Road
Albany, NY 122336010


Jim Sullivan U.S.Environmental Protection Agency Phone: (212) 637-4138 Federal HADCO
290 Broadway Fax: (212) I637-4949
New York, NY 100071866


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