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World Resources Company to EPA

1600 Anderson Road Tel: 703.734.9800
McLean, Virginia 22102 Fax: 703.790.7245


Joshua Secunda, Senior Enforcement Counsel
U.S. Environmental Protection Agency, Region I
John F. Kennedy Federal Building
Boston, MA 02203

FROM: World Resources Company


For many years, World Resources Company (WRC) has worked to have selected F006 sludges, such as those generated by the printed circuit board industry, be deemed under environmental regulations not to be solid waste when the sludges are recycled and used as feedstocks within the metals extraction industry. Consistently, WRC has argued that, if these sludges are managed as recyclable materials rather than as hazardous waste, the generator's cost for purchase of recycling services provided by WRC will be reduced.

Reduction of the cost of recycling the F006 sludge generated by HADCO Corporation is the objective at the heart of its proposed Project XL. HADCO asserts that management of its F006 sludge as not solid waste will provide less expensive recycling because the material can be sent directly to smelters for metal extraction. However, HADCO has not demonstrated, were this to be the case, that the cost of recycling would be reduced as compared with its present recycling system whereunder it contracts with WRC for full recycling services including certification that the sludge has been used as an ingredient in the production of metal concentrates that have been sold for the purpose of extraction of metal.

As presently structured, HADCO's Project XL presumes, without demonstration, that if HADCO can offer its sludge for recycling as not a solid waste, its cost for direct recycling by a smelter will be significantly lower than the costs charged by WRC for comparable services. It is prejudicial to WRC to presume either (1) that WRC's cost for recycling F006 sludge that is deemed not be solid waste would not be lowered, or (2) that HADCO can obtain lower cost recycling services directly from a smelter than from WRC under the same circumstances.

Therefore, the Final Project Agreement Work Plan for Project XL -- HADCO Corporation must be modified to recognize these facts and provide WRC opportunity, without prejudice, to compete for HADCO's recycling business.

If requested, WRC will submit language that appropriate provides WRC acceptable access to the recycling business opportunities under the HADCO Project XL. WRC is of the view that modification/substitution for Section IV. Storage and Handling detailed as Paragraph 25. of the Final Project Agreement Work Plan provides the proper vehicle for this objective.


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