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Lucent Technologies

Reading Sludge Proposal


XL Project

One Page Program Description

Waste Water Treatment Sludge Delisting

Note: This is a flexibility proposal which first would be applicable to the Reading facility and then to Allentown.

Microelectronics' waste water treatment sludge is currently being transported as F006 hazardous waste to Envirite, a hazardous waste treatment facility. Envirite has obtained a de-listing for the wastes it generates, including Microelectronics' sludge. Microelectronics's sludge does not have to be treated by Envirite to meet the de-listing criteria. It already meets those criteria at the point of generation, which is the Reading facility. Nonetheless, the Reading facility transports the sludge to Envirite, paying hazardous waste fees, after which the sludge is transported to a State-permitted non-hazardous waste facility that is actually closer to the Reading plant than is Envirite.

Microelectronics is proposing to ship its waste water treatment sludge directly to the industrial non-hazardous waste facility where it now eventually ends up, without having to first transport the sludge as hazardous waste to Envirite. The reading facility would continue its current management practices with respect to the storage, containerization and transportation of the sludge, with the sole exception that it would not be manifested as hazardous waste and Microelectronics would not incur the unnecessary additional cost of transporting the sludge as hazardous waste.

SEP Element: The money currently being spent to transport the sludge as hazardous waste would then be spent to reduce air emissions from the Reading plant. Specifically, the money would be spent to buy condensers to condense and recycle propanol fumes that currently are part of the VOC emission load of the facility. By condensing and recycling the proponal used to clean chips and other products, the plant reduces ground level ozone precursors in the form of VOC emissions and further reduces the need to purchase and consume raw propanol. This is an issue that has been raised on numerous occasions by the LEAG and would be a great step in responding to their concerns.

An additional environmental benefit of delisting the sludge will be the savings of transportation costs, including vehicle emissions reduced by a shorter haul to the non-hazardous landfill.

The specific flexibility requested by Microelectronics is that Pennsylvania DEP determine, in a manner consistent with its de-listing authority, that the Reading facility's sludge is not a F006 hazardous waste. A de-listing petition covering this sludge has already been granted to Envirite for purposes of disposal at the same facility that Microelectronics intends to dispose of the sludge.

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