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HADCO
IPC to EPA RE: Comments
February 21, 1997
Mr. James Sullivan
U.S. Environmental Protection Agency
Region II, Mail Code DECA-RCB
290 Broadway
New York, NY 10007-1866
RE: IPC's Comments on Hadco's Project XL Proposal
Dear Mr. Sullivan:
As the U.S.-based trade association representing the electronic interconnection
industry, the Institute for Interconnecting and Packaging Electronic
Circuits (IPC) is submitting these comments on the draft Final Project
Agreement developed for the Hadco Corporation under EPA's Project XL
initiative. For the reasons set forth below, IPC strongly supports Hadco's
Project XL proposal.
The Electronic Interconnection Industry
The IPC represents approximately 21000 companies in the electronic interconnection
industry. IPC's regualr membership includes companies that produce bare
printed circuit boards (commonly referred to as printed wiring boards
(PWBs)) as well as companies that produce electronic assemblies by attaching
electrical components to bare PWBs. IPC members also include suppliers
to the industry as well as major original equipment manufacturers (OEMs),
that use PWBs in their own products, including consumer electronics
as well as more sophisticated industrial and military electronic systems.
IPC membership also includes over 100 representatives from government
and academia with vital interests in the crucial technology.
Hadco's Project XL Proposal
Hadco Corporation (Hadco) is a member of the IPC. Hadco manufactures
PWBs and backplane assemblies at six manufacturing facilities -- five
of which produce PWBs and generate wastewater treatment sludge (WWT),
which was classified by the U.S. EPA as a listed hazardous waste (F006)
in 1980. Hadco generates over 600 tons of WWT sludge each year -- all
of which has been beneficially recycled since 1990. This copper-rich
sludge (5-10% copper) is shipped to facilities in Pennsylvania and Arizona
where it is dried to reduce the water content from 50-65% to approximately
20% before it is shipped to copper smelters for recycling. The dried
sludge is then sent to copper smelters in Canada, Arizona, or Mexico
or other countries.
Hadco also generates over 150 tons of copper-bearing dust each year.
This dust results from PWB drilling, edging, and routing operations.
The dust is neither a listed nor characteristic hazardous waste. Since
the transportation costs associated with shipping the copper-bearing
dust to a smelter are prohibitive, the dust is landfilled.
Hadco's Project XL proposal seeks to maximize the company's recycling
of copper-bearing waste streams from its PWB manufacturing facilities.
To accomplish this, Hadco requires an expedited delisting of its WWT
sludge in order to generate sufficient cost savings that would enable
Hadco to economically justify the transportation of copper-bearing dust
to copper smelters for recycling.
An expedited delisting of Hadco's WWT sludge would achieve cost savings
in three ways: (1) Hadco would be able to use commercial haulers instead
of licensed hazardous waste haulers when transporting the sludge, (2)
Hadco's hazardous waste taxes would go down, and (3) Hadco would have
fewer and shorter sludge transportation trips since Hadco could ship
its WWT sludge directly to smelters. These cost savings will enable
Hadco to install sludge dryers in its facilities. The dryers will minimize
the volume and weight of Hadco's WWT sludge, enabling Hadco to offset
the costs associated with the recycling of its copper dust.
IPC Strongly Supports Hadco's Project XL Proposal Because PWB WWT Sludge
is not Hazardous
The listing of PWB WWT sludge as a hazardous waste was based on field
analysis of both electroplating and PWB WWT sludge in 1979. The listing
was based on four constituents -- cadmium, chromium, cyanides, and nickel.
Although chromic-sulfuric acid etchant was widely used in the PWB industry
in the 1970s, its use waned in the late 1970s/early 1980s and now it
has been virtually eliminated and replaced with non-chrome etchants
such as ammnia or muriatic acid based etchants. Cyanide plating is also
virtually extinct in the PWB industry, except for small quantity, specialized
plating of gold tabs on some PWBs.
As a result, the WWT sludge that PWB manufacturers now generate does
not contain the high concentrations of hazardous constituents which
prompted the sludge's original F006 listing in 1979. Furthermore, Toxic
Characteristic Leaching Procedure (TCLP) analysis of typical PWB WWT
sludge shows that constituent levels for cadmium, chromium, as well
as for the six other RCRA metals covered by the TCLP test, are beneath
levels that EPA considers "hazardous." In addition, total
content analyses of PWB WWT sludge shows that both cadmium and nickel
are present at levels that are below EPA-set levels for the land disposal
of sewage sludge.
Because PWB WWT sludge is listed by the U.S. EPA as an F006 hazardous
waste, the industry spends thousands of dollars each year in unnecessary
hazardous waste management costs for a watse that technically is not
hazardous. In addition, PWB WWT sludge contains very valuable levels
of copper; however, the costs associated with RCRA hazardous waste management
of the sludge discourage some generators from recycling the sludge.
Instead, they send the sludge to hazardous waste landfills where the
valuable and highly reusable copper is entombed and wasted.
IPC Strongly Supports Hadco's Project XL Proposal Because the Project
will Result in "Cleaner, Cheaper, and Smarter" Results
IPC strongly supports Hadco's Project XL proposal because it will release
Hadco from unnecessary and costly hazardous waste regulations and, in
doing so, free up capital which will enable to increase its recycling
of copper-bearing wastes. The proposal, therefore, will truly achieve
a "win-win" situation for Hadco, the environment, and state
and federal regulatory agencies.
Depending upon the facility size and its production capabilities, Hadco
expects that its Project XL proposal will reduce the company's hazardous
waste generation rates by 10-30%. This reduction in hazardous waste
generation rates will directly save Hadco money through lower hazardous
waste taxes. In addition, Hadco will be relieved of onerous and costly
hazardous waste regulatory requirements associated with RCRA Subtitle
C management.
Hadco's proposal promises to increase the amount of copper-bearing waste
that Hadco's facilities generate. The incrase in copper recycling will
reduce the demand of virgin ore, resulting in less being extracted.
Furthermore, Hadco's proposal promises reduce motor vehicle air emissions
since the expedited delisting of WWT sludge will enable Hadco to ship
its WWT sludge directly to copper smelters, resulting in fewer, shorter,
and more direct trips. In addition, the proposal commits Hadco to install
sludge dryers, which will further minimize the volumes of sludge shipped
and, thereby, the air emissions associated with such shipment.
Hadco's Project XL proposal will also benefit the U.S. EPA and state
regulatory agencies by reducing or eliminating paperwork that is currently
associated with Hadco's sludge shipments. Regulators will primarily
benefit from reduced regulatory burdens that will result from Hadco's
ability to ship its WWT sludge directly to Canadian smelters.
Conclusion
Hadco's Project XL proposal is limited to Hadco's New England facilities;
however, IPC urges the U.S. EPA to use the Haco PWB WWT sludge delisting
experience to delist PWB WWT sludge on an industry-wide basis. Delisting
PWB WWT sludge on an industry-wide basis will enhance the environmental
and economic performance of the PWB industry. More PWB WWT sludge will
be recycled, less copper will be mined, less sludge will be landfilled,
and the industry as well as regulatory agencies will enjoy significant
cost savings through reduced regulation.
Thank you for considering IPC's comment on Hadco's Project XL proposal.
If you have any questions, please contact Ms. Holly Lynch, IPC's Director
of Environmental, Health and Safety Programs, at (202) 638-6219.
Sincerely,
Thomas J. Dammrich
President