HADCO

Project XL Fact Sheet

EPA 100-F-98-018
United States Environmental Protection Agency
Office of the Administrator
September 1998

[Mail Code 1802] (https://www.epa.gov/)
EPA

Project XL:
HADCO Corporation

WHAT IS PROJECT XL?

Project XL, which stands for "eXcellence and Leadership," is a national initiative that tests innovative ways of achieving better and more cost-effective public health and environmental protection. The experience and lessons learned from Project XL will assist EPA in redesigning its current regulatory and policy-setting approaches. Project XL encourages testing of cleaner, cheaper, and smarter ways to attain environmental results superior to those achieved under current regulations and policies, in conjunction with greater accountability to stakeholders. Project XL is limited in scope, having a goal commitment of 50 pilot projects. Therefore, it is vital that each project test new ideas with potential for wide application and broad environmental benefits. As of August 1998, nine pilot experiments are being implemented and twenty additional projects are currently being developed.

SUMMARY OF THE HADCO PROJECT

HADCO is a leading manufacturer of printed wiring boards (PWB) and electronic interconnection products. Due to process changes since the 1970's, HADCO believes that the sludges created as a by-product of its operations are far less toxic and no longer need to be regulated as a hazardous waste. HADCO's XL project proposes to remove these wastes, which are rich in valuable copper, from regulation under the Resource Conservation and Recovery Act (RCRA) based on analyses of the waste with the hope that they are sent directly to be recycled. Four HADCO facilities are participating in Project XL--Owego, NY, and Derry, Hudson, and Salem, NH. The Final Project Agreement was signed on October 2, 1997.

SUPERIOR ENVIRONMENTAL PERFORMANCE

HADCO has committed to direct 100 percent of cost savings realized from the project towards expanding its efforts to recover valuable metals or prevent pollution. HADCO will voluntarily recycle copper dusts--another by-product of its operations--that are currently sent to land fills and may install sludge dryers to reduce the volume of sludge wastes. Other environmental benefits will be achieved by reducing the risks created by transportation of wastes that currently must be shipped one hundred miles in the opposite direction to a "middleman" for processing. HADCO believes that, in the future, a potentially large number of facilities in its industry could use this expedited process to reclaim valuable materials from their wastes.

FLEXIBILITY

Because HADCO's waste water sludges are currently listed as a hazardous waste under RCRA, it must ship these wastes to a third party processor prior to sending them to a facility that will reclaim the valuable copper from the sludges. HADCO seeks to remove these sludges from regulation under RCRA through a "conditional delisting" or a solid waste variance -- a removal of the waste from the list of regulated wastes, on the condition that the sludges be sent directly for recycling. The project agreement with HADCO specifies the tests that will be done on the waste to determine which, if either, regulatory option would safely allow HADCO's sludges to be sent directly for recycling, rather than having to ship them first to a third party processor. HADCO proposed this flexibility to encourage recycling, and to provide an alternative to the current process for delisting hazardous waste, which the company saw as prohibitively long and costly.

STAKEHOLDER INVOLVEMENT

Direct participants included a regional environmental group, local representatives of national environmental groups (Audubon Society, Sierra Club), representatives from local towns, and industry representatives. Stakeholder committees were formed in New Hampshire in March, 1996, and in New York in April, 1996. Meetings were conducted in both New Hampshire and New York, and two were conducted via video conference with stakeholders in both states. A public hearing was held at the New York facility on February 13, 1997, during the public comment period for the Final Project Agreement. The purpose of each meeting was to inform all interested citizens about the development and implementation of HADCO's Project XL proposal and to seek public comment and input on the proposal.

APPROACHES TO BE TESTED

The HADCO project explores whether valuable materials determined to be safe can be reclaimed from waste streams without shipping them long distances to "middleman" processors, which is costly and increases risk. Further, the project may demonstrate that
new regulatory approaches can tip the economic scales in favor of recycling throughout HADCO's industry by tailoring regulatory requirements to the specific circumstances of the facility and the waste.

CONTACTS

Regional Contact: Anne Kelly, Region 1 617-565-3426
Sherry Bishko, Region 2 212-637-3571
EPA HQ: Christopher Knopes 202-260-9298
Project Lead: Ken Rota, Region 1 617-565-3349
James Sullivan, Region 2 212-637-4138
State: Ken Marschner,NH 603-271-2943
Larry Nadler, NY 518-457-2553
Company: Lee R. Wilmot 603- 898-8010

FOR ELECTRONIC INFORMATION

More information about Project XL is available on the Internet at https://www.epa.gov/projectxl, via Project XL's fax-on-demand line at 202-260-8590, or via Project XL's Information Line at 703-934-3239.

HADCO

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