HADCO proposes to de-list its wastewater sludges from RCRA

Citation

(2000), "HADCO proposes to de-list its wastewater sludges from RCRA", Circuit World, Vol. 26 No. 3. https://doi.org/10.1108/cw.2000.21726cab.033

HADCO proposes to de-list its wastewater sludges from RCRA

HADCO proposes to de-list its wastewater sludges from RCRA

Keywords: HADCO, Hazardous materials

Owing to process changes since the 1970s, HADCO believes that sludges created as a by-product of its operations are far less toxic and no longer need to be regulated as a hazardous waste. The company's XL project proposes to remove these wastes, which are rich in valuable copper, from regulation under the Resource Conservation and Recovery Act (RCRA) on the condition 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.

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. The company will voluntarily recycle copper dusts that are another by-product of its operations and are currently sent to landfills, 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 100 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.

Because the 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 specifies the tests that will be done on the waste to determine which, if either, regulatory option would safely allow the 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 because it believes that the current process for delisting hazardous waste is prohibitively long and costly.

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.

The HADCO project attempts to test 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 the PWB industry by tailoring regulatory requirements to the specific circumstances of the facility and the waste.