Dear Compliancenetters:
A recent draft survey of PWB manufacturers indicates that >90% of PWB shops recycle their F006 sludge instead of placing it in a landfill. I am very interested in understanding why this is done when the cost associated with recycle are on the order of 2-4X the cost of landfilling the sludge.
Under current RCRA rules we can landfill this "valuable commodity," so why is it that we incur the costs when there are really no economic benefits derived from this activity. After all, the regulatory burden (land ban, manifesting, cost of transportation, reporting and recordkeeping) are the same. Is it just a future liability issue?
I am interested in hearing others views on why we (the PWB industry) with limited margins, choose to do the environmentally responsible thing (recycle, reclaim) without any regulatory relief from our respective EPA's.
Secondly, I am also interested in gaining a better understanding of management practices regarding D002 (Ammoniacal Etchant). In the state of Ohio, this material is classified as a hazardous waste. Yet I understand that in several other states it is not, and can be managed (i.e. shipped) under "straight-bill-of-lading" and common carrier. I would appreciate any thoughts any of you may have on these two topics.
Regards
Michael A. Kerr
Circuit Center, Inc.
(937) 435-2131
Date: Tue, 6 Jan 1998 11:22:59 -0700
2. I believe that the EPA should provide some type of regulatory relief
to the manufacturer that recycles waste materials.
3. The recycling/landfill decision may be based on the "quality" of the
sludge being generated. If the sludge is low in copper and other
valuable/reclaimable metals, it may not be worth recycling. This issue
may be corrected by reevaluating your waste water treatment systems and
determining if there are better treatment chemistries.
4. Shops that recycle may have bought into treatment programs that
have the treatment chemistry vendor taking the sludge for reclaim. In
this scenario, not only are valuable metals being reclaimed but the
residual treatment chemistry supplied by the vendor is also extracted.
In this case, there is added value in the sludge that shifts the
decision from landfill to recycling.
Dave Haughey
Date: Tue, 10 Feb 1998 11:35:45 EST
Hello Everyone,
I don't recall seeing any responses to Michael's Qs below. Since our
system deletes messages after 30 days, I wanted to respond before this issue was
forgotten.
On the fundamental issue of cost comparison, we do not see 2-4X higher
costs for recycling our F006 sludge as compared to landfilling. When we switched
to recycling from landfilling in 1990, the cost was almost equal. One reason for
this in New Hampshire is that haz waste that is recycled is not taxed; only haz
waste that is treated or disposed is taxed at $60/ton, so this helped balance
the recycling scale. This is not true in either New York or California, where
all haz waste is taxed, regardless of whether it's recycled or treated/disposed.
(NOTE: In 1994, 52% of NH's haz waste was recycled. This compares to EPA's
estimate of 2% nationwide in its report on the definition of solid waste. I
believe one of the main differences is NH's tax policy on recycled haz waste.)
Because every PWB shop's F006 sludge recycling situation is different,
factors such as tax status, the nearness to a recycling facility, the copper
content of the sludge, the water content of the sludge, the shipping container
size, the frequency of shipments, total annual volume, available space for
accumulating storage, the cost agreement with the recycler, the type of
transport (highway v rail) must all factor into the decision. Since our costs
were basically a tradeoff, we decided to recycle our F006 sludge. Whereas our
F006 is accumulated and shipped in rolloffs, I can understand that someone
generating waste in drums might have a different economics. (This is why one of
our smaller facilities empties drums of sludge from the filter press into a
rolloff. It's more economical to ship in rolloffs, but lately I'm hearing that
it's cheaper yet to ship in supersack packages (assuming dried sludge (or
dust)), as the end site recyclers are set up to handle them.)
Regarding spent ammoniacal etchant, both NH and NY recognize that spent
amm. etch is a raw material used in making a product without being reclaimed,
and thus is not a solid waste pursuant to 261.2(e). Accordingly, facilities in
both states ship spent amm. etch on a bill of lading as "Corrosive liquid,
basic, inorganic. n.o.s. ..." and this material is not considered a haz waste,
just as solder dross and scrap boards are not.
Lee
Subject: [CN] End disposition of F006 Sludge and Management of D002 E
Dear Compliancenetters:
A recent draft survey of PWB manufacturers indicates that >90% of PWB sho=
ps recycle their F006 sludge instead of placing it in a landfill. I am =
very interested in understanding why this is done when the cost associate=
d with recycle are on the order of 2-4X the cost of landfilling the sludg=
e.
Under current RCRA rules we can landfill this "valuable commodity," so =
why is it that we incur the costs when there are really no economic benef=
its derived from this activity. After all, the regulatory burden (land =
ban, manifesting, cost of transportation, reporting and recordkeeping) =
are the same. Is it just a future liability issue?
I am interested in hearing others views on why we (the PWB industry) with=
limited margins, choose to do the environmentally responsible thing (rec=
ycle, reclaim) without any regulatory relief from our respective EPA's.
Secondly, I am also interested in gaining a better understanding of manag=
ement practices regarding D002 (Ammoniacal Etchant). In the state of Ohi=
o, this material is classified as a hazardous waste. Yet I understand =
that in several other states it is not, and can be managed (i.e. shipped)=
under "straight-bill-of-lading" and common carrier. I would appreciate =
any thoughts any of you may have on these two topics.
Regards
Michael A. Kerr
Reply-To: "ComplianceNet Mail Forum."
Sender: ComplianceNet Mail Forum
From: "Haughey, Dave"
Subject: Re: End disposition of F006 Sludge and Management of D002 Et chant
X-To: Michael Kerr
With regard to sludge disposal and the issue of recycling, a few
thoughts came to mind:
1. Recycling sludge may alleviate the future liability that may face
manufacturers that landfill. There are companies that are now paying for
"sins" that were committed in the 1970's, 1960's,..etc.
Merix Corporation
Reply-To: "ComplianceNet E-Mail Forum."
Sender: ComplianceNet Mail Forum
From: lwilmot@HADCO.COM
Subject: Re: End disposition of F006 Sludge and Management of D0
X-To: Michael Kerr mak@CIRCUITCENTER.COM
Author: "ComplianceNet Mail Forum."
Date: 1/6/98 8:44 AM
Circuit Center, Inc.
(937) 435-2131