Project XL Progress Report
HADCO Corporation
On March 16,1995, the Clinton Administration announced a portfolio of reinvention initia-
tives to be implemented by the U.S. Environmental Protection Agency (EPA) as a part of its
efforts to achieve greater public health and environmental protection at a more reasonable
cost. Through Project XL, which stands for excellence and Leadership, EPA enters into
specific proj ect agreements with public or private sector sponsors to test regulatory, policy,
and procedural alternatives that will produce data and experiences to help the Agency make
improvements in the current system of environmental protection. The goal of Proj ect XL is to
implement 50 proj ects that will test ways of producing superior environmental performance
with improved economic efficiencies, while increasing public participation through active
stakeholder processes. As of October 1999,15 XL projects are in the implementation
phase and 3 5 XL proj ects are under development. EPA Proj ect XL Progress Reports
provide overviews of the status of XL proj ects that are implementing Final Proj ect Agree-
ments (FPAs). The progress reports are available on the Internet via EPAs Proj ect XL web
site at http://www.epa.gov/Project XL. Or, hard copies may be obtained by contacting the
Office of Reinvention's Project XL general information number at 202-260-7434. Additional
information on Proj ect XL is available on the web site or by contacting the general informa-
tion number.
Background
The FLADCO Corporation, headquartered in Salem, New Hampshire, is a leading manufac-
turer of printed wiring boards (PWB) and electronic interconnection products. Founded in
1966 as a three-person operation in Cambridge, Massachusetts, HADCO has grown to
employ over 8,000 employees in the U.S. and Malaysia. It reported one billion dollars in
sales in 1999. There are three HADCO facilities currently involved in the XL proj ect—
Owego, New York; Deny, New
Hampshire; and Hudson, New
Hampshire. The HADCO Corpora-
tion, in partnership with the New
York State Department of Environ-
mental Conservation (NYSDEC), the
New Hampshire Department of
Environmental Services (NHDES),
and EPA, is piloting an initiative
Major Milestones
HADCO
Corporation
XL Project,
Hudson NH,
Derry NH,
Owego NY
July 21, 1995
HADCO XL Proposal
Submitted
October 2, 1997
HADCO Final Project
Agreement Signed
January 7, 2000
HADCO submitted its first
annual Project XL report
April 2002
Final Report for HADCO
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HADCO Corporation XL Project 12-31-99
examining ways to overcome barriers to the recovery of metals that are associated with sludge waste. The
HADCO project is testing whether valuable coppermetal thatisused as an electricity conductor on PWBs can
be reclaimed directly by a recycler without shipping the copper long distances to "intermediate" processors.
This transport is costly. Further, the HADCO project may demonstrate that new regulatory approaches to safely
handling sludge can tip the economic scales in favor of recycling certain wastes throughout the PWB industry.
Through a series of commitments and agreements among HADCO, EPA, and the States of New York and
New Hampshire, the HADCO XL proj ect will improve recycling efforts, reduce pollution, and reduce risks to
surrounding communities by the following.
• Taking steps to show that its Resource Conservation and Recovery Act (RCRA) F006 waste stream can be
recycled safely by either primary-metals smelters or other appropriate metal reclamation facilities.
• Reducing the risks created by transportation of wastes across a large distance to an "intermediate" processor,
by shipping the waste directly to an approved reclamation facility.
• Voluntarily recycling copper dusts that are another by-product of its operations; currently these copper dusts
are sent to landfills.
• Examining the potential of installing sludge dryers to reduce the volume of sludge wastes.
• Committing all of the cost savings realized from this proj ect to expand HADCO's existing programs for
recovering valuable metals or preventing pollution.
The Experiment
The HADCO proj ect examines whether valuable copper metals can be recovered more safely and cost effec-
tively through direct reuse by a primary metals smelter rather than through following the current regulatory
requirement to first ship copper sludge wastes long distances to intermediate processors.
The Flexibility
Background. Currently, HADCO ships its listed wastewater sludge to a third-party processor before sending it
to an outside recycling facility that will reclaim the valuable copper from the sludge. HADCO's XL proj ect is
testing approaches to handling the facilities' electroplating sludge wastes—which have a high concentration of
several valuable metals, especially copper, and relatively low toxicity in comparison to typical electroplating
sludges—which can both reduce the company's RCRA regulatory burden and promote waste recycling. The
statutory programs and the EPA offices administering the programs affecting the HADCO proj ect are
• Resource Conservation and Recovery Act (RCRA), administered by EPA's Office of Solid Waste and
Emergency Response; and
• Pollution Prevention Act (PPA) programs, administered by EPA's Office of Prevention, Pesticides, and Toxic
Substances.
Under the RCRA regulations, HADCO's sludge waste is classified as F006, which means that it is a solid waste
that contains certain hazardous constituents. The solid waste specifically listed in the F category defines it as a
hazardous waste generated from a nonspecific production or operation source, and the 006 category specifies
the hazardous waste in question as wastewater treatment sludge from electroplating operations— which can add
certain hazardous constituents to the waste. Due to process changes since the 1970s, HADCO believes that
the sludge currently created as a by-product of its operations is far less toxic than before, and no longer needs
to be regulated as hazardous waste under RCRA. The following are two ways in which the EPA and state
agencies can offer regulatory flexibility to the three HADCO facilities by removing the F006 waste from under
the RCRA regulation: (1) a solid waste variance; and (2) a conditional delisting.
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HADCO Corporation XL Project 12-31-99
A solid waste variance granted for the F006 wastes would mean that the sludge is no longer considered a solid
waste under either RCRA or the corresponding state-level hazardous waste regulations in New York and New
Hampshire. A conditional delisting would exclude a listed waste from RCRA regulations as well as the corre-
sponding state-level hazardous waste regulations in New York and New Hampshire as long as the waste
exhibits no hazardous waste characteristics. Eligibility for a conditional delisting is granted only if the sludge
waste is considered safe by EPA and the states. Eligibility for a solid waste variance is granted only if the
partially-reclaimed sludge is considered commodity-like by EPA and the states. Whether or not the sludge is
"safe" only affects delisting. Variances are based on whether or not the material is commodity-like. Then, once
the waste is removed from under both RCRA and state hazardous waste regulations, the waste would be
managed as municipal and industrial solid waste in accordance with other Federal, state, and local regulations.
Requirements for HADCO's Conditional Delisting or Solid Waste Variance. HADCO, EPA, NYSDEC,
and NHDES signed the FPA on October 2,1997. The FPA required sludge testing by HADCO facilities in
order for their sludge wastes to be considered eligible for either a solid waste variance or a conditional
delisting. The sampling of the sludge waste was conducted according to the schedule outlined in the "Proj ect
Commitments" tables presented on page 5, and the samples were sent to a State-approved laboratory for
analysis. HADCO submitted the initial analytical results of its sludge samples to EPA, NYSDEC, and NHDES
on January 8,1998. Additional analyses were submitted in 1998 on January 27, May 19, July 22, and Sep-
tember 16. The sludge analyses tested for the levels of copper and the presence of other constituents to
determine the sludge's potential to be recycled and to see whether other constituents present were below the
allowable Federal and state toxicity characteristic limits for a delisting or a variance. After reviewing the analy-
ses of the sludge, EPA and NHDES determined on July 2,1998, that HADCO's Deny, and Hudson, New
Hampshire facilities were eligible to pursue either a conditional delisting or a solid waste variance. NYSDEC
did not determine that the Owego facility is eligible for conditional delisting, but has determined that it is eligible
for a solid waste variance.
HADCO's Responsibilities. On September 16,1998, HADCO indicated that it would submit petitions for a
conditional delisting for each of the New Hampshire facilities and a solid waste variance for the New York
facility. These petitions must comply with specific regulatory requirements that are outlined in the Code of
Federal Regulations (CFR), and they must be submitted to EPA. A conditional delisting will provide limitations
and restrictions on how and where the sludge will be managed in order to protect human health and the envi-
ronment. On December 18,1998, HADCO filed petitions for conditional delistings for the Deny and Hudson
facilities. EPA notified HADCO by letter dated January 25,1999, that several items required by the Final
Proj ect Agreement were missing, that the delisting application was therefore considered administratively
incomplete, and that EPA would not complete its initial review until receipt of this information. Specifically, the
petition did not include the "Initial Proj ected Benefits Report" (see FPA paragraphs 18 and 26) or copies of
letters of intent between HADCO and the receiving reclamation facilities that detail the acceptance criteria for
the sludge (FPA paragraph 24). HADCO submitted this information to EPA by letter dated January 7,2000.
HADCO submitted a petition for a solid waste variance for the Owego facility on September 28,1999.
EPA's Responsibilities. EPA is responsible for determining whether the petitions for conditional delisting for
the New Hampshire facilities, and for a solid waste variance for the New York facility, are in accordance with
the specific regulatory requirements in the CFR, and then for informing the states that HADCO's petitions are
complete. The states can then review the petitions and may apply additional requirements. Jf the information
submitted by HADCO appears to support a delisting, EPA will propose the delisting by publishing the decision for
public notice and opportunity for comment. Since the petition for a solid waste variance for the Owego facility
has been filed, EPA is now required to review it and provide comments before a variance is granted by the State
of New York.
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HADCO Corporation XL Project 12-31-99
State Responsibilities: New Hampshire. The sludge generated at HADCO's New Hampshire facilities is listed
as F006 generic industrial process waste under the New Hampshire hazardous waste rules. Although the
NHDES delisting procedures generally follow the Federal delisting procedures, NHDES has some additional
requirements to the Federal hazardous waste delisting petition requirements. The HADCO petitions must
address these additional State requirements in order for the NHDES to grant regulatory flexibility to HADCO's
New Hampshire facilities. HADCO also can apply for a waiver of these state requirements. NHDES would
then review the waiver request and decide whether or not HADCO must comply with the additional require-
ments. NHDES is waiting for EPA to make its decision on whether the Agency will grant regulatory flexibility
before reviewing the petition.
State Responsibilities: New York. The sludge generated at HADCO's Owego facility in New York is also
listed as F006 generic industrial process waste under New York's hazardous waste regulations. HADCO
submitted a petition for a variance to NYSDEC on September 28,1999. Upon receipt of the petition,
NYSDEC is authorized under state hazardous waste regulations to issue the variance if the petition meets the
state's requirements.
Next Steps. EPA and New Hampshire will review the delisting petition to determine if the information appears
to support a delisting. EPA and the state agencies will publish their decisions on whether to grant flexibility to each
of the HADCO facilities in the respective statewide newspapers. EPA will issue a public notice and once the
public comments have been addressed, the states and EPA will issue their final decisions regarding HADCO's
petitions requesting regulatory relief. On the date that this decision is placed in the Federal Register and in appro-
priate state notices, the HADCO facilities will start to monitor and report on the environmental performance of the
XL project.
Promoting Innovation and System Change
Proj ect XL provides EPA opportunities to test and implement approaches that protect the environment and
advance collaboration with stakeholders. EPA is continually identifying specific ways in which XL proj ects are
helping to promote innovation and system change. The innovations and system changes emerging from the
HADCO Corporation XL project are described below.
Alternative Regulatory Approaches to Encourage Recycling. By offering regulatory flexibility to HADCO,
EPA and the state agencies may be able to evaluate the effectiveness of offering a conditional delisting or solid
waste variance for the F006 waste in order to encourage the recycling of copper as well as other recycling and
pollution prevention efforts at the HADCO facilities. The information that will be gained on environmental
benefits and cost savings experienced by HADCO under Proj ect XL may be used by EPA to develop a frame-
work to address the potential transferability of this type of regulatory flexibility to the PWB industry at large.
Already this XL proj ect has provided a great deal of information to the EPA's Office of Solid Waste, which has
completed Phase I of a data collection report, developed jointly with environmental groups and industry.
Project Commitment Summary
In the FPA, the HADCO Corporation agreed to have the terms of the XL proj ect apply to four HADCO facilities:
Salem, New Hampshire; Deny, New Hampshire; Hudson, New Hampshire; and Owego, New York. On May 18,
1998, HADCO removed its Salem, New Hampshire, facility from the XL proj ect because the Salem facility opera-
tions were consolidated into another facility. The FPA for the HADCO XL proj ect laid out a significant number of
initial commitments on which HADCO would report baseline data, to be followed by implementation of the superior
environmental performance commitments. The following table and the environmental performance section that follows
summarize progress in meeting commitments described in the FPA for HADCO Corporation.
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HADCO Corporation XL Project
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Commitment Status
Schedule for Collection of Samples
Collect first weekly set of samples.
Collect second weekly set of samples.
Collect third weekly set of samples.
Collect fourth weekly set of samples.
Completed October 13-19, 1997.
Completed October 20-26, 1997.
Completed October 27, 1997- November 2, 1997.
Completed November 3-9, 1997.
Sample Analysis
Collect quarterly sets of samples, beginning the first
quarter 4-6 months after the effective date of the
FPA, and continued for each following quarter until
termination of the FPA. However, with EPA and
state agency approval, HADCO could begin annual
sampling if the samples taken during the first year fall
within a limited range of variability.
Collect four representative sludge samples for each set.
Combine representative samples to create a com-
posite sample and grab sample.
Conduct analysis for Toxic Characteristic Leaching
Procedure (TCLP) metals to determine inorganics.
Collect grab samples and duplicates, and conduct
TCLP organics analysis.
Collect grab samples and duplicates, and conduct
total volatile organic analysis, semivolatile organic
analysis, and carbonyl compounds analysis.
Collect grab samples directly from the filter press or
installed sludge dryer to avoid organic volatilization.
Send each sample to certified laboratories for
analysis.
Ensure each composite sample is analyzed for each
parameter as specified in the FPA.
Completed January 1-12, 1998.
Completed April 13-19, 1998.
Completed July 13-19, 1998.
Completed October 4- 10, 1999.
Note: HADCO requested that EPA Region 1 ap-
prove a change from quarterly to annual sampling in
its December 18, 1998, delisting petition to NHDES.
HADCO plans to request the same from EPA Region
2 in its variance petition, which was submitted to
NYSDEC on September 28, 1999.
Completed October 13-19, 1997.
Completed October 20-26, 1997.
Completed October 27, 1997- November 2, 1997.
Completed November 3-9, 1997.
Completed October 27-November 2, 1997.
Completed November 3-9, 1997.
Completed October 20, 1997; October 27, 1997;
Novembers, 1997; November 10, 1997; January
19, 1998; April 20, 1998; July 20, 1998; October
11, 1998.
Complete.
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HADCO Corporation XL Project
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Commitment Status
Petitions for Regulatory Flexibility
Demonstrate that samples do not exceed 500 parts per
million (ppm) in total concentration for organic com-
pounds, as needed.
HADCO Owego, New York, files variance petition.
HADCO Hudson and Deny, New Hampshire, file
delisting petitions.
EPA will review delisting petition and determine
whether the petition is complete and accepted for
filing.
State of New York informs HADCO that petition is
complete.
State of New Hampshire informs HADCO that
petitions are complete.
EPA and state parties grant regulatory flexibility as
appropriate.
State and EPA authorization for regulatory flexibility
for HADCO New Hampshire facilities published in
Federal Register.
State and EPA authorization for regulatory flexibility
for HADCO New York facility published in Federal
Register.
Public comments received on regulatory flexibility
notice for New Hampshire facilities.
Public comments received on regulatory flexibility
notice for New York facility.
Stakeholder meetings on regulatory flexibility deci-
sion.
Initial report for 1995-1997 and Annual Reports for
1 998 and 1 999 to be submitted to EPA for HADCO
New York and New Hampshire facilities.
Completed May 18, 1998.
Submitted September 28, 1999.
Submitted December 18, 1998.
EPA notified HADCO of several items missing from
the delisting petition by letter dated January 25,1 999.
The FPA states that HADCO should submit correc-
tions within 30 days of receipt of notification from EPA.
This information was submitted January 7, 2000.
Within 30 days of receipt of the petition.
Update on status will be available in the 1999
Annual Report.
45 days after receipt of the petitions.
HADCO must submit to EPA and the states letters
of intent, contacts, or agreements with the reclama-
tion facilities. Relevant information was submitted to
the EPA and states on January 7, 2000.
To be determined.
To be determined.
To be determined.
To be determined.
To be determined.
All submitted January 7, 2000.
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HADCO Corporation XL Project
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Environmental Performance
This section summarizes progress in meeting the environmental performance described in the FPA for
HADCO Corporation. Once EPA and the state agencies grant regulatory flexibility to the three HADCO
facilities participating in this project, those facilities will address their superior environmental performance
commitments that are presented below. The HADCO facilities will be responsible for collecting environmental
performance data on a state-by-state basis—one report on the two facilities in New Hampshire, and one
report on the Owego plant in New York. This information is compiled in HADCO's first annual report, which
was submitted to EPA and the states on January 7,2000. This report details the efforts of the facilities to
achieve the goals of superior environmental performance, which are broadly defined in four categories—
reduction of mobile source air emissions associated with disposal/recycling, copper dust recycling, sludge
reduction, and pollution prevention. Whereas no regulatory relief has been provided to date, all of the data
collected and submitted should be considered baseline.
Reduction of Number of Sludge Shipments for
New Hampshire Facilities
Baseline 1999
Baseline1998
Baseline 1997
Baseiine 1996
Baseline 1995
23
28
32
25
21
10 15 20
Number of Shipments
25 30
Reduction of Fuel Usage Associated with Recycling
Reduction of Mobile Source Air Emissions
Associated with Recycling/Disposal: HADCO
collected data at each HADCO facility involved with
this XL proj ect on the reduction of mobile source air
emissions associated with the direct recycling of
F006 sludge and included this data in its annual
report, which was submitted to EPA and the states
on January 7,2000. This report includes baseline
data that was developed from F006 sludge shipment
records from 1995 through 1999. The report also
includes data analyses and estimates of additional
parameters for the same time period. For the New
Hampshire facilities, the analyses includes baseline
information on the total number of sludge
shipments, the truck and rail miles required for
transporting the sludge shipments, and the total
gallons of fuel consumed by those shipments.
For the New York facility, the analyses includes
baseline information on the truck and rail miles
required for transporting the sludge shipments
and the total gallons of fuel consumed by those
shipments. This will assist the company in
calculating the reduction of air emissions associ-
ated with recycling to determine whether the
proj ect is meeting the goal of reducing fuel usage
by 75% once regulatory relief is provided. Cost
savings resulting from reduced transportation or
recycling under the XL proj ect will be used to increase copper reclamation activities at the HADCO facility.
Progress: HADCO provided baseline data on fuel usage on a statewide basis in its annual report, which was
submitted to EPA and the states on January 7,2000. Performance data on the reduction of air emissions
associated with both direct recycling of F006 sludge and the reduction in the numbers of sludge shipments to
processing facilities will be determined once regulatory relief is provided.
35
Performance
Goal
Baseline 1999
Baseline 1998
Baseline 1997
Baseline 1996
Baseline 1995
New Hampshire
To be determined
Reduce by 75%
2912
3544
4051
3164
2659
New York
To be determined
Reduce by 75%
5252
3680
1831
1134
1134
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Percentage of Copper Dusts in Waste Stream
Currently Landfilled
Performance
Goal
Baseline 1999
Baseline 1998
Baseline 1997
Baseline 1996
Baseline 1995
New Hampshire
To be determined
0%
100%
100%
100%
84%
97%
New York
To be determined
0%
48%
100%
100%
100%
100%
Amount of Copper Reclaimed Under Project XL
Copper Dust Recycling: HADCO has
voluntarily committed to applying all of its
project-related savings to reclaiming and
reducing production of its copper drilling,
sawing, and edging dusts. HADCO will
begin its reclamation at all three facilities
within eight months of the date that each
facility is officially granted regulatory flexibil-
ity by EPA and the states. HADCO de-
scribes its progress in implementing the
reclamation and provides relevant data and
documentation in each of its annual reports
on a facility basis. The first annual report
was submitted on January 7,2000. If
HADCO finds that the amount of cost
savings is insufficient to finance the recycling
of 100% of the copper dusts from its pro-
ductions, then the precise amount of copper
dusts to be recycled will be agreed upon by
HADCO, EPA, and the states.
Progress: HADCO provided baseline data
associated with implementing the reclamation
in its first annual report, which was submitted
to EPA and the states on January 7,2000.
Sludge Reduction: HADCO has voluntar-
ily committed to examining ways its New
Hampshire facilities may be able to use sludge dryers in
order to reduce the quantity of sludge transported. The
New York facility currently is operating with a sludge
dryer. Prior to this XL proj ect, HADCO installed one
sludge dryer in the Deny facility. The goal is to reduce
the sludge from the New Hampshire facilities by 40%
from the 1997 baseline. HADCO expects cost savings
due to the reduction of the number of sludge shipments
to processing facilities. HADCO will begin the installa-
tion of additional sludge dryers if it determines that the
sludge dryers are technically and economically feasible.
The sludge dryer installation would qualify as a pollution
prevention activity for HADCO. HADCO describes
the status of the sludge dryer installation and includes
relevant data and documentation in its first annual report,
which was submitted to EPA and the states on January 7,2000. In future reports, HADCO will evaluate the
technical and economic analyses supporting its decision to install or not install sludge dryers in the New Hamp-
shire facilities once regulatory relief is provided.
Progress: HADCO installed one sludge dryer in its Deny, New Hampshire facility as part of a new installation.
Performance
Goal
Baseline 1999
Baseline 1998
Baseline 1997
Baseline 1996
Baseline 1995
New Hampshire
To be determined
100%
0%
0%
0%
16%
3%
New York
To be determined
100%
52%
0%
0%
0%
0%
Reduction of Sludge (in tons) with the Use of a
Sludge Dryer in the New Hampshire Facilities
Baseline1999
Base!ine1998
Baseline 199/
Baseline 1996
Baseline 1995
299
401
497
370
329
150
300
Tons per Year
450
600
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1999
1998
1997
1996
1995
40
28
21
13
13
0 5 10 15 20 25 30 35
Number of Shipments
Pollution Prevention: HADCO has voluntarily Number of Sludge Shipments for the
committed to investigating ways it can use the cost Owego, New York, Faci I ity
savings generated from reducing mobile air emis-
sions and sludge to reclaim copper dusts or im-
prove pollution prevention efforts at its three
facilities.
Progress: HADCO installed one sludge dryer in its
Deny, New Hampshire facility as part of a new
installation. HADCO will report its progress on
copper dust reclamation or pollution prevention
activities on a statewide basis once regulatory relief
is provided.
Stakeholder Participation
An integral part of the HADCO XL project is to involve local and national stakeholders in its development and
implementation at the three participating HADCO facilities. A number of stakeholders did not participate in
day-to-day negotiations and proj ect development, but have expressed their perspectives with written or oral
comments. This group of stakeholders includes the Merrimack Watershed Council of New Hampshire, New
Hampshire Town of Hudson Health Office, the Audubon Society of New Hampshire, the Sierra Club New
Hampshire Chapter, the Atlantic States Legal Foundation of New York, Teradyne, M/A-Com, Lockheed
Martin Loral Federal Systems, the World Legal Foundation, the IPC (the PWB industry association), New
Hampshire Wastecap (a New Hampshire Business and Industry Association) and the World Resources
Corporation.
HADCO Corporation conducted the maj ority of its stakeholder meetings in 1996 in both New Hampshire and
New York so that interested citizens could provide comments and input into the development of the XL
project proposal. Local citizens from the towns of Deny, Hudson, and Owego also participated. Subsequent
to EPA's acceptance of the HADCO XL project proposal, HADCO conducted stakeholder meetings to
obtain comments and input into the development of the FPA as well. Signatories to the HADCO FPA were
the HADCO Corporation, Region I EPA, Region II EPA, NHDES, and NYSDEC. The signatories to the
FPA did not include citizen or environmental groups.
In the FPA, HADCO agreed to continue to communicate with its stakeholders using the following methods.
• Place the signed FPA and subsequent annual reports in local libraries in Deny and Hudson, New Hamp-
shire, as well as in Owego, New York. Copies of the same documents and the analytical data will be
publicly available at EPA headquarters, EPA's regional offices in New York City and Boston, and at the
offices of the Atlantic States Legal Foundation in Syracuse, New York.
• Mail copies of the signed FPA and executive summaries of the sub sequent annual reports to stakeholders
invited to participate in the FPA development process.
• Post the signed FPA and executive summaries of the subsequent annual reports on HADCO's World Wide
Web page (http://www.hadco.com).
• Conduct annual site meetings with those stakeholders who request meetings to review proj ect progress and
discuss other aspects of the project, after stakeholders receive the annual report summaries.
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HADCO Corporation XL Project 12-31-99
• File press releases of pertinent proj ect accomplishments, such as completion of sludge drier installation in all
New Hampshire facilities or commencement of copper dust reclamation, in both New York and New
Hampshire newspapers and trade journals.
When a Federal Register notice is published regarding the proposed regulatory relief to be granted to
HADCO, EPA will notify each of the stakeholders that submitted comments during FPA development.
Six-Month Outlook
EPA will take the steps necessary to propose a conditional delisting for HADCO's New Hampshire facilities
with opportunity for public notice and comment. EPA also will review and comment on any proposal by New
York to grant a variance to HADCO's New York facility. If no adverse comments are received, EPA and the
respective states intend to publish the action in a final Federal Register notice and appropriate state notices.
Once this occurs, HADCO will begin addressing and quantifying its goals and commitments for achieving
superior environmental performance.
Project Contacts
• Lee R. Wilmot, Director of Health and Human Safety, HADCO Corporation, (603) 896-2424.
• KenMarschner, NHDES, (603) 271-2943.
• MarkMoroukian,NYSDEC, (518)485-8988.
• Larry Nadler, NYSDEC, (518)485-8988.
• Martha Curran EPA Region 1, (617)918-1802.
• James Sullivan, EPA Region 2, (212) 63 7-413 8.
• Katherine Dawes, EPA Headquarters, (202) 260-8394.
Information Sources
The information sources used to develop this progress report include (1) discussions during a teleconference
among representatives of the U. S. EPA, HADCO Corporation, NYSDEC, NHDES, the Atlantic States Legal
Foundation, and the World Resources Corporation; and (2) the FPA for the HADCO Corporation XL
proj ect. The information sources are current through December 1999.
Glossary
Baseline: The measure by which future environmental performance can be compared.
Carbonyl Compound Analysis: The identification of key chemical functional groups. A carbonyl compound
contains a single carbon atom with a double bond to an oxygen atom and two open double bonds.
Composite Sample: A series of samples taken over a given period of time and combined proportionally by
time, flow, volume, or mass.
Conditional Delisting: Use of the petition process to have the toxicity designation of a facility's waste rescinded
and to subsequently exclude that waste from applicable regulations.
Electroplating Operations: Involves plating various metals onto PWBs and computer components that provide
electronic interconnection.
10
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F006 Listing: A wastewater treatment sludge produced from nonspecific electroplating processes and opera-
tions that is considered a hazardous waste under RCRA.
Final Project Agreement (FPA): The FPA outlines the details of the XL project and each party's commitments.
The project's sponsors, EPA, state agencies, other regulators, and direct participant stakeholders negotiate a
FPA.
Grab Sample: Single sample collected at a particular time and place that represents the composition of the
water, air, or soil only at that time and place.
Hazardous Waste: By-products of society that can pose a substantial or potential hazard to human health or
the environment when improperly managed. Possesses at least one of four characteristics (ignitability,
corrosivity, reactivity, or toxicity), or appears on special EPA lists.
Landfill: Sanitary landfills are disposal sites for nonhazardous solid wastes spread in layers, compacted to the
smallest practical volume, and covered by material that is applied at the end of each operating day. Secure
chemical landfills are disposal sites for hazardous waste, selected and designed to minimize the chance of
release of hazardous substances into the environment.
Media: Specific environments—air, water, soil—which are the subj ect of regulatory concern and activities.
Mobile Source: Any non-stationary source of air pollution such as from cars, trucks, motorcycles, buses,
airplanes, and locomotives.
Multimedia: Several environmental media, such as air water, and land.
Printed Wiring Boards (PWB): A device that provides electronic interconnections and a surface for mounting
electronic components.
Reclamation (in recycling): Restoration of materials found in the waste stream to a beneficial use that may be
for purposes other than the original use.
Resource Conservation and Recovery Act (RCRA): Passed in 1976, RCRA gives EPA the authority to
control hazardous waste from "cradle-to-grave." This includes the generation, transportation, treatment,
storage, and disposal of hazardous waste. RCRA also sets forth a framework for the management of nonhaz-
ardous wastes. RCRA enables EPA to address environmental problems that could result from underground
tanks storing petroleum and other hazardous substances. RCRA focuses only on active and future facilities
and does not address abandoned sites.
Semivolatile Organic Compounds: Organic compounds that volatilize slowly at standard temperature (20
degrees C and 1 atmosphere pressure).
Sludge: A semi solid residue from any of a number of air or water treatment processes; this can be a hazardous
waste.
Sludge Dryers: A piece of equipment that reduces the volume and weight of semisolid sludge wastes by drying
and reducing the water content of the sludge.
Solid Waste: Nonliquid, nonsoluble materials ranging from municipal garbage to industrial wastes that contain
complex and sometimes hazardous substances. Solid wastes also include sewage sludge, agricultural refuse,
demolition wastes, and mining residues. Technically, solid waste also refers to liquids and gases in containers.
Toxic Character!sticLeachate Procedure (TCLP): Required under RCRA, the TCLP determines whether a
waste exhibits hazardous toxicity characteristics and tests whether toxic constituents may leach from land-
disposed waste.
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HADCO Corporation XL Project
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Variance: Government permission for a delay or exception in the application of a given law, ordinance, or
regulation.
Volatile Organic Compounds (VOCs): Any organic compound that easily evaporates and participates in atmo-
spheric photochemical reactions, except those designated by EPA as having negligible photochemical reactivity.
Wastewater: Spent or used water from a home, community, farm, or industry that contains dissolved or
suspended matter.
Wastewater Treatment Sludge: The sludge that is produced from the treatment and removal of pollutants in
wastewater.
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