Project XL Progress Report
Molex Incorporated
In 1995, the U.S. Environmental Protection Agency (EPA) embarked on a series of innova-
tive initiatives in an effort to test new ways to achieve greater public health and environmental
protection at a more reasonable cost. Through Proj ect XL, which stands for excellence and
Leadership, EPA enters into specific proj ect agreements with public or private sector spon-
sors to test regulatory, policy, and procedural alternatives that will produce data and experi-
ences to help the Agency make improvements in the current system of environmental protec-
tion. 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 January 200 1 , EPA has
reached its goal of 5 0 proj ects in the implementation phase. EPA Proj ect XL Progress
Reports provide overviews of the status of XL proj ects that are implementing Final Proj ect
Agreements (FPAs). The progress reports are available on the Internet via EPAs Proj ect XL
Web site at http://www.epa.gov/Project XL. Hard copies may be obtained by contacting the
Office of Policy, Economics, and Innovation's (formerly the Office of Reinvention) Project
XL general information number at (202) 260-5754. Additional information on Proj ect XL is
available on the Web site or by contacting the general information number. The information
and data presented in this Progress Report is current as of January 200 1 .
Background
Molex Incorporated (Molex) is a multinational company that operates 47 facilities world-
wide, in manufacturing, electroplating, metal stamping, plastic molding, and fiber optics.
Molex electroplates coatings of nickel, copper, and tin and lead metals on substrate materials
for a variety of manufacturing purposes.
The process generates large volumes of
wastewater containing metal contami-
nants, which are subsequently captured
in wastewater treatment systems and
become classified as hazardous waste
under the Resource Conservation and
Recovery Act (RCRA). Molex previ-
ously operated a wastewater treatment
system that combined the wastewater
streams from nickel, copper, and tin and
lead plating processes. These
Molex XL Project"
Lincoln' Nebraska
Major Milestones
July 11, 1995
Molex XL Proposal
Submitted
s
August?, 1998
Nebraska DEQ
Temporary Variance
Issued
s
August 11, 1998
Final Project
Agreement Signed
February 2001
Expiration of Nebraska
DEQ Temporary Variance
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wastestreams were treated in a single wastewater treatment process that generated a hazardous multiple-metal
waste material from which only one of the metals could be recovered, with the rest disposed. Molex switched to
a process that segregates the wastewater streams from the plant's multiple electroplating processes and treats
each one separately. Therefore, Molex recovers metal contaminants separately, reduces the amount of metal
that would otherwise be disposed of in RCRA-regulated landfills or released to the environment at secondary
smelters, and reduces metal-contaminant levels in the effluents discharged from the facility's wastewater treat-
ment systems to Lincoln's publicly owned treatment works (POTW). In its XL proposal, Molex requested a
variance from hazardous waste regulations in order to reduce the costs of storing and shipping these wastes to
make it more cost-efficient to recover metals from electroplating wastestreams.
Molex believes that its new segregated wastewater treatment system results in superior environmental perfor-
mance through a reduction in the amount of metals discharged to Lincoln's POTW, as well as through an
increase in metals recycling. Operational process lines were changed to generate separate treatment sludges for
nickel, copper, and tin/lead that are classified as hazardous waste under the Nebraska Department of Environ-
mental Quality (NDEQ) Hazardous Waste Management Program. Through these operational process changes,
the Molex XL proj ect seeks to provide superior environmental performance by:
• reducing the amount of metals loading in the effluent discharged to Lincoln's POTW;
• increasing the level of metals reclamation or recycling; and
• reducing the amount of material that would otherwise require landfill disposal.
The segregated treatment system, however, costs more to operate than a combined treatment system. Addition-
ally, the segregated system results in increased costs from compliance with current regulations for handling the
resultant sludges. By providing the facility with a temporary variance from classifying nickel, copper, and tin/lead
sludges as a solid waste, the Molex proj ect is helping to financially justify the continued operation of the segre-
gated system. This temporary variance, which was issued by NDEQ on August 7,1998, allows Molex to
handle the storage and shipment of these non-precious metals sludges at substantially reduced costs for two
years. The variance was set to expire on August 7,2000, but has been extended an additional six months. This
extension will allow Molex to complete its final report.
Molex estimates that the recovery of non-precious metals under the former combined processing system costs
approximately $14,500 annually. Under the new system, Molex anticipates receiving an annual income of more
than $7,600 from the sale of the separated, non-precious metals-bearing sludges, and benefiting from a net
annual savings in waste management costs of more than $22,000.
The Experiment
The Molex proj ect tests whether regulatory flexibility through a variance from hazardous waste regulations will
lead to a reduction in the costs of storing and shipping these wastes and an increase in the rate of metals recov-
ery from the multiple wastestreams the proj ect generates.
The Flexibility
As an incentive to achieve superior environmental performance at Molex's Lincoln facility, EPA and the NDEQ
are providing more flexible and cost-effective processes for regulatory management. The statutory programs,
and the EPA offices administering the programs, affecting the Molex XL project are:
• Resource Conservation and Recovery Act (RCRA) programs administered by EPA's Office of Solid Waste;
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• Pollution Prevention Act (PPA) programs administered by EPA's Office of Prevention, Pesticides, and Toxic
Substances; and
• Federal Water Pollution Control Act (FWPCA) programs administered by EPA's Office of Wastewater
Management.
EPA, pursuant to RCRA Section 3005(b), has authorized NDEQ to carry out Nebraska's Hazardous Waste
Management Program in lieu of the Federal program. Under this authority, NDEQ issued a variance to Molex
granting the facility a temporary exemption from the classification as hazardous waste of segregated sludges
generated during wastewater treatment. Without this variance, the sludge materials would be subj ect to NDEQ
generator requirements for storage and shipment of hazardous wastes.
Sludges from the former combined treatment system at Molex's Lincoln facility contained copper, nickel, tin,
lead, and gold. The sludges' gold content allowed Molex to handle the combined treatment sludge as recyclable
materials from which precious metals are reclaimed, under Title 128, Rules and Regulations Governing Hazard-
ous Waste Management in Nebraska, Chapter 7, Section 010. Sludges generated at the upgraded facility,
however, do not contain precious metals and no longer qualify under the recyclable precious metal exclusion.
By obtaining approval from the NDEQ under RCRA to classify its segregated process sludge as a "partially
reclaimed" material rather than as a hazardous waste, Molex can ship the sludges using common carriers, rather
than hazardous waste carriers that are subj ect to additional regulations for transportation, storage, and disposal
(TSD) facilities under RCRA. Additionally, Molex is permitted to ship the hazardous materials on an as-needed
basis, rather than every 90 days as required for hazardous waste.
On July 10,2000, Molex requested a two-year extension of the temporary variance that had remained in effect
for two years and was set to expire August 7,2000. In the request for this extension, Molex noted that it is
expanding the production area of the plating department at its facility. This expansion, Molex stated, may offer
an opportunity to continue to gather data under a greater process flow. In response, on August 2,2000, EPA
and NDEQ issued a six-month extension of the variance. The additional six months will allow Molex to com-
plete the final report. After reviewing Molex's final report, EPA and NDEQ have the option to issue an addi-
tional two-year variance.
The final data will be examined to determine the effect that separate treatment of Molex's wastestreams has on
metal content in wastewater effluents. Data gathered will also be examined to demonstrate whether the segre-
gated system produces a recyclable sludge with market value. Ultimately, data gained through this proj ect will
provide the information necessary to assess whether modifications to national or state performance standards
are possible.
This XL project supports RCRA, PPA, and Nebraska Hazardous Waste Management Program's goals of
resource recovery and conservation. Specifically, the project results in recycling of metal sludges by recycling
facilities, which will decrease the need for mining of ores or other virgin materials. This will result in the conser-
vation of mineral resources and a reduction in the amount of materials that would otherwise be sent to a landfill.
The Molex XL proj ect also supports the goals of the FWPCA and Nebraska Surface Water Quality Standards
to restore and maintain the chemical, physical, and biological integrity of the nation's and state's waters. Specifi-
cally, the proj ect reduces the amount of metals being loaded into the City of Lincoln's POTW, thus reducing
metals discharged from the POTW into surface waters and the amount of metals-bearing sludges that are
ultimately sent to a landfill. Additionally, the reduced loading gives the POTW a reserve treatment capacity,
reducing the need to replace or enlarge the publicly financed facility.
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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
Molex XL project are described below.
UsingaRCRA Solid Waste Variance to Encourage Recycling. Under the RCRA regulations, regulated
entities may petition EPA to exempt or exclude materials from classification as a solid or hazardous waste.
Molex is testing the use of a solid waste variance for RCRA-listed wastes to encourage metals recycling and
reduce solid waste generation. The environmental performance and economic feasibility of the Molex proj ect
could serve as a benchmark against which other potential requests for temporary variances may be measured.
Project Commitment Summary
This table and the environmental performance section that follows summarize progress in meeting the commit-
ments described in the FPA and temporary variance for the Molex Facility in Lincoln, Nebraska.
Commitment
Status
Waste Analysis and Reporting
Conduct and submit results of initial waste analysis
on each of the three sludges (nickel, copper, and tin/
lead) for toxicity characteristic leaching procedure
(TCLP), toxic metals, pH, and moisture content, in
accordance with the variance and Attachment B of
the FPA.
Analytical results were included in the initial baseline
report, which was submitted to NDEQ and EPA on
November 17, 1998.
Conduct and submit results of waste analysis on each
of the three sludges for chlorine, sulfides, antimony,
beryllium, thallium, heating value, and total organic
carbon (TOC), in accordance with the FPA.
Analytical results (with the exception of TOC) were
submitted to EPA on September 15,1998.
If waste analysis indicates that TOC exceeds 500
parts per million (ppm) (by weight), submit data that
prove that samples do not include greater than a 500
ppm total concentration of organic compounds, in
accordance with the FPA.
Analytical results on TOC were included in the first
quarterly report, which was submitted to NDEQ and
EPA on December 4, 1999.
Conduct waste analyses on each sludge shipment
prior to reclamation of total copper, nickel, lead, tin,
zinc; of pH; and of moisture content, in accordance
with the variance and FPA.
As of 1999, waste analyses has been conducted
prior to each shipment.
Provide an initial Baseline Report describing (1) the
performance of the combined treatment system for
the most recent 12-month period prior to implemen-
tation of the segregated treatment system, and (2)
productivity estimates of the segregated treatment
system, in accordance with the variance and FPA.
The initial Baseline Report was submitted to NDEQ
and EPA on November 17, 1998.
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Commitment Status
Waste Analysis and Reporting (Continued)
Submit quarterly reports to EPA and NDEQ every
3 months after submitting the initial baseline report
describing current data for the segregated treatment
system, in accordance with the variance and FPA.
Provide a final report in accordance with the terms
outlined in the variance and FPA.
Maintain records of test results, waste analyses, and
other variance conditions.
Notify the NDEQ of the name, address, and facility
contact for each facility to which material is sent for
reclamation, and a description of anticipated pro-
cessing.
First quarterly report: December 4, 1998
Second quarterly report: March 4, 1999
Third quarterly report: May 27, 1999
Fourth quarterly report: August 7, 1999
Fifth quarterly report: November 11, 1999
Sixth quarterly report: February 1 1 , 2000
Seventh quarterly report: May 24, 2000
Eighth quarterly Report: September 7, 2000
Received by EPA November 13, 2000.
Since 1 998, Molex has maintained a records man-
agement system supporting terms of the variance.
In 1 999, Molex began to notify NDEQ of each
facility that receives material for reclamation.
Waste Recordkeeping, Storage, and Transfer
Maintain nonhazardous waste manifests identifying
each specific shipment.
Accumulate the nickel and copper sludges for no
longer than 180 days before shipment, and store and
transfer the tin/lead sludge in accordance with
variance provisions.
Molex began to maintain nonhazardous waste
manifests for each shipment in 1 999.
Storage conditions specified in the variance are being
met by Molex; shipment of the segregated sludges
began in 1999.
EPA Commitments
Determine need for additional sampling.
EPA has determined that additional sampling and
analysis will not be necessary for the duration of the
temporary variance.
Environmental Performance
This section summarizes progress in meeting the environmental performance described in the FPA and tempo-
rary variance for the Molex Facility in Lincoln, Nebraska.
Note about the Baseline Data: In its Baseline Report Molex (1) collected data on the combined treatment
system for the most recent 12-month period prior to implementation of the segregated treatment system, and (2)
provided productivity estimates of the segregated treatment system. For the combined treatment system, the
report presented data on the concentration and mass of metals in the effluent discharged to Lincoln's POTW,
the volume of sludges generated and stored on site, the volume of sludges shipped to the recycler, and an
analysis of the sludges. The report also estimated the productivity of the segregated treatment system. It is
important to note that sludge volumes between the combined treatment process and the segregated treatment
process are not strictly comparable, because the combined treatment sludges were dried but the segregated
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treatment sludges were not. This section compares the estimated sludge generation rates from the Baseline Re-
port, and actual sludge generation rates of the segregated treatment system. Data from 1999 were measured
based on four Molex quarterly reports, which cover proj ect performance from August 7,1998, to August 7,
1999. Data from 2000 were measured based on four Molex quarterly reports, which cover proj ect performance
from August 8,1999, to August 7, 2000.
Copper Sludge Generation and Loading
In the Baseline Report, Molex estimated that 13,376 pounds of
copper sludge would be generated with the segregated treatment
system. However, 1999 actual generation rates were 59 percent
higher (21,242 pounds) than the estimated baseline. For 2000,
Molex has generated 35,200 pounds of copper sludge, a 163
percent increase from the baseline data. Based on the Quarterly
Reports, it is estimated that the use of the segregated system has
resulted in decreased copper concentrations in the POTW's
effluent by 66 percent in 1999 and 79 percent in 2000, com-
pared to baseline.
Nickel Sludge Generation and Loading
In the Baseline Report, Molex estimated that 45,089
pounds of nickel sludge would be generated with the
segregated treatment system. However, 1999 actual
generation rates were 8.5 percent higher (48,928
pounds) than the estimated baseline. In 2000, a total
of 60,684 pounds of nickel sludge have been
generated. Based on the Quarterly Reports, use of
the segregated system has resulted in decreased
nickel concentrations in the POTW's effluent by 67
percent in 1999 and 82 percent in 2000.
Tin/Lead Generation and Loading
In the Baseline Report, Molex estimated that 12,863 pounds of
tin and lead sludges would be generated with the segregated
treatment system. Actual generation rates in 1999 were 34
percent lower (8,539 pounds) than the estimated baseline.
However, in 2000, Molex has generated 16,614 pounds of tin
and lead sludges. Based on the Quarterly Reports, use of the
segregated system in 1999 resulted in estimated decreased
concentrations of tin (98 percent) and lead (29 percent) in the
effluent being discharged by the POTW. In addition, in 2000 the
use of the segregated system has resulted in estimated decreased
concentrations of tin (98 percent) and lead (44 percent) in the
effluent.
Copper Sludge Generation Rates
For the Segregated Treatment System
Baseline Estimate
13,376
0 10000 20000 30000 40000 50000
Pounds of Copper Sludge
*This information is based on Molex's quarterly reports,
which cover project performance from 8/7/98-8/7/99
**This information is based on Molex's quarterly reports,
which cover project performance from 8/8/99-8/7/00
Nickel Sludge Generation Rates
For the Segregated Treatment System
Baseline Estimate
60,684
10000 20000 30000 40000 50000
Pounds of Nickel Sludge
60,000 70,000
*This information is based on Molex's quarterly reports,
which cover project performance from 8/7/98-8/7/99
**This information is based on Molex's quarterly reports,
which cover project performance from 8/8/99-8/7/00
Tin/Lead Sludge Generation Rates
For the Segregated Treatment System
Baseline Estimate
12,863
0 10000 20000 30000 40000 50000
Pounds of Tin/Lead Sludge
*This information is based on Molex's quarterly reports,
which cover project performance from 8/7/98-8/7/99
**This information is based on Molex's quarterly reports,
which cover project performance from 8/8/99-8/7/00
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Estimated Reductions in Metal
Concentrations in Effluent
•Copper 1999 Actual
* Copper 2000 Actual
•Nickel 1999 Actual
** Nickel 2000 Actual
*Tin 1999 Actual
"Tin 2000 Actual
•Lead 1999 Actual
** Lead 2000 Actual
66%
79%
67%
82%
98%
98%
29%
44%
20 40 60 80 100
Percent Reduction of Metals Concentrations
This information is based on Molex's quarterly reports,
which cover project performance from 8/7/98-8/7/99
**This information is based on Molex's quarterly reports,
which cover project performance from 8/8/99-8/7/00
Volume of Metals Sludge Shipped to Recycler
134,988
Baseline Estimate
Total Generation of Sludge
In the Baseline Report, Molex estimated that the
segregated treatment system would generate a total of
71,328 pounds of sludge, but 1999 actual generation
rates based on the Quarterly Reports indicate that
actual sludge generation rates were 10.3 percent
higher (78,709 pounds) than the estimated baseline for
the segregated system. In 2000, the total amount of
metal sludge generated was 112,498, a 58 percent
increase over the estimated baseline. Based on the
Quarterly Reports, it is estimated that the segregated
treatment system has resulted in an average 65 percent
reduction in the concentration of copper, tin, lead, and
nickel in the effluent discharged by the POTW in 1999
and an average 76 percent reduction in 2000.
Sludge Recycling
In the Baseline Report, Molex estimated that it would
be able to recycle 71,328 pounds of metals sludges
in a year. However, the Quarterly Reports indicate
that between August 1998 and August 1999, a total
of 78,709 pounds of sludge were senttotherecycler,
10.3 percent more than estimated. In addition, in
2000, a total of 134,988 pounds of sludge were sent
to the recycler, 89 percent more than expected.
Stakeholder Participation
Molex worked to ensure that stakeholders were
involved in the environmental design and impact
assessment of its XL proj ect and had an opportunity to participate fully in proj ect development. The organiza-
tions directly involved in negotiating the FPA included Molex, EPA, NDEQ, the Lincoln-Lancaster County
Health Department, and the City of Lincoln.
Meetings were held on August 24,1996, andOctober30,1996, to discuss the Molex XL proj ect proposal
and develop the FPA. EPA received stakeholder comments on the implementation of the Molex XL proj ect
following notification to the public on November 3,1997. While recognizing the potential benefits of Proj ect
XL, organizations such as the Environmental Defense Fund and the World Resources Company expressed
concern with specific aspects of the Molex XL proj ect. The issues of concern included apparent weaknesses in
the administrative record with respect to baseline practices and historical records; determination of the com-
modity-like nature of the various sludges; and the adequacy of follow-up waste testing, particularly with respect
to TOC content. In response to these concerns, EPA gathered additional data required for the administrative
record, conducted further analysis of the economic value of the generated sludges, and requested that Molex
implement a more comprehensive sampling and analysis program.
Meeting agendas and documents pertaining to FPA negotiations are available to the public through the State of
Nebraska, EPA Region 7, and EPA Headquarters' Offices and are accessible via the Internet on the Proj ect
25000 50000
75000 100000
Pounds per Year
125000 150000
*This information is based on Molex's quarterly reports,
which cover project performance from 8/7/98-8/7/99
**This information is based on Molex's quarterly reports,
which cover project performance from 8/8/99-8/7/00
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XL homepage. The public has been notified since initiation of this project and invited to participate, and will
continue to be informed through report dissemination during implementation of the project.
Six-Month Outlook
NDEQ and EPA will review analytical data and the final report provided by Molex in accordance with require-
ments in the temporary variance and the FPA. Among the factors to be considered in any final variance determi-
nation following the expiration of the existing temporary variance are:
• the degree of processing the material has undergone and the degree of further processing that is required;
• the value of the material after it has been reclaimed;
• the degree to which the reclaimed material is like an analogous raw material;
• the extent to which an end market for the reclaimed material is guaranteed; and
• the ability to handle the reclaimed material in a manner that minimizes loss.
Project Contacts
• Paul Eckerson, Molex, (402) 475-1700.
• David Doyle, U.S. EPA, Region 7, (913) 551-7667.
• Mitch Kidwell, EPA Headquarters, (202) 260-2515.
• Bill Gidley, NDEQ, (402) 471-4217.
• Brian Gorman, NDEQ, (402) 471-8846.
• Annette Kovar, NDEQ, (402) 471-3585.
• Beth Mann, Lincoln/Lancaster County Health Department, (402) 441 -623 5.
• Rick Shibata, City of Lincoln, (402) 441 -7961.
Information Sources
The information sources used to develop this progress report were (1) 1]\Q December 1999 Project XL
Progress Report—Molex Incorporated (EPA 100-R-OO-OO11); (2) focus group discussions in December
1999 with representatives of Molex, EPA Regional and Headquarters staff, World Resources (a national
environmental group), NDEQ, City of Lincoln, and local community stakeholders; and (3) Molex Proj ect XL
quarterly reports through September 2000.
On December 9,1999 EPAs Office of Policy, Economics and Innovation convened a two-hour focus group
teleconference with representatives of the Molex Company, EPA Regional and Headquarters staff, World
Resources Company, NDEQ, and the City of Lincoln. The purpose of the focus group was to gain partici-
pants' opinions on the lessons learned and innovations resulting from implementation of the Molex XL proj ect.
Comments from this focus group were incorporated into this report.
Glossary
Baseline: The measure by which future environmental performance can be compared.
Delisting: The process of excluding from regulations a waste that EPA has defined as hazardous, if it can be
shown that the waste no longer threatens human health and the environment.
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Disposal: The discharge, deposit, inj ection, dumping, or placing of any solid or hazardous waste on or in the
land or water.
Effluent: Treated or untreated wastewater that flows out of a treatment plant, sewer, orindustrial outfall. Gener-
ally refers to wastes discharged into surface waters.
Electroplating: The electrodeposition of an adherent metallic coating upon an electrode for the purpose of
securing a surface with properties or dimensions different from those of the base metal.
Federal Water Pollution Control Act (FWPCA): The FWPCA of 1972 established the foundation of the
current National Pollutant Discharge Elimination System (NPDES) program. This legislation and its subsequent
amendments in 1976 and 1987 were enacted to address the direct connection between effluent (a point source)
or runoff (a nonpoint source) and the water bodies that receive them. The 1976 amendment affirmed a legal
agreement to control the growing problem of toxic discharges. In 1987, Congress amended the FWPCA again
through the Clean Water Act (CWA) to address the inability of permits to meet the CWA goal of protecting
swimming, fishing, and fish propagation. These amendments strengthened the ability of states to establish water
quality standards.
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, Tribal governments, other regulators, and direct participant
stakeholders negotiate the FPA.
Hazardous Waste: Byproducts of society that can pose a substantial or potential hazard to human health or the
environment if improperly managed. Under the RCRA program, hazardous wastes are specifically defined as
wastes that possess at least one of four characteristics (ignitability, corrosivity, reactivity, or toxicity), or appears
on special EPA lists.
Listed Wastes: Wastes that are considered hazardous under RCRA because they meet specific listing descrip-
tions.
Media: Specific environments—air, water, soil—that are the subj ect of regulatory concern and activities.
Multimedia: Several environmental media, such as air, water, and land.
Pollution Prevention Act (PPA): The Act that focuses on enhancing industry, government, and public attention
on reducing the amount of pollution through cost-effective changes in production, operation, and raw- materials
use. Pollution prevention also includes other practices that increase efficiency in the use of energy, water, or
other natural resources, and protect our resource base through conservation. Practices include recycling, source
reduction, and sustainable agriculture.
Publicly Owned Treatment Works (POTWs): Publicly owned facilities that receive and treat sewage and/or
wastewater from residences, commercial activities, and industries.
Reclamation: Restoration of materials found in the wastestream to a beneficial use that may be for purposes
other than the original use.
Recycling: The separation and collection of wastes, their subsequent transformation or remanufacture into usable
or marketable products or materials, and the subsequent purchase of those products made from recyclable
materials.
Resource Conservation and Recovery Act (RCRA): RCRA gives EPA the authority to control hazardous waste
from "cradle-to-grave." This includes the generation, transportation, treatment, storage, and disposal of hazard-
ous waste. RCRA also sets forth a framework for the management of nonhazardous wastes. RCRA enables
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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.
Sludges: Any solid, semisolid, or liquid wastes generated from a wastewater treatment plant, water supply
treatment plant, or air pollution control device.
Substrate: Material upon which electroplating coatings are deposited.
Transportation, Storage, and Disposal (TSD) Facilities: Facilities engaged in the treatment, storage, or disposal
of hazardous waste.
Toxicity Characteristic Leaching Procedure (TCLP): A laboratory procedure designed to predict whether a
particular waste is likely to leach chemicals into groundwater at dangerous levels.
Variance: Government permission for a delay or exception in the application of a given law, ordinance, or
regulation.
Wastewater: The spent or used water from a home, community, farm, or industry that contains dissolved or
suspended matter.
Water Pollution: The presence in water of enough harmful or objectionable material to damage the water's
quality.
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