Date: Tue, 12 May 1998 15:29:55 -0700
Hi compliancenetters,
Date: Wed, 13 May 1998 09:33:46 -0400
Hi everyone --
The U.S. EPA considers router dust from PWB manufacture to constitute a
"characteristic by-product" due to its lead content. It is, therefore,
not a solid waste (and, therefore, not subject to RCRA) when it is
Regarding, drilling dust, facilities would be required to conduct a TCLP
test to determine whether the dust fails the TCLP for any substance.
Since drill dust mainly contains copper and epoxy/glass, I doubt that it
would fail TCLP, but generators must test to affirm. If it fails TCLP,
the dust is a hazardous waste and subject to RCRA Subtitle C.
Does anyone have any more insight as to the regulatory status of these
two by-products?
Thanks,
Date: Wed, 13 May 1998 11:48:16 -0400
We use a company out of Minnesota to reclaim gold and copper out of
the dust. We have only been doing this for about 6 weeks and are still
waiting to find out if the gold and copper value of the dust will pay for
itself. If you would like additional information please e-mail me direct or
call me at 612-930-8067.
Troy Christensen
Date: Wed, 13 May 1998 09:17:38 -0700
Our interpretation of the Federal regulation of drilling dust is consistent
with IPC's, and we do not consider it a RCRA hazardous waste as long
as it is reclaimed.
In California, our local DTSC branch has determined that drill/routing dust
may be regulated as an "Excluded Recyclable Material" if it is a fine
powder (<100 microns) which has hazardous constituents.
As such, it is subject to special provisions under H&S Code Section
25143.9. It must be labeled as an "Excluded Recyclable Material", but no
manifest is required as long as it is reclaimed. Since this solution is very
manageable, we have not had TCLP done....
Good Luck!
Debra A. Emery
Date: Wed, 13 May 1998 18:14:25 -0400
Holly et al,
Drill and edger dust are different, as they contain only those
constituents that you've listed. I don't know if we've done TCLPs on this stream
or not (I'm copying this message to our folks to see if they have), but
certainly our knowledge of the process would support a non-RCRA classification.
Accordingly, except for our CA facilities (which Debra Emery addressed in her
reply), we landfill drill and edger dusts as the cost of recycling them is
prohibitive. Our vendors are saying $100+/ton to recycle versus the local
landfill fee. There's additional packaging and container management issues too.
Besides Debra's point about <100 micron rationale, CA also has a copper
content threshold of 2500 mg/kg (for solids) and 25 mg/l for liquids for state
wastes. If I did my math correctly, 2500 mg/kg is about 2.5%, and our analyses
shows drill & edger dusts contain about 10% copper. So, unless CA changes its
rules, which Lief Peterson said they are proposing to do (4/19/98 Notice of
Preparation for Revisions of CA's Non-RCRA Waste Classification Regulation) at
the FREE forum held at IPC Expo two weeks ago, CA shops will have to manage
drill and edger dusts as a regulated state waste.
The cost of recycling drill & edger dusts is a non-starter. That is why
we've linked regulatory relief on a delisted F006 sludge with recycling these
dusts on a $ for $ basis in our Project XL project. Hopefully some recyclers can
offer some economies for recycling both, possibly commingled, as a non-regulated
solid waste?!
Lee Wilmot
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From: Nirav Sheth
Subject: Drilling & routing dust
I was wondering how other companies are handling drilling and routing dust. Has anybody done STLC or TTLC ? Orange County Health Care Agency is requiring us to handle this waste stream as hazardous waste because drilling dust would not qualify as scrap metal.
Thanks in advance for you input.
Reply-To: "ComplianceNet E-Mail Forum."
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From: Holly Evans
Subject: Re: Drilling & routing dust
X-To: Nirav Sheth
In-Reply-To:
Reply-To: "ComplianceNet E-Mail Forum."
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From: Troy Christensen
Subject: Drilling & routing dust -Reply
X-To: owner-compliancenet@IPC.ORG
christt@mtka.advcir.com
Johnson Matthey Advance Circuits, Inc.
Specialty Products Division
E, H & S Engineer.
612-930-8067
Reply-To: "ComplianceNet E-Mail Forum."
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From: Debra Emery
Subject: Drilling & routing dust -Reply
Director of Facilities & Environmental Affairs
Praegitzer Industries, Inc.
Fremont Division
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From: lwilmot@HADCO.COM
Subject: Re[2]: [CN] Drilling & routing dust
X-To: Holly Evans
Our TCLP tests confirm EPA's classification of rout dust, as there is
enough lead in it to trip the 5 mg/l leachate threshold. However, since we
recycle this under the scrap metal exemption of RCRA, it is not a solid waste.
HADCO Corp
603/896-2424
lwilmot@hadco.com