Date: Thu, 18 Jun 1998 14:01:29 –0400
Dear Compliancenetters:
For those of you that report to the EPA's Toxic Release Inventory, you
will be interested to know that the U.S. EPA released its 1996 TRI data
today. For the first time, the data for five industrial categories
(including electronics) are broken down by SIC code.
The data ranks the printed circuit board industry as the
Folks who are familiar with the TRI know that the high ranking of the PWB
industry is due to the listing of copper compounds and the fact that the
industry generates large amounts of copper-containing sludge and etchant.
Unfortunately, the TRI does not reflect the fact that the majority of
the industry's shipments are sent off-site for beneficial reclamation!
Again, be advised that this information will be misreported as "toxic
releases" by proponents of "community right-to-know."
Information on the TRI is available online at www.epa.gov/opptintr/tri
Holly Evans
Director of Environmental and Safety Programs
Date: Thu, 18 Jun 1998 18:16:38 -0400
Holly and ComplianceNetters,
In addition to release and transfer totals, our industry reported
14.5M lbs of on-site waste management, and when these three categories
are combined, you get the 58.95M lbs of "production-related waste" as
we first say from the scorecard reports.
I was advised prior to this release that EPA was going to include
the off-site releases in its rankings for the 1996 TRI data. Further,
I was advised that our Derry facility had edged back onto the top 10
list for NH when off-site transfers were included. While Derry's 1996
on-site releases of 50,275 lbs were 13,500 lbs below the #10 company,
we had 16,970 lbs of off-site releases, Virtually all of this was the
copper in the copper dust which goes to landfill. So, I concluded that
it's a reasonable ranking system, albeit different that we've seen.
However, when I see the industry totals, I'm both surprised and
somewhat confused. While Derry's off-site releases were 33% of its
on-site releases, the industry off-site was seven times its on-site
releases! ??? I don't know what other major materials are in this
off-site release category other than our experience with copper in
saw/drill/edger dusts, but if this is the major chemical, then our
industry's 7.3M lbs must mean that a lot of folks are sending their
sludge to landfill. (NOTE: Our experience is that both wet sludge and
the dusts have about 10% copper as is, but we see about 4 lbs of
sludge for every lb of dust.) But is this a correct conclusion?
One conflict with this conclusion is that the table (9-7) which
ranks the top 15 chemicals for SIC 36 doesn't even list copper! The
top chemical is lead compounds (7.6M in off-site releases). The only
other possibility for our industry (based on SIC 36 totals) is nitrate
compounds (#3 w/1.1M lbs). (Both manganese and zinc compounds had
about 2M lbs each in off-site releases, but I don't see them coming
out of our industry.) Glycol ethers, ammonia, and even TCE and MEC for
those that still use them are each under 100K lbs in off-site
releases. So, the chemical conclusion is that lead cmpds from our
industry are being landfilled? First, I don't see this quantity.
Second, who's not recycling solder, scrap boards, etc???
Another conflicting fact is the comparison of off-site releases by
year (table 9-14 on page 359). This shows that for our industry,
off-site releases totalled 2.1M lbs in 1988, 504K lbs in 1994, 637K
lbs in 1995 and 7.1M lbs in 1996! That's almost a 12 fold increase in
off-site releases in one year. I don't believe it. There's got to be
either mis-reported data, or a blown data input on this total. The
same year to year comparison for on-site waste mgt shows 6.7M in 94,
3.6M in 95 and 6.5M in 96. No 12 fold increase or huge decrease here.
And off-site further waste mgt (recycling, treatment, etc) shows 22M
lbs in 94, 21.4M in 95 and 24.7 in 96. The off-site release number is
clearly out of whack with all the other numbers for our industry.
Still confused.
Lee Wilmot
Date: Fri, 19 Jun 1998 08:09:00 -0400
Holly:
How can we get the message out that the TRI [as it relates to our industry]
is a very poor statement about tax-payer dollars being used by our
government in an effort to erroneously suggest that we (the PWB industry)
are polluters of the environment. The credibility of this [TRI] tool is at
stake when thanks to the lack of understanding by the EPA of PWB
manufacturing, our copper is miss-reported. It's time to take action.
Michael
Sender: ComplianceNet Mail Forum
From: Holly Evans
Subject: 1996 TRI Reporting Data Released
IPC
1400 Eye St., N.W., Suite 540
Washington, D.C. 20005-2208
phone: 202-638-6219
fax: 202-638-0145
e-mail: HollyEvans@ipc.org
Reply-To: "ComplianceNet E-Mail Forum."
Sender: ComplianceNet Mail Forum
From: lwilmot@HADCO.COM
Subject: Re: 1996 TRI Reporting Data Released
X-To: Holly Evans HollyEvans@IPC.ORG
While the PWB industry ranked #1 in the electrical equipment SIC
for combined on and off-site releases with 8.5M lbs in 1996 (20.5% of
the SIC total), most of this (7.3M lbs or 86% of the total) was
OFF_SITE releases. However, I do not totally agree with Holly's
conclusion that this is due to etchants and sludges recycled off-site,
as these totals (34.5M lbs) are listed separately as transfers. In
this category, we ranked #2 behind storage batteries who had 229M lbs.
The PWB off-site waste mgt (NOT releases) was 9.1% of the SIC total.
HADCO Corp
lwilmot@hadco.com
Reply-To: "mak@circuitcenter.com"
Sender: ComplianceNet Mail Forum
From: Michael Kerr
Organization: Circuit Center, Inc.
Subject: Re: 1996 TRI Reporting Data Released
X-To: Holly Evans HollyEvans@IPC.ORG
It's about time that we (the PWB industry) take these idiots on. This type
of "scare mongering" under the guise of responsible "information
dissemination" in regard to TRI is unconscionable on the part of the US
EPA. I do not know of a single company that is disposing of [copper
bearing] sludge in a landfill anymore (i.e. truly 'releasing' material to
the environment). I firmly believe that all PWB manufacturers are
responsibly managing the copper in their etchant. Further, the only
'actual' releases to the environment are those allowable by law under the
CWA that we find in our wastewater discharges, and we know that has no
environmental impact at the levels we discharge because the EPA has
determined those limits.