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HADCO Corporation's Project XL Pilot

Logo of EPA II Project XLOn March 16, 1995, the Clinton Administration announced a portfolio of reinvention initiatives 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 project 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. 

Description of Hadco's Project

Through its XL Pilot Project, HADCO, a manufacturer of complex multilayer rigid printed circuits boards, seeks to remove its wastewater treatment sludge from regulation as hazardous waste F006 under RCRA Subtitle C.  The regulatory relief sought would be either a conditional delisting (a hybrid of the traditional RCRA delisting) or solid waste variance (currently delegated to NYSDEC).  This relief would allow the company to directly ship its waste sludge to a primary copper smelter, thus bypassing a treatment facility where the sludge is currently dried prior to smelting.  With the cost savings from this short cut, HADCO would be able to fund the reclamation of copper from facility non-hazardous wastes that are rich in copper (i.e., drilling and edging dusts).  Due to cost considerations, HADCO currently and legally sends these dusts to solid waste landfills for disposal.  If this project is successful and transferable, in the future other electronics companies may be able to utilize this system as a means to keep their metals laden non-hazardous waste out of landfills. 

Project Status

EPA and NYSDEC have received the seven rounds of sludge sample analysis from HADCO.  The results indicate recoverable amounts of copper exist in the sludge (about 19 percent copper content for the Owego, N.Y. facility).  HADCO is currently preparing a petition for regulatory relief.  Upon receipt, EPA and NYSDEC will either grant or deny the request in a process which will allow for public comment. 

Project Agreement Between EPA and HADCO

A copy of the Final Project Agreement (FPA) for HADCO can be viewed on screen or downloaded, or you can read the Federal Register Notice for more details: 

Contacts and Additional Sources of Information

Questions or comments concerning Project XL, the Region's involvement in the HADCO project, or the FPA may also be directed to Mr. Jim Sullivan at (212) 637-4138 or sullivan.james@epa.gov

General information about Project XL

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