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Recycling Aspects of RCRA
Certain recycling activities can be implemented by PWB facilities that may remove materials from RCRA regulation that otherwise would be considered hazardous wastes. Recycling can be accomplished in several ways: (1) using or reusing materials in an industrial process to make a product, provided the materials are not being reclaimed (see definition of reclaimed material); (2) using or reusing the material as an effective substitute for commercial products; or (3) returning materials to the original process from which they are generated, without first being reclaimed (where the material is returned as a substitute for raw material feedstock).
Materials managed by recycling are not classified as solid waste and therefore are out of the scope of RCRA Subtitle C regulation, except for certain situations. The exceptions include: (1) materials used in a manner constituting disposal or used to produce products that are applied to the land; (2) materials burned as a fuel or for energy recovery; (3) materials that are speculatively accumulated; and (4) inherently waste-like materials (these materials include listed hazardous wastes that are always subject to RCRA regulation).
The regulations themselves are rather complex and it is not always clear exactly which wastes and which activities qualify for recycling exemptions. To reduce uncertainty, EPA has released regulatory determinations that address specific production processes and wastes. By comparing their own situations to those in the determinations, industry personnel can develop a clearer understanding of the regulations and improve their waste management practices. The available determinations address the following materials: etchant, photoresist skins, solder dross, pot dumps, off-spec boards and trimmings, and used printed circuit boards. Generators should check with their state regulating offices to determine if the Federal interpretations apply.
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Question or Consideration |
Clarification/Interpretation |
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Does solder dross meet the description of a "by-product" or a "spent material" in the context of the hazardous waste regulations? |
The determining consideration in classifying a secondary materials is how the material is generated. As a product that has been used in the process, the solder skimmings, when removed (i.e., skimmed off) from the process due to contamination of the molten solder bath during its use in the process, would more clearly meet the definition of a spent material than a by-product. Rather than being a by-product of the solder itself, the skimmings are spent materials from the use of the solder. [ Full Text] [Related] |
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How are the unused off-spec boards classified under 40 CFR 261.2. Are the board trimmings from manufacturing considered by-products or scrap metal? Would these materials be solid wastes under RCRA? |
The unused circuit boards are considered to be non-listed commercial chemical products, and thus, are not solid wastes when reclaimed. If, however, the circuit boards had been used and were no longer fit for use, they would be considered spent materials and defined as solid wastes when reclaimed.
The printed circuit board trimmings meet the definition of characteristic by-product rather than scrap metal, and are not solid wastes when reclaimed under Section 261.2(c)(3). Although the trimmings are physically similar to scrap metal, to meet the definition of scrap metal, the material must have significant metal content, i.e., greater than 50% metal. [Full text] |
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What is the regulatory status of used printed circuit boards? |
As a matter of policy, the Agency has decided that unprocessed, spent (i.e., used) printed circuit boards are subject to regulation as scrap metal for the purposes of 261.6(a)(3)(iv), and are therefore exempt from RCRA Subtitle C regulation when recycled.
After the boards are processed (including shredding, grinding, burning or smelting), the resulting material (e.g., shredded pieces) may no longer be similar to the materials that meet the definition of a scrap metal. The Agency believes that certain materials generated from the processing of spent printed circuit boards may be in a physical state which is inherently different from the more "traditional" scrap metal materials. Spent circuit board processing, particularly those reclamation steps that do not involve simple physical processing, may generate materials in a form which allows the dispersion of hazardous constituents during subsequent handling. Therefore, some of these materials may not meet the definition of, nor the intent of, the scrap metal definition (analogous to the fluff generated by the shredding of scrap automobiles). Thus, at this point, the processed material may no longer be exempt from regulation as scrap metal, and could be subject to regulation as a spent material. [ Full text] |
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Do photoresist skins fall under the definition of F006 waste? |
Their regulatory status is dependent on the type of operation employed at each individual facility.
If stripping solutions are not electroplating wastewaters then the skins would not be wastewater treatment sludges and thus not F006. If the stripping solutions employed are electroplating wastewaters, the filtering of skins from that solution should be considered the generation of wastewater treatment sludge from electroplating operations and thus would be considered F006 listed hazardous wastes. [ Full text] |
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If spent alkaline etchant is sent off-site for recovery is it a hazardous waste or does it qualify for a variance under the modified closed-loop provision (40 CFR 260.31(b))? |
To qualify for a variance pursuant to 260.31(b) the material that is reclaimed must be used as a feedstock within the original primary production process in which the waste was generated. The regulations do not require that this all occur at a single production/regeneration facility; however, the material (after reclamation) must be returned to the process from which it was generated. If a facility does not return the reclaimed material to the process which generated the waste, the situation does not meet the basic conditions of the modified closed-loop provision. Therefore, the spent alkaline etchant is subject to regulation by the generator (which includes the manifest), must be transported by a hazardous waste transporter, and the reclamation facility must comply with the appropriate standards regarding storage of the spent alkaline etchant. [Full text]. |
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Are solder bath pot dumps subject to regulation if the material is reclaimed? |
EPA has determined that pot dumps generally meet the definition of scrap metal ( 40 CFR 261.1(c)(6)) and therefore are not currently subject to regulation when reclaimed. EPA encourages shops to manage lead pot dumps being recycled in a manner that minimizes potential releases to the environment. Do not store spent pot dumps or other solder residues on the ground or uncovered such that lead constituents of the material may leach into soil or surface water or become airborne if the material is in a dispersable form. [Full text] (http://www.nmfrc.org/nmfrc/regs/epadocs/1993f.htm). |
Solder dross. is generated by the periodic skimming of molten solder baths used in the production of printed circuit boards to remove contaminants acquired through use of the molten solder baths.
Off-spec boards and board trimmings. Manufacturer’s of computer circuit boards send unused off-specification printed circuit boards and board trimmings from the production process off-site for reclamation. The printed circuit boards are made of alternating layers of thin copper and fiberglass plates coated with tin lead; containing approximately 30% copper, 68% fiberglass, and 2% tin lead.
Used printed circuit boards. Old electronic equipment may be disassembled and the usable parts salvaged. Parts may also be scrapped and processed (e.g., shredded) for metal values.
Photoresist skins. Dry film resists are typically stripped in hot potassium hydroxide, which does not fully dissolve the resist material. The solids (photoresist skins) are filtered out to prevent clogging of spray nozzels, prevent redeposition on panels, and prolong the life of the stripper.
Etchant. Commercial alkaline etchant is distributed for use to manufacturers of printed circuits. After a period of use, the alkaline etchant is reduced below acceptable levels and becomes spent. The spent material is then returned to the manufacture of the alkaline etchant where copper is recovered and the remainder of the etchant is then used as a raw material to produce additional alkaline etchant.
Pot dumps. When solder baths become spent, they are known as "pot dumps".
Definitions of Terms Related to Waste Management/Recycling
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Term |
Definition |
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solid waste |
Any discarded material that is not excluded under RCRA (exclusions are found in 40 CFR Part 261.4) or by a variance granted under RCRA (procedures for variances are covered in 40 CFR 260.30 and 260.31). |
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hazardous waste |
A solid waste that meets any of the RCRA hazardous waste criteria (described in 40 CFR 261.3) and is not excluded from regulation as a hazardous waste (exclusions are found in 40 CFR 261.4(b). |
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spent material |
Any material that has been used and as a result of contamination can no longer serve the purpose for which it was produced without processing. |
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by-product |
A material that is not one of the primary products of a production process and is not solely or separately produced by the production process. |
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reclaimed material |
A material is ‘‘reclaimed’’ if it is processed to recover a usable product, or if it is regenerated. Examples are recovery of lead values from spent batteries and regeneration of spent solvents. |
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secondary material |
Materials that may otherwise meet the definition of a solid waste except that they are excluded due to implementation of processes involving reclamation and reuse. |
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scrap metal |
Bits and pieces of metal parts (e.g., bars, turnings, rods, sheets, wire) or metal pieces that may be combined together with bolts or soldering (e.g., radiators, scrap automobiles, railroad box cars), which when worn or superfluous can be recycled. |
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recycle |
A material is ‘‘recycled’’ if it is used, re-used, or reclaimed. |
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