July, 2014
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EPA Compliance: Understanding Management of Solder Waste
By Peter C. Ruth II, North American Business Manager, and Nelson Mossholder, Ph.D., VP, Conecsus LLC, Terrell, TX
due to the increasing complexity and scope of the Resource Conservation and Recovery Act (RCRA) enacted in 1976. Anyone generating hazardous wastes is responsible and liable for those wastes. so it is important to
M
anaging solder wastes and byproducts has grown in complexity over the years,
and have been administering their own RCRA programs. This has led to some confusion, since the state regu- lations are quite different, some far more stringent than the federal regu- lations. For example, Rhode Island has only two hazardous waste gener- ator status subsets with no exemp- tions; in contrast, most other states offer exemptions to entities that pro-
duce small amounts of hazardous waste. As a result, some states allow shipping small amounts of hazardous waste using any trucking company, while other states require the use of a Licensed Hazardous Waste Transporter and a Hazardous Waste Manifest, irrespective of volume. So, it is important to understand the obligations when managing waste
streams both in the state where the waste is generated and in the state where the waste is being shipped.
Recycling Encouraged In 2008, the EPA revised the
RCRA regulations with the intention of encouraging recycling rather than disposing of certain types of waste
Continued on next page
Page 53
Pouring an ingot of reclaimed metal.
understand how different solder- related wastes should be managed. Solder-related materials such as “Paste & Wipes” are solid wastes that under Regulation 40, Code of Federal Regulations (CFR), section 262.11-c usually identified as charac- teristically hazardous wastes be - cause they fail the toxicity character- istic leaching procedure (TCLP) test for lead or because they have a flash point less than 135°F. Those generating waste must
declare their waste generator status (large or small generator) based on the volume of hazardous waste pro- duced annually, according to the firm’s state RCRA program. They must determine a classification for each waste stream generated, stored, or treated at a particular facility. This places a burden on environmen- tal and plant managers to under- stand regulations regarding those wastes, since not all states have the same regulations. In general, genera- tors of waste should be familiar with their own state’s RCRA-equivalent programs as well as federal regula- tions. What follows will expand on some of the regulations that apply specifically to solder and solder- related waste streams and the importance of understanding which federal regulations apply. The RCRA was the first major
amendment to the 1965 Solid Waste Disposal Act, drafted in response to this nation’s unprecedented growth of municipal solid waste and the need to safely manage it. At that time, it was revolutionary, since the previous solid waste rules did little to encourage reuse, recycling, or control of hazardous waste streams. As part of the RCRA, individual states were given the option to administer the new programs, after submitting a plan to the federal Environmental Protection Agency (EPA), or cede control of their programs to the fed- eral government. The RCRA required that any state program must be at least as stringent as the federal program, establishing a min- imum threshold.
Two States Approved As of this writing, all but two
states have had their plans approved See at SEMICON West, Booth 5556
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