Classification and Disposal of Lead Wastes Generated by the Circuit Board Manufacturing Industry in Texas #0022

Classification and Disposal of Lead Wastes Generated by the Circuit Board Manufacturing Industry in Texas

This document was created to answer common questions regarding lead wastes generated in the circuit board manufacturing industry in Texas. The following references were used to create this document:

· Federal regulations contained in 40 Code of Federal Regulations (CFR) including Parts 262, 261, and 172.

· State regulations contained in 30 Texas Administrative Code (TAC) including Chapter 335.

· EPA policy and rule determination letters including 9441.1993(17), 9441.1990(09a), 9441.1991(03), 9441.1992(27), and 9441.1993(18).

· Texas Commission on Environmental Quality (TCEQ) fact sheet “Paste Wipes Handout-ECS2”.

Table 1 - Solder and Lead Waste Classification summarizes the classification of solder and lead wastes in the circuit board manufacturing industry. Several companies have also found the following tips regarding disposal of lead waste to be helpful:

· Both dross and printed circuit boards can be classified as a Class I waste on your state Notice of Registration (NOR) to generate hazardous wastes.

· Paste/paste wipes are generally classified as hazardous wastes. According to 30 TAC 335.9, you must report to the TCEQ ALL hazardous wastes generated, regardless of if they are recycled or not.

· In addition, according to 30 TAC 335.10 ALL hazardous waste transported must be properly manifested using a hazardous waste manifest, regardless of if it is recycled

· If the receiver recycles the waste, you will not be required to pay fees to the TCEQ for the disposal of that waste.

· Recycled Class I waste like solder dross does not need to be reported on the annual waste summary (although you do need to have it on your Notice of Registration as a waste that you generate)

· Lead paste and paste wipes should be manifested as hazardous waste unless you can show they are not flammable and that they can pass a TCLP test for lead. You can combine these into one hazardous waste stream.

· All wastes containing lead must be labeled for DOT requirements as “Environmentally hazardous substance, solid, n.o.s., UN3077 PG III” . According to 49 CFR 172.101, this material is hazardous for shipping purposes when the containers hold more than 10 lb of lead (the reportable quantity in this regulation.)

Solder Waste	Description	RCRA Waste Classification	Other Information	Documentation
Solder Paste and Wipes	Used IPA wipes contaminated with solder paste. Solder paste in partially used or expired full containers. Associated debris like gloves that are contaminated with the solder paste.	Hazardous unless wipes can be shown to be dry and not flammable AND the wipes and paste can pass a TCLP test. REPORTABLE AS HAZARDOUS WASTE ON ANNUAL WASTE SUMMARY EVEN IF RECYCLED.	A spent material that is a solid waste. Hazardous as a characteristic hazardous waste (both flammable and toxic).	40 CFR 261.2(c)(3) Spent materials that are recycled are solid wastes. 40 CFR 261.1(c)(1) "A "spent material" is 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;" Also see technical bulletin "Tin/Lead Solder Paste and Wipes Hazardous Waste Classification and Management"
Solder Dross from Virgin Solder	Generated prior to using the bar solder when virgin bars are melted and the contaminants and oxides developed since the metal or alloy was refined.	Non-hazardous CLASS I WASTE NOT REPORTABLE ON ANNUAL WASTE SUMMARY IF RECYCLED.	Not a solid waste because it is a characteristic by-product that is recycled. Hazardous wastes are a sub-class of solid waste.	40 CFR 261.2(c)(3) By-products that are recycled are not solid wastes even though they may exhibit a characteristic of hazardous waste. See March 19, 1991 letter from EPA discussing types of "drosses".
Solder Dross from Process	Generated by skimming contaminated solder from the bath. Contamination in this case is caused by its use in the process.	Non-hazardous. CLASS I WASTE NOT REPORTABLE ON ANNUAL WASTE SUMMARY IF RECYCLED.	Subject to regulation as scrap metal and exempt from solid waste regulation as a hazardous waste when recycled. Hazardous wastes are a sub-class of solid waste.	Note that, although an EPA determination to this effect has not been issued, it could also reasonably be asserted that this dross generally meets the definition of a scrap metal (""Scrap metal" is 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.") that is exempt from solid waste regulation as a hazardous waste when recycled. See March 19, 1991 letter from EPA discussing types of "drosses".
Pot Dumps	Discarded solder baths that are changed out as a whole.	Non-hazardous. CLASS I WASTE NOT REPORTABLE ON ANNUAL WASTE SUMMARY IF RECYCLED.	Subject to regulation as scrap metal and exempt from solid waste regulation as a hazardous waste when recycled. Hazardous wastes are a sub-class of solid waste.	EPA determination in letters dated September 24, 1993 and September 20, 1993
Unused off-spec circuit boards and board trimmings	Sent off-site for recycling	Non-hazardous. CLASS I WASTE NOT REPORTABLE ON ANNUAL WASTE SUMMARY IF RECYCLED.	Not a solid waste because it is a characteristic by-product that is recycled. Hazardous wastes are a sub-class of solid waste.	40 CFR 261.2(c)(3) By-products that are recycled are not solid wastes even though they may exhibit a characteristic of hazardous waste. EPA determination letter date March 1990.
Used circuit boards	Sent off-site for recycling	Non-hazardous. CLASS I WASTE NOT REPORTABLE ON ANNUAL WASTE SUMMARY IF RECYCLED.	Subject to regulation as scrap metal and exempt from solid waste regulation as a hazardous waste when recycled. Hazardous wastes are a sub-class of solid waste.	EPA determination in letter dated August 26, 1992.
Shredded circuit boards	Recycled, free of mercury switches, mercury relays and nickel-cadmium batteries and lithium batteries, and kept in containers to prevent release to environment are not solid waste.	Non-hazardous. CLASS I WASTE NOT REPORTABLE ON ANNUAL WASTE SUMMARY IF RECYCLED.	Not a solid waste. Hazardous wastes are a sub-class of solid waste. Shredded circuit boards that are recycled, free of mercury switches, mercury relays and nickel-cadmium batteries and lithium batteries, and kept in containers to prevent release to environment are not solid waste.	40 CFR 261.4(14) excludes circuit boards of this type from definition of solid waste.

Karen M. Bullard, P.E. is an Engineering Partner and the President of Bullard Environmental Consulting, Inc. She has over 12 years experience in environmental engineering, compliance, and permitting. She worked for the Texas Commission on Environmental Quality (TCEQ) for four years as an Air Permit Specialist in the Coatings and Combustion Section, where she developed a thorough understanding of the governmental procedures and policies in Texas. Karen has a Bachelors of Science Degree in Chemical Engineering from the University of Texas at Austin.

2. By-products that are recycled are ______ even though they may exhibit a characteristic of hazardous waste.

3. Lead paste and paste wipes should be manifested as hazardous waste unless ...

4. All hazardous waste transported must be properly manifested using a hazardous waste manifest, ....

5. Per this article, All wastes containing ___ must be labeled for DOT requirements as “Environmentally hazardous substance, solid, n.o.s., UN3077 PG III” .

6. Per 49 CFR 172.101, the reportable quantity in this regulation for shipping purposes is when the containers hold more than ___ of lead.