WASTE

AUDIT STUDY
PRINTED CIRCUIT BOARD
MANUFACTURERS

PREPARED FOR

TOXIC SUBSTANCES CONTROL PROGRAM

CALIFORNIA DEPARTMENT OF
HEALTH SERVICES

PREPARED BY

PLANNING RESEARCH CORPORATION

SAN JOSE, CALIFORNIA
REVISED 1989
 WASTE AUDIT STUDY
OF THE
PRINTED CIRCUIT BOARD MANUFACTURING INDUSTRY

Prepared by

Planning Research Corporation

San Jose, California

Prepared For

California Department of Health Services

Toxics Substances Control Program
Alternative Technology Division
714/744 P Street
Sacramento, California

June 1987
 TABLE OF CONTENTS

Disclaimer ..................... ii
Foreword ..................... iii
Abstract ..................... iv
Acknowledgments .................... iv

Section Paae

1 - Introduction .................. 1

Overview of Waste Minimization Assessment ...

...........
Planning and Organization
Assessment Phase ...............
.............
Feasibility Analysis
Implementation ................
References ..................
2 - Printed Circuit Board Manufacturing Industry
Profile .................... 7

Products and Their Use ............ 7

Raw Materials . . . . . . . . . . . . . . . . . 8
Process Description . . . . . . . . . . . . . . 9
Waste Description . . . . . . . . . . . . . . . 11
References .................. 13

3 - Waste Minimization Options for Printed Circuit

Board Manufacturers .............. 14

Product Substitution ........... . . 17

. . . . .
Cleaning and Surface Preparation . . 18
.
Use Abrasive Instead of Aqueous Cleaning . . ia
....
Use Non-Chelated Cleaning Chemicals . . 18
Extend Bath Life and Improve Rinse Efficiency . 19
Use Countercurrent Cleaning Arrangement .... 19
 Section Pase

Reuse/Recycle of Cleaning Agents ....... 19

.........
Reuse/Recycle of Rinse Water 20
.........
Pattern Printing and Masking 21
....
Electroplating and Electroless Plating 22
.........
Eliminate Need for Operation 22
........
Reduce Hazardous Materials Used 22
...........
Extend Process Bath Life 22
...........
Improve Rinse Efficiency 29
.......
Recovery/Reuse of Spent Materials 32
Etching .................... 36
.............
Wastewater Treatment 37
...........
Waste Stream Segregation 37
Use of Alternative Waste Treatment Chemicals . 38
-
Alternative Wastewater Treatment Ion Exchange 38
References .................. 39

4 - Guidelines for Using the Waste Minimization

Assessment Worksheets ............. 43

Conducting Your Own Assessment ........ 43

Appendix One - Case Studies of Printed Circuit Board

Manufacturing Plants ........... 60

Appendix Two - Where to Get Help: Further Information

on Waste Minimization .......... 111
Fisure Pase

1.1 The Waste Minimization Assessment Procedure ... 3

3.1 Multiple Closed Circuit Counterflow Rinse System . 27

Table

2.1 Waste Streams from Printed Circuit Board

Manufacturing ................ 12

3.1 Waste Minimization Methods for the Printed Circuit

Board Industry ................ 15

3.2 Factors That Increase the Amount of Drag-out ... 24

3.3 Costs of Technology for Material Recovery .... 35

4.1 List of Waste Minimization Assessment Worksheets . 44

I ABSTRACT

This report presents the results of PRC's waste audit study for the printed
circuit (PC) board manufacturing industry. The study was conducted to identify
opportunities for waste reduction available to the PC board manufacturing industry
and to develop a generic audit protocol that can be used by manufacturers to assess
~

I
their own waste reduction opportunities. The study emphasized technologies
available to small- and medium-sized PC board facilities. The tasks included in the
study were: (1) selecting PC board manufacturing facilities to include in the study,
(2) performing waste audits a t each facility, (3) developing recommendations for
implementing waste reduction technologies a t each audited facility, (4) discussing
with facility representatives the feasibility of implementing the waste reduction
recommendations, and ( 5 ) developing this waste audit study report.

Three categories of waste reduction technologies are available to PC board

manufacturers: (1) source reduction, (2) recycling a n d resource recovery, and (3)
alternative treatment. The costs associated with implementing these technologies
range from a few hundred dollars for simple improvements in housekeeping and
minor process modifications to tens o f . thousands of dollars for installation of
recovery or treatment units. The benefits realized from implementation include
reductions in material purchase and waste disposal costs in addition to reduction in
the liability associated with generating, handling a n d disposing hazardous wastes. A
generic audit protocol has been developed as a result of the study and should be
made available to the PC board manufacturing industry.

1989 REVISION

This r e v i s i o n of t h e o r i g i n a l JUNE 1987 study r e p o r t a l s o includes the

f u l l report "Guide t o Waste Minimization i n t h e P r i n t e d C i r c u i t Board
Manufacturing I n d u s t r y , " prepared by Jacobs Engineering Group f o r t h e USEPA.
This Jacobs/USEPA r e p o r t w a s t h e r e s u l t of t h e JUNE 1987 r e p o r t being adapted
by Jacobs t o meet USEPA needs. This 1989 r e v i s i o n d e l e t e s those p o r t i o n s o f
t h e JUNE 1987 r e p o r t t h a t a r e covered i n t h e Jacobs/USEPA r e p o r t .

The Jacobs/USEPA r e p o r t is included i n APPENDIX A as a SUPPLEMENT.

T h i s r e v i s i o n a l s o contains added APPENDIX E as l i s t e d i n t h e CONTENTS.

i
 DISCLAIMER

The information in this document has been funded wholly or in part by the United
States Environmental Protection Agency under Contract 68-02-4286 to Radian
Corporation. It has been subjected to the Agency‘s peer and administrative review
and it has been approved for publication as an EPA Document.
This guide is advisory only. It is intended to provide guidance to printed circuit
board manufacturers in developing approaches for “ S n g wastes. Compliance
with environmental and occupational safety and health laws is the responsibility of
each individual business and is not the focus of this document. Mention of trade
names or commercial products does not constitute endorsement or recommendation
for use.
The statements and conclusions of this document are those of the contractor and not
necessarily those of the State of California. The mention of commercial products,
their source, or their use in connection with material reported herein is not to be
construed either as actual or implied endorsement of such products by the State of
California.

ii
 FOREWORD

Today's rapidly developing and changing technologies and industrial products and
practices frequently carry with them the increased generation of materials that if
improperly dealt with,can threaten both public health and the environment. The
U.S. Environmental Protection Agency is charged by Congress with.protect.ing the
Nation's land, air, and water resources. Under a mandate of ~ t i o n aenvironmental
l
laws, the agency strives to formulate and implement actions leading to a compatible
balance between human activities and the ability of natural systems to support and
nllrture life. These laws direct the EPA to perfom research to define our
environmental problems, measure the impacts, and search for solutions.
The Risk Reduction Engineering Laboratory is responsible for planning,
implementing, and mamging research, development, and demonstration programs
to provide an authoritative, defem'ble engineering basis in support of the policies,
programs, and regulations of the EPA with respect to drinldng water, wastewater,
pesticides, toxic substances, solid and hazardous wastes, and Superfund-related
activities. This publication is one of the products of that research and provides a
vital communication liok between the researcher and the user community.
.. .
waste Mtnuntzation is a policy specifically mandated by the U.S. Congress in the
1984 Hazardous and Solid Wastes Amendments to the Resoutoe Conservation and
Recovery Act. This guide to waste " h a t i o n for the printed Circuit board
industry is the fourth of a series of Seven manuals being developed to provide
industry-specific information about hazardous waste "hition,

E. Timothy @pelt, Director,

Risk Reduction Engineering Laboratory

iii
 ABSTRACT

This guide identifies and analyzes waste " h a t i o n methodologies appropriate for
the printed circuit board manufacturing industry. The wastes resulting from printed
circuit board manufacturing are associated with five types of processes: cleaning and
surface preparation; catalyst application and electroless plating; pattern printing and
masking; electroplating; and etching. The wastes themselves include airborne
particulates, spent acids and alkaline solutions, spent solvents, spent plating baths,
waste rinsewater, and other wastes. The guide also presents a set of detailed waste
" h a t i o n assessment worksheets suitable for use by shop managers and
engineers, or by outside consultants, to formulate a waste " h a t i o n strategy for
the particular plant. Finally, case histories of waste " b a t i o n assessments
performed at three plants are given.
Planning Research Corporation, San Jose, California, conducted the original
California Department of Health Services (DHS) waste " h t i o n assessments
which are cited in this guide. Jacobs Engineering Group Inc., Pasadena, California
edited and produced this version of the waste " h a t i o n assessment guide. Much
of the information in this guide that provides a national perspective on the issues of
waste generation and " h a t i o n for printed circuit board manufacturing was
provided originally to the U.S.Environmental
. . . Protection Agency by Versar, Inc.,and
-
Jacobs Engineering Group in "Waste h4"mtion Issues and Options, Volume I&"
report no. PB87-114369(1986).
This report was submitted in fulfillment of Contract 68-02-4286 by Jacobs
Engineering Group under the sponsorship of the U.S. Environmental Protection
Agency. This report covers a period &om January to June 1989, and work was
completed as of July 1989.

ACKNOWLEDGMENTS

We would like to thank those individualswhose reviews of this guide contributed to

its development: Bonnie Blam, IBM corporation;Box& Gariepy and Terrence J.
McManus, Intel Corporation; and Arthur H. PurceU, UCLA Engineering Research
Center.
In addition, we would like to recognize those who contributed to the original DHS
assessments: David Leu, Benjamin Fries, Kim Wilhetm, and Jan Radimsky of the
Alternative Technology Section of DHS, and the technical and management staffs
of the cooperating firms for their imraluable support and guidance.

iv
 ACKNOWLEDGEMENTS

Many people contributed to and assisted in the development of this report. In

particular, we wish to thank: David Leu, Benjamin Fries, Jan Radimsky, and Kim
Wilhelm of the Alternative Technology Section of the California Department of
Health Services, the owners' and personnel of the printed circuit board
manufacturing companies that participated in this study, and representatives of
equipment manufacturers, chemical suppliers and hazardous waste recycle/disposal
faciiities who provided us with a great deal of cost and technical data.

This report was submitted in fulfillment of Contract No. 85-87160 by Planning

Research Corporation under the sponsorship of the Department of Health Services,
Work was completed as of June 10, 1987.

DISCUIMEB

The statements and conclusions of this report are those of the

Contractor and not necessarily those of the State of Cali ornia. The mention
of commercial products, their source, or their use in connection with
material reported herein is not to be construed either as actual or implied
endorsement of such products.

REGULATORY CAVEAT

All text pertaining to law and regulations contained within this report
are provided for general information only. That information is not reliable
for use as a legal reference. The generator must contact the appropriate
legal sources and regulatory authorities for up-to-date regulatory
requirements, and their interpretation and implementation.

CONTRACTS

Contract No. 85-87160 provided $25,000 to prepare this report. No

subcontractors were involved in the preparation.

ii
 Section One
INTRODUCTION

This guide is designed to provide printed circuit board manufacturers with waste
" h t i o n options appropriate for this industry. It also provides worksheets designed to
be used for a waste " i o n assessment of a manufacturing facility, to develop an
understanding of the facility's waste generating processes and to suggest ways that the
waste may be reduced.
The worksheets and the list of waste " h a t i o n options were developed through
assessments of three Santa Clara area prototype circuit board manufacturing shops. The
assessments were commissioned by the California Department of Health Services (CDHS
1987). The f"operations, manufactwing processes, and waste generation and
management practices were surveyed, and their existing and potential waste " h t i o n
options were characterized. Economic analyses were performed on selected options.
Today's industry is faced with the major tecbnorogical challenge of identifying ways to
effectively manage hazardous waste. Technologies designed to treat and dispose of wastes
are no longer the optimal strategy for handling these wastes for two major reasons. First,
the potential liabilities associated with handling and disposing of hazardous wastes have
increased significantly. Second, restrictions placed on land disposal of hazardous wastes
have caused considerable increases in waste disposal costs. The economic impact of these
changes is causing industry to explore alternatives to treatment and disposal technologies.

Waste " b a t i o n is a policy specifically mandated by the U.S. congresS in the 1984
Hazardous and Solid Wastes Amendments to the Resource Conservation and Recovery Act
(RCRA). As the federal agency responsible for writing regulations under RCRA,the U.S.
Environmental Protection Agency (EPA)has an interest in ensuring that new methods
and approaches are developed for ~-g hazardous waste and that such information
is made available to the industries concerned This guide is one of the approaches EPA
is using to provide industry-specific information about hazardous waste " b a t i o a
EPA has also developed a general manual for waste " h t i o n in industry. The Waste
MinimiratiOn Oppwtmdy AsreSam M .(USEPA 1988) tells how to conduct a waste
" k a t i o n assessment and develop options for reducing hazardous waste generation at
a facility. It explains the management strategies needed to incorporate waste " b a t i o n
into company policies and structure, how to establish a company-wide waste "&ion

1
Figure 1 .l. The Waste Minimization Assessment Procedure

The Reeognlzad Need to Mlnlmlre Waste

PLANNING AND ORGANEATION

Get management commitment
9 Set overall ass8ssmont program goals
9 Organlu asmssment program task f o m

ASSESSMENT PHASE
Coiloct pmcoss and trclllty drtr Select New Assessment
Prlorttb and mloct asms8ment targets Targets and RmaIu%te
9 ~ o cpooplo
t for assessment toam8 __c.A Prwloua Optlons
Rwkw deu and inspect slto
9

9
Ganoata optlonr
Scrnn and solat optlons for furtlnr study I

Repaat tho Proces8

3
PLANNING AND ORGANIZATION
Essential elements of planning and organization for a waste " k a t i o n program are: .
getting management commitment for the program; setting waste " h a t i o n goals; and
organizing an assessment program task force. The importance of these initial steps cannot
be over estimated.

ASSESSMENT PHASE
The assessment phase involves a number of steps:
0 Collect process and facility data
0 Prioritize and select assessment targets
0 Select assessment team
0 Review data and inspect site
o Generate options
0 Screen and select options for feasibility study
C o l l e c p m and f i d i i y &a The waste streams at a facility should be identifled and
characterized. Information about waste streams may be available on hazardous waste
manifests, waste profile sheets, routine sampling programs and other sources.
Developing a basic understanding of the processes that generate waste at a facility is
essential to the WMOA process. Flow diagrams should be prepared to identify the
quantity, types and rates of waste generating processes, Also, preparing material balances
for various processes can be useful in tracking various process components and identifying
losses or emissions that may have been unaccounted for previously.
'Aioritireand seled use"t targets Ideally, all waste streams in a facility should be
evaluated for potential waste " h a t i o n opportunities. With limited resources, however,
a plant manager may need to concentrate waste " h a t i o n efforts in a specific area
Such considerations as quantity of waste, hazardous properties of the waste, waste disposal
restrictions, regulations, safety of employees, economics, cost of disposal, and other
characteristics need to be evaluated in selecting a target stream.
Sew arsesmtart team The team should include people with direct responsibility and
knowledge of the particular waste stream or area of the plant, including machine operators
and maintenance personnel.
Review data and inrpedsite The assessment team evaluates process data in advance of the
inspection. The inspection should follow the target process from the point where raw
materials enter the facility to the points where products and wastes leave. The team should
identi@ the suspected sources of waste. This may include the production process;
'maintenance operations; and storage areas for raw materials, finished product, and work
in progress. The inspection may result in the formation of p r e l i " y conclusions about
waste " b a t i o n opportunities. Full confirmation of these conclusions may require
additional data collection, analysis, and/or site visits.

4
Generate optiolrr. The objective of this step is to generate a comprehensive set of waste
" h a t i o n options for further consideration. Since technical and economic concerns will
be considered in the later feasibility step, no options are ruled out at this time. Information
from the site inspection, as well as trade associations, government agencies, technical and
trade reports, equipment vendors, consultants,and plant engineers and operators may sewe
as sources of ideas for waste " b a t i o n options.
Both source reduction and recycling options should be considered. Source reduction may
be accomplished through:
0 Good operating practices
0 Technology changes
0 Input material changes
0 Product changes
Recycling includes:
0 Use and reuse of waste
0 Reclamation
Smen and select options firjidaerstudy. This screening process is intended to select the
most promising options for full technical and economic feasibility study. Through either an
informal review or a quantitative decision-making process, options that appear marginal,
impractical or inferior are eliminated from consideration. Some of the criteria used in
screening options include impacts on product quality; employee safety; and environmental
impacts of the alternatives.

FEASIBILITY ANALYSIS
An option must be shown to be technically and economically feasible in order to merit
serious consideration for adoption at a facility. A technical evaluation determines whether
a proposed option will work in a specific application. Both process and equipment changes
need to be assessed for their overall effexts on waste quantity, toxicity, aud product quality.
Also, any n w products developed through process and/or raw material changes need to be
tested for market acceptance.
An economic evaluation is carried out using standard measuTes of profitability, such as
payback period, return on imrestment, and net present value. As in any project, the cost
elements of a waste " k a t i o n project can be broken down into capital costs and
economic costs. Savings and changes in revenue also need to be considered.
IMPLEMENTATION
An option that passes both technical and economic feasibility reviews should then be
implemented at a facility. It is then up to the WMOA team, with management support, to
continue the process of tracking wastes and identifling opportunities for waste " h a t i o n
throughout a facility and by way of periodic reassessments. Either such ongoing

5
reassessments or an initial investigation of waste " h t i o n opportunities can be
conducted using this manual.
While it is difficult to quantify the future liability reduction that could result from
implementing an option, this is an important factor in choosing a particular strategy, and
should at least be discussed qualitatively in the evaluation.

References

CDHS. 1987. Waste Audit Study: Printed Circuit Board Manufact-rers. Report prepared
by Planning Research Corporation, San Jose, California, for the California Department of
Health Services, Alternative Technology Section, Toxic Substances Control Division, April
1987.
USEPA 1988. Waste Minimization OpportunitV Rrresmtent Manual Hazardous Waste
Engineering Research Laboratory (currently Risk Reduction Research Laboratory),
Cincinnati, Ohio, EPA/625/7-88/003.

6
 Section Two
PRINTED CIRCUIT BOARD
MANUFACTURING INDUSTRY PROFILE

Manufacturers of printed circuit boards (PCboards) are included as part of the electronic
component manufacturing industry. As of 1984, the printed circuit board manufacturing
industryconsisted of a total of 585 plants with an employment of 435,100 (NCO 1984).
Industry personnel indicate that the actual number of plants may be closer to 1,OOO
(USEPA 1986). c

The industry consists of large facilities totally dedicated to printed Circuit boards, large
and small captive facilities, small job shops doing contract work, and specialty shops doing
low-volume and high-volume precision work. Approximately half of the printed circuit
boards produced are by independent producers, while the rest are by captive producers.
Over 65 percent of all printed circuit board manufactdq sites are located in the
northeastern states and in California (NCO 1984).
The printed circuit board manufacturers visited as a part of this study are all considered
small. Generally, these small companies can be characterized as those that produce up to
3,000 to 5,000 square feet of processed board each month and require approximately 8,000
to 10,OOO square feet of building space. Large companies can be characterized as those that
produce or 30,000 to 50,OOO square feet per month.

Products and Their Use

Printed circuit boards can be classified into three basic types: single-sided, double-sided, and
multi-layered. The total board production in 1983 was 14 million square meters (PEI1983).
Double-sided boards accounted for about 55 percent of the printed circuit boards produced,
while multi-layer board production made up 26 percent (PEI 1983). The type of board
produced depends on the spatial and density requirement, and on the complexity of the
circuitq. Printed circuit boards are used mainly in the production of business machines,
computers, communication equipment, control equipment and home entertainment
equipment.

7
 Raw Materials

The following- raw materials are used by the industry (Stintson 1983, PEI 1983, Cox and
Mills 1985):

Board materials glass-epoxy, ceramics, plastic, phenolic paper, copper foil

Cleaners sulfuric acid, fluoroacetic acid, hydrofluoric acid, sodium hydroxide,
potassium hydroxide, trichloroethylene, 1,1,1-trichloroethane,
perchloroethylene, methylene chloride
Etchants sulfuric and chromic acid, ammonium persulfate, hydrogen peroxide,
cupric chloride, ferric chloride, alkaline ammonia

cata&sts stannous chloride, palladium chloride

Electroless copper copper sulfate, sodium carbonate, sodium gluconate, Rochelle salts,
bath sodium hydroxide, formaldehyde

Screen silk, polyester, stainless steel

Screen ink composed of oil, cellulose, asphalt, vinyl or other resins
Resists polyvinyl cinnamate, allyl ester, resins, isoprenoid resins, methacrylate
derivatives, poly-olefin sulfones

Sensitizers thiazoline compounds, azido compounds, nitro compounds, nitro

aniline derivatives, anthones, quinones, diphenyls, azides, xanthone,
benzil
Resist solvents ortho-xylene, meta-xylene, para-xylene, toluene, benzene,
chlorobenzene, cellosolve and cellosolve acetate, butyl acetate, 1,1,1-
trichoroethane, acetone, methyl ethyl ketone, methyl isobutyl ketone

Electroplating baths copper pyrophosphate solution, acidcopper sulfate solution, acid-

copper fluoroborate solution, tin-lead, gold, and nickel plating
solutions

Resist stripping sulfuric-dichromate, ammoniacal hydrogen peroxide,

solutions metachloroperbenzoic acid, methylene chloride, methyl alcohol,
furfural, phenol, ketones, chlorinated hydrocarbons, non-chlorinated
organic solvents, sodium hydroxide

8
 Process Description

Printed circuit (PC) boards, also called printed Wiring boards, consist of patterns of
conductive material formed onto a non-conductive base. The conductor is generally copper,
although aluminum, chrome, nickel and other metals have been used. The metal is fixed
to the base through use of adhesives, pressure/heat bonding, and sometimes screws. Base
materials include pressed epoxy paper, phenolic, epoxy glass resins, teflon-glass, and many
other materials.
There are three common types of PC boards: single-sided, double-sided, and multilayer.
Single sided boards are those with a conductive pattern on one side only. Double-sided
boards have conductive patterns on both faces. Multilayer boards consist of alternating
layers of conductor and insulating material, bonded together. The conductors are connected
together through plated-through holes.
Production methods that have been employed by the industry to produce printed circuit
boards iqclude subtractive processes and additive processes. Detailed descriptions of the
pnwxss sequences are given elsewhere (Yapoujian 1982, Coombs 1979, USEPA 1979, PEI
1983). Because of the limitations of the additive processes, the subtractive method is
currently the one most widely used, although it can produce more metal wastes than
additive methods. The subtractive method is briefly described below for double-sided
panels. Most of the operations shown are atso common to the production of other types
of printed circuit boards such as single-sided or multi-layered boards.
The conventional subtractive process employs a copper-clad laminate board composed of
a non-conductive material such as glass epoxy or plastic. Printed circuit board
manufacturers often purchase panels of board that are already copper dad from
independent laminators. The manufacturing process consists of the following operations:
-
W p m M The process sequence begins with a baking step to ensure that the
copper laminated boards are completely cured. Holes for the components are then drilled
through stacks of boards or panels, often four layers thick. The drilling operation results
in burrs being formed on one or both sides of the panel. These are removed mechanically
through sanding and deburring steps to create an wen surface.
-
E&c~roZesscopperp&zcing The smooth copper-clad board is subsequently electroless- plated
with copper to provide a conducting layer through the drilled holes for circuit connections
between the copper-clad board surfaces. Electroless plating involves the catalytic reduction
of a metallic ion in an aqueous solution containing a reducing agent, resulting in deposition
without the use of external electrical energy. The circuit board must be thoroughly cleaned
before it is electroless-plated.
Materia typically used in the operation, that appear in the waste streams, include:

o Abrasive and alkaline cleaning compounds

9
o Ammonium persulfate or peroxide-sulfuric acid etchant, for removing the oxidation
inhibitor in the copper foil
o Tin and palladium catalyst
o Cupric chloride or copper sulfate plating bath containing formaldehyde or
hypophosphate reducing agents, and amino acid, carboxylic acid, hydroxy acid, or
amine chelating agents
0 Rinsewaters
-
Patrent printing and m u s h Electroless plating with copper provides a uniform but very
thin conducting layer over the entire surface, that has little mechanical strength. It is used
initially, to deposit metal on non-conducting surfaces such as inside the holes.
Electroplating is required to build up the thickness and strength of the conducting layers.
Pattern plating is one method of biding up conducting layer thickness, and is the most
common type of subtractive process used. It consists of electroplating only the insides of
thk holes and the circuit patterns. A layer of resist is deposited, using screen or
photolithography techniques, in areas where electroplated conducting material is not
desired. The layer of resist on these areas is later stripped off, and the copper foil is etched
away.
The area where the resist has not been deposited constitutes the circuit pattern These
areas receive several electrodeposition layers. Tin/lead plating is one of the layers
deposited, and it functions as another resist layer, allowing copper foil in the non-circuit
areas to be etched away without the circuit pattern being damaged. The circuit pattern
then receives final electroplated layers of metals such as nickel and gold. Chemicals used
for these processes include:
o Photo-sensitive inks (for silk screening circuit patterns onto the board)
o Resists composed of epoxy vinyl polymers, halogenated aromatics, methacrylates,
and/or polyolefin sulfones
o Alkaline cleaners to remove residuals from pattern developing operations
o Acid dips to remove oxides
o Electroplating solutions typically containing copper, tin/lead, nickel and gold salts,
cyanide, sulfate, pyrophosphate, and fluoroborate compounds
o Etchants such as peroxide-sulfuric acid, sodium persulfate, ferric or cupric chloride,
and chromic acid
PaneZplating methods of PC board manufacture differ from pattern plating in that the
entire board is electroplated with copper, including the holes, after which the non-circuit
areas are etched away. Because of the additional copper deposited, panel plating can
produce more metal wastes.

10
T h e $ @ additive method differs from the subtractive method described above in that it
involves deposition of plating material onto the board only in the pattern dictated by the
circuit, and does not require removal of the metal already deposited. The process begins
with an unclad board. Plating resist is then applied onto the board in non-circuit areas.
Electroless copper is subsequently deposited to build up the circuit to the desired thickness.
Since the board doesn’t initially have any copper in non-circuit areas, a copper etching step
is thus eliminated, as well as much of the metal wastes.

Waste Description

There are five principal operations common to the production of all types of printed circuit
boards. These include:
o Cleaning and surface preparation
o Catalyst application and electroless plating
o Pattern pMting and masking
o Electroplating
o Etching
Typical waste streams generated €tom the unit operations in the printed circuit board
man- industry are listed in Table 21.
Airborne particulates generated from the cutting, sanding, routing, drillin& beveling, and
slotting operations during board preparations are normally collected and separated using
baghow and cyclone separators. They are then disposed of, along with other solid wastes
at landfills.
Acid fumes €tom acid cleaning and organic vapors from vapor degrcasing are usually not
contaminated with other materials, and therefore are often kept separate for subsequent
treatment. The acid fume air stream is collected via chemicai fume hoods and sent to a
scrubber where it is removed with water. The scrubbed air then passes on to the
atmosphere, and the absorbing solution is neutralhd along with other acidic waste streams.
Similarly, organic fumes are often collected and passed through a bed of activated carbon.
The carbon bed is then regenerated with steam. In many cz1scs,the regenerative vapor is
condensed and the condensate containing water and solvents is drummed and sent for
offsite treatments. In a few cases, the regenerative vapor is combusted in a closed fumes
burner.
The spent acid and alkaline solutions from the cleaning steps are either contract hauled for
off-site disposal or neutralized and discharged to the sewer. Spent chlorinated organic
solvents are often gravity separated, and are recovered in-house or hauled away for
reclaiming.

11
 Table 2.1 Waste Streams from Printed Circuit Board Manufacturing

Waste Stream Waste Stream

Waste Source Description Composition

Cleaning/Surface preparation 1. Airborne particulates Board materials,

2. Acid fumes/organic vapors sanding materials,
3. Spent acid/alkaline solution metals, fluoride,
4. Spent halogenated solvents acids, halogenated
5. Waste rinse water solvents, alkali.

Cata1yst application/ 1. Spent electroless copper bath Acids, stannic

Electroless plating 2. Spent catalyst solution oxide, palladium,
3. Spent acid solution complexed metals,
4. Waste rinse water chelating agents.

Pattern printing/masking 1. Spent developing solution Vinyl polymers,

2. Spent resist removal solution chlorinated
3. Spent acid solution hydrocarbons, organic
4. Waste rinse water solvents, alkali.

Electroplating 1. Spent plating bath Copper, nickel, tin,

2. Waste rinse water tin/lead, gold,
fluoride, cyanide, sulfate.

Etching 1. Spent etchant Ammonia, chromium,

2. Waste rinse water copper, iron, acids.
The remaining majority of the wastes produced are liquid waste streams containing
suspended solids, metals, fluoride, phosphorus, cyanide, and chelating agents. Low pH
values often characterize the wastes due to acid cleaning operations. The liquid wastes
may be controlled using end-of-pipe treatment systems, or a combination of in-line
treatment and separate treatment of segregated waste streams. A traditional treatment
system for the wastes generated is often based on pH adjustment and the addition of
chemicals that will react with the soluble pollutants to precipitate out the dissolved
contaminants in a form such as metal hydroxide or sulfate. The solid particles are removed
as a wet sludge by filtration or flotation, and the water is discharged to the sewer. The
diluted sludge is usually thickened before dumping into landfills. Recent improvements in
in-line treatment technologies such as reverse osmosis, ion exchange, membrane filtration,
and advanced rinsing techniques increase the possibility for the recovery and reuse of water
and metallic resources.

References

Coombs, C.F. 1979. Printed C h i t Handbook 2nd ed. New York, N.Y.: McGraw-Hill Book
co.
Cox, D.S.,and A.R. Mills. 1985. Electronic chemicals: a growth market for the 80's. C k m .
Eng. Prog. 81(1): 11-15.
NCO. 1984. National Credit Office. Electmnk marketing directory. New York: National
Credit Office.
PEI. 1983. Pedco-Environmental, Inc. Industrial Prvcas Pmfles for Environmental Use.
Chapter 30. The Electronk Component Manufactruing Industy EPA-600-2-83433.
Cincinnati, Ohio. U.S. Environmental Protection Agency.
Rothschild, B.F., and Schwartz, M. 1988. Printed Circuit/Wiring Board Manufacture.
American Electroplaters and Surface Finishers Society.
Stintson, S.C. 1983. Chemicals for electronics: new growth in competitive field. Chem.
Eng. News. 61(30): 7-12.

USEPA. 1979. U.S. Environmental Protection Agency, Office of Water and Hazardous
Materials. Development Document for Existing Source Pretreatment Standards for the
Electroplating Point Source Category. EPA-440-1-79-003. Washington, D.C.: U.S.
Environmental Protection Agency.
-
USEPA 1986. Waste Minimization Issues and Options, Volume II. PB87-114369.
Prepared by Versar, Inc. and Jacobs Engineering Group Inc.
Yapoujian, F. 1982. Overview of printed circuit board technology. Met. Finish. 80: 21-5.

13
 Section Three
WASTE MINIMIZATION OPTIONS FOR PRINTED
CIRCUIT BOARD MANUFACTURERS

This section discusses recommended waste " h t i o n methods for printed circuit board
manufacturers. These methods come from accounts published in the open literature and
through industry contacts. The primary waste streams associated with manufacturing are
listed in Table 3.1 along with recommended control methods. Many control measures
associated with photoprocessing and cleaning wastes are not discussed in this report. The
reader is referred to the appropriate reference material for information regarding these
waste streams (USEPA 1989a, USEPA 1989b, USEPA 1986, CDHS 1986).
The waste " h a t i o n methods listed in Table 3.1 can be classified generally as source
reduction, or recycling. Source reduction can be achieved through material or product
substitution, process or equipment modification, or better operating practices. Recycling
can include recovery of part of the waste stream or reuse of all of it, and can be performed
on-site or off-site.
Better operating practices are procedural or institutional policies that result in a reduction
of waste. They include:
0 Waste stream segregation
o Personnelpractices
- Management initiatives
- Employee training
- Employee incentives

0
-Procedural measures
Documentation .
- Material handling and storage
-
- Material tracking and inventory control
Scheduling

14
 Table 3.1 Waste Minimization Methods for the Printed Circuit Board Industry

Operation Waste Minimization Method

PC Board Manufacture Product Substitution:

Surfacc mount technology
Injection molded substrate and additive plating
Cleaning and Surface Materials substitution:
Preparation use abrasives
Use non-chelated cleaners
Increase cffiaency of process:
m e n d bath life, improve rinse effiaency,
countercurrent cicaning

Recycle/reusc:
Rccyclc/reusc cleaners and rinses

Pattern Printing and Reduce hazardous nature of process:

Aqueous processable resist
Screen print;rg versus photolithography
Dry photoresist removal
Recycle/reusc:
Recycle/reusc photoresiSt Stripper

Electroplating and
..
-pro==
Electroless Plating MrEhrnical board production
MateriabJubditution:
Nonqanidebaths
Non-cyanide str#s relievers
Extend bath life: reduce drag-in
Proper rack d&gn/mahtenance, better
predeaning/riosina usc of demineralized
water as makeup, proper storage methods

.. .
Extend bath life: reduce drag-out
Mraunrze bath chemical concentration,
..
increase bath .
temperalure, usc wetting agents,
proper
ample e on rack, slow withdrawal and
computerizcd/automated systems,
recoverdrag-out,drainboards
Extend bath life: maintain bath solution quality
Monitor solution activity. Control temperature.
M a agitation. Continuous 6ltration/carbon
treatment.
Impurity removal
Continudonnextpage

15
 Table 3.1 Waste Minimization Methods for the Printed Circuit Board Industry
(continued)

Operation Waste Ibhi”

‘onMethod

Electroplating and Improve rinse efficiency:

Electroless Plating Cld-circuit rinses. Spray rinses. Fog nozzles.
(continued) Increased agitation. Countercurrent riming. Proper
q i p m e n t design/operatnon. Deionized water use.
RCCOVCX-y/fClW:
Segregate streams.
Reumr metal values
Eliminate proccslE
Differential plating
Materials substitutiox
Non-chclatcd etchants. Non-chrome etchants
Increase cff+cncy
Usc thinner copper cladding. Pattem vs. panel phhg
Additivt vk subtractiVt method.
Reuse/@:
Reuse/rccyde etchants
Wastewater Treatment Reduce hazvdous nature:
Atcrnativc treatmentchemicalsthat generatelesssludge
Usc of ion cxchaqc and activated carbon for recyding
wrstewpter

16
0 Loss prevention practices
- Spill prevention
- Preventive maintenance
- Emergency preparedness

0 Accounting practices
- Apportion waste management costs to departments that generate the waste
Better operating practices apply to all waste streams. In addition, specific better operating
practices that apply to certain waste streams are identified in the appropriate sections that
follow.

Product Substitution

While not under the control of most printed circuit board manufacturers, improvements in
the techniques used in the packaging of microchips can result in a decrease of waste
associated with printed circuit board manufacturing. Two new techniques include:
Increased use of SUrJace mount technology. Presently, the dual-in-line package (DIP)
accounts for 80% of all packaging of integrated circuits (Bowlby 1985). More efficient
packages, however, are being developed which utilize a relatively new method of attaching
packages to printed circuit boards. One important method is called surface mount
technology (SMT). The use of S M T instead of the conventional through-hole insertion
mounting allows for closer contact areas of chip leads, and therefore reduces the size of
printed circuit boards required for a given number of packages or DIPS. For a fixed
number of packages, the printed circuit board needs to be only 35 percent to 60 percent as
large as a printed circuit board designed for the old style package (Bowlby 1985). As the
metal area on which cleaning, plating and photoresist operations are performed is
decreased, the wastes associated with these operations can also be reduced. At present,
however, S M T uses considerably higher quantities of chlorofluorocarbons for degreasing
than through-hole mounting. CFC-113is one of the major degreasing agents in current use.
Because of the danger that some chlorofluorocarbons present to the atmospheric ozone
layer, the overall environmental risks of SMT must be carefully examined, and alternative
degreasing solvents identified, before replacing through-hole technology with SMT.
Use of hjection molded substrate and additiveplating. The development of high-temperature,
high-performance thermoplastics has introduced the use of injection molding into the
manufactwing of printed circuit boards. In this process, heated liquid polymer is injected
under high pressure into precision molds. Since the molded substrates are unclad, semi-
additive or fully additive plating is used to produce metalized conductor patterns
(Engelmaier and Frisch 1982). Injection molding, coupled with a fast-rate electrodeposition
(FRED)technique, such as that developed by Battelle (LWVM 1985), can be used to
manufacture complex three-dimensional printed circuit boards with possible reduction in
hazardous waste generation due to the elimination of spent toxic etchants.

17
 Cleaning and Surface Preparation

As mentioned in the introduction, the reader should refer to the appropriate reference
material (USEPA 1989, CDHS 1986) for information regarding the reduction of waste
associated with parts cleaning. Information is provided below on: abrasive cleaning; use of
non-chelated cleaning chemicals; extending bath life and improving rinse efficiency; use of
countercurrent cleaning arrangements; apd reuse/recycle of cleaning agents and rinse water.

USE ABRASIVE INSTEAD OF AQUEOUS CLEANING

Mechanical cleaning methods offer an alternative to aqueous techniques and generate less
hazardous waste; however, these methods can only be employed before electronic
components have been added to the boards. Abrasive blast cleaning uses plastic, ceramic,
or harder media such as aluminum oxide to remove oxidation layers, old plating, paint and
burrs from workpieces, and to create a smooth surface. The aim is to select a blast medium
that is harder than the layer to be stripped, but softer than the substrate, in order to
prevent damage to the part. Abrasives can also be used in Vibratory cleaning (in which
parts are immersed in a vibrating tank containing abrasive material and water), in tumbling
barrels, or applied Via a buffing wheel. More information on abrasive cleaning, particularly
tumbling barrels and vibratory cleaning, can be found in Durney (1984)and ASM (1987).

USE NON-CHELATED CLEANING CHEMICALS

The use of non-chelate process chemicals instead of chelated chemical baths can reduce
hazardous waste generation. Chelators are employed in chemical process baths to allow
metal ions to remain in solution beyond their normal solubility limit. This enhances
cleaning, metal etching, and selective electroless plating (Couture 1984). Once the chelating
compounds enter the waste stream, they inhibit the precipitation of metals, and additional
treatment chemicals must be used. These treatment chemicals end up in the sludge and
contribute to the volume of hazardous waste sludge.
Ferrous sulfate is a common reducing agent used to treat wastewaters that contain
chelators. The ferrous sulfate breaks down the complex ion structures to allow metals to
precipitate. However, the iron added to the treatment process also precipitates as a metal
hydroxide. Since enough ferrous sulfate is usually added to the wastewater to achieve an
iron to metal ratio of 81, a significant additional volume of sludge is generated (Couture
1984). One printed circuit board manufacturer visited during the audit study used ferrous
sulfate to break down chelators prior to metals precipitation. The iron present in the
resultant sludge contriiuted approximately 32 percent of the total dry weight of the sludge.
Common chelators used in printed circuit board manufacturing chemicals include
ferrocyanide, ethylenediaminetetraaceticacid (EDTA), phosphates, and ammonia (Foggia
1987). Chelating agents are commonly found in cleaning chemicals and etchants. Non-
chelate alkaline cleaners are available; however, laboratory tests have shown that some of
these products still have the ability to chelate metals (Couture 1984).

18
In addition to using non-chelated chemistries, the use of mild chelators can also reduce the
need for additional treatment of wastewaters. Mild chelators are less difficult to break
down. Therefore, metals can be precipitated out of solution during treatment without
using the volume of treatment chemicals that is often necessary with strong chelators. For
example, EDTA is a mild chelator that only requires lowering the pH to below 3.0to allow
metals to precipitate (Foggia 1987).
One disadvantage of using non-chelated process baths is that they usually require
continuous filtration to remove the solids that form in the bath. The costs of these filter
systems range from approximately $400 to $l,OOO for each tank using a non-chelated process
chemistry. These systems generally have a 1to 5 micron filter with a control pump that can
filter the tank contents once or twice each hour (Foggia 1987). In addition to the purchase
and setup costs, filter replacement and maintenance costs are incurred when this system is
used.

EXTEND BATH LIFE AND IMPROVE RINSE EFFICIENCY

This method applies to nearly any tank of processing solution used in the facility. See the
discussion of electroplating waste reduction methods for detailed information.

USE COUNTERCURRENT CLEANING ARRANGEMENT

A common hazardous waste stream generated by printed circuit board manufacturers is
waste nitric acid from the cleaning of electroplating workpiece racks. Typically, racks are
placed in a nitric acid bath to clean off the plated copper. When the copper content in the
bath gets too high to effectively clean the racks, the nitric acid is containerized for disposal.
Use of a cascade cleaning system can significantly reduce nitric acid waste generation.
During the audiy one small printed circuit board manufacturer who operated a five tank
plating rack cleaning line generated approximately 15 gallons of waste nitric acid in 6
months compared to another smaU company that used a single tank for cleaning racks and
generated approximately 60 gallons each month. Both companies operate similar size
process lines, and are considered dprinted circuit boatd manufacturers (both estimated
their printed circuit board production to be 3,000 square feet per month). Assuming that
waste disposal for the spent nitric acid is $50 per 55-gallon drum and the cost of technical
grade nitric acid is approximately $350per gallon, the differential operating costs are BO42
per year (excluding differences in labor-increased rack handling versus decreased waste
handling). The total cost of adding four additional tanks to the one-cleaning-tank line
would be $1620.

REUSE/RECYCLE OF CLEANING AGENTS

Peroxide/sulfuric acid solution is used as a mild etchant for cleaning copper and removing
oxides prior to plating. When the solution is brought off-line and cooled, the copper
c r y s t a l b s as copper sulfate. The supernatant can then be returned to the tank,
replenished with oxidizers, and reused. The copper sulfate crystals can be used as copper

19
crystallizes as copper sulfate. The supernatant can then be returned to the tank,
replenished with oxidizers, and reused. The copper sulfate crystals can be used as copper
electroplating bath makeup (Couture 1984). The practice is only advisable, however, if the
crystals are first dissolved into solution and treated with activated carbon to remove the
organics. Otherwise, the organics present in the crystals could ruin the plating bath.
In addition to recovering metals from the spent bath, spent acid can be regenerated by
means of ion exchange (Basta 1983). Eco-Tec Ltd., in Ontario, Canada, markets an acid
purification system that employs a proprietaq resin that recovers mineral acids. The metals
are recovered in a concentrated (but still dissolved) form. The concentrated metals can
then be recovered by electrolytic means.
Ion exchange is employed by Modine Manufacturing, in Trenton, Mo., to treat copper-
contaminated sulfuric acid/hydrogen peroxide solution which is used to brighten brass
(Basta 1983). Sodium phosphate salts, formed in nickel/copper electroless plating, can be
converted into useful hypophosphite salts by ion exchange resins activated with
hypophosphorous acid. The use of ion exchange resins for regeneration, however, suffers
from the disadvantage of generating additional wastes, such as spent resins and resin
regeneration solutions.

REUSE/RECYCLE OF RINSE WATER

After rinse-solutionsbecome too contamhated for their original rinse process, they may be
useful for other rinse processes. For example, rinses containing high levels of process
chemicals can be concentrated through evaporation and returned to the process baths as
makeup. Closed-circuit rinsing of this type can dramatically reduce the hazardous chemicals
content of the waste stream.
Effluent from a rinse system that follows an acid cleaning bath can be reused as influent
water to a rinse system following an alkaline cleaning bath. If both rinse systems require
the same flow rate, 50 percent less rinse water would be used to operate them. In addition,
using the effluent from the rinse solution that follows an acid cleaning process as the feed
to the rinse system that follows an alkaline cleaning process rinse system can actually
improve rinse efficiency for two reasons. First,the chemical diffusion process is accelerated
because the concentration of alkaline material at the interface between the drag-out film
and the surrounding water is reduced by the neutralization reaction. Second, the
neutralization reaction reduces the viscosity of the alkaline drag-out film (USEPA 1982a).
One successful example of this technique was observed in a nickel plating process in which
the same rinse water stream was used for the rinses following the alkaline cleaning, acid
dip, and nickel plating tanks. Instead of having three different rinse streams, only one
stream was used, greatly reducing the overall rinse water requirements (USEPA 1983).
Adding acid rinses to alkaline rinses can result in problems, however. Unwanted
precipitation of metal hydroxides onto the cleaned workpieces can occur in some instances.
Before being implemented, a combined acid and alkaline rinse system must be thoroughly
investigated in the particular environment of the process line.
Other rinse water recycling opportunities are also available. Acid cleaning rinse water
effluent can be used as rinse water for workpieces that have gone through a mild acid etch

20
rinse efficiencies. The water from fume scrubbers has been shown to be practical for
rinsing in certain cases (Cheremisinoff,Peina, and Ciancia 1976). Spent cooling water or
steam condensate can also be employed for rinsing if technically permissible and
economically justified Printed circuit board manufacturers should evaluate the variouS
rinse water requirements for their process lines and configure rinse system arrangements
that take advantage of rinse water reuse opportunities.

Pattern Printing and Masking

Many of the source reduction techniques discllssed for the photoprocessing industry
(USEPA 1988) apply to this phase of printed circuit board manufacturing. G t e d below
are several techniques that deal with circuit board fabrication.
Use aqueorrs pmcessable resirt M e a d of solvent processable &. Aqueous processable
resists (such as the Du Pont Riston photopolymer film resists which allow for the use of
caustic and carbonates as developer and stripper) can be used in place of solvent
processable resists whenever possible to eliminate the generation of toxic spent solvents.
Hundred of facilities are now employing these aqueous processable films for the
manufacturing of printed circuit boards.
Use screm-printing M e d of photolithogmphv to eliminate the need for developem. Screen-
printing has conventionally been used only to produce printed circuit boards which require
very low resolution in the width and spacing of the circuit lines, Some companies have
recently developed screen-printing techniques which can provide higher degrees of
resolution. For example, General Electric has developed a method for screen-printing down
to 0.01 inch resolution which can be used to manufacture printed circuit boards for
appliances (Greene 1985). The majority of printed circuit board manufacturers, however,
are still using the photolithographic technique for printed circuit boards having circuitry
finer than 12 mil lines and spaces.
Use A s b dy phot- rmtovrJ method to cltninazc the L(SC of organic mist str@p%
solutions. Although this method is increasiqiy popular in the senimnductot industIy, its
use has not been reported by printed circuit board manufhcturers, probably because the
printed circuit board resists are usually much thicker than the conesponding semiconductor
resist layers.
€ky&e/rezLuphotomktstr@per. Photoresist stripper is used to remove photoresist material
from the board This photoresist is a polymer material that remains in the stripper tank
in small flakes that slowly settle to the bottom. When the sludge formed at the bottom
of the stripper tank builds up, the flakes begin to adhere to circuit boards and the stripper
solution is considered spent. Increased use of the solution can be achieved by decanting
and filtering the stripper solution out of the tank into a clean tank. This is feasible because
the stripper usually becomes spent as a result of the residue buildup long before it becomes
spent as a result of a decrease in chemical strength.

21
 Electroplating and Electroless Plating
Source reduction methods associated with electroplating and electroless plating center
around eliminating the need for the operation, reducing the hazardous nature of the
materials used, extending process bath life, improving rinse efficiency, and
recovering/reusing spent materials.

ELIMINATE NEED FOR OPERATION

Use mechanical boardprodudion methak/'systems. For facilities that produce low-volume
prototype circuit boards, mechanical board production systems are available which bypass
all operations involving chemicals. Circuit boards are designed on a computer and the
pattern is then etched by means of a mechanical stylus on a copper-clad board. While this
system is not viable for producing boards in large quantities, it is highly suited for use in
development/research settings.

REDUCE HAZARDOUS MATERL4X.S USED

Use non-cymtide plating baths.
Use non-cyanide strcsr relievers. In the case of electroless copper plating, water soluble
cyanide compounds of many metals are typically added to eliminate or " k the
internal stress of the deposit. It has been found that polysiloxanes are also effective stress
relievers (Durney 1984). By substituting polysiloxanes for cyanides, the hazardous nature
of the spent bath solution can be reduced.

EXTEND PROCESS BATH LIFE

Process baths may contain high concentrations of heavy metals, cyanides, solvents and other
toxic constituents. They are not discarded frequently but rather are used for long periods
of time. Nevertheless, they do require periodic replacement due to impurity build-up
resulting from drag-in or decomposition and the loss of solution constituents by drag-out.
When a solution is contaminated or exhausted, the resulting waste solution may contain
high concentrations of toxic compounds and require extensive treatment. The source
control methods available for extending process bath life include reducing or removing
impurities formed in the bath, reducing the loss of solution (-+ut) from the bath, and
maintaining bath solution quality.

Reduce Impurities
Impurities come from five sources: racks, anodes, drag-in, water or chemical make-up, and
air. The buildup of impurities can be limited by the following techniques:
R v p Mck da&n and " a m e . Corrosion and salt buildup deposits on the rack
elements contaminate solutions if they chip away or fall into the solution. Proper design

22
and regular cleaning will "ize this form of contamination. Fluorocarbon coatings
applied to the racks have also been found to be effective ( h e 1985). Such a coating
lowers drag-out as well since less bath solution remains in the corroded crevices on the
racks or barrels.
Use purer culodes cmd anocie b q . During the plating process, metal from the anode
dissolves in the plating solution and deposits on the cathode (workpiece). Some of the
impurities contained in the original anode matrix stay behind in the plating solution,
eventually accumulating to prohibitive levels. Thus, the use of purer metal for the anode
extends the plating solution life. Anode bags can also be used to prevent pieces of
decomposed anodes from falling into the tank.
Drag-in reduction by better riming. Efficient rinsing of the workpiece between different
process baths reduces thedrag-in of plating solution into the next process bath.
Use of debnkd or d M & d make-up water. To compensate for evaporation, water is
required for makeup of plating solutions. Using deionized or distilled water is preferred
over tap water, since tap water may have a high mineral or solids content, which can lead
to impurity buildup.
hperstomge of chemic&. Roper storage of the process solutions can also reduce waste
generation. Usually, the process solutions are stored as. a two-part solution and are mixed
when a batch is needed, Prolonged storage of mixed solutions may allow some chemical
reactions to occur that could generate contaminants that reduce bath Me. In electroless
copper plating, if formaldehyde (a reducing agent) is stored with a hydroxide, the hydroxide
can cause the formaldehyde to break down into formic acid and methyl alcohol. Thus, it
is better to only store non-reactive mixtures of materials or to store each item separately.
Once you have reduced impurity buildup in the bath, you need to concentrate on reducing
solution losses through drag out.
Reduce Drag-out
Several factors contribute to drag-out. These include workpiece size and shape, viscoSity
and chemical concentration, surface tension, and temperature (USEPA, 1982a). By
reducing the volume of drag-out that enters the rinse water system, valuable proass
chemicals can be saved and sludge generation can be reduced More discussion of the
impact on sludge generation due to drag-out is presented under "alternative treatment
methods."
During the course of this study, it was found that most printed circuit board manufacturers
have little idea of the volume of drag-out their various process lines generate. Roass
chemical suppliers assess drag-out using a standard rate of 10 to 15 ml/@ of circuit board
(Foggia 1987). However, this standard rate docs not take into account the various process
bath operating parameters that can be used or the effects of various workpiece rack
withdrawal methods. Nevertheless, this standard drag-out rate is a good starting point for
determining the impact of drag-out on waste generation. Factors affecting drag-out are
described in Table 32.

23
 Table 32 Factors That Increase the Amount of Drag-out

High surface tension

Highly viscous plating solution
Larger workpiece size
Faster workpiece withdrawal
Shorter drainage time
Orientation of workpiece during removal so that drainage is reduced

Generally, drag-out " i z a t i o n techniques include:

Minimire bath chemiccrlconcentmtion. Controllingthe chemical concentration of the process
bath can reduce drag-out losses in two ways. Reducing toxic chemical concentrations in a
process solution reduces the quantity of chemicals and the toxicity in any dragout that
occus. Also, greater concentrations of some of the chemicals in a solution increase the
viscoSity (USEPA 1982a). As a result, the film that adheres to the workpiece as it is
removed from the process bath is thicker and will not drain back into the process bath as
quickly. Therefore the volume of drag-out loss is increased and a higher chemical
concentration in the drag-out is created. In electroless copper plating for printed circuit
board manufacture, dilute solutions have been tried successflluy by many manufacturers
(USEPA 1981).
Chemical product manufacturers may recommend an operating concentration that is higher
than necessary to perform the job. A printed circuit board manufacturer should determine
the lowest process bath concentration that will provide adequate product quality. This can
be done by mixing a new process bath at a slightly lower concentration than normal. As
fresh process baths are mixed the chemical concentration can continue to be reduced until
product quality begins to be aEcctcd. At this point, the manufacturer can identify the
process bath that provides adequate product quality at the lowest possible chemical
concentration.
Fresh process baths can often be operated at lower concentrations than used baths.
Makeup chemicals can be added to the used bath to gradually increase the concentration.
This procedure allows newer baths to be operated at lower concentrations and older baths
to be main- for longer periods of time before requiring dispod.
Increare bath operrrting tcmperrrturc in ordet to bwer viscosiiy. Increased temperature lowers
both the viscosity and surface tension of the sotution, thus reducing drag-out. The resulting
higher evaporation rate may also inhibit the carbon dioxide absorption rate, slowing down
the carbonate formation in cyanide solutions. Unfortunately, this benefit may be lost due
to the formation of carbonate by the breakdown of cyanide at elevated temperatures.
Additional disadvantages of this option would include higher energy costs, higher chance
for contamination due to increased make up requirement, and increased need for air
pollution control due to the higher evaporation rate.

24
Use wetting agents. Wetting agents can be added to a process bath to reduce the surface
tension of a solution and, as a result, reduce the volume of drag-out loss. The use of
wetting agents in the metal finishing industry has been estimated to reduce drag-out loss
by as much as 50 percent (USEPA, 1982a). However, most printed circuit board
manufacturers prefer using process chemicals that are free of wetting agents because they
can create foaming problems in the process baths. Although the process bath chemistries
of a printed circuit board manufacturing line may not always allow the addition of wetting
agents, their use should be evaluated.
Position workpkcepmperfy on the plating ruck. When a workpiece is lifted out of a plating
solution on a rack, some of the excess solution on its surface (drag-out) will drop back into
the bath. Proper positioning of the workpiece on a rack will facilitate maximum drainage
of drag-out back into the bath. The position of any object which will "izc the carry-
over of drag-out is best determined exprimentally, although .the following guidelines were
found to be effective (USEPA 1981):
- Orient the surface as close to vertical as possible.
- Fhck with the longer dimension of the workpiece horizontal.
- Rack with the lower edge tilted from the horizontal so that the runoff is from a
corner rather than an entire edge.
-
While positioning of the printed circuit bokd offers little variability the boards are
-
generally placed upright in a rack a board that is tilted at an angle, allowing it to drip-
downbnto an adjacent board instead of directly into the bath, may lead to increased drag-
out loss. The operator must ensure that the workpiece is positioned properly to prevent
unnecessary drag-out loss.
Wuhdraw boarcls slow& and allow ampk dmhqe. The faster an item is removed from the
process bath, the thicker the film on the workpiece surface and the greater the drag-out
volume will be. The effect is so significant that it is believed that most of the time allowed
for withdrawal and drainage of a rack should be used for withdrawal only (USEPA,1982a).
However, since workpieces are usually removed from a process bath manually, it is difficult
to control the speed at which they are withdrawn. Nevertheless, supervisors and
management should emphasize to process line operators that workpieces should be
withdrawn slowly.
Workpiece drainage once the part is removed from the bath also depends on the operator.
The time allowed for drainage can be inadequate if the operator is rushed to remove the
workpiece rack &om the process bath area and place it in the rinse tank. However,
installation of a bar or rail above the process ta& and the requirement that all workpieces
be hung from it for at least 10 seconds, may help ensure that adequate drainage time is
provided prior to rinsing. Printed circuit board manufacturers express concem that
increasing workpiece rack removal and drainage time will allow for chemical oxidation on
the board. Although some process steps m y not be amenable to these drag-out reduction
techniques, increased workpiece rack removal and drainage time can stiU be effective for
many process steps.
Use comput&ed/hutomated contrvl systems. Computerized process-control systems can be
used for board handling and process bath monitoring to prevent unexpected decomposition

25
of the plating bath. Since the use of a computerized control system not only requires a
large capital outlay for initial installation but also increases the demand for skilled
operations and maintenance personnel, only very large companies which manufacture both
printed circuit boards and other electronic components are incorporating this change in
their manufacturing process. For example, Hewlett-Packard in Sunnyvale, California
reported its successful use of computers for plating operations on printed circuit boards
(Anonymous 1983).
Recover dmg-out j b m baths. In addition to reducing the volume of drag-out that is lost
from the process bath, printed circuit board manufacturers can recover drag-out losses by
using drain boards and close-circuit rinsing. Drain boards are used to capture process
chemicals that drip from the workpiece rack as it is moved from the process bath to the
rinse system. The board is mounted at an angle that allows the chemical solution to drain
back into the process bath. Drainage boards should be installed if there is space between
the process bath tank and the rinse tank where chemical solutions would otherwise drip
onto the floor and enter the wastewater system when the floor is washed down
Another method of reducing drag-out loss is to recover it for reuse in the process tank
The most common way to do this is through use of drag-out tanks (also called still or dead
rinses). Drag-out tanks can be used to capture process chemicals that adhere to the circuit
board and return them to the process bath. Drag-out tanks are essentially rinse tanks that
operate without a continuous flow of feed water. Chemical concentrations in these tanks
increase as-moreworkpieces are passed through. Since there is no feed water flow to cause
rinse water turbulence, air agitation is often used to enhance ribsing After a period of
time, the concentration of the drag-out tank solution will increase to the point where it can
be used to replenish the process bath. Drag-out tanks are primarily used with proccss baths
that operate at an elevated temperature. The high temperature causes evaporative water
losses that can be compensated for by adding the drag-out tank solution back to the proccss
bath. If the evaporation rate of the process tank is not high enough, evaporators can be
installed on it. They can also be installed on the drag-out tank, to further concentrate the
rinse solution to be used as makeup.
Closed-circuit rinse systems can employ continuously flowing rinses as well as static rinses
that are periodically added as makeup to the process bath. Often, two or more rinses are
used in a couuter-current arrangement such as is illustrated in Figure 3.1. In this
arrangement, the work is first rinsed in the least clean rinse bath, and then in successively
cleaner baths. Spent rinse water from the cleanest bath gets added to the next cleanest
bath, and eventually to the process bath itself. The use of closcd-circuit rinses can be very
significant in reducing the amount of heavy metal wastes and other hazardous chemicals in
the waste streams (Meltzer 1989).
The printed circuit board manufactwing companies visited during this study all used drag-
out tanks, but none of them used the drag-out solution to replenish the process bath.
Instead, these companies dumped the solutions into their treatment systems. They are
reluctant to reusc the drag-out solution because of fear of contarnination Since a drag-
out tank can often be used for more than a week between dumps and because the tank is
uncovered, operators are concemed that someone could improperly use the tank to rinse
a workpiece; the contaminated drag-out solution would then contaminate the process bath
when used to replenish the process tank Also, some proccss bath chemistries are such that

26
 FIGURE 3.1
MULTIPLE CLOSED CIRCUIT
COUNTERFLOW RINSE SYSTEM

P a t h of work

N
4

Process
Rinse

P a t h of Makeup Water
adding drag-out solution back into the process tank would spoil the bath. For example,
electroless copper baths contain chemicals that break down in a diluted drag-out solution.
If the solution is then added back to the process tank, these breakdown chemicals could
adversely affect the electroless copper bath (Stone 1987). If the potential for contamination
or deterioration of the drag-out solution can be overcome, however, drag-out tanks can be
used on copper and tin/lead electroplating lines.
Maintain Bath Solution Quality
Once the amount of drag-in and drag-out from the process bath has been reduced, attention
should focus on ways to maintain the bath at optimum operating conditions. Many facilities
rely on drag-out from the bath as the way of purging impurities that would otherwise build
up and interfere with operation. From an environmental viewpoint, this is a poor technique
since it does not directly address the issue of impurity formation, results in high losses of
valuable process solutions, and moves the problem downstream to the treatment unit.
The following methods are noted as ways of increasing bath life and " h h g the impact
on existing treatment systems:
Monitot solution odiviry. By frequent monitoring of the bath activity and regular
replenishment of reagents or stabilizers, bath life can be prolonged ( h e y 1984). These
reagents or stabilizers differ from process to process, stabilizers such as 2-
mercaptobenzothiozole and methanol are found effective in electroless copper plating used
for man- printed circuit boards. The addition of stabilizers can sometimes
decrease the deposition rate, but can still be economical in the long run.
Contrd bath t t ? q " . Good control of the bath temperature is important from the
viewpoint of performance predictability and is another method of prolonging bath life.
Many surface treatment operations use tanks with immersed cooling/heating coils. As the
salts precipitate and form scales on the coils the heat transfer is impeded and temperature
control becomes increasingly difficult. Heat transfer efficiency can be maintained by
periodic cleaning of the coils or by using jacketed tanks instead of coils.
Usc "tLcal @uti&. Many process baths employ air agitation to increase and maintain
the efficiency of the bath. This practice can introduce contaminants into the bath. The two
principal const- are oil from the compressor or blower and carbon dioxide. The oil
will lead to undue organic loading while the carbon dioxide can lead to carbonate buildup
in alkaline baths. A viable alternative is to use mechanical agitation.
usc CO?lth#w ~~~ t"ent. To avoid surface roughness in the plating
resulting in high reject rates, baths should be continuously filtered to remove impurities.
The flow rate to the filter should be as high as practical to prevent particles from settling
on the parts. Since filters can seldom remove solids at the same rate that they are
introduced by way of drag-in, filtering should be performed even when the bath is not in
use. Install as coarst a filter as practical, since coarse filters allow higher loading before
requiring replacement, allow for higher flow rates and hence greater tank tum-overs, and
require less seMcing. When organic buildup is a problem, use of carbon filter cartridges
is appropriate.

28
Regenemte solution t h u g h impwity removal. There are methods that have been successfully
used to increase the longevity of plating solutions through impurity removal. More efficient
filtering of a plating solution has kept levels of impurities low and extended solution life
(McRae 1985). Metallic salts can sometimes be removed by temporarily lowering the bath
temperature so as to form solid crystals. In the case of electroless nickel plating, the
sodium sulfate that forms can be crystallized by lowering the bath temperature to 41-50°F
( h e y 1984). The crystals can then be removed by filtration.

IMPROVE RINSE EFFICIENCY

Most hazardous waste from a printed circuit board manufacturing plant comes from the
treatment of wastewater generated by the rinsing operations that follow cleaning, plating,
stripping, and etching processes (Couture 1984). Three basic strategies are used to provide
adequate rinsing between various process bath operations. These are (1) turbulence
between the workpiece and the rinse water, (2) sufficient contact time between the
workpiece and the rinse water, and (3) sufficient volume of water during contact time to
reduce the concentration of chemicals rinsed off the workpiece surface (USEPA 1982a).
The third strategy is most commonly employed by printed circuit board manufacturers.
Reliance on this strategy c a w s printed circuit board manufacturers to use significantly
more rinse water than is actually required (couture 1984).
Many techniques are available that can improve the efficiency of a rinsing system and
reduck the volume of rinse water used. These techniques include:
Use of &sed-cimd &sa. As mentioned above, instailing one or more closed-circuit still
or counter-flow rinsing tanks immediately after a plating bath allows for metal recovery and
lowered rinse water requirements. The contents of the rinses are used to replenish the
upstream plating bath. As previously mentioned, a major problem with the use of still
rinses is that while they are commonly installed at many plants, operators typically do not
return the solution to the bath due to concern over solution contamination.
Generally, the use of a drag-out or still rinse tank can reduce both rinse water usage and
chemical losses by 50 percent or more (USEPA 1982a). Assuming that a chemical bath
processes 3,000 square feet of board each month, the total volume of process bath drag-
out loss each month would be 12 gallons, with a drag-out rate of 15 ml/square foot of
board. If the rinse system following the process bath operates at a flow rate of 10 gpm for
a total of two hours each day, water usage would be 24,OOO gallons per month based on 20
work days per month. A 50 percent reduction in process bath chemical loss and water
usage achieved by installing a drag-out tank would reduce process bath losses by six gallons
per month and water usage by 12,OOO gallons.
Use s p 9 rinsing. Although spray rinsing uses between onecighth and one-fourth the
volume of water that a dip rinse uses (USEPA1982a), it is not always applicable to printed
circuit board manufactwing because the spray rinse may not reach many parts of the circuit
board. However, spray rinsing can be performed along with immersion rinsing. This
technique uses a spray rinse as the first rinse step after the workpieces are removed from
the process tank. The spray rinsing typically takes place while the parts are draining above

29
the process tank. This permits lower water flows in the rinse tank because spray rinsing
removes much of the drag-out before the workpiece is submerged into the dip rinse tank.
Usefbg IuIIzles. A variation on the spray n o d e is the fog nozzle. A fog nozzle employs
water and air pressure to produce a fine mist. Much less water is needed than with a
conventional spray nozzle. It is more often posu'ble to use a fog n o d e rather than a spray
nozzle directly over a heated plating bath to rinse the workpiece, becaw less water is
added to the process bath using the fog nozzle.
Inctease *e of agitrltion. Agitation between the workpiece and the rinse water can be
performed either by moving the workpiece rack in the water or by creating turbulence in
the rinse water. Since most printed circuit board manufacturing plants operate hand rack
lines, operators could easily move workpieces manually by agitating the hand rack.
However, the effectiveness of this system depends on cooperation from the operator.
Agitating the rinse tank by using forced air or water is the most efficient method for
creating effective turbulence during rinse operations. "his is achieved by pumping either
air or water into the immersion rinse tank rinsing operations. Air agitation provides the
best rinsing because the air bubbles create the best turbulence for removing the chemical
process solution from the workpiece surface (USEPA 1982a). This type of agitation can
be performed by pumping filtered air into the bottom of the tank through a pipe distriiutor
(air sparger). Great care should be exercised, however, to ensure that the air is free of dust
or oil so as not to contaminate the boards being cleaned. Asfllming the plant has a
sufficient q k t i t y of compressed air onsite that is rcadily available, the cost of installing
air spargers is $100 to $125 per tank for a 50 gallon capacity tanlr.
Use counter aurtnt rinrC stages. Multiple stage rinse tanks increase contact time between
the workpiece and the rinse solution and thereby improve rinsing efficiency compared to
a single-stage rinse. If these multiple tanks are set up in series as a counter current rinse
system, water usage can also be reduced Mawfacturers do not need to rely on large
volumes of rinse water to prevent chemical concentrations in the rinse solution from
becoming excessive. Multiple rinse tanks can be used to provide s a c i e n t rinsing while
[email protected] reducing the volume of rinse water used. A multistage counter current rinsing
system can use up to 90 percent less rinse water than a conventional single-stage rinse
system (Couture 1984).
The effectiveness of a multistage system in reducing rinse water usage is illustrated in the
following example. A plant operates a proass line where approximately 1.0 gallon of drag-
out per hour results from a chemical process bath. This proass bath is followed by a
single-stage rinse tank. "he proctss requires a dilution rate of lo00 to 1 to maintain
acceptable rinsing in the tank. Therefore, the flow rate through the rinse tank is lo00
gal/hr. If a double stage counter current rinse system were used, a rinse water flow rate
of only 30 to 35 gal/hr would be needed If a triple stage counter current rinse system
were used, only 8 to 12 gal/hr would be required (Watson 1973).
A multistage counter current rinse system allows greater contact time between the
workpiece and the rinse water, greater diffusion of process chemicals into the rinse solution,
and more rinse water to come into contact with the workpiece. The disadvantage of
multistage counter current rinsing is that more process steps are required and additional

30
equipment and work space are needed. A counter current triple-rinse system requires the
installation of two additional rinse tanks and the associated piping. The cost of such a
system is typically about $l,O00 ("erran 1987).
h p r equipment d & p / o ~ n . Printed circuit board manufacturers can use excessive
amounts of rinse water if their water pipes are oversized or if the water is left on even
when the rinse tanks are not being used. Rinse water control devices can be installed to
increase the efficiency of a rinse water system. Flow restrictors limit the volume of rinse
water flowing through a rinse system. These are used to maintain a constant flow of fresh
water into the system once the optimal flow rate has been determined. Also, since most
small and medium-sized printed circuit board manufacturers operate batch process lines in
which rinse systems are manually turned on and off throughout the day, pressure activated
flow control devices, such as foot pedal activated valves, can be helpful for assuring that the
water is not left on after the rinse operation is completed. If the water lines are over-sized
at a plant, pressure-reducing valves can be installed upgradient of the rinse water influent
lines. This is also helpful for controlling water use in the rioSe tanks.
A conductivity probe or pH meter can also be employed to control fresh water flow through
a rinse system. A conductivity/pH cell is used to measure the level of dissolved solids or
hydrogen ions in the rinse solutio^^ When this level reaches a pre-set minimum, the
conductivity probe activates a valve that shuts off the flow of fresh water into the rinse
system. When the concentration builds to the pre-set maximum level, the probe again
activates the valve, which then opens to continue the flow of fresh water. "his control
equipment is especially valuable to the printed circuit board manufacturhg industry. A pH
meter equipped with the necessary control valves and solenoids could cost approximately
$700 per tank (Ryan 1987).

Use &W&ed wattr fw &wing.Natural contaminants found in water used for production
processes can contriiute to the volume of waste generated. During treatment of
wastewater, these natural contaminants precipitate as carbonates and phosphates and
contribute to the volume of sludge (USEPA 1982b). The extent to which these
cont a " t s increase sludge volume depends on the hardness of the rinse water. In
addition to the direct effect on sludge volume, the presence of natural contaminants in the
water may reduce rinse water efficiency and the ability to reuse/rccycle rinse water.
Therefore, rinse systems may require more water than would be necessary if the water were
pretreated.
The cost of deionizing process water depends on the condition of the water supplied to the
plant. The cost is dependent on the concentration of total dissolved solids (TDS) in the
water (Prothro 1987). For example, in the Santa Clara Valley a plant supplied with surface
water spcnds approximately 2 cents per gallon to pretreat process water. A plant supplied
with ground water spends clw to 4 cents per gallon. A t y p i d deionizing system that
includes two Winch mixed bed deionizers costs approximately S2,O00 for equipment and
installation and treats up to 5,OOO gallons a day (Prothro 1987).

31
RECOVERY/REUSE OF SPENT MATERIALS
Recycling and resource recovery includes technologies that use waste as raw material for
another process or that recover valuable materials from a waste stream before the waste
is disposed of. Opportunities for both the direct use of waste materials and the recovery
of materials from a waste stream are available to the printed circuit board manufacturing
industry. Many of the spent chemical process baths and much of the rinse water can be
reused for other plant processes. Also, process chemicals can be recovered from rinse
waters, and valuable metals such as copper can be recovered from waste streams.
A printed circuit board manufacturer must understand the chemical properties of its waste
stream before it can assess the potential for reusing the waste raw material. Although the
chemical properties of a process bath or rinse water solution may become unacceptable for
their original use, these waste materials can still be employed in other applications. Printed
circuit board manufacturers should therefore evaluate waste streams for properties that
make them useful as well as properties that render them waste.
Segregate Streams to Promote Recycling

In a typical facility, the mixing of different rinse streams is not uncommon, and in the
recent past, rinse waters and spent baths were frequently mixed and treated together. By
segregating various rinses, their reuse or recycling can be promoted. Metal reclamation by
electrolysis from various streams is made easier if they are not mixed.
Recover Meal Values &om Bath Rinses

In the past, copper and other metal recovery from printed circuit board manufactwing has
not proven to be economical. However, effluent pretreatment regulations have made the
cost of treatment an economic factor. Also, the cost of management of sludges containing
heavy metals has increased significantly because of the i n c r d regulatory requirements
placed on the handling and dispaal of hazardous wastes. As a result, board manufacturers
m a y now find it economical to recover copper and other metals and metal salts lost due to
drag-out from process chemical baths.
Recovered metal can be used in two ways: (1) recovered metal salts can be recirculated
back into process baths, and (2) recovered elemental metal can be sold to a metals
reclaimer. Some of the technologies that are being su- used to recover metals and
metal salts include:
Evaporrztion. Waste rinse water is evaporated by heating, leaving behind a concentrated
solution. The equipment used includes single or multiple effect evaporators. Vapor
recompression applications have also been reported (Seaburg and Bacchetti 1982). In
evaporative methods, the solution is concentrated until its metal concentration is equal to
that of the plating bath, and then this solution is reused. Using this method, 90.99 percent
efficient metal recoveries can be achieved (Clark 1984). Depending on the design, the
evaporated water vapor can either be condensed and re-used as rinse water, or it can be
vented off into the atmosphere (Campbell and Glenn 1982). Evaporation is the best
established of all the metal recovery techniques used in electroplating. Although it is the
most energy intensive recovery technique, its simplicity and reliability make it an attractive

32
 a

option for metal recovery. In order for evaporation to be economical, multiple counter
current rinse tanks or spray/fog rinsing should be used to the amount of rinse
water being processed (MDEM 1984). Apart from the energy cost, a distinct disadvantage
of evaporative techniques is that the concentrates may also contain the calcium and
magnesium salts originally present in the rinse water. Adding them to the plating solution
may result in its more rapid deterioration. This problem is alleviated in situations where
rinse water is de-ionized or softened prior to use.
Reverse m o s i r . Reverse osmosis is also used to recover drag-out that can be returned to
the process bath. The reverse osmosis process employs a semipermeable membrane that
permits only certain components to pass through. When pressure is applied, these
components pass through the membrane and concentrate in the recovered solution.
Although the technology is designed to recover drag-out, some materials (such as boric
acid) can not be fully recovered and are, therefore, returned to the process bath at a lower
concentration. Also, reverse osmosis is a delicate process that is limited by the ability of
the membranes to withstand pH extremes and long-term pressure. Reverse osmosis systems
are commonly used to recover nickel plating solutions and regenerate rinse waters.
Liqrrid membnmes. Liquid membranes are composed of polymeric materials loaded with
an ion-carrYing solution (Basta 1983). Liquid membranes have been used to remove
chromium from rinse waters and spent etching baths. Chromium in the form of dichromate
is drawn across the membrane, forming a tertiary amine metal complex. This complex is
then broken down on the other side of the membrane with sodium hydroxide solution.
Ion erdwrgc. Ion exchange concentrates metals from a dilute rinse stream onto a resin
material. As rinse water is passed through a bcd containing the resin, the resin substitutes
ions for inorganics in the rinse water. The metals are then recovered from the resin by
cleaning it with an acid or alkaline solution. Ion exchange units can be used effectively on
dilute waste streams and are less delicate than reverse osmosis systems. However, the
equipment is complex and requires careful operating and maintenance practices.
EZectmlytic recovery. This method recovers only the metallic content of rinse water. The
process requires a cathode and an anode placcd in the rinse solution. As current passes
from the anode to the cathode,metallic ions deposit on the cathode. This type of system
generates a solid metallic slab that can be reclaimed or used as an anode in an
electroplating tank. Electrolytic systems c ~ u lrecovct 90 to 95 percent of the available
metals. Electrolytic recovery has been suuxssfuUy used to recover gold, silver, tin, copper,
zinc, solder alloy, and cadmium (Campbell and Glenn 1982). One great advantage of the
electrolytic method over other metal recovery techniques is that it recovers only the plating
metal, not the impurities, &om the waste rinse water. Electrolytic metal recovery is most
efficient on concentrated solutions. For solutions with less than 100 mg/l of the metal ion,
low current efficiencies limit proctss effectiveness.
EZeddidysis. In electrodialysis, an electric current and selective membranes are used to
separate the positive and negative ions from a solution into two streams. This is
accomplished by feeding a solution through a series of alternating cation and anion selective
membranes, through which a current is passed. Electrodialysis is used mainly to
concentrate dilute solutions of salts or metal ions. Electrodialysis can remove nickel,
copper, cyanide, chromium, iron and zinc from waste rinse water (MDEM 1984, Kohl and

33
Triplett 1984). This technology has not been used as widely in the electroplating industry
as have other metal recovery techniques (Campbell and Glenn 1982, Kohl and Triplett
1984).

High szujbce area e k t m ~ e k c t m r e j i n h g This

. method operates on the same principle
as electrolytic recovery. The metal-containing solution is pumped through, and plates out
on, a carbon fiber cathode (Mitchell 1984). To recover the metals, the carbon fiber cathode
assembly is removed and placed in an electroreher, which reverses the current, removes
the metals from the carbon fibers, and allows them to plate onto a stainless steel starter
sheet. These systems can be used to recover a wide variety of metals and to regenerate
many types of solutions.
The cost associated with implementing a chemical recovery technology depends on a
number of variables: the size of the unit, the space available, equipment rearrangement,
production down time, and the specific application. Table 33 contains cost data for several
chemical recovery units from electroplating plants. Although the specific materials
recovered may be different for a printed circuit board manufacturing plant, the basic
technology is transferable between these two industries. While the equipment costs shown
can be applied to board manufacturing, the annual savings depend on the wastewater metal
concentrations and volume of wastewater treated by the recovery systems.
One limiting factor for a small printed circuit board manufaddng company is the volume
and chemical concentration of its various rinse water efnuents. The examples in Table 33
are all designed to recover a specific material from a single waste generating source (for
example, nickel salts from a nickel plating line). To achieve savings in chemicals and sludge
handling that create a justifiable payback, the waste stream must be mly concentrated
and continuous. Each company must evaluate its OWXI conditions to determine the
feasibility of material recovery. The information nectssacy to determine the feasibility
includes waste stream generation rates and chemical concentrations, and the value of
materials to be recovered.

34
 TABLE 3 3

Costs of Technology for Material Recovery

Materials Equipment
Technology Recovered costsa

Evaporation Unit: Rinse water $47,000

Capacity of Chromic acid
approximately
20 gph.
Reverse Osmosis Nickel salt $27,000
Unit: Capacity of Plating chemicals
approximately 100 gph.
Ion Exchange Unit: Rinse water $38,000
Capacity of Chromic acid
approximately 20 gph.
Electrolytic Unit: Rinse water
Capacity of Copper
approximately 15 gph.

'Equipment costs include equipment purchase, installation,and materials.

Source: USEPA 1987.

35
 Etching

Most of the source control techniques listed under plating and electroplating apply as well
to waste produced by etching. Special source reduction methods associated with etching
operations are discussed below.
Use differential plating instead of the conventional electroless plating process. If the
concentrations of certain stabilizers in the electroless copper bath are controlled, copper
deposits three to five times faster on the through-hole walls than on the copper cladded
surface (Poskanzer and Davis 1982). This reduces the amount of copper that must be
subsequently etched away in the subtractive method. The use of differential electroless
plating has not been reported by printed circuit board manufacturers, and it may require
sigdicant developmental work before commercialization is possible.
Use non-chelated etchants. Non-chelate mild etchants such as sodium persulfate and
hydrogen peroxide/sulfuric acid can be used to replace ammonium persulfate chelate
etchant.
Use thinner copper foil to clad the laminated board. This change reduces the amount of
copper which must be etched, and thus reduces the amount of waste generated from the
etching process. Printed circuit board manufacturers are switching to boards cladded with
thinner copper as their starting materials.
Use pattem instead of panel plm'ng. Since panel plating consists of copper plating the entire
board area, while pattern plating requires copper electroplating only the holes and Circuitry,
the use of the latter technique reduces the amount of non-circuit copper which must be
subsequently etched away. This practice can therefore reduce the amount of waste
generated from the etching operation. The switch from panel to pattern plating has been
made by a large number of printed circuit board manufacturers. Customers demanding
applications for a uniform cross section of circuitry in computer and microwave printed
circuit boards, however, may dictate the use of panel plating to provide highly uniform
copper thickness.
Use additive instead of subtmctive method. This change eliminates the copper etching step,
and therefore eliminates the generation of substantial volumes of spent etchant as well as
reducing the amount of metal hydroxide sludges generated. Although the subtractive
method is still the most widely used in the manufacturing of printed circuit boards, the
additive method is gaining in popularity since it results in less waste and lower
manufacturing costs (Brush 1983). A noted drawback to the additive method, however, is
the requirement for solvent processable instead of aqueous processable photoresists.
Furthermore, the spent additive plating bath often contains heavily complexed copper which
may result in waste treatment problems.
Use non-chrome etchants. Whenever possible, ferric chloride or ammonium persulfate
solution should be used instead of chromic-sulfuric acid etchants. Non-chromium etching
solution has reportedly been used by printed circuit board manufacturers in an effort to
reduce the toxicity of the waste generated.

36
RecycZe spent etchants. Use of an electrolytic diaphragm cell for regeneratingspent chromic
acid from etching operations has been reported (=SI 1981). The electrolytic cell oxidizes
trivalent chromium to hexavalent chromium and removes contaminants. The quality of the
regenerated etchant has been reported to be equal to or better than fresh etchant.
In one such application, extensively tested at the U.S.Bureau of Mines in Rolla, Mo.,
copper etching solution was regenerated and metallic copper recovered at the same time.
Recovery was accomplished by depositing the copper onto the cathode of the electrolytic
diaphragm cell (Basta 1983).
Another recycling example involves the regeneration of cupric chloride, used as a strong
etchant for producing circuit patterns on circuit board base material. The etchant becomes
spent as the copper etched from the base material reduces the cupric chloride (CuCl,) to
cuprous chloride (CUCI). This spent etchant can be regenerated by oxidizing to cuprous
chloride through direct chlorination (Couture 1984).

Wastewater Treatment

Process chemical loss due to drag-out is the most significant source of chemicals entering
wastewater. Treatment of this wastewater is a major source of hazardous waste in PC
board operation because of the resulting sludge. The volume of sludge generated is
proportional to the level of contamination in the spent rinse water (Couture 1984). The
major ways of reducing waste associated with treatment (in addition to those associated with
drag-out reduction, reduction in the use of rinse water, and use of deionized water) include
waste stream segregation, use of alternative treatment chemicals, and alternative treatment
technologies.

WASTE STREAM SEGREGATION

Segregating waste streams can improve the efficiency of a waste treatment system. An
example of waste stream segregation is the separation of chelating agent waste streams from
nonchelating agent streams. Since most small printed circuit board manufacturing plants
use treatment systems that can be operated as a batch process, they can implement waste
stream segregation and selective treatment with minimal impact on the production system.
The main drawback to this alternative is usually the limited storage capacity for the
segregated waste streams.
If waste streams containing chelating agents are treated in a batch process separately from
other waste streams, the use of ferrous sulfate to break down the chelators can be
minimized. Since the iron in ferrous sulfate will precipitate out in the sludge, reduction in
its use will also reduce the volume of sludge generated.
By isolating cyanide-containing waste streams from waste streams containing iron or
complexing agents, the formation of cyanide complexes is avoided, and treatment made

37
much easier (Dowd 1985). Segregation of wastewater streams containing different metals
also allows for metals recovery or reuse. For example, by treating nickel-plating wastewater
separately from other waste streams, a nickel hydroxide sludge is produced which can be
reused to produce fresh nickel plating solutions.
Another waste alternative is to separate noncontact cooling water from industrial wastes.
It is likely that this cooling water can bypass the treatment system and be discharged
directly to the sewer because it does not come in contact with process chemicals. This
practice can reduce wastewater volume and, as a result, reduce the amount of treatment
chemicals used. Also, acidic or alkaline waste streams that do not contain metals can
simply be neutralized prior to discharge; therefore, if they are segregated from other wastes
that require metal removal, the volume of treatment chemicals can be reduced. This, in
turn, will reduce the volume of sludge generated.

USE OF ALTERNATIVE WASTE TREATMENT CHEMICALS

The selection of chemicals used in the waste treatment process can affect the volume of
sludge generated. This selection should, therefore, consider a chemical's effect on sludge
generation rates. For example, lime and caustic soda are two common chemicals used for
neutralization and precipitation. Although lime costs less per unit of neutralizing capacity,
it can produce as much as ten times more dry weight of sludge than caustic soda (USEPA
1982b).
Alum and ferric chloride are commonly employed as coagulating agents to improve floc
formation. When used, they convert to hydroxides and contribute to the volume of sludge.
Polyelectrolyte conditioners can also be used as coagulants, but they are more expensive
than inorganic coagulants. However, polyelectrolytes do not add to the quantity of sludge
and may actually be less expensive overall when considering waste handling costs. One
printed circuit board manufacturer visited during this study recently switched from alum to
a polyelectrolyte coagulant in order to reduce sludge generation. Specific data on the
volume of sludge reduction are not yet available from the company.
The selection of alternative treatment chemicals depends on specific waste characteristics
and removal efficiency needs for a particular treatment facility. The potential use of
various treatment chemicals should be discussed with chemical manufacturers'
representatives and experimented with to determine their effectiveness.

'ALTERNATIVEWASTEWATER TREATMENT ION EXCHANGE -

Ion exchange systems can be employed to treat the entire wastestream prior to discharge
to the publicly-owned treatment works. When used for this purpose, the ion exchange units
do not recover process chemicals for reuse because all sources of wastewater are mixed
prior to treatment. The units can be used to recycle rinse water, however, by utilizing an
activated carbon treatment system following ion exchange treatment. The costs for
operating an ion exchange system depend on the volume and chemical concentrations of
the wastewater.

38
One plant visited recently installed an ion exchange system to replace its conventional
precipitation/clarification treatment system. The ion exchange unit is designed for a
treatment capacity of 12 to 14 gallons per minute. The unit does not generate any sludge
but does generate approximately two 55-gallon drums of spent ion exchange resin each
month. The old treatment system generated approximately four to six 55-gallon drums of
sludge per month.
The ion exchange system was purchased and installed for approximately $16,000 and
required one week of production down time to install. The system costs $1,000 per month
to operate, including material purchases and waste disposal, compared to $1,500 per month
for the old system. The new system also requires less labor to maintain it. The payback
on investment for the new system is estimated to be 3.3 years.

References
AESI. 1981. American Electroplateis Society, Inc. Conferenceon Advanced Pollution C o w l
for the Metd Finishing Industry (3rd) held at Orlando Hyatt House, Kissimmee, Florida on
April 14-16, 1980. EPA-600-2/81-028. Cincinnati, Ohio: U.S. Environmental Protection
Agency.
Anonymous. 1983. California-style circuit manufacturing using computerization. P h . Surf:
Finish. 70 26-9.
ASM. 1987. Metals Handbook,Ninth Edition, Volume 5: Surfcrce Cletmhg, Finkhing, and
Coating. American society for Metals. Metals Park, Ohio.
Basanese. J. 1987. West General Associates, persod communication with T. Adkisson,
Planning Research Corporation (February 1987).
Basta, N. 1983. Total metal recycle is metal finishers’ goal. Chemical Engineering. August
8, 1983. pp. 16-19.
BCL, 1976. Battelle Columbus Lab. Assessment of Industrial Hazardous Waste Practices:
Electroplating and Metal Finishing Industries Job Shops. EPA-53O-SW-136C. Washington,
D.C.: U.S. Environmental Protection Agency.
Bowlby, R. 1985. The DIP may take its final bows! IEEE Spectnun June. 1985. pp. 37-
42.
Brush, P.N. 1983. Fast track for printed circuit boards. prod Finish November 1983, pp.
84-5.

Campbell, M.E, and W.M. Glenn, 1982. Proven Prop From PoUution Prevenhn Toronto,
Canada: The Pollution Probe Foundation,

39
CDHS. 1986. Guide to Solvent Waste Reduction Alternatives. Final report prepared by
ICF Consulting Associates, Inc., for Alternative Technology and Policy Development
Section, Toxic Substances Control Division, California Department of Health Services.
October 1986.
Cheremisinoff, P.N., AJ. Peina, and J. Ciancia. 1976. I d Wmtes. 22(6):314.
Clark, R., ed. 1984. Massachusetts Hazardous Waste Source Reduction. Conference
Proceedings, October 17, 1984. Boston, Mass.: Massachusetts Department of
Environmental Management.
Cook, T.M., M.L Cubbage, and LJ.Fister. 1984. Draining process solutions from sheets,
baskets, pipes, threads and fins. Metal Finishing (7): 33.
Couture, S.D.1984. Source Reduction in the Printed Circuit Industry. Proceedings - the
Second Annual Hazardous Materials Management Conference, Philadelphia, Pennsylvania,
June 5-7, 1984.
Dowd, P. 1985. Conserving water and segregating waste streams. Plat. Surf: Finish. 72(5):
104-8.
h e y , LJ.,ed. 1984.- Ekctroplating Engineering Handbook 4th ed. New York, N.Y.: Van
Nostrand Reinhold Co. .
Engelmaier, W., and D.C. Frisch. 1982. Injection molding shapes new dimensions for
boards. Electronia. December 15. pp. 155-158.
Engles, KO., and J.T. Hamby. 1983. Computerized controller for electroplating printed
wiring boards. Met. Finish 81: 95-100.
Foggia, M. 1987. Shipley Company, Inc., personal .communication with T. Adkisson,
Planning Research Corporation (January 21, 1987).
Greene, R., ed. 1985. CE Alert, New Technology. Chem. Eng. March 4. pp. 85.
Gunderson, R., and H. Holden. 1983. CAM techniques improve circuit board production.
ControL Eng. 30: 141-2.
Kohl,J., and B. Triplett. 1984. Mhnaging and Minimiring Hazardous Waste Metal Sludges.
North Carolina State University.
Lane, C. 1985. Fluorocarbon coating eliminates corrosion of acid bath racks. Chem.
Process. 48( 10): 72.

Lyman, J. 1984. Surface mounting alters the printed circuit board scene. Electronics.
February 9, 1984.

40
LWVM. 1985. Waste Reduction -- The Untold Story. Proceeding of a seminar at the
National Academy of Sciences Conference Center on June 19-21,1985. Wood Hole, Mass.:
The League of Women Voters of Massachusetts.
Mathews, J.E. 1980. Industrial reuse and recycle of wastewater: literature review. Robert
S. Kerr Environmental Research Lab. EPA-600-2-80.183. Ada, Okla: US.Environmental
Protection Agency.
McRae, G.F. 1985. In-process waste reduction: part 1. Pht. Surf: Finirh. 72(6): 14.
MDEM. 1984. Massachusetts Hazardous Waste Source Reduction: Metallic Waste Session.
Conference proceedings May 23, 1984. Boston, Mass.: Massachusetts Department of
Environmental Management.
Meltzer, M.P. 1989. Reducing Environmental Risk: Source Reduction for the Electroplating
Industry. Doctoral Dissertation, School of Public Health, University of California, Los
Angeles, CA.
Mitchel, G.D. 1984. A Unique Method for the Removal and Recovery of Heavy Metals
From the Rinse Waters in the Metal Plating and Electronic Interconnection Industries.
Proceedings - Massachusetts Hazardous Waste Source Reduction, Clinton, Massachusetts.
Olsen, AE. 1973. Upgrading Metal Finishing Facilities to Reduce Pollution. Oxy Metal
Finishing Corp., EPA-625-3-73-002, Washington, D.C.: U.S. Environmental Protection
Agency.
Poskanzer, A.M. 1983. Plating printed circuit substrates: circuit topics. Plat. Surf: Finish
70: 10.
Poskanzer, A.M., and S.C. Davis. 1982. An efficient electroless plating system for printed
circuitry. Plat. St@ Finirh. 69: 95-7.
Prothro, J. 1987. Culligan Industrial Water Treatment, personal communication with T.
Adkisson, Planning Research Corporation (March 16, 1987).
Ryan, W.M. 1987. William M.Ryan Company, personal communication with T.Adkisson,
Planning Research Corporation (January 14, 1987).
Seaburg, J L , and J.A. Bacchetti. 1982. Chemical Processing 45(12): 30-31.
Stone, P. 1987. Shipley Company, Inc., personal communication with T. Adkisson, Planning
Research Corporation (February 24, 1987).
Terran, A. 1987. Advanced Process Machinery, personal communication with T. Adkisson,
Planning Research Corporation (January 14, 1987).
USEPA. 1981. U.S.Environmental Protection Agency, Industrial Environmental Research
Lab. Changes for Metal Finishers. Cincinnati, Ohio.

41
USEPA. 1982a. Control and Treatment Technology for the Metal Finishing Industry-In-
plant Changes. EPAX 8606-0089.
USEPA. 1982b. Environmental Pollution Control Alternatives: Sludge Handling,
Dewatering, and Disposal Alternatives for the Metal Finishing Industry. EPA 625/5-82/018.
USEPA. 1983. U.S.Environmental Protection Agency, Office of Water Regulations and
Standards. Development Document for Effluent Limitation Guidelines and Standards for
the Metal Finishing Point Source Category. EPA40-1-83-091. Washington, D.C.
USEPA. 1986. Waste Minimization - Issues and Options, vol II. PB 87-114369. Prepared
by Versar, Inc. and Jacobs Engineering Group Inc.
-
USEPA. 1987. Environmental Pollution Control Alternatives Reducing Water Pollution
Control Costs in the Electroplating Industry. September 1987. EPA 62!5/5-85/016.
USEPA. 1989a. Waste Minimization in Metal Parts Cleaning Operations. In preparation
by Jacobs Engineering Group Inc. for the U.S. Environmental Protection Agency.
USEPA. 1989b. Guide to Waste Minimization in the Commercial Printing Industry. In
preparation by Jacobs Engineering Group Inc. for the U.S. Environmental Protection
Agency.
Versar, Inc. 1984. Technical Assessment of Treatment Alternatives for Wastes Containing
Metals and/or Cyanides. Contract no. 68-03-3149, finaldraft report for U.S. Environmental
Protection Agency. Springfield, Va.: Versar, hc.
Watson, M. R. 1973. Pollution Control in Metal Finishing. Noyes Data Corporation, Park
Ridge, New Jersey.
Wynschenk, J. 1983. Electroless copper plating chemistry and maintenance. Plat Surf:
Finish. 70:28-9.

42
 ~ ~ ~

Section Four

GUIDELINES FOR USING THE WASTE

MINIMIZATION ASSESSMENT WORKSHEETS

Waste " h a t i o n assessments were conducted at several printed circuit board

manufacturing plants in California. The assessments were used to develop the waste
"ion questionnaire and worksheets that are provided in the following section.
A comprehensive waste " h a t i o n assessment includes a planning and organizational ,
step, an assessment step that includes gathering background data and information, a
feasibility study on specific waste " h a t i o n options, and an implementation phase.

Conducting Your Own Assessment

The worksheets provided in this section are intended to assist printed circuit board
manufacturers in systematically evaluating waste gencrating processes and in identifying
waste " h i o n opportuuities. These worksheets include only the assessment phase of
the procedure described in the Warte Mintniration o p p o r t u n i r ~ M M m u r a LFor a
full description of waste " h a t i o n assessment procedures, refer to the EPA Manual.

Table 4.1 lists the worksheets that are provided in this section.

43
 Table 4.1 List of Waste Minimization Assessment Worksheets

Number Title Description

1. Waste Sources Typical wastes generated at

printed circuit board manufacturing plants.

2A. Waste Minimization: Questionnaire on general handling

Material Handling tcchniques for raw material handling.

2B.
.. .
Waste Mu”tion: QuestioMaire on procedures used
Material Handling for bulk liquid handling.

2c. Waste Minimiition: Q u e ~ t i o ~ a i on

r c procedures used
Material Handling for handling drums, containers and packages.
3. Option Generation: Waste minimiition options for
Material Handling material handling operations.

4. Waste Minimization: QwstioMaire on material and

Material and Process Substitution process substitutions.

5. Option Generatim Waste “ h t i o n options for

Material and Process Substitution material and process substitution.

6A. Waste Minimiition: Questionnaire extending process bath

Process Modification life by redudng &%-in and drag-out.

6B & 6C. Waste Minimization! Questionnaire 011: 1) extending bath life

Process Modification by avoiding decomposition and impurity removal;
and 2) improving rinse efficiency.
7. Option Generation: Procws modification waste ‘onoptions.
Process Modification

8. Waste Minimilation: Questionnaire on use of good

Good Operating Practices operating practices.

9. OptionGenCratim Waste “ktboptions for

Good Operating Practices good operating practices.

1OA. waste Mini” ’ n: Segregation, QueJtionnaire on opportunities for

Reuse, Recovety and Treatment segregation and reuse of wastes.

10B. Waste Minimization: Segregation, Questionnaire on opporhlnities

Reuse, Recovery and Treatment for recovery and treatment of wastes.

44
 I

Firm Waste Mlnlmlzatlon Assessment Prepared By

Site Checked By
Date Proj. No. Sheet- of - Page - of -

WORKSHEET
WASTE SOURCES
T

~~ ~~

Significance at Plant
Waste Source: Matertal Handling
Law I Medium I High
Off-spec materials
Obsolete raw materials
Spills & leaks (liquids)
_ _ _ ~ ~

Spills (powders)
Empty container cleaning
i
Container disposal (metal)
~~~ ~ ~

Container disposal (papew)

PipelineAank drainage

Evaporative bsses I I I
Contaminatedwipes and gbves
Other

Board Scrap
Waste Source Procos8 0p.ratlons
I
Board Cleaners
Catalysts
L

Electroless Plating Baths

Photoresist
c Developers
Copper Plating Baths
TiNLead Plate
Stripping Solutions
Etching Solutions
NickeVGold Electroplate
Refb w Oil
Rinsing
Equipment Cleaning
Other

45
E
 I

Firm Waste Mlnlmlzatkm Assessment Prepared B~

Sile Checked By
Date Proj. No. Sheet- of - Page - of -

WORKSHEET I WASTE MINIMIZATION: I

2A I Material Handling I

A. GENERAL HANDLING TECHNIQUES

Does the plant accept samples from chemical suppliers? 0 yes On0
Do unused samples become waste? 0 yes On0
Are suppliers required to take back unused samples they provide? 0 yes On0
Are all raw materials tested for quality before being accepted from suppliers? 0 yes On0

Describe safeguards to prevent the use of materials that may generate off-spec product:

Is obdete raw material returnedto the supplier? 0 yes On0

Is inventory used in first-in first-out order? 0 yes On0
Is the inventory system computerized? 0 yes On0
Does the current inventory control system adequately prevent waste generation? 0 yes On0

What informationdoes the system track?

Is there a formal personneltraining program on raw material handling, spill prevention,

proper storage techniques, and waste handling procedures? 0 yes On0
Does the program include informationon the safe handling of the types of drums, containers
and padcages received? 0 yes 0no
How often is training given and by whom?

Describe spill containment used in material storage area:

46
Firm Waste Mlnlmlzatlon Assessment Prepared B~
Site Checked By
Date Proj. No. Sheet - of - Page - of -

WORKSHEET

2B

B. BULK LIQUIDS HANDLING

What safeguards are in place to prevent spills and avoid ground contamination during the filling of storage tanks?
High level shutdowrValarms 0 Secondary containment 0
Flow totalizers with cutoff 0 Other D
Describe the system:

Are air emissions from solvent storage tanks controlled by means of:
Conservation vents 0 yes On0
Nitrogen blanketing 0 yes On0
Adsorber/Absorber/Condenser 0 yes On0
Other vapor loss control sytem 0 yes On0
Describe the system:

Are all storage tanks routinely monitored for leaks? 0 yes On0
Describe procedure and monitoring frequency for above-gmWaulted tanks:

Underground tanks:

How are the liquids in these tanks dispensed to the users? (Le., in small containers or hard piped.)

What measures are employed to prevent the spillage of liquids being dispensed?

When a spill of liquid occurs in the facility, what dry cleanup methods are employed (e.g., wet or dry)? Also discuss the
way in which the resultingwastes are handled:

~ _ _

Would different cleaning methods allow for direct reuse or recycling of the waste? (explain):
 Firm Waste Mlnlmlzatlon Assessment Prepared BY
Site Checked By
Date Proj. No. Sheet- of - Page - of -

WORKSHEET I WASTE MINIMIZATION: 1

2c I Material Handling 1
C. DRUMS, CONTAINERS, AND PACKAGES

Are drums, packages, and containers inspected for damage before being accepted? 0 yes 0 no
Are employees trained in ways to safely handle the types of drums & packages received? 0 yes 0 no
Are they properly trained in handling of spilled raw materials? 0 yes 0 no
Are stored items protected from damage, contamination, or exposure to rain, snow, sun & heat? 0 yes 0 no

Describe handling procedures for damaged items:

Does the layout of the faciliy result in heavy traffic through the raw material storage area? 0 yes On0
(Heavy traffic increases the potential for contaminating raw materials with dirt or dust
and for causing spilled materials to become dispersed throughout the facility.)
Can traffic through the storage area be reduced? 0 yes 0 no

To reduce the generation of empty bags & packages, dust from from dry material handling and
c.
liquid waste due to cleaning of empty raw material drums, has the facility attempted to:
Purchase hazardous materials in preweighed containers to avoid the need for weighing? 0 yes On0
Use reuseablelrecyclable drums with liners instead of paper bags? 0 yes 0 no
Use larger containers or bulk delivery systems that can be retumed to supplier for cleaning?0 yes 0 no

Discuss the results of these attempts:

._

Are all empty bags, packages, and containers that contained hazardous materials segregated
from those that contained non-hazardous wastes? 0 yes On0
Are containers properly "cleaned" (per EPA methods)priorto disposal? 0 yes On0

I.
Describe the method currently used to dispose of this waste:
 Firm Waste Mlnlmlzatlon Assessment prepared BY
Site Proc. UniVOper. Checked By
Date Proj. No. Sheet- of - Page __ of -

WORKSHEET
I OPTION GENERATION: I
3
~~ ~ ~ ~

Meeting Format (e.g., bralnstormlng, nominal group technlque)

Meeting Coordinator
Meeting Partlclpants

Suggested Waste Mlnlmlzatlon Optlons Currently Ratlonale/Remarks on Optlon

Done ym?
A. General Handllng T e c h n l q w
~~

Quality Control Chedc

Return Obsolete Material to Supplier
Minimize Inventory
~ _ _ _ ~

Computerize Inventory
Formal Training

B. Bulk Llqulds Handllng

High Level ShutdowWAIarm

~~~
Fkw Totalizers with Cutoff
~
I I
Secondary Containment
Air Emission Control
Leak Monitoring I I
c
Spilled Material Reuse
~
I I
Cleanup Methods to Promote RecycPng

C. Dr", Contalnen, a d Packages

.-
Raw Material Inspection
Proper StorageMandling
Preweighed Containers
Reusable Drums
Bulk Delivery
Waste Segregation

~~ ~~

49
 I

;irm Waste Minimization A s s e s m " Prepared By

Site Checked By
3ate Proj. No. Sheet- of - Page __ of -

WORKSHEET I WASTE MINIMIZATION: 1

4 I Material and Process
Substitution I
To reduce the use of hazardous chemicals and the generation of hazardous wastes, has the
facility attempted to use any of the following methods:

CLEANING AND SURFACE PREPARATION

Abrasives instead of solvents, acids, or alkalis? 0 yes On0

Nonchelated cleaning compounds? 0 yes On0

PATTERN PRINTING AND MASKING

Aqueous processable resist instead of solvent based resist? 0 yes on0

Screen printing instead of photolithography to eliminate need for developers? 0 yes On0
Dry photoresist removal methods to avoid use of organic strippers? 0 yes On0

ELECTROPLATING AND ELECTROLESS PLATING

Mechanicalboard production methods? 0 yes On0

Non-cyanideprocess baths? 0 yes On0
Non-cyanide stress relievers? 0 yes On0

ETCHING

Differential plating instead of conventional electroless plating? 0 yes On0

Pattem instead of panel plating? 0 yes On0
Additive instead of subtractive methods? 0 yes On0
Nonchelated etchants? 0 yes On0
Nonchromated etchants? 0 yes 0no
WASTEWATER TREATMENT

Alternative (bw dry solids volume) chemicals? 0 yes On0

Alternative treatment methods? 0 yes On0
Disarss the results of these attempts:

Discuss the obstades that prevent the use of these methods:

Note: The auditor should refer to the USEPA report on Waste Minimization in Metal Parts Cleaning for information regarding
material substitution and ~rocessmodification aimed at reducing waste from parts cleaning.

50
 Firm Waste Mlnlmlzatlon Assessment Prepared BY
Site Proc. UnitlOper. Checked By
Date Proj. No. Sheet- of - Page __ of -

WORKSHEET I OPTION GENERATION: I

5 I aterial and Proces
Substitution I
Meeting Format (e.g., brainstorming, nomlnai group technique)
Meetlng Coordinator
Meeting Partlcipants

Suggested Waste Minimization Options ICurrently I

Done Y/N? Rationalememarks on Option
n. Substhution Options
Abrasives
Nonchelated Cleaning Compounds
Aqueous Processable Resist
~~

Screen Printing
Dry Resist Removal
Mechanical Production
Non-cyanide Process Baths
Non-cyanide Stress Relievers
Differential Plating
~~~ -

Use Thinner Copper Clading

Pattem Plating
Additive Method
~

Nonchelated Etchants
Nonchrome Etchants
Other Raw Material Substitution

51
 I

Firm Waste Mlnlmlzatlon Assessment Prepared BY

Site Checked By
Date Proj. No. Sheet- of - Page - of -

WORKSHEET

6A 1 WASTE MINIMIZATION:
Process Modification I
For cleaning, electroplating, ekdroless plating, and etching, there are many similar ways of reducing waste. This is
because most of these operations involve the insertion and removalof a part from a tank of processing solution followed
by the rinsing of the part in a tank of water. Waste can be reducedby extending pracess bath life (reduce drag-in, reduce
drag-out, avoid bath decomposition and remove impurities) and by improving rinse efficiency.

A. EXTENDING PROCESS BATH LIFE

Drag-In Reductlon
Are racks cleaned regularly to ensure that corrosion does not contaminate the process baths? 0 yes On0
Are coated racks used to avoid contamination? 0 yes On0
Has the plant investigatedthe use of purer anodes to avoid contamination from
metdlic iinpurities in the anodes? 0 Y= on0
Are anode bags used to prevent corroded anodes from falling into the bath? 0 yes OK)
Are anodes removed when the bath is not in use? 0 yes On0
Is rinsing adequate to prevent or minimize drag-in? 0 yes On0
Is deionizedwater used for p~ocessbath make-up? 0 yes On0
Are chemicals properly stored and mixed just before use to avoid deconposition and
shortened bath life? 0 Y= On0
Drag-out Reductlon
Are process baths operated at the lower end of the manufactureh suggested range of
operating concentrations? 0 yes On0
Are fresh process bath solutions operated at a lower concentrationthan
replenished process bath solutions? 0 yes On0
Can any of the chemical process baths be operated at a higher temperature without
adversely affecting production qualii? 0 yes On0
H a s the plant investigatedthe use of wetting agents to reduce dragout? 0 yes On0
Are boards properly racked to avoid excessive drag-out (typical drag-out values
should range from 10 to 15 mUW)? 0 yes On0
Are boards withdrawn slowly, and is ample time provided to albw for drainage? 0 yes On0
Has an optimal removal rate and drainage time for workpiece racks been
determined for each process bath? 0 yes On0
Are personnel trained to follow proper workpiece rack removal rates 8 drainage times?
Would use of an automatic board handler reduce drag-out? 0 yes On0
Is there space between process bath tanks and their associated rinse tanks that allows
process chemicals to drip onto the floor? 0 yes On0
If yes, can drain boards be used to direct drainage back into the process tank? 0 yes On0
Do process baths that operate at elevated temperatures utilize drag-out tanks as the initial
rinse following the bath? 0 yes On0
If yes, is the drag-out tank solution added back to the process tank? 0 yes On0
Has the company studied the possibility of using the drag-out solution for process 0 yes on0
bath replenishing?

52
irm I Waste Mlnlmlzatfon Assessment I Prepared BY
iite Checked By
late Proj. No. Sheet - of - Page - of -

WORKSHEET WASTE MINIMIZATION:

6B Process Modification

Avoldlng Bath Decomposition and lmpurlty Removal

Is bath activity regularly monitored? 0 yes on0
Are corrective actions taken promptly to promote maximum bath life? 0yes on0
Is bath temperature properly controlled? 0 yes On0
Are heating coils cleaned regularly? 0 yes on0
Has the plant used heated jacketed tanks instead of coils? 0yes on0
Are the process baths agitated? 0 yes On0
Is agitation achieved by air sparging? 0 yes On0
Could mgchanical agititation be used to avoid the formation of carbonates u e to air agitation? 0 yes on0
Are process baths continuously filtered? 0 yes on0
Are they batch filtered? 0 yes On0
Is sludge build-up in the tank a problem? 0 yes On0
Would increased filtering help? 0 yes On0
Can coarser filters be used? (Coarserfilters hold more sludge & need replacement less often.) 0 yes on0
Is carbon filtering employed? 0 yes On0
Has the plant attemptedto regeneratelpurifysolutions by cooling or freezing? 0 yes On0
Can the recovered solids be used in another process? (Copper sulfate crystals from
regenerated etchant may be used for regenerating copper electroplatingbaths.) 0 yes 0 no
Does the plant use an alkaline sttipper to clean photoresist material off of
printed circuit boards? 0 yes on0
Is the stripper decanted or filtered periodically to remove polymer flakes and
increase the useful life of the stripper? 0 yes On0

B. IMPROVING RINSE EFFICIENCY

Can a still rinse or drag-out tank be employed to recover drag-out and reduce loading on the
rinse system? 0 yes On0
If recovered drag-out cannot be returnedto the process bath, is it treated separately from the
spent rinse water? 0 yes On0
Does the plant use spray or fog rinsing to reduce rinse water use? 0 yes On0
Do all the rinse systems utilize forced air or forced water as a means of agitating
the rinse solution? 0 yes On0
If no, are workpiece racks agitated manually while submersed in the rinse solution? 0yes On0
Does the plant have the available space to install multiple counter-current rinse tanks at any of
the rinsing stations? 0 yes On0
Have the flow rates used on all the rinse systems been determined based on rinsing needs of
the particular process chemistry? (Based on a drag-out value of 15 mVft2 and a required dilution
ratio of 1000:1,a single stage rinse tank should use approximately 4 gallons of rinse per square
foot of board.) 0 yes On0
Firm Waste Mlnlmlzatlon Assessment Prepared BY
Site Checked By
Date Proj. No. Sheet - of __ Page - of -

WORKSHEET

6C 1 WASTE MIN1MIZATlON:
Process Modification I
B. IMPROVING RINSE EFFICIENCY (CONT.)
Does the sum of each rinse system's estimated daily water usage approximatethe average
daily volume of wastewater treated? (If no, rinse water lines are most likely being left on even
when the process line is not in operation.) 0 yes On0
Does the plant utilize the flow restrictors, flow control meters, or other devices intended to
regulate the flow of water through all the rinse tanks? 0 yes On0
Does the plant generate rinse water effluents from rinse operations that follow mild andlor
strong acid etching and cleaning pmasses? 0 yes on0
If yes, are the rinse solutions recycledfor use in rinse systems following alkaline
cleaning baths? 0 yes On0
Has the plant investigatedthe use of deionized water-for rinsing? 0 yes uno
Would the use of deionized rinse water promote the potential for recycling? 0 yes On0

54
I
F

Firm Waste Mlnlmlzation Assessment Prepared By

Site Proc. UniUOper. Checked By
Date Pmj. No. Sheet- of - Page - of -

WORKSHEET
OPTION GENERATION:
7 Process Modification k

Meetlng format (e.g., bralnstormlng, nominal group technlque)

Meetlng Coordinator
hhtlng Partlclpants

Suggested Waste Mlnlmlzatlon Optlotas IDoneY

~- - 3 I Ratlonale/Remarkr on Optlon

A. mending P~OCOSS
Bath LHO
P-1 Rack DesigrMaintenance
Purer Anodes and Anode Bags
Better Rinsing
Deionized Water
Proper Storage
c Lower Bath Concentration
Increase Bath Temperature

i Wetting Agents
Proper Board WithdrawaUOrainage

I Automation
Recover Dragout
r Monitor Bath Activity
t Control Bath Adivity
Mechanical Agitation
I Filtering/lmpurity Removal

I 8. Impmvo R l n u Efllckncy
Still Rinses
Spray Rinsing I I
Fog Nozzles
Increase Aoitation

ReuWRecycle Rinse
Use Deionized Water

5s
Firm Waste Mlnlmlzation A ~ s e s s " t Prepared By
Site Checked By
Date Proi. No. Sheet- of - Page - of -

WORKSHEET
WASTE MINIMfZATION:
8 Good Operating Practices

Is the production schedule varied to decrease waste generation? (For example, do you
attempt to increase size of production runs and minimize cleaning by accumulating orders or
production for inventory?)
0 yes n
no
Describe

Are plant material balances routinely performed? 0 yes On0

Are they performedfor each material of c o n " (e.g. solvent) separately? 0 yes On0
re " i i kept ot individualwastes with their sou- oi origin and eventualdisposal? 0 yes On0
(This can aid in pinpointing large waste stream and focus reuse efforts.)
Are the operators provided with detailed operating manuals or instructionsets? 0 Yes On0
Are all operator job functions weU defined? fl Yes on0
Are regutarty scheduled training program offeredto operators? 0 yes On0
Are there empkyee incentive programs relatedto waste minimization? 0 Yes Dm
Does the facility have an established waste minimization prooram in place? 0 Yes 0 no
If yes, is a specific person assigned to oversee the success of the ~xogram? 0 Yes an0

Discuss goals of the pmgram and results:

0 Yes On0
Has a waste minimizationassessment been performedat the facility in the past?

If yes, discuss:

56
 Firm Waste Mlnlmlzatlon Assessment Prepared By
Site Proc. UnWOper. Checked By
Date Proj. No. Sheet - of - Page __ of -

WORKSHEET
I OPTION GENERATION:
Good Operating Practices I
Meeting format (e.g., bralnstormlng, nominal group technique)
Wetlng Coordinator
Meetlng Partlclpants

Suggested Waste Mlnlmkatlon Options currently RatlonaWRemarks on Optlon

Done Y/N?
Increase Size of Production Run
Perform Material Balances
Keep Records of Waste Sources 8 Disposition

~~
WasWMaterials Documentation
____ ~

Provide Operating Manuals/lnstnrctions

Employee Training
Increased Supervision

~
Provide Employee Incentives
~

Encourage Dry Cleanup

Increase Plant Sanitation
Establish Waste Minimization Policy
~~~ ~

Set Goals for Source Reduction

Set Goals for Recycling
Conduct Annual Assessments
!
1
!
I
I
~

j
!

!
Firm Waste Mlnlmlzatlon Assessment Prepared By
Site Checked By
Date Proj. No. Sheet __ of - Page - of -

WORKSHEET

1OA
I WASTE MINIMIZATION:
Segregation, Reuse,
Recovew. & Treatment I
A. SEGREGATION
Segregationof wastes reduces the amount of unknown material in waste and improves prospects for reuse 8 recovery.

Are different solvent wastes segregated? 0 yes On0

Are aqueous wastes segregated from solvent wastes? 0 yes on0
Are spent solutions segregated from the rinse water streams? 0 yes on0
If no, explain:

Does the plant use chelators in any of the process baths? 0 yes On0
If yes, are waste streams that contain chelators segregated from other waste streams
prior to treatment? (Waste streams that contain chelators often require additionaltreatrent.
This additional treatment will cause a greater volume of wastewater treatment sludge
to be generated.) On0

B. CONSOLIDAllON/REUSE
Are many diflerent solvents used for cleaning? 0 Yes On0
If too many small-volume solvent waste streams are generated to justify on-site distillation,
can the solvent used for cleaning be standardized?
Is spent cleaning solvent reused?
Does the plant generate spent a l k a l h and/or addic baths that can be used for elementary
neutralizationin the industrialwaste treatment prOceSS? 0 yes On0

Describewhich measures were succeSsful:

Has off-site reuse of wastes through Waste Exchange senrices been considered? 0 Yes On0
Or reuse through commerdal brokerage firms? 0 Yes On0

If yes, results:

58
~

Firm Waste Mlnlmizatlon Assessment Prepared BY

site Checked By
Date Proi. No. Sheet- of - Page - of -

WORKSHEET

10B r- WASTE MINIMIZATION:

Segregation, Reuse,
Recovetv, & Treatment I
C. On-Slte Recovery
On-site recovery of solvents by distillation is economically feasible for as little as 8 galbns of solvent waste per day.

Has on-site distillation of the spent solvent ever been attempted? 0 yes On0
If yes, is distillation still being performed? 0 yes On0

If no, explain:

Does the plant generate waste streams that contain valuable process chemicals or metals? 0 yes On0
If yes, does the plant currently utilize any recyclingtechnologies to recover valuable process
chemicals or metals? 0 Ym On0
Does the plant utilize treatment technologies to recycle rinse water? 0 yes On0
ll no, has the plant assessed the potentialfor devebping a dosed kop rinse water system? 0 yes On0

Discuss the results of recycling:

D. Altomathre T " m t Technoloqy

Does the plant operate an industrialwaste tm-nt fadlily? 0 yes 0 no
If yes, does the treatment facility produce a wastewater treatment sludge that is handled
as a hazardous waste? 0 yes On0
Has the plant evaluated the use of alternative treatment Chemicals (such as caustic soda
instead of lime or polyelecbolytesinstead of alum or ferrlc chbride) to identify those that
generate the bwest volume of sludge? 0 yes 0 no
If yes, has the piant evaluated the use of an alternative treatment system that produce less
residual waste than the exlsting treatment facility? 0 yes On0

59
P

APPENDIX ONE

CASE STUDIES OF PRINTED CIRCUIT BOARD MANUFACTURING PUNTS

In 1986 the California Department of Health Services commissioned a waste minimization

study (DHS1987) of three printed circuit (PC)board manufacturing firms, called plants A,
B and C in this guide. The results of the three waste assessments were used to prepare
waste minimization assessment worksheets to be completed by other printed circuit board
manufacturers in a self-audit process.
The three printed circuit board manufacturing plants were chosen for their willingness to
participate in the study, their applicability to the study's objectives, and the potential
usefulness of the resulting data to the industry as a whole. The waste minimization
assessments were concerned with waste generated within the plant boundaries and not with
i
waste derived from printed circuit board application or disposal of board parts.
This Appendix section presents the results of the assessments of Plants A, B and C and the
1 waste minimization options either already in use or being considered for use by the firms.
The waste minimization assessments were conducted according to the description of such
assessments found in the "Introduction: Overview of Waste Minimization,"in this guide.
The steps involved in the assessments were (see also Figure 1.1):
I o
o
Planning and organization
Assessment phase
o Feasibility analysis phase
The fourth phase, Implementation, was not a part of these assessments since they were
conducted by an outside consulting firm. It was left to the printed circuit board
manufacturers themselves to take steps to implement the waste minimization options that
passed the feasibility analysis.

60
I
 PLANT A WASTE MINIMIZATION ASSESSMENT

Planning and Organization

Plmvring and orgMirarion of the arresment was done by the connJtingjh with the d a m e
of personnel jivm the PC bead manuf- @a Initial contact was made with the
PC board manufacturer’sphnt operations m e , a high level manager who could provide
the company’s commitment to cooperate in the assessment and pmvide all the necessaryfrrciity
and process infomation. The goal of this joirtt flrt was to conduct a comprehensive waste
minimization arsesrment for the plant. Under different cirnunrrancq in a company with its
own on-going waste minimuation p t o g ” , goals c& be set to tatget a s p e m amount or
type of wate to be &ed; ot to conduct a waste “ i r a t i o n nrresmrent each year; or other
goal The waste assessment task force in the cppe of Plant A consisted of the c o d a n t s
wolnking tqether with the phnt m e r . Thir task f m e aLw f i u t c t i o n e d as the arsessment
team

Assessment Phase: Process and Facility Data

Initial dircrrrsiorrs by telephone between the c o t l d b w and the pliant F?uznqer were used to
requestpmess and facility infonnatin prior to a site virit. These &&ns also served to
Mfiparticular w e streanrs of concem to plant
At the Site vt‘sir: the plant opemtiwrs manqer and consultants met to teyieW the f i d t y ’ s
opemtbns and itspotartirJtarget waste s”s 7he manugerconducted a facility tour and
introduced the coILaJtcpLts to procesr “qp and woinkers ihvolved in mat& and waste
hamil@. Some of these people were intewiewed to obtcrin hfbmation about spedflc
proceduresusedattheplant.

FACILITY DESCRIPTION
Plant A is a prototype Circuit board manufacturer that specializes in jobs involving limited
production and fast turnaround. Manufactwing operations include drilling and routing,
layering (for multilayer boards), photoresist printing, plating, etching, and stripping.

61
PROCESS DESCRIPTION

Figure A1 is a floor plan of the plant’s plating, etching, and stripping operations. The
numbers listed on the floor plan represent the identification number for each process bath
and rinse tank. Tables Al, A2, and A3 provide information on the plant’s operations.
Table A1 describes each process bath used at plant A and Table A2 describes each rinse
system used at the plant.

WASTE DESCRIPTION

Production activities that generate hazardous waste are the plating, etching, and stripping
processes. The sources of waste from these activities are rinsing operations, spent process
bath dumping, industrial waste treatment, and equipment cleanout. Table A3 describes the
hazardous wastes produced at the plant.
Spent Chemical Bath
When a process chemical bath becomes too contaminated or diluted for use (spent), it is
removed from the process tank. The spent chemical bath is then either containerized for
reclaim by the manufacturer, containerized for off-site disposal, used as a neutralization
chemical in the industrial waste treatment system, or dumped into the wastewater collection
sump. The chemical baths are changed periodically according to the plant’s current time
schedule. This schedule was developed by Plant A based on its experience with various
process baths.
Only two of the spent bath handling methods contribute to the amount of hazardous waste
generated at the plant. These methods are containerizing waste for off-site disposal and
dumping of spent chemical baths into the wastewater sump. Two process chemical baths
are containerized for disposal: (1) photoresist stripper and (2) reflow oil. Approximately
3 5 gallons of waste stripper are generated monthly. Plant A did not estimate the volume
of waste reflow oil generated each month.
Photoresist stripper waste is generated at the conditioning and stripping line. The stripper
is used in a 3@gdon tank where circuit boards are immersed to strip off the remaining
photoresist material. The chemical bath is changed approximately every 2 weeks. The
resultant stripper waste is highly alkaline with a pH over 12. The waste stripper contains
a polymer residue which, when agitated, remains suspended in the solution.
Reflow oil is used to enhance the formation of a smooth, uniform film of solder onto
printed circuit boards. The reflow oil bath is maintained at an elevated temperature during
use. When the bath becomes spent, it is containerized for off-site disposal. Analytical data
for the spent oil were not available.
The plant’s standard practice for dumping spent chemical baths into the wastewater sump
is to transfer waste chemicals to one of the two metering tanks (tanks A and B in Figure
Al). These tanks slowly discharge waste chemicals into the waste sump. The purpose for
slowly feeding the spent bath chemicals into the wastewater sump is to prevent surges in
the waste stream pH or metals content. These two metering tanks have not, however, been

62
 .

Line

k n i a Etching Line

1
I 3Y

a 292726 22 21 20

Electroplating
Line

-
FIGURE A I
n
PLANT A'S PLATING
ETCIIING AND STItIPPINC OPERATIONS
 !

TABLE A1
PROCESS BATH INFORMATION

PROCESS BATH/ PROCESS METHOD FREQUENCY

IDENTIFICATION BATH OF OF DUMPS
NUMBER VOLUME DISPOSAL
(do=) IN TANK

Cleaner-Conditioner/l 30 To treatment 2 weeks

Sulfuric-Peroxide Etch/3 30 To treatment 4 weeks

Catalyst Premix/5 30 To treatment 2 weeks

Catalyst/6 30 ---
AcceIerator/8 30 To treatment 2 weeks

Electroless Copper/ll 30 --
5% Sulfuric Acid/U 30 To treatment 2 weeks

100% Sulfuric Acid/W 30 To treatment 1week

Neutralizer 30 To treatment 4 weeks

Etchback/lS

Brown Oxide/l7 30 -
Ammonium Biflouride/l9 30 To treatment 4weeks
Metex Cleaner/U) 20 To treatment 1week

10% Sulfuric Add/= 400 To treatment lweek '

Copper Gleam/= 400 3-

Copper Gleamj24 400 3-
10% Fluorboric Aud/27 20 To treatment 2 weeks
Tin Lead/28 400 - 3-
Resist Stripper/31 30 off-site 2weeLs
disposa
Tin Immersion 30 Redaimed by -
Conditioner/33 supplier
Ammoniated Etch/% -- Reclaimed by 4 weeks
supplier
Reflow Oil/% 30 off-site disposal --

64
 I r r r I t I i

TABLE A2
RINSE SYSTEM INFORMATION

RINSE SYSTEM/ RINSE WATER NUMBER COUNTER PROCESS BATH(S) EST1MATED

NUMBER FLOW RATE OF TANKS CURRENT PRECEDING RINSE DAILY WATER
SYSTEM SYSTEM USE
(Y/N)

Dip Rinse/l2 16 gal/min one no Cleaner/ 1500 gallons

conditioner
Dip Rinse/4 16 gal/min one no Sulfuric/ 1500 gallons
peroxide etch
Dip Rinse/7 16 gal/min one no Cata1yst 1500 gallons

m Dip Rinse/9 16 gal/min one no Accelerator 1500 gallons

VI

Dip Rinse/lO 16 gal/min two no Rinse tank #9 1500 gallons

Dip Rinse/l4 16 gal/min one no Sulfuric acid 500 gallons

Dip Rinse/l6 16 gal/min one no Neutralizer 500 gallons

etchback

Spray Rinse/21 1.5 gal/min one no Metex cleaner

Drag-out/25 --- one no Gapper gleam
Spray Rinse/26 1.5 gal/min one no Sulfuric acid

Drag-out/29 one no Fluorboric acid

Spray Rinse/30 one no Drag-out tank #29

 I

TABLE A3
HAZARDOUS WASTE DATA

ANNUAL ANNUAL
QUANTITY DISPOSAL DISPOSAL DISPOSAL
WASTE GENERATED METHOD COST/UNIT COSTS

Industrial Waste 5400 gal. off-site Sl.Oo/gal sz400

Treatment Sludge metal
reclamation

Photoresist 720 sal.

Stripper
Reflow Oil --- off-site ---
&poaal
N&ricAcid mgal.

Copper Sulfate - off-site -

crystals disposal

66
1

in operation since July 1986. The present practice is to manually dump the spent baths into
the collection sump. Plant A personnel indicated that this practice causes a fluctuation in
the pH of the waste stream entering the treatment system.
Copper sulfate crystals are generated when some of the process baths are taken off-line.
The crystals form in the process bath as the copper content increases. Before the process
baths are dumped into the wastewater sump, the crystals are removed and containerized as
a solid waste since they cannot be fed into the treatment system.
Rinsing Operations
Rinsing operations associated with the chemical process lines are the major source of
wastewater at Plant A. Plant A estimates that approximately 10,OOO gallons of wastewater
are generated each day. The rinse operations contribute to hazardous waste generation
because waste rinse water carries away chemicals which are then removed by treatment at
the industrial waste treatment plant. The sludge that is generated from this treatment is
handled as a hazardous waste.
Plant A uses nine dip rinse tanks and three spray rinse tanks. AU rinse water used at Plant
A is deionized onsite prior to use. All but two of the rinse tanks are plumbed directly to
the wastewater treatment system through a 500-gallon collection sump. The other two are
batch dump tanks which require manual dumping into the sump.
Discussions with facility personnel indicate that water flows through the dip rinse tanks only
when the process line d a t e d with the tank is in operation. However, during both visits,
the assessment team observed water flowing through several rinse tanks even when the
process line was not being operated. The flow rate of water through each dip rinse tank
was measured to be approximately 16 gallons per minute. This was measured by closing
the drain line, turning on the feed water for 20 seconds, measuring the water level rise in
the rinse tank,and calculating the volume of water that entered the tank during the time
period. The flow rate of water through the spray rinse tank has been estimated by the
assessment team to be approximately 1.5 gallons per minute.
Industrial Wastewater "reatment
Plant A's industrial waste treatment facility treats all wastewater before dischatging it to the
San Jose/Santa Clara Water Pollution Control Plant. Plant A's treatment facility removes
metals and adjusts the pH of the wastewater to meet discharge requirements set by the
water pollution control plant. The maxi" allowable concentration of metals in the
discharged effluent, as set by the San Jose/Santa Clara Water Pollution Control plant, are
as follows:
0 Chromium 1.0 mg/L
o Copper 2.7 mg/L
0 Cyanide 1.0 mg/L
0 Lead 0.4 mg/L
0 Nickel 2 6 mg/L
0 Silver 0.7 mg/L
0 zinc 2.6 mg/L

67
The treatment process includes metal reduction, neutralization, and flocculation. The
treatment plant is located outside the main building in a fenced and curbed area. The
metal hydroxide sludge generated by the treatment process is a hazardous waste.
Chemical treatment is performed in three separate tanks;the wastewater then goes through
sludge separation and dewatering. Approximately 10,OOO gallons of wastewater are treated
each day. Wastewater characterization data were not provided by Plant A. The incoming
wastewater is pumped from the collection sump to the first tank where ferrous sulfate and
sulfuric acid are added. Ferrous sulfate is used to reduce the copper to its precipitable
form. The sulfuric acid is used to maintain the pH between 2.0 and 3.0 during the ferrous
sulfate reaction. The waste is then neutralized with alum and sodium hydroxide. The alum
causes the suspended solids to collect, forming larger particles, and the sodium hydroxide
raises the pH to approximately 9.0. A polyelectrolyte coagulant is then introduced to aid
in the flocculation of the contaminants. The polyelectrolyte causes the precipitated
cont a " D t s to congeal into large flakes which can be settled out of the waste stream.
Plant A personnel provided information on the quantities and costs of treatment chemicals
used each month (Table A4).

TABLE A4
QUANTITIES AND COSTS OF TREATMENT CHEMICALS PLANT A -
~ ~~ ~

chemical Monthly Usage Cost/unit Cost/Month

Ferrous sulfate 850 lbs SO33/lb $280

Alum 850 lbs SO.47/lb $400

Sodium hydroxide 200 gallons

(30% solution in $OS/@ $110 winter
winter)
(5096 solution in SO.92/gal $185 summer
summer)
Polyelectrolyte 3 lbs $75O/lb u
z
Total $812/inwinter
$887/'m Summer

68
The wastewater treatment sludge that is settled out of the effluent waste stream is
transferred to the sludge dewatering unit, and the effluent is discharged to the San
Jose/Santa Clara Water Pollution Control Plant. Sludge is dewatered in a bag filter that
increases its solids content to 11 percent. The dewatered sludge is transferred into 55-
gallon drums and stored for pickup by a metal reclaimer (World Resources Company).
Plant A plans to use large storage bags in the future which will hold the equivalent of four
55-gallon drums. Plant A estimates that four drums of industrial waste sludge are generated
each month. The sludge is considered a hazardous waste because of the copper content.
Analytical data for the sludge were obtained from World Resources Company of Phoenix,
Arizona. World Resources analps a sample from each load of sludge transported to them
for metal reclamation. The data provided by World Resources are as follows:

Percent solids 11%

Metal content in pounds per dry ton

Copper 195
Nickel 6
Tin 46
Iron 399
zinc 9
Lead 23
ChTOmiUm 20

Equipment Cleanout

The primary sources of hazardous waste associated with equipment deanout are the
cleaning of the copper etching tank, cleaning of tanks used in the electroplating line, and
cleaning of electroplating rack This equipment is cleaned by using nitric acid. Plant A
estimates that one 55-gallon drum of waste nitric acid is generated every 6 months. The
waste nitric acid has too low a pH and too high a copper content to be treated at the
plant's wastewater treatment system. Analytical data on the waste nitric acid were not
available from Plant k
Other cleaning activities, such as floor washing and chemical bath tank riming, generate
waste streams that discharge into the wastewater collection sump. According to Plant A
personnel, these waste streams make up a small portion of the chemicals that enter the
treatment system.

69
 I

Assessment Phase: Option Generation

The comltants reviewed the prcurt opmtiions &a obtained prior to and during the site
inspection They developed a set of waste minimiration options based on this information and
on infomation in the lite". These options were screened for their effectiveness in reducing
waste and for theu fuhve implementation potential The plant manager partkipated in this
screening with the result that there was general cons- on the lkt of recommended options.

SOURCE REDUCIlON
The following paragraphs describe the application and use of source reduction measures to
various waste stteams at Plant A.
Material Substitution
Opportunities for material substitution that apply to Plant A include (1) using process
chemistries that can be recycled or treated prior to discharge to the publicly owned
treatment works (POTW)and (2) using chemistries that have less impact on sludge
generation. Process chemistries that Plant A currently containerizes for off-site disposal
include spent reflow oil and nitric acid waste. Several reflow oil products are available that,
when spent, either can be returned to the supplier for recycling or can be treated by the
facility prior to discharge to the POTW. Plant A could eliminate a hazardous waste stream
by replacing its present reflow oil with a recyclable or treatable reflow oil.
Nitric acid waste, which is generated from the cleaning of electroplating racks, can also be
eliminated by using an alternative cleaning solution. One chemical supplier offers an
electroplating rack cleaning solution that can be regenerated. The metal stripped off of
racks can be plated out in a tank equipped with a cathode and an anode. The metallic
sludge then settles to the bottom of the cleaning tank where it can be removed and mixed
with the wastewater treatment sludge. Once the cleaning solution becomes spent,it can be
treated in the plant's industrial waste treatment system before being discharged to the
POTW. The use of recyclable cleaning solution will eliminate the generation of waste nitric
acid. The metallic sludge that is generated can be sent to a metal reclaimer along with the
wastewater treatment sludge.
The use of non-chelated process chemistries can reduce the volume of sludge generated
during wastewater treatment. Plant A uses ferrous sulfate to treat its wastewater. The
ferrous sulfate is used to break down chelators so that metals can be precipitated. The iron
in ferrous sulfate also precipitates as a metal hydroxide and contributes to sludge volume.
The analytical data for Plant A's industrial waste treatment sludge indicate that iron
contributes approximately 57 percent of the total metal content of the sludge. If aIl the iron
precipitates as metal hydroxide, the iron hydroxide contributes 34 percent of the total dry
weight of the sludge. If plant A used non-chelated process chemistries, ferrous sulfate

70
 treatment could be eliminated and sludge generation could be reduced. Most chemical
suppliers offer non-chelated process chemistries or chemistries with mild chelators that do
not require ferrous sulfate treatment. Plant A should consult with chemical suppliers to
identify alternative process chemistries that can be used so that ferrous sulfate treatment
canbe " b e d .

Rinse Water Reduction

Although rinse water is not a hazardous waste, the treatment of this waste produces a
sludge that is a hazardous waste. Since the volume of the sludge generated by treatment
is a function of the volume of wastewater treated as well as the concentration of
contaminants in the waste, the plant can reduce the volume of sludge generated by reducing
its rinse water generation. Several rinse reduction options are available to Plant A that can
reduce the volume of wastewater requiring treatment. Multiple stage rinse water systems
were not evaluated because not enough space is available at Plant A's facility.

i
Plant A now operates several of its dip rinse tanks as flow-throughtanks. Deionized water
I is plumbed into the tank during operation and the overflow is plumbed to the collection
sump. Each of the rinse tanks holds approximately 30 gallons of rinse water, and the flow
of water through each tank is approximately 16 gallons per minute. PRC believes that the
c plant could modify its operation of th& rinse tanks to reduce the volume of wastewater
generated. Two options are available for Plant A: (1) the dip rinse tanks can be operated
as batch rinse tanks or (2) the flow rate through the tanks can be reduced.
i If these seven dip riaSe tanks were operated as batch rinse tanks (which means they would
operate as stagnant rinse tanks that are emptied between rinse operations and then refilled
with deionized water), Plant A could reduce its rinse water generation significantly. Table
I A4 shows the volume of rinse water generated by Plant A and the volume that would be
generated if the seven dip rinse tanks were operated as batch rinse tanks. The values for
t the time water is running and for the n&r of workpiece racks processed daily were
provided by Plant A personnel. Tbis option assumes that each rinse tank can provide
adequate rinsing of one process rack when filled with fresh deionized water. Plant A did
not provide the auditors with informationon the required operating parameters of the rinse
systems. Therefore, the impact of batch rinsing on the efficiency of the rinsing operations
could not be assessed. The following example, however, illustrates the feasibility of batch
rinsing.
The equation for determining the volume of rinse water needed to rinse a full workpiece
rack is as follows:

71
b
 I

Where Q = rinse tank flow rate

D = drag-out rate
C, = concentration of salts in process solution
C, = allowable concentration in rinse solution

Several assumptions must be made to use this equation to illustrate the potential for
operating the rinse tanks as a batch rinse system. These are as follows:
0 The concentration of chemicals in the rinse solution cannot exceed 1/1OOO
of the concentration of chemicals in the process bath. This value is a
common parameter used in the electroplating industry for rinse water
contaminant concentration.
0 The drag-out rate of chemicals used for manufacturing printed circuit boards
is approximately 15 ml/@ of board. This value is a standard approximation
used for estimating drag-out created by a printed circuit board (Foggia,1987).
0 An average workpiece rack holds approximately 25 ft? of boards (example:
30 4-inch by 3-inch boards).

The drag-out rate for each workpiece rack is:

15 ml x 2.5 ft? = 37.5 ml.

Converted to gallons, drag-out equals 0.01 gallon.

By substituting the values into the equation:
0.01 gallon x = 10 gallons
1

10 gallons of fresh rinse water will provide adequate rinsing under the operating parameters
previously described. Since the rinse tanks hold approximately 30 gallons of rinse water,
theoretically, a full tank of fresh water would provide adequate rinsing without operating
the tank as a flow-through tank. Workpiece rack agitation or air spargers can be used to
improve efficiency to assure adequate rinsing in the batch rinse tank.
Although using the dip rinse tanks as a batch process can provide si@cant reductions in
wastewater generation, there may be several process lines for which this is not feasible
because of the chemistry of the process. However, even if some of the tanks must operate
as flow-through rinse systems, the volume of deionized water used can still be reduced for
these tanks. The same equation can be used to demonstrate that the present flow rate used
in the rinse tanks may be excessive.

72
i

The equation can be rearranged to indicate the ratio of process bath concentration to rinse
solution concentration, as follows:

9,= CJC,
D
The same drag-out volume (0.01 gallon) will be used. and it will be assumed that the
process rack remains in the rinse tank for 3 minutes. The ratio of the process bath
concentration to rinse solution concentration is as follows:
3~=4,809
0.01 gal.
Therefore, to justify the present rinse water flow rate, the concentration of chemicals in the
rinse solution can only reach 1/4,800 or 2/10,000 of the concentration of chemicals in the
process bath before rinse efficiency is reduced. As previously stated, the electroplating
industry usually allows rinse water concentrations to reach 1/1ooO the concentration of
chemicals in the process tank. Plant A should consult chemical manufacturers’
representatives and perform experiments to determine the proper flow rate for its rinse
banks if batch operation is not feasible.

By calculating the flow rate necessary to maintain the rinse water at an acceptable chemical
concentration, Plant A m a y find that the 16 gallon per minute flow rate presently used is
too high. In addition, the use of air spargers or work piece rack agitation should improve
rinse efficiency and allow for use of lower rinse water flow rates.

Rinse Water Flow Controls

Plant A presently turns on the rinse water in-flow valves manually. When the process line
is in operation, plant personnel turn on the water for all the rinse tanks and then turn the
water off after the production process is complete. However, the consultants observed that
rinse tanks were left on even when the process line was not in use. The use of automated
flow controls would be helpful for ensuring that rinse water is not left running and for
controlling the flow rate when the rinse water is turned on.
The plant should consider installing pH meters in each of the rinse tanks to control the flow
of water through the rinse systems. The meters should be set to turn the fresh water feed
valve on when the chemical concentration in the rinse gets too high. If the required pH
range for each rinse tank is determined, the meters catl be set to turn on the water
automatically. When the rinse tank solution pH reaches the maximum allowable level to
provide efficient rinsing, the meter will send a signal that activates a valve on the influent
line. When the rinse solution again reaches an acceptable pH, the pH meter will send a
signal that turns off the water feed valve.
Flow restrictors can also be used to reduce flow rates. A limiting orifice or similar flow-
- restricting device can be installed in the water line to each tank to reduce the flow rate to
each tank. Plant A uses approximately 2-inch diameter piping for its rinse inflow lines.
This piping may be oversized for the pressure on the line and the required flow rate. The
use of flow restrictors, therefore, m a y provide better controls Over the rate of rinse water
usage. One circuit board manufacturer who installed pH meters, flow rcstrictors, and other

73
 water reduction devices, such as foot pedal pressure switches, was able to reduce water
usage by two thirds.

Process bath chemicals are carried into the rinse water when the racks that hold the printed
circuit boards are removed from a process bath tank and placed in a dip rinse tank. This
is performed manually at Plant A. The operator removes the rack, briefly holds it above
the process bath tank, and submerges the rack into the rinse tank. The consultants
personnel observed plant personnel performing this operation and found that the racks are
quickly removed from the process bath and held over the process bath tanks for less than
10 seconds. This procedure allows excessive chemicals to enter the waste rinse water
stream. Actual drag-out volumes were not available from Plant A, however.
The manner in which racks are removed from process baths will significantly affect the
amount of drag-out carried into the rinse tanks. Slow removal of workpieces causes a
much thinner film of process chemicals to adhere to the workpiece surface. Tbis effect is
so significant that most of the workpiece drainage time should be used to remove the
workpiece rack from the process bath. The consultants observed that Plant A personnel
remove racks in one quick movement. We suggest that Plant A train its personnel to
remove racks in a slow, smooth manner. Plant A could also improve the drag-out recovery
efficiency of the process lines by installing a bar or rail above the process tank so that the
racks can be hung and allowed to drain longer.
The auditors did not predict the drag-out volume that can be recovered by removing racks
at a slower rate and allowing racks to drain for a longer period of time. However, the
savings realized by reducing drag-out losses include reducing process chemical purchases
and reducing wastewater treatment sludge generation. Plant A can determine the
effectiveness of these drag-out reduction techniques by holding the racks over a collection
pan after removing them. The volume of drag-out that can be recovered after removing
racks at various rates and allowing racks to drain for various lengths of time can then be
measured and the optimal removal rate and drainage time can be determined.

Equipment CIerrnorrt
Plant A generates approximately 55 gallons of waste nitric acid every 6 months from
cleaning out the electroplating tanks and from cleaning the electroplating racks. Plant A
may be able to reduce the volume of nitric acid generated by modifying the existing
cleaning methods.
One method for reducing the volume of waste nitric acid produced is to set up a workpiece
rack cleaning line with several small tanks of nitric acid. The cleaning line is then used like
a multi-stage rinse system. The first tank contains the most contaminated nitric acid
~ solution and the final tank in the cleaning line contains the freshest nitric acid. When the
first tank no longer perfonns adequate initial cleanin& it is containerized for disposal (or
used as initial cleaning solution for tank cleanout). Then the second tank in the cleaning
line becomes the first. The empty tank is then filled with fresh nitric acid and it becomes
the last tank in the cleaning line.

74
The use of a multi-stage rinse system can provide significant reductions in waste cleaning
solution generation. One printed circuit board manufacturing plant visited by the
consultants uses a five-stage multiple tank cleaning line and only generates approximately
15 gallons of waste nitric acid each 6 months.

Chemical Process Baths

The chemical load on wastewater can be reduced by operating the process baths at lower
concentrations. A manufacturer's recommendations for chemical concentrations in process
baths are not always appropriate. We recommend that Plant A evaluate the efficiency of
the concentration parameters of its present chemical process bath to determine if these
concentrations can be reduced. By reducing the concentration of chemicals in a process
bath, the plant will "ize the chemical load in the wastewater when these baths are
dumped. This reduction will also reduce the chemical concentration in the rinse water by
"k@ drag-out chemical loses.
One method of reducing process bath chemical concentrations is to operate fresh baths at
lower concentrations than older baths. Plant A can accomplish this by gradually increasing
the chemical concentration in the process bath as it gets older. This practice can reduce
the chemical concentration of the drag-out from fresh baths and also extend the life of
some process baths.

Waste Segregation
The wastewater generated at Plant A is plumbed or manually dumped into a 500-gallon
collection sump. Therefore, all wastes that can be treated on-site are mixed prior to
treatment. This practice may cause excessive use of treatment chemicals and an increase
in the volume of sludge generated. Waste segregation m a y reduce the use of treatment
chemicals and the generation of sludge in two areas: the noncontact cooling water used for
the copper etch machine and the waste streams generated by processes that Contain
chelating chemistries.
Plant A personnel indicated that the cooling water system used in the copper etcher is a
once-through system,with the effluent discharged to the collection sump. If the system
were operated as a closed loop system, there would not be an effluent waste stream. Also,
since this water is used as nomcontact cooling water, the effluent that is now generated by
the system may not require treatment. The effluent, therefore, could possibly be discharged
directly to the sanitary sewer, if permitted by the Publicly-owned Treatment Works
CpOTw).
The use of a closed loop cooling system would lead to reductions in water and sewer fees,
treatment chemical use, and sludge generation. Direct discharge of non-contact cooling
water to the sanitary sewer would result in savings from reduced treatment chemical use
and sludge handling. The consultant was unable to obtain estimates on the volume of
water used in the etcher cooling system; therefore, specific values for savings cannot be
presented.

75
The primary purpose of the treatment system used at Plant A is to remove metals from the
waste stream so that the discharged effluent can meet San Jose/Santa Clara Water
Pollution Control Plant pretreatment standards. The highest metals concentration in the
wastewater is copper, and the treatment system is designed to remove the copper through
a ferrous sulfate reduction process. The ferrous sulfate process is designed to break down
chelators that keep metals in solution past their normal solubility limit. The ferrous sulfate
contributes significantly to the volume of sludge generated in the wastewater treatment
process. Analytical data indicate that iron content in the sludge is 399 pounds per dry ton
of solids. Assuming that all the iron precipitates as a hydroxide, iron hydroxide contributes
34 percent of the total dry weight of solids in the sludge. If there is a direct relationship
between solids content and total sludge volume, the plant could reduce sludge volume by
34 percent by eliminating iron from the waste treatment system.
Several options are available to eliminate or reduce the amount of ferrous sulfate used in
the treatment process. These include: (1) eliminating the use of chelated process
chemistries, (2) using process chemistries that only contain mild chelators, (3) segregating
waste streams that contain chelators from other waste streams, and (4) segregating waste
streams that contain copper from other waste streams. Plant A was unable to identify
Which process baths use chelators or what type of chelators are used. Therefore, specific
recommendations for waste segregation cannot be developed. However, several waste
segregation options are described.
Use of non-chelated process chemistries or mild chelators may allow Plant A to eliminate
the use of ferrous sulfate. Since the primary purpose of ferrous sulfate is to break down
chelators so that copper can be precipitated from the wastewater, non-chelated process
chemistries would allow the use of an alternative precipitant such as caustic soda. Mild
chelators, such as ethylenediamine tetraacetic acid (EDTA),can be broken down through
pH reduction. Therefore, if EDTA is used where chelators are needed, such as in an
electroless copper bath, ferrous sulfate may not be required for wastewater treatment.
Mixing waste streams that contain chelating agents with waste streams that are non-chelated
appears to cause a significant increasein the amount of treatment chemicals used, and
should be avoided when possible. Ferrous sulfate use can also be reduced by segregating
waste streams. According to Plant A p e r ~ o ~ ethe l , sources of copper that enter the
wastewater are (1) the copper drag-out tank,(2) spray rinse tank 29,and (3) dip rinse tanks
9 and 10. If these waste streams were segregated from the rest of the wastewater, ferrous
sulfate treatment would only be necessary for a percentage of the waste. This could be
done on a batch treatment basis if a holding tank is used to store the waste until treatment.
The remaining wastewater could have metals removed by neutralization and precipitation
with caustic soda. This would reduce the amount of treatment chemicals used at the
facility. If other waste strezym contain chelators, these could also be segregated from the
rest of the waste stream.

- RECYCLE AND RESOURCE RECOVERY ALTERNA'ITVES

Recycling and resource recovery includes the direct use of a waste stream or the recovery
of materials from a waste stream. Plant A appears to handle many of its waste streams in

76
 this manner. Spent sulfuric acid is used in the wastewater treatment system, and several
chemical process baths are returned to the manufacturer when they become spent. This
chapter describes several additional recycling and resource recovery techniques that may
be implemented by Plant k
Stripper Waste
Plant A personnel indicated that the plant's stripper waste is an alkaline solution that could
be reused or used in the treatment system if the polymer residue could be removed. The
plant could use a filter or decantation system to separate the residue from the waste
solution. Also, the volume of stripper waste generated can be reduced significantly by using
a multiple tank stripper system. This type of system allows the first stripper tank (the one
with the most contaminated stripper solution) to be used for a longer period of time
because the second stripper tank will be used for additional photoresist stripping.
Therefore, the photoresist stripper does not have to be replaced every 2 weeks. When the
first tank is dumped, the second tank becomes the first. Fresh resist stripper is then added
to the second tank,

Rinse Water Recycling

Currently, Plant A plumbs all its rinse water efnuent directly into the collection sump.
However, the plant may be able to recycle some of the rinse water solutions. For example,
rinse systems that follow an acid process chemical bath, such as a peroxide/sulfuric acid
etch, can sometimes be used for feed water to a rinse system that follows an alkaline
cleaning bath. Implementation of such a system, however, should be done only after careful
testing to make sure that addition of acid rinse water to the alkaline rinse bath does not
c a w problems with metal hydroxide precipitation on clean parts.

The configuration of Plant A's process lines may allow some of these rinse systems to be
plumbed together in series. For example, rinse tank 14, which follows a sulfuric acid bath,
could be plumbed into rinse tank 16, which appears to follow an alkaline cleaning bath.
Based on data of the existing water used, rinse tanks 14 and 16 both use approximately 500
gallons each day. If 100 percent of the water used in rinse tank 14 could be used for
rinsing operations in tank 16,500 gallons of water could be saved each day. The plant
would also reduce the volume of wastewater treated each day by 500 gallons and could,
therefore, reduce treatment chemical usage and sludge generation. Rinse water could also
be recycled if the rinse tanks were operated on a batch proass.

Copper Sulfate Cystals

Plant A personnel indicated that they were unsure of how to handle the copper sulfate
-crystals generated at the plant. Currently, these crystals are disposed of offsite as a
hazardous waste. One option available to the facility is to mix the crystals with the
industrial waste treatment sludge. Since this sludge is sent to a reclaimer, the copper
content in the crystals may bring Plant A a larger payment on reclaimed copper. This
practice Will also prevent Plant A from accumulating containers of crystals.

77
TREATMENT ALTERNATIVES

Waste reduction through alternative treatment can be achieved by modifying a treatment

system to reduce the volume of hazardous waste generated. One of the treatment
alternatives available to Plant A is segregation of waste streams, which is described earlier
in this report. Another treatment alternative available to Plant A is sludge dewatering.
Sludge Dewatering

Wastewater treatment sludge generated at Plant A is dewatered by a gravity filter system.

Although this type of dewatering can remove some of the free water in the sludge, it is not
as effective as mechanical dewatering. Analytical data for the waste treatment sludge show
that the gravity filter system can increase solids content to 11 percent. Mechanical
dewatering equipment can achieve a solids content up to 35 percent for most industrial
waste sludge. Figure A2 shows the decrease in sludge volume that ca,n be achieved by
increasing solids content. The figure shows that increasing the solids content from 10
percent to 35 percent reduces sludge volume from 80 gallons to 20 gallons.
Plant A now removes the sludge from the filter system and allows it to air dry in open
drums. This has significantly reduced the sludge volume, according to Plant A personnel.
However, this method of dewatering will not work during the rain season, and it also
presents problems for complying with the 9O-day accumulation limits placed on hazardous
waste generators. Therefore, the use of a mechanical dewatering system may be beneficial
for reducing sludge volume and also for complying with hazardous waste regulations.
Assuming a direct correlation between wastewater volume and sludge volume, Plant A
could also reduce its sludge generation by 80 percent. This would equal three drums less
each month at a savings at $50 per drum, or $150. Total savings for operating each rinse
tank as a batch rinse system could be as great as $1020 each month.
Savings from reducing the flow rate of water through each rinse tank depends on the
mini" flow rate that can be used to maintain adequate rinsing. In the Rinse Water
Reduction section, it was shown that the present flow rate of 16 gallons per minute creates
a ratio of process bath concentration to rinse solution concentration of 5,000 to 1. For
illustration purposes, assume the flow rate could be reduced to 12 gallons per minute; ratio
would be reduced to 3750 to 1. The rinsing requirements for Plant A rinse systems were
not available to the consultants. However, since the standard ratio of process chemical
concentration to rinse solution concentration used in the electroplating industry is
approximately lo00 to 1, a 25 percent reduction in flow rate, which produces a 3750 to 1
ratio, appears achievable. If the flow rate could be reduced by 25 percent: (1)water and
sewer fee savings would be $46 per month (based on a reduction in water usage of 34,600
-gallonsand water and sewer fees of $050 per 750 gallons each); (2)treatment chemical
savings would be $210 per month (based on a 25 percent reduction in existing treatment
chemical costs); and (3) sludge disposal cost savings would be $50 per month (based on a
25 percent reduction in sludge volume generated each month). Total savings would be
approximately $310per month.

78
 n
a
rl
200 -

40 --
30 -.
20 -
-
I
10 b I I I I I I

5 10 1s 20 25 30 35

SLUDGE S O L I D S CONCENTRATION ( % by w8ight)

FIGURE A2 - SLUDGE VOLUME VS SLUDGE SOLIDS CONCENTRATION

79
 The use of automated rinse water flow controls will require significant capital investment.
A pH/conductivity meter used to automatically turn rinse water on and off will cost
approximately $700 to purchase and install. If these controls were purchased for all nine
rinse tanks,the total a t would be $6,300. Savings would depend on the reduction in water
usage that could be achieved. Since drag-out rates for process baths and operating
parameters for the rinse systems were not available, estimates on saving that can be
achieved by installing automated flow controls cannot be calculated. However, one printed
circuit board manufacturer estimated that water use was reduced by 67 percent by installing
flow control meters. For illustrative purposes, a more conservative estimate of 25 percent
reduction in water use will be used. Therefore, the use of automated flow control meters
could also save Sun Circuits $310 per month. At that savings rate, payback on investment
would take 21 months.

Feasibility Analysis Phase

lk mcommended options wem evaluated fw their technical and economic f e d * by the

u"tr,who obtatradcmtandperfonnancedata~mvendors where new equipment w4s
rrecosnmended Thc mu& of the technical anii eo"& fearibw anaiysa was a list of
f d k options, which k a m e patt of the a s " m t 3 final report. ;T3re l ~ e r twaste
. e .
muwnuation ~ ~ e n t p h a sI cm, p ~ a t i WCLS
o ~kjt to the dircretion of theprinted circuit
board manuf-, P W R

The specific economic aspects of implementing each of the source reduction/resource

recovery options were not separately documented by Plant k Most of the source reduction
options employed are essentially good operating practices, and hence did not require a large
capital investment. However, the rework strategies and their evolution did require a large
R&D expenditure. The implementation of these measures seemed to be guided more by
the intuition and foresight of the plant personnel than by the calculated benefits that may
have been indicated by a specific detailed economic evaluation.

RINSE WATER REDUCI'ION

Operating the rinse tanks as batch rinse systems or reducing the rate of water flow through
the rinse tanks can be implemented for minimal costs, To operate the rinse tanks as batch
rinse systems, the plant would need additional labor to manually dump the rinse tanks.
Flow restrictors for reducing the flow of water through rinse tanks would require only minor
capital investments. The resulting savings in water usage, sewer fees, and treatment
- chemical costs would depend on the reduction in water use achieved.

Table A5 indicates that water usage can be reduced by 6,920 gallons per day, or
approximately 80 percent, if all the rinse tanks were operated as batch rinse systems.

80
 TABLE AS

RINSE WATER WASTE GENERATION

Time Water
TAf&"h iLlmnb Flow I?&2

-
2 96 minutes 1536 gallons
4 96 minutes 1536 gallons
7 96 minutes 1536 gallons
9 96 minutes 1536 gallons
10 96 minutes 1536 gallons
14 30 minutes 480 gallons
16 30 minutes
8640 gallons

8640 gallons wastewater generated each day.

Volume of
Number of Wastewater
33raubw d D&
2 12 360
4 12 360
6 12 360
8 12 360
10 12 360
14 2 60
16 2 AQ
1720 gallons

1720 gallons generated each day.

81
Assuming 20 work days per month, water usage could be reduced by 138,400 gallons each
month. Since both water usage and sewer discharge fees are approximately $0.50 per 750
gallons, Plant A would save approximately $190 each month on water and sewer fees by
reducing water usage by 138,400 gallons. As stated in Section 23, Plant A spends
approximately $850 each month on treatment chemicals. Therefore, an 80 percent
reduction in wastewater generation could reduce treatment chemical costs by as much as
80 percent. This would amount to a savings of $680 each month. Actual treatment
chemical savings may be less because the wastewater will have a higher contaminant
concentration and thus may require greater treatment chemical feed rates per volume of
wastewater. Reductions in sludge volume will depend on the efficiency of the treatment
system and the actual reductions in treatment chemical usage.
The use of various drag-out reduction techniques will increase the potential for reducing
rinse water usage because less process chemicals will enter the rinse system. By installing
a bar rail above each process tank for hanging workpiece racks, the plant could allow.for
greater drainage time before rinsing. This bar could be installed by Plant A personnel for
a few hundred dollars if constructed out of 1 inch PVC piping. Other drag-out reduction
techniques such as slowing workpiece rack removal rates and operating process baths at
the lowest possible concentration can be implemented for little cost. Savings associated
~ S t hdrag-out minimization cannot be quantified until the techniques are implemented.

EQUIPMENT CLEANOUT
Plant A can reduce waste nitric acid generation by using a multiple tank c1eani.q~line. The
costs associated with setting up such a system include the cost of additional tanks and the
installation labor costs. The costs for setting up a cascade cleaning line would be
approximately $350 per tank, Labor costs of $55 an hour for 4 hours would be $220.
The savings associated with a multiple tank plating rack cleaning line include reduced costs
for nitric acid purchases and waste acid handling. The consultants visited one plant that
used five 15-gallon tanks as a multiple stage cleaning line. The plant generates 15 gallons
of waste nitric acid every 6 months. If Plant A could reduce its waste nitric acid generation
from 60 gallons to 15 gallons per 6 months, it would achieve a savings of $140 in nitric acid
purchases and $90 in waste disposal costs each 6 months. This is based on nitric acid
costing approximately $3.10 per gallon and waste disposal costs being approximately $2.00
per gallon.

MATERIAL RECYCLING
The auditors identified three waste materials for recycling: (1) photoresist stripper waste,
(2) acidic rinse water effluent, and (3) copper sulfate crystals. Decanting or filtering spent
stripper waste so it can be reused will require minor purchases to set up a decantation
system or a filter system. Savings would include fewer fresh stripper purchases and lower
-stripper waste disposal costs. If decantation or filtration could be used to extend the
process bath life from 2 weeks to 4 weeks, Plant A could reduce stripper purchases by 30
gallons each month. Once the stripper becomes too dilute for continued use, it can be
filtered once more and used in the treatment system for pH adjustment. This could save

82
 Plant A $50 each month for disposal of stripper waste. A polymer sludge residue would
still be generated, however.

To implement a system to reuse rinse water effluent from rinse tank 16 for feed water into
rinse tank 14, Plant A would need to spend approximately $l,OOO. This includes $500 for
contractor labor for 1 day and $500 for materials that include piping materials and a three-
quarter horsepower pump, which would be adequate for a typical rinse system. Assuming
that both rinse systems operate at the same flow rate, no storage tank capacity would be
necessary.
Savings associated with recycling rinse water have been estimated based on Plant A's
current water usage. Water and sewer fee savings would be approximately $13 each month
based on a reduction in water usage of 500 gallons each day. Since wastewater generation
would be reduced by 5 percent, treatment chemical usage could also be reduced by
approximately 5 percent. A 5 percent reduction in the company's existing treatment
chemical costs, which are $850 per month, would save Plant A $42 each month in treatment
chemical purchases.

L..
Copper sulfate crystals generated by Plant A could be recycled by adding them to the
industrial waste sludge. There is no additional cost associated with mixing the crystals and
the sludge since the crystals are also handled as hazardous waste if kept separate. Since
the sludge is sent to a metal reclaimer, Plant A may be able to save money because the
copper content of the sludge will be increased and, therefore, a larger payment for
reclaimed metals will be received

WASTE SEGREGATION
The costs and savings associated with segregating chelated and nonchelated waste streams
will depend on the design requirements of the segregation and the modifications to the
treatment system that can be made once the materials are segregated. Assuming
L-
segregation will only entail installing a 500-gallon storage tank, pumps, gauges, and
necessary piping, equipment costs would range between $2,OOO and $4,0o0. Double
containment would be more wrpensive. In addition, installation costs may be as high as 100
percent of equipment costs.
As discussed in Section 5.1, the ferrous sulfate used to treat the wastewater contributes
approximately 34 percent of the total sludge volume. The ferrous sulfate also costs Plant
A approximately $250 each month to purchase. Savings associated with segregating
chelated waste streams and batch treating them will depend on the percentage of ferrous
c sulfate usage that can be eliminated through batch treatment of chelated waste streams.
Since information on which process chemicals contain chelators was not available to the
audit team, development of segregation alternatives and estimates for material and waste
disposal cost savings could not be developed.

83
SLUDGE DEWATERING
Small filter press units designed to handle from 0.75 to 3.75 gallons of sludge per load cost
between $2,800 and $4,900. Assuming that Plant A already has a source of compressed air,
the company can install the unit itself. The unit can handle 7.5 to 37.5 gallons of sludge
per 5-day work week. These units can increase solids content from 1 percent to
approximately 35 percent. Plant A’s current bag filter dewatering unit can achieve a sludge
solids concentration of 11 percent. An increase in solids concentration from 11percent to
35 percent will reduce sludge volume by approximately 75 percent. This could reduce the
plant’s sludge generation from approximately 200 gallons to about 50 gallons per month.
Since Plant A estimates that sludge disposal costs approximately $1.00 per gallon, this
sludge dewatering could save the company approximately $150 each month in disposal costs.

SUMMARY
The audit of Plant A ms performed to identify opportunities for waste reduction. The
following hazardous wastes are generated by Plant A each month:
o Industrial waste sludge Approximately 200 gallons
o Photoresist stripper waste - Approximately 60 gallons
o Copper sulfate crystals - Undetermined
0 Nitric acid waste - Approximately 10 gallons
0 Reflow oil - Undetermined

The audit provided information that is useful to identify several waste reduction techniques
that may be feasible for Plant A to implement. The following waste reduction opportunities
were identified:
Use process chemistries that can be recycled or treated when they are spent instead
of chemistries that currently are containerized for off-site disposal.
Use non-chelated process chemistries to replace chelated chemistries.
Operate the rinse tanks as batch rinse systems.
Reduce the flow rate used in the flow-through rinse tanks.
Use flow restrictors and automated flow controls to reduce rinse water usage.
Aggressively pursue drag-out reduction by developing operational procedures and
training personnel to slowly remove workpiece racks and increase drainage time
prior to rinsing.
Install a multiple-stage electroplating rack cleaning line to reduce nitric acid waste
generation.

84
o Reuse rinse water effluent from rinse systems following acidic baths as rinse water
influent to rinse systems that follow alkaline cleaning baths.
o Mix copper sulfate crystals with industrial waste sludge for off-site metals
reclamation.
o Segregate chelated waste streams from non-chelated waste streams and batch treat
them.
o Dewater sludge using a mechanical filter press.

References
DHS. 1987. Waste Audit Study - Printed Circuit Board Manufacturers. June 1987.
Prepared for California Department of Health SeMces, Alternative Technology Section
(Sacramento, California) by Planning Research Corporation.

85
t
 PLANT B WASTE MINIMIZATION ASSESSMENT

The waste “ h a t i o n assessment of Plant B followed the same protocol used for Plant
A, and included:

I . o Planning and organization

o Assessment phase
0 Feasibility analysis phase
Implementation of selected waste minimization options was left to the discretion of Plant
B.

Planning and Organization

P l a n n i n g d o r gMiurtion of the assessment were a joint of the wmdtingjh and the

PC board m a n u f ~ p l a n t ’operetiolls
s “ger. As sz”&d in Figure 1.1, thirphare
of the assessment involved getting company management commitment to the project, setting
goals for the assessment, and establishing a task f m e (the coIIsultants working in coopetation
with the prcUtt openations manager) to conduct the assessment.

Assessment Phase: Process and Facility Data

The consultants worked with the plant operahbrts manager to estabkh a data base of the
facility3 mw materid wetis, mat- handlingprtxedimx, and opemtions pmesses. Block
flow d@”swere dmwn up to id en^@ where materials are used and where waste irgenemteti
Initial study of this informotion and discussions of warte stream concems at the plant served
as preliminary steps to the site inspection, during whkh additionalpnxess a d waste handling
infomation was obtained

FACILITY DESCRIPTION
Plant B is a prototype circuit board manufacturer specializing in jobs involving limited
production and fast turnaround. Manufacturing operations include drilling and routing,
layering (for multilayer boards), photoresist printing, plating, etching, and stripping.

86
PROCESS DESCRIPTION
Figure B1 is a floor plan of the plant's plating and etching process area. The numbers
listed in the floor plan represent the identification number for each process bath and rinse
tank. Tables Bl and B2 describe Plant B s rinsing operations and chemical process baths,
respectively.
The plant presently uses seven dip tanks and two spray rinse tanks. All the dip rinse tanks
are equipped with pH/conductivity meters that control the flow of water through the rinse
tanks. The spray rinse tanks are all operated with foot pedals for turning on the water.

WASTE DESCRIPTION

Production activities that generate hazardous waste are the plating, etching, and stripping
processes. The sources of waste from these activities are rinsing operations, spent process
bath dumping, and industrial waste treatment, and equipment cleanout. This chapter
describes the hazardous waste generating and handling activities performed at Plant B and
describes the volume and characteristics of the hazardous wastes generated. Table B3 lists
Plant B s hazardous waste management characteristics.

Rinsing Operations
Rinsing operations associated with the chemical process lines are the major source of
wastewater at Plant B. Wastewater generation fluctuates between 7,000 to 11,OOO gallons
per day. The rinse operations contribute to hazardous waste generation because waste rinse
water carries away chemicals which are then removed by treatment at the industrial waste
treatment plant. The sludge that is generated from this treatment is handled as a hazardous
waste.

Spent Chemical Bath Dumping

When process chemical baths become too contaminated or diluted for use (spent), it is
removed from the process tank. The spent chemical bath is then either containerized for
reclamation by the manufacturer, containerized for off-site disposal, used as a neutralization
chemical in the industrial waste treatment system, or dumped into the wastewater collection
sump. A schedule for dumping each spent process bath was not available from Plant B,
but plant personnel indicated that the frequency varies. A bath is changed when personnel
recognize that the effectiveness of the bath is no longer adequate.

87
 Electroplating Precleaning

32
. c

-
3/ Etchbac k
7

~1
30

Electroless Copper -
29 I 15- I 8
Electroplating
-
28

-
27
23 28
9

26
119 I
-
25
/O
2u
1

7
Ref1ow

3
1
J

1 7
C

FIGURE B1
PLANT B’S ETCHING
AND PLATING
FACILITY
88
 TABLE B1
RINSE SYSTEM INFORMATION

RINSE TANK/ RINSE WATER NUMBER COUNTER PROCESS BATH

NUMBER FLOW CONTROLS OF TANKS CURRENT PRECEDING
INSYSTEM SYSTEM RINSE

Dip Rinse/l pH/Conductivity one no Ammonium

Meters Bifluoridep

Dip Rinse/3 pH/Conductivity one no MBL Cleaner/4

Meters
Dip Rinse/S pH/Conductivity one no 98% sulfuric
Meters Aad/6

Dip Rinse/U pH/Conductivity one no Black Oxide/ll and

Meters Tin Immerse/U

Drag-outll4 Manual Dumping one NA

Spray Rinse/lS Footpedals one NA Drag-out Tank/l4

Drag-out / 18 Manual Dumping one NA --
Spray Rinse/l9 Footpedals one NA Drag-out Tank/l8

Dip Rinse/% pH/Conduct ivity two no Rinse Tank/27

Meters
Dip .Rinse/27 pH/Conductivity two no Catalyst
Meters
Dip Rinse/30 pH/Conductivity OLlc no Sulfuric-Peroxide
Meters Etch/31
Dip Rinse/32 pH/Condu&ty one no Cleaner-Conditioner
Meters /33

89
 TABLE B2
PROCESS BATH INFORMATION

PROCESS BATH/ PROCESS BATH METHOD OF

NUMBER VOLUME (gallons) DISPOSAL

Ammonium Bifluoride/Z To wastewater treatment facility

MBL Cleaner/4 To wastewater treatment facility

98% Sulfuric Acid/6 To wastewater treatment facility

Tin-Lead Bath/7 --
Fluorboric Acid18 To wastewater treatment facility

Copper Sulfate/9
Copper Sulfate/lO --
Black Oxide/ll To wastewater treatment facility

Tin Immcrsell3 To wastewater treatment facility

10% Sulfuric Acid/l6 To wastewater treatment facility

Sulfuric/Pcroxide Etch/l7 To wastewater treatment facility
Soap Cleancr/U] To wastewater treatment facility
Reflow Flw/21 off-site disposal

Reflow Oi1/22 off-site disposal

Reflow Oi1/23 Off-site disposal

Electroless Copper/24 To wastewater treatment facility

Accelerator/25 To wastewater treatment facility
Catalyst/28 To wastewater treatment facility
Catalyst Prep/% To wastewater treatment facility
Sulfuric-Peroxide Etch/31 To wastewater treatment facility
Cleaner-Conditioner/33 To wastewater treatment facility

90
 TABLE B3. HAZARDOUS WASTE DATA

ANNUAL ANNUAL
QUANTITY DISPOSAL DISPOSAL DISPOSAL
WASTE GENERATED METHOD COST/UNIT COSTS

Industrial mgal. off-site w 5 5 Bat $240

Treatment metal drum
Sludge redpmatioll

Photoresist -- off-site 5100/55 gal. ---

Stripper &posol drum
Nitric Acid 30 gal. off-site Sl00/55 gal. $50
disposal drum

Reflow Oil "l

. off-site 5100/55 gal. 5300
d i
J m drum

Only two of the spent bath handling methods contribute to the amount of hazardous waste
generated at the plant. These methods include containerizing spent baths for off-site
disposal and dumping of spent chemical baths into the wastewater sump. The only process
chemical baths containerized for disposal are the photoresist strippers and the reflow oil.
Approximately 25 gallons of waste reflow oil is generated every 2 months. The volume of
stripper waste generated was not estimated by Plant B. Chemical baths treated at the
industrial waste treatment facility are transferred to one of the two wastewater sumps where
the chemicals are neutralized. The waste is then fed into the industrial waste treatment
system.
Copper sulfate crystals are also generated when some of the process baths are taken off-
line. The crystals form in the process bath as the copper concentration increases. Before
the process baths are dumped into the wastewater sump, the crystals are containerized as
a solid waste since they m o t be fed into the treatment system. The crystals are mixed
with the plant's industrial waste sludge, which is transported offsite for metal reclamation.

Industrial Wastewater lkatment

Plant B's industrial waste treatment facility treats all wastewater prior to discharge to the
San Jose/Santa Clara Water Pollution Control Plant. Plant B's treatment facility removes
. metals and adjusts the pH of the wastewater to meet the maximum allowable concentration
of metals in the discharged effluent, as set by the San Jose/Santa Clara Water Pollution
Control Plant. These maximum concentrations are as follows:

91
 Chromium 1.0mg/L
Copper 2.7 mg/L
Cyanide 1.0 mg/L
Lead 0.4 mg/L
Nickel 2.6 mg/L
Silver 0.7 mg/L
Zinc 2.6 mg/L

The treatment process includes neutralization, metals precipitation, filtration, and sludge
dewatering. The treatment plant is located outside the main building in a curbed area.
The metal hydroxide sludge generated by this treatment process is a hazardous waste. The
treatment system generates approximately 25 gallons of sludge every month. The sludge
dewatering unit produces a sludge that has a solids concentration of 35 percent. The sludge
is transported offsite to World Resources of Phoenix, Arizona for metal reclamation.
World Resources analyzes a sample from each load of sludge it receives. The analytical
data provided by World Resources for the sludge generated by Plant B are as follows:
Percent solids - 35%
Metal content in pounds per dry ton

Copper . 250
Nickel 11
Tin 59
Iron 12
Lead 22
Zinc 8

Equipment Cleanout

The primary source of hazardous waste associated with equipment cleanout is the cleaning
of electroplating racks. Plant B uses nitric acid in a five tank cleaning line to clean
electroplating rack. Each tank holds approximately 15 gallons of nitric acid. The acid in
the first tank requires changing approximately every 6 months. When the nitric acid in the
first tank is dumped, the remaining four tanks all move up one step in the cleaning line.
The empty tank is filled with fresh nitric acid and is used as the last tank in the cleaning
line. The waste nitric acid has too low a pH and too high a copper content to be treated
in the industrial waste treatment system.
Other cleaning activities, such as floor washing and chemical bath tank riming, generate
-waste streams that discharge into the wastewater collection sump. According to Plant B
personnel, these waste streams make up a small portion of the chemicals that enter the
treatment system.

92
 I

Assessment Phase: Option Generation

After the Sire inspectiOrr, the plant opetatiorrS manager a d the c o d a n t team teviewed the
mw maten!& p r v c u , and waste stremn inf- n and devebped a number of warte
minimiration options for cons&mtioa %e oprionr f d into the catq& of some
redrrction techniques and raycling and m o m e movery techniques

SOURCE REDUCTION MEASURES

Plant B appears to have effectively implemented several technologies to reduce the volume
of hazardous waste it generates. Water consexvation techniques, such as rinse water flow
control meters and pressure activated spray rinse tanks, are presently used at the plant.
The industrial waste treatment system appears to effectively treat wastewater without
producing excessive volumes of sludge. Plant B personnel stated that their egluent
consistently meets the discharge requirements set by the San Jose/Santa Clara Water
Pollution Control Plant. Also, the volume of sludge generated by the wastewater treatment
system is lower than the volume generated at other manufactwing plants of comparable size
and wastewater generation rates. For example, Plant B generates approximately 50 gallons
of sludge every 2 months compared to another plant with a comparable wastewater
generation rate that generates approximately 200 gallons of sludge every month.
Nevertheless, several additional opportunities for waste reduction may be available to Plant
B that can further reduce its hazardous waste generation. This section describes these
opportunities.

MATERIAL SUBSTITUTION
Plant B may be able to reduce the volume of spent process chemicals and cleaning solutions
containerized for off-site disposal by substituting materials. Two materials that Plant B
handles as hazardous waste are spent reflaw oil and spent nitric acid. Several reflow oil
products are available that,when spent,either can be returned to the supplier for recycling
or can be treated by the facility prior to discharge to the Publicly Owned Treatment Works.
Plant B could eliminate a hazardous waste stream by replacing its present reflow oil with
a recyclable or treatable reflow oil.
Nitric acid waste, which is generated from the cleaning of electroplating racks, can also be
eliminated by using an alternative cleaning solution. One chemical supplier offers an
electroplating rack cleaning solution that can be regenerated. The metal stripped offof
racks during the cleaning process can be plated out in a tank equipped with a cathode and
an anode. The metal stripped from the racks is plated onto the cathode and forms a
metallic sludge that settles to the bottom of the cleaning tank. Once the solution becomes
spent, it can be treated in the plant’s industrial treatment system instead of being
containerized for off-site disposal. Plant B should consult with chemical suppliers to

93
 I

identify alternative materials that can be recycled or treated and that will meet its specific
operating requirements.
DRAG-OUT LOSS REDUCTION

Discussions with Plant B personnel indicated that little attention is placed on drag-out
reduction. Although the plant does not generate excessive amounts of sludge, further
reductions in sludge volume may be obtained by using drag-out reduction technologies.
Reductions in drag-out loss should also have a direct impact on water usage. Since water
flow through the rinse systems are controlled by pH/conductivity controls, drag-out
reduction will decrease the frequency of rinse water flow through the rinse tanks. Plant B
may be able to reduce drag-out by instituting operational modifications and training
personnel in drag-out reduction techniques. Drag-out reduction techniques include slowing
the workpiece rack withdrawal rates and increasing drainage time prior to rinsing. Other
drag-out reduction methods include operating process baths at the lowest allowable
concentration and using heated process baths when possible.
The faster an item is removed from the process bath, the thicker the film on the workpiece
surface and the greater the drag-out volume will be. The effect is so significant that most
of the time allowed for withdrawal and drainage of a rack should be used for withdrawal
only. Plant B management should emphasize to process line operators that workpieces
should be withdrawn slowly. An optimal removal rate. can be determined by removing
loaded workpiece racks from process baths at Merent rates and allowing the rack to drain
into a catch basin. Drag-out volume can then be measured volumetrically.
Workpiece drainage also depends on the operator. The time allowed for drainage can be
inadequate if the operator is rushed to remove the workpiece rack from the process bath
and place it in the rinse tank. However, installation of a bar or rail above the process tank
may help ensure that adequate drainage time is provided prior to riasing. Plant B has
expressed concern that increasing workpiece rack removal and drainage time will allow for
chemical oxidation on the board. Plant B should identify the proasses that are not highly
susceptible to oxidation and emphasize drag-out " k a t i o n techniques to personnel
operating those processes.

RINSE WATER RECYCUNC

Plant B may be able to recycle its rinse water by further treating effluent from the industrial
waste treatment plant. This additional treatment may only require activated carbon
treatment to remove traa organics from the water. Plant B should assess the need for
other levels of treatment, such as ion-cxchange or other technologies, based on the quality
of the treated effluent. This recycled water would contain less natural contaminants,such
as phosphates and carbonates, than tap water, which is presently used. Since these natural
contaminants contribute to sludge volume because they precipitate during treatment, the
-useof recycled rinse water can reduce hazardous waste sludge generation and sigdicantly
reduce water usage and sewer discharge fees.

94
 Feasibility Analysis Phase

Afler dkcumons with Plant B personnel, some of the options &cussed in the previous section
were selected for investgath of their techkal and economic feasibility. The economic
an&& war bared on the mw material and w e & p o d costs pmvided by the facility
personnel and on economic and technical infomation pnovi&d by eqwpment m a n u f a n .
The meczflues evaluated in thk section include.- material substhtion, drag-out bss teduction
and rinse water mycling.

MATERIAL SUBSTITUTION
The benefits associated with using recyclable and/or treatable process chemistries will
depend on the costs of substitute materials cornpared with the costs of materials presently
used. Also, additional process bath maintenance requirements and treatment costs need
to be identified. These costs will depend on the type of substitute material chosen by Plant
B.
Savings will include reduced waste disposal costs and material usage costs if the substitute
material can be recycled. Plant B generates 150 gallons of waste reflow oil and 30 gallons
of waste nitric acid annually. Since waste disposal costs for the waste reflow oil and waste
nitric acid are both $100 per 55-gallon drum, which is the average cost for disposing of
various liquid hazardous wastes according to PC board manufacturers, waste disposal cost
savings would be approximately $300 per year for spent reflow oil and $50 per year for
nitric acid waste. Actual savings associated with using recyclable reflow oil and nitric acid
will depend on the difference in the cost of the substitute materials.

DRAG-OUT LOSS REDUCTION

Several drag-out " k a t i o n techniques can be implemented at Plant B for minimal
costs. The use of a bar rail above each process tank for hanging workpiece racks will allow
for greater drainage time before rinsing. This could be installed by Plant B's personnel for
a few hundred dollars if constructed of 1 inch PVC piping. Other drag-out reduction
techniques, such as slowing workpiece rack removal rates and operating process baths at
the lowest possible concentration, can also be implemented for little cost. Developing a
training program and emphasizing drag-out " i r r a t i o n will require time from
management and operations p e r s 0 ~ ~ 1Since
. information on drag-out rates and workpiece
rack removal and drainage times were not available from Plant B, savings associated with
. drag-out " h t i o n cannot be quantified prior to implementation.

95
P

RINSE WATER RECYCLING

Considerable capital investment may be needed to recycle wastewater for reuse in
I production. The costs associated with recycling treated wastewater effluent will depend on
the level of additional treatment necessary to return the effluent back into the production
processes. Other plants that are considering rinse water recycling have indicated that their
primary concem is to remove organics from the treated effluent before reusing the water.
An activated carbon system to treat the effluent can be used to remove organics from the
water. If various anions and/or cations in the effluent must also be removed, treatment
technologies such as reverse osmosis or ion-exchange may be required.
Information describing the rinse system operating parameters and the water quality or Plant
B’s treated effluent were not obtained during the audit. Therefore, treatment requirements
for returning treated effluent to the rinse systems could not be developed. Plant B should
investigate the potential for recycling rinse water by characterizing its rinse water emuent,
determining the water quality needs for reusing treated effluent, and identifying potential
technologies that can be used to treat the effluent for reuse.
Tbe primary savings associated with recycling rinse water is lower water purchase and
sewer discharge fees. Plant B generates approximately 7,000 to 11O , OO gallons of
wastewater each day. For an average daily water usage of 9,OOO gallons, and assuming that
90 percent of the water can be recycled, Plant B could reuse approximately 8,000 Mons
i
of water each day. Since water and sewer fees are both approximately $050 per 750
gallons, Plant B could save approximately $10 each day in water and sewer costs.
1
i
i

i SUMMARY
The audit of the Plant B was performed to identify opportunities for waste reduction. The
t following hazardous wastes are generated by Plant B an nu all^
IndWrid waste Sludge - Approximately 300 gallons
Photoresist stripper waste -- Undetermined
Coppersulfatecrystals Undetermined
Nitric acid waste - Approximately 30 gallons
Reflow oil - ApprorCimately 150 gallons
The audit was used to identify several waste reduction techniques that may be feasible for
Plant B to implement. The following waste reduction opportunities were identified:
o Use alternative reflow oil and electroplating rack stripper materials that can
be recycled or treated when they are spent instead of chemistries that
currently are containerized for off-site disposal.
~ o Aggressively pursue drag-out reduction by developing operational procedures
and training personnel to slowly remove workpiece racks and increase
drainage time prior to rinsing.
o Recycle treated effluent for reuse in the production process.
 PLANT C WASTE MINIMIZATION ASSESSMENT

The waste " h a t i o n assessment of Plant C followed the same protocol used for Plant
A, and included:

0 Planning and organization

o Assessment phase
0 Feasibility analysis phase
Implementation of selected waste minimization options was left to the discretion of Plant
C.
Planning and Organization

Planning and organization of the arsesrment were a joint @OH of the connrltingjh and the
~ ~ operatiorts manager. As summarired in Figure 1.1, this phase of
paint m a n u f plant's
the assessment involved getting company mamgment commitment to the pmject, setting go&
for the arresrment, and establishing a task fotce (the c o d m w ow in coopemlion with
the plant opemtaons manager) to condl(ct the mesment.

Assessment Phase: Process and Facility Data

The c o " t s worked with the plant o p e " mmuligcT to establish a data base of the
facility's mw material needr, mat- handling pmedum, and operuttom p m a s a Block
flow d@"s were dmwn up to i&nt# where materials me usedand were waste isgenerated
I& study of thk infonnation and tihusiom of waste stremn concems at the plant served
as preliminmy steps to the site inrpecton, during which additionapmas and waste handling
infomation was obtained

FACILITY DESCRIPTION
Plant C is a prototype circuit board manufacturer specializing in jobs involving limited
production and fast turnaround. Manufacturing operations include drilling and ,routing,
layering (for multilayer boards), plating, and etching.
PROCESS DESCRIPTION
- Figure C1 is a floor plan of the plant's plating and etching process area. The numbers
listed on the floor plan represent the identification number for each process bath and rinse
tank. Tables C1 and C2 describe Plant Cs rinsing operations and chemical process baths,
respectively.

97
 26 27 20
Electroplating

Electroplating Precleaiii ng

Ref 1 ow
7
El ec trol ess Copper
n

FIGURE Cl
PLANT C'S
ETCHING A N 0 PLATING
B;ACII.BT\r'
 I

TABLE C1
RINSE SYSTEM INFORMATION

RINSE SYSTEM NUMBER COUNTER PROCESS BATH

NUMBER OF TANKS CURRENT PRECEDING RINSE
SYSTEM SYSTEM
k.

Dip Rinse/3 One No Soap Cleaner/Z

L Dip Rinse/S Two No Peroxide Etchba&/4

Dip Rinse/6 Two No Dip Rinse Tank/S
L Dip Rinsc/9 One No Catalyst/8

Dip Rinse/l2 One No Electroless Coppcr/ll

i.
Dip Rinse/l5 TWO No Tin/Lead Strippcr/l4
Dip Rinse/l6 TWO No Dip Rinse Tank/S
i
Dip Rinsc/20 TWO No Micro Etch Clcaner/l9

L
Dip Rinse/21 TWO - NO Dip Rinse Tank/20
Drag-out/27 One No Copper Sulfate/%
Drag-out/B One No Tii-Lead/28
L

Dip Rinsc/30 TWO No Reflow Oil/17

L Dip Rinsc/31 TWO No Reflow Oi1/17

L
99

k
 TABLE C2
PROCESS BATH INFORMATION

PROCESS BATH/ PROCESS BATH METHOD OF

IDENTIFICATION NUMBER VOLUME IN TANK DISPOSAL

Nickel Sulfatejl Discharge to treatment facility

Soap Cleaner/2 Discharge to treatment facility

Peroxide Etchback/4 Discharge to treatment facility

10% Hydrochloric Acid/7 Discharge to treatment facility

Catalyst/8 Replenished, not disposed

Accelerator/lO Discharge to treatment facility

Electroless Copper/ll Replenished, not disposed

10% Hydrochloric Acid/U Discharged to treatment facility

Ti/Lcad Stripper/l4 Discharged to treatment facility

Reflow Oi1/17 off-site & p o d

Ammonium Etchant/lS Recycled by manufacturer

Micro Etch Clcaaer/l9 Dkhargcd to treatment facility

Sulfuric Acid/= Dischatged to treatment facility

Fluorboric Acid/= Discharged to treatment facility

Solder Bright/24 Dischugd to treatment facility

Nitric Acid/= off-site disposal

Copper Sulfate/% Replenished, not disposed

Tin-Lead/28 Replenished, not disposed

100
WASTE DESCRIPTION
Production activities that generate hazardous waste are the plating and etching processes.
The sources of waste from these activities are rinsing operations, spent process bath
dumping, industrial waste treatment, and equipment cleanout. This chapter of the report
describes the hazardous waste generating and handling activities performed at Plant C and
describes the volume and characteristics of the hazardous wastes generated. Table M lists
Plant Cs 'hazardous waste management characteristics.
Rinsing Operations
Rinsing operations associated with the chemical process lines are the major source of
wastewater at Plant C. Facility personnel estimate that approximately 3,000 gallons of
wastewater are generated each day. The rinse operations contribute to hazardous waste
generation because waste rinse water carries away chemicals which are then removed by
treatment at the industrial waste treatment plant. The sludge waste that is generated from
this treatment is then handled as a hazardous waste.
The plant uses 11 dip rinse tanks that discharge to the industrial waste treatment plant and
two drag-out tanks that are periodically dumped manually into the wastewater sump. All
of the rinse tanks are plumbed directly to the wastewater treatment system via a collection
sump. Discussions with facility personnel indicate that water flows through the dip rinse
tanks only when the process line associated with the tank is in operation. Water flow for
each rinse tank is turned on and off manually by production personnel. Plant C installed
flow restrictors in each rinse system's water inflow line to control water usage.

TABLE C3
HAZARDOUS WASTE DATA

ANNUAL ANNUAL
QUANTITY DISPOSAL DISPOSAL DISPOSAL
WASTE GENERATED METHOD COSTS

101
 I

Four of the rinsing operations are double rinse tank system (tanks 5 and 6, tanks 15 and
16, tanks 21 and 22, and tanks 30 and 31). These four rinse systems, however, are not
plumbed in series as counter-current rinse systems. Instead, each tank has a separate rinse
water influent and eMuent water line.
Spent Chemical Bath Dumping
When process chemical baths become too contaminated or diluted for use (spent), they are
removed from the process tank. The spent chemical bath is then either containerized for
reclamation by the manufacturer, containerized for off-site disposal, or dumped into the
wastewater collection sump. A schedule for dumping each spent process bath was not
available from Plant C,but plant personnel indicated that the frequency varies. A bath is
changed when personnel recognize that the effectiveness of the bath is no longer adequate.
Only two of the spent bath handling methods contribute to the amount of hazardous waste
generated at the plant. These methods are containerizing waste for off-site disposal and
dumping of spent chemical bath into the wastewater sump. The process chemical bath
containerized for disposal is the reflow oil. Tbe plant generates approximately 20 gallons
of waste reflow oil each month.
Other process baths are discharged to the treatment plant when they are spent (except for
the etchant, which is sent back to the supplier for reclaim). Copper sulfate crystals are also
generated when some of the process baths, such as the peroxide/sulfuric etch, are taken off-
line. The crystals form in the proccss bath as the copper content increases. &fore the
process baths are dumped into the wastewater sump, the crystals are removed and
containerized as a solid hazardous waste since they cannot be fed into the treatment system.
Plant C did not estimate the volume of copper sulfate crystals generated each month.

Industrial Wastewater 'batment

Plant Cs industrial waste treatment faciiity treats all wastewater prior to discharge to the
San Jose/Santa Clara Water Pollution control Plant. Plant Cs treatment facility removes
metals and adjusts the pH of the wastewater to meet the maximum allowable concentration
of metals in the discharged effluent, as set by the San Jose/Santa Clara Water Pollution
Control plan^ These maximum concentrations are as follows:
chromium l.Omg/L
Copper 2.7 mg/L
Cyanide 1.0 mg/L
Lead 0.4 mg/L
Nickel 2 6 mg/L
Silver 0.7 mg/L
zinc 2.6 mg/L

-The treatment process includes filtration, ion-exchange, and neutralization. The ion-
exchange (IE) system was recently installed to replace Plant Cs conventional
precipiktion/cl&er treatment system. The Ion Exchange unit has a treatment capacity
of 12 to 14 gallons per minute. The Ion Exchange unit produces less hazardous waste than

102
the old treatment system. The hazardous waste generated by the Ion Exchange treatment
process is spent ion-exchange resin. Approximately 100 gallons of waste resin are generated
each month, compared to approximately 300 gallons of sludge generated by the old
treatment system.

Equipment Cleanout
The primary source of hazardous waste associated with equipment cleanout is the cleaning
of the copper etching tank,the tanks used in the electroplating line, and the electroplating
racks. This equipment is cleaned by using nitric acid. Plant C estimates that approximately
40 gallons of waste nitric acid are generated each month. The waste nitric acid has too low
of a pH and too high of a copper content to be discharged to the treatment facility.
The nitric acid solution is stored in a single SO-gallon tank where electroplating racks can
be immersed in the solution for cleaning. The nitric acid is used to strip the copper, tin,
and lead from the equipment. When the acid loses its ability to effectively oxidize the
metal, it is containerized for disposal. Electroplating rack cleaning is the greatest source
of waste nitric acid.

Assessment Phase: Option Generation

Afler the d e kpectbn, the plant opercrtiOnr "qer and the consultan! team rwiewcd the
raw mat- pmctw, and waste stream b j b m d o n and developed a number of waste
minimtation options for con&" ' a W e options fdinto the categoties of some
redrcction techniques and recycling and resoLuI=c recovay tehkpuzs

SOURCE REDUCIlON MEASURES

plant C appears to have effectively implemented several technologies to reduce the volume
of hazardous waste it generates. Water consewation techniques such as rinse water flow
restricton are presently used at Plant C,the plant's water use appears to be significantly
lower than that of other plants of comparable size and production. For example, two other
plants visited by the consultant generate approximately 10,000gallons of wastewater each
day compared to 3,000 gallons generated by Plant C each day. The ion exchange treatment
system effectively treats wastewater without producing a hazardous waste sludge. This new
treatment system produces approximately 100 gallons of spent ion exchange resin each
month, with no sludge generated; the old treatment facility produced approximately 300
gallons of sludge each month. Nevertheless, several additional opportunities for waste
reduction may be available to Plant C to further reduce its hazardous waste generation.
This section describes these opportunities.

103
 I

Material Substitution
Plant C may be able to reduce the volume of spent process chemicals and cleaning solutions
containerized for off-site disposal by substituting materials. Two materials that Plant C
handles as hazardous waste are spent reflow oil and spent nitric acid. Several reflow oil
products are available that, when spent,either can be returned to the supplier for recycling
or can be treated by the facility prior to discharge to the Publicly Owned Treatment Works.
Plant C could eliminate a hazardous waste stream by replacing its present reflow oil with
a recyclable or treatable reflow oil.
Nitric acid waste, which is generated from equipment cleanout, can also be eliminated by
using an alternative cleaning solution, One chemical supplier offers an electroplating rack
cleaning solution that can be regenerated. The metal stripped off of racks during the
cleaning process can be plated out in a tank equipped with a cathode and an anode. In this
method, me.@ stripped from the racks is plated onto the cathode and forms a metallic
sludge that settles to the bottom of the cleaning tank. Once the solution becomes spent,
it can be treated in the plant’s industrial treatment system instead of being containerized
for off-site disposal. Plant C should consult with chemical suppliers to identify alternative
qaterials that can be recycled or treated and that will meet its specific operating
requirements.

RINSE WATER REDUCTION

Plant C can reduce rinse water usage, as well as reduce the quantity of hazardous chemicals
entering the waste stream, by converting several of its double tank rinse systems into two-
stage, closed circuit counterarrent rinse systems. By reducing water usage and quantity
of chemical wastes, the load on the treatment system will be reduced and the longevity of
the ion exchange resin can be increased. The plant currently uses four double tank rinse
systems (tanks 5 and 6, tanks 15 and 16, tanks 20 and 21, and tanks 30 and 31; see Figure
Cl). Each tank,however, is plumbed separately. If the two tanks associated with each of
the four rinse systems were plumbed in series as counter-current rinse systems, the plant
could significantly reduce its rinse water use. Figure C2 illustrates the set-up for a two
stage counternurent rinse system.
Plant C did not provide data on the flow rate used for each rinse tank. Therefore,
calculations on actual water use savings cannot be presented. However, the following
example illustrates how a counternurent rinse system can reduce water use compared with
the present rinse system used at the plant. A facility operates a two stage rinse system with:
(1) each tank having a separate water inflow line; (2) a water flow rate of 10 gallons per
minute; and (3) the rinse water for the system tumed on a total of 120 minutes per day.
The total water usage for this system would be 2,400 gallons per day. The following
equation can be used to illustrate how a two stage counternurent system could reduce
rinse water usage at the facility:

Q [(CJCJ’’” + l/n]D

104
 f
L

r. k

i
I aJ
i 3

w 2c
k
a
s
cr
3
Q)
2c
0
3cr
0
rc
3
cd
tL
u"

L Q)
0
rc
J
3
0 Q
a" p3

105
 Q = rinse tank flow rate
D = drag-out rate
= chemical concentration on process solution
c* = allowable chemical concentration in rinse solution
cr
n = number of rinse tanks in series
Several assumptions must be made to use this equation. These are as follows:
o The concentration of chemicals in the rinse solution cannot exceed 1/1OOO of
the concentration of chemicals in the process bath. This value is a common
parameter used in the electroplating industry for rinse water contaminant
concentration.
o The drag-out rate of chemicals used for manufacturing printed circuit boards
is approximately 15 ml/ft? of board. This value is a standard approximation
used for estimating drag-out created by a printed circuit board.
o An average workpiece rack holds approximately 2.5 f? of boards (example:
30 4inch by 3-inch boar&).
The drag-out rate for each workpiece rack is:
15 ml x 23 f+ = 375 ml.
Converted to gallons, drag-out equals 0.01 gallon.
By substituting the values into the equation:
[(1000)'/2 + 1/21 0.01 gallonslminute = 032 gallon/minute.

Therefore, if the facility converted its existing rinse system into a twwtage closed circuit
counter-current rinse system, it could reduce the flow rate from 10 gallons per minute
through each tank to 032 gallon per minute through both tanks. This would in theory
reduce the daily w t e r usage from 2,400 gallons to 38 gallons and would significantly reduce
the quantity of iiuardous chemicals entering the shop's treatment system. The actual
volume of rinse water reduction that can be achieved by Plant C depends on the drag-out
rate from the plant's pnwxss baths and the rinse system parameters for the four double
rinse tank systems.

DRAGOUT LOSS REDUCIlON

Discussions With Plant C personnel indicated that little attention is placed on drag-out
reduction. The plant may be able to generate less spent ion-exchange resin by using drag-
~ out reduction technologies. Reductions in drag-out loss should also have a direct impact
on water usage. Since water flow through the rinse systems are controlled by
pH/conductivity controls, drag-out reduction will decrease the frequency of rinse water flow
through the rinse tanks. Plant C may be able to reduce drag-out by instituthg operational
modifications and training personnel in drag-out reduction techniques. Drag-out reduction

106
 techniques include slowing workpiece rack withdrawal rates and increasing drainage time
prior to rinsing. Other drag-out reduction methods include operating process baths at the
lowest allowable concentration and using heated process baths when possible.
The faster an item is removed from the process bath, the thicker the film on the workpiece
surface and the greater the drag-out volume will be. The effect is so significant that most
of the time allowed for withdrawal and drainage of a rack should be used for withdrawal
only. Plant C management should emphasize to process line operators that workpieces
should be withdrawn slowly. An optimal removal rate can be determined by removing
loaded workpiece racks from process baths at different rates and allowing the racks to drain
into a catch basin. Drag-out volume can then be measured volumetrically.
Workpiece drainage also depends on the operator. The time allowed for drainage can be
inadequate if the operator is rushed to remove the workpiece rack from the process bath
and place it in the rinse tank. However, installation of a bar or rail above the process tank
m a y help ensure that adequate drainage time is provided prior to rinsing. Other printed
circuit board manufacturers have expressed concem that increasing workpiece rack removal
and drainage time will allow for chemical oxidation on the board. Plant C should identify
the processes that are not highly susceptible to oxidation and emphasize drag-out
minimization techniques to personnel operating those processes.

EQUIPMENT CLEANOUT
Plant C generates approximately 40 gallons of waste nitric acid every month from
equipment cleanout. Plant C may be able to reduce the volume of nitric acid generated
by modifying the existing cleaning methods.
One method for reducing the volume of waste nitric acid produced is to setup a workpiece
rack cleaning line with scveral.small tanks of nitric acid The cleaning line is then used like
a multi-stage rinse system. The first tank contains the most contaminated nitric acid
solution, and the final tank in the cleaning line contains the freshest nitric acid. When the
first tank no longer performs adequate initial cleaning, it is containerized for disposal (or
used as initial cleaning solution for tank cleanout). Then the second tank in the cleaning
line becomes the first. The empty tank is then filled with fresh nitric acid and it becomes
the last tank in the cleaning line.
The use of a multi-stage rinse system can provide significant reductions in waste cleaning
solution generation. One printed circuit board manufacturing plant uses a five-stage
multiple tank cleaning line and only generates approximately 15 gallons of waste nitric acid
i each 6 months.

i RINSE WATER RECYCLING

Plant C may be able to recycle its rinse water by further treating effluent from the industrial
4 waste treatment plant. This additional treatment may only require activated carbon
treatment to remove trace organics from the water. This recycled water would contain less
natural contaminants, such as phosphates and carbonates, than the tap water that is
L

c 107
 presently used. Since these natural contaminants contribute to ion-exchange resin use
because they are removed during treatment, recycling of rinse waters can reduce spent resin
generation and significantly reduced water usage and sewer discharge fees.

Feasibility Analysis Phase

Afi'et dircrrrsionr with Plant Cpersonnel, some of the options dircrrrsed in the p d u s section
were selected for investigation of their technical and economic feasibility. The economic
was based on the mw m a t e d and waste &pad costs pnwided by the facilir),
penonnel and on economic and technical infwwtw ' npnwided by equipment manuf-.
The mea" evaluated in thhir section include: matend substhtiott, rinse water reduction,
drag-out bss reductron, equipment ckanout reduction Md h e watet recycling.
,

MATERIAL SUBSTITUTION
The benefits associated with using recyclable and/or treatable process chemistries will
depend on the costs of substitute materials compared with the costs of materials presently
used. Also,additional process bath maintenance requirements and treatment costs need
to be identified. These costs will depend on the type of substitute material chosen by Plant
c.
Savings will include reduced waste disposal costs and material usage costs if the substitute
material can be recycled onsite. Plant C generates approximately 250 gallons of waste
reflow oil and 500 gallons of waste nitric acid annually. Since waste disposal costs for the
waste reflow oil and waste nitric acid are both $100 per SS-gallon drum, which is the
average cost for disposing of various liquid hazardous wastes according to circuit board
manufacturers, waste disposal cost savings would be approximately $500 per year for spent
reflow oil disposal and Sl,ooO per year for nitric acid waste. Actual savings associated with
using recyclable reflow oil and nitric acid will depend on the difference in cost of the
substitute materials.

RINSE WATER REDUCIlON

The costs associated with converting the plant's four double tank rinse systems into two
stage counter-current rinse systems would be minimal. Since the pairs of tanks are already
next to each other, the only modifications necessary would be to re-plumb each rinse
system. This could be done by Plant C personnel for less than a few hundred dollars.
Savings would include reduced water use and sewer fees and reduced ion exchange resin
purchases. Since rinse water flow rates, drag-out rates, and rinse system operating
- parameters were not available, we could not calculate estimates on savings in water use,
sewer fees, and ion exchange resin purchases.

108.
 DRAGOUT LOSS REDUCTION
The use of a bar rail above each process tank for hanging workpiece racks will allow for
greater drainage time before rinsing. This could be installed by Plant Cs personnel for a
few hundred dollars if constructed of 1 inch PVC piping. Other drag-out reduction
techniques, such as slowing workpiece rack removal rates and operating process baths at
the lowest possible concentration, can also be implemented for little cost. Developing a
training program and emphasizing drag-out minimization will require time from
management and operations personnel. Since information on drag-out rates and workpiece
rack removal and drainage times were not available from Plant C,savings associated with
drag-out minimization cannot be quantified prior to implementation.

EQUIPMENT CLEANOUT REDUCTION

Plant C can reduce waste nitric acid generation by using a multiple tank cleaning line. The
costs associated with setting up such a system include the cost of additional tanks and the
installation labor costs. The costs for setting up a cascade cleaning line would be
approximately $350 per tank. Labor costs of $55 an hour for 4 hours would be $220.
L

The savings associated with a multiple tank plating rack cleaning line include reduced costs
for nitric acid purchases and waste acid handling. Plant C now generates approximately 480
i gallons of waste nitric acid annually. The consultants visited one plant that used five 30.
gallon tanlts as a multiple stage cleaning line. That plant generates 3O-gallons of waste
nitric acid each year. If Plant C could reduce its waste nitric acid generation down to 30
gallons per year, it would achieve an annual savings of approximately $1,400 in nitric acid
purchases and $800 in waste disposal costs. This assumes that nitric acid costs $3.10 per
I gallon and waste disposal costs are $100 per 55-gallon dnun.

RINSE WATER RECYCLING

Considerable capital investment may be needed to recycle wastewater for reuse in
E production. The costs associated with recycling treated wastewater effluent will depend on
the level of additional treatment neoessary to return the efnuent back into the production
processes. Other plants that are considering rinse water recycling have indicated that their
primary conctm is to remove organics from the treated effluent before reusing the water.
An activated carbon system to treat the effluent can be used to remove organics from the
water. Waste treatment efnuent data for the plant were not available from Plant C.
Therefore, specific treatment requirements for recycling treated effluent could not be
identified. Plant C should investigate the potential for recycling rinse water by
characterizing its rinse water effluent, determining the water quality needs for reusing
treated effluent, and identifying potential technologies that can be used to treat the effluent
for reuse.
The primary savings associated with recycling rinse water are lower water purchase and
sewer discharge fees. Plant C generates approximately 3,000 gallons of wastewater each
day. Assuming that 90 percent of the water can be recycled, Plant C could reuse
approximately 2,700 gallons of water each day. If water and sewer fees are both $05 per

109
750 gallons, Plant C could save approximately $75 each month in water and sewer costs,
assuming a 2O-day work month.

SUMMARY
The audit of Plant C was performed to identify opportunities for waste reduction. The
following hazardous wastes are generated by Plant C each month:
Spent Ion Exchange Resin - Approximately 100 gallons
Copper Sulfate Crystals - Undetermined
Nitric Acid Waste - Approximately 40 gallons
Reflow Oil - Approximately 20 gallons
The audit provided information that was used to identify several waste reduction techniques
that may be feasible for Plant C to implement. The following waste reduction opportunities
were identified:
o Use alternative reflow oil and electroplating rack stripper materials that can
be recycled or treated when they are spent instead of chemistries that
currently are containerized for off-site disposal.
0 Aggressively pursue drag-out reduction by developing operational procedures
and mining personnel to slowly remove workpiece racks and increase
drainage time prior to rinsing.
0 Convert the four double tank rinse systems into two-stage counter-cunent
rinse systems.
o Install a multiple stage electroplating rack cleaning line to reduce nitric acid
waste generation.
o Recycle treated effluent for reuse in the production process.

110
 APPENDIX TWO
WHERE TO GET HELP:
FURTHER INFORMATION ON WASTE MINIMIZATION

Additional information on source reduction, reusc and recycling approaches to waste

"ion is available in EPA reports listed in this section, and through state programs
(listed below) that offer technical and/or financial assistance in the areas of waste
" h a t i o n and treatment.
In addition, waste exchanges have been established in some areas of the U.S.to put waste
generators in contact with potential users of the waste. Four waste exchanges are listed
below. Finally, EPA's regional offices are listed.
EPA REPORTS ON WAS"JZ MINIMIZATION
. . . tion Audit Report: Case Studies
U.S.Environmental Protection Agency. "Waste Muumxza
of Corrosive and Heavy Metal Wahe Minimization Audit at a Specialty Steel
Manufactwing Complex." Executive Summary..
U.S.Environmental Protection Agenq. "Waste Minimization Audit Report: Case Studies
of Minimization of Solvent Waste for Parts Cleaning and from Electronic Capacitor
Manufacturing qPeration." Executive Summary..
U.S.Environmental Protection Agency. "Waste M h h k t i o n Audit Report: Case Studies
of Minimization of Cyanide Wastes from Electroplating Operations." Executive Summary.*
.
. . tion, Vok I
U.S.Environmental Protection Agency. Report to Congress: Waste Mm"
and II. EPA/53OsW-86-033 and -034 (Washington, D.C U.S. EPA, 1986).**
U.S. Environmental Protection Agency. Waste Minimization - Issues and Options, Vols.
I-III EPA/53O=SW-86441through -043. (Washington, D.C: U.S.EPA, 1986).**

* Executive Summary available from EPA, PPRB, RREL,26 West Martin Luther King
Drive-Cincinnati,OH,45268; full report available from the National Technical Information
Service (NTIS), U.S. Department of Commerce, Springfield, VA 22161.
** Available from the National Technical Information Service as a five-volume set, NTIS
NO.PB-87-114-328.

111
 TABLE OF CONTENTS

CHAPTER TITLE
1.0 SUMMARY AND CONCLUSIONS PAGE
1.1 INDUSTRY DESCRIPTION 1-1
1.2 WASTE REDUCTION TECHNOLOGIES
1-1
1.2.1 Source Reduction 1-1
1.2.2 Recycling and Resource Recovery
1.2.3 Treatment Alternatives 1-2
1-3
1 3 ECONOMICS 1-4
1.4 WASTE AUDIT PROTOCOL
i m -
1.5 INDIVIDUAL AUDIT FINDINGS 1-4
1-5
4.U
I
RECOMMENDATIONS 1-7
t 3.0 INTRODUCTION 2-1
3.1 BACKGROUND 3-1
3.2 PURPOSE OF THE STUDY
3.3 PROJECT APPROACH 3-1
3 4 WASTE GENERATING CHARACTERISTICS 3-1
OF THE PC BOARD INDUSTRY 3-2
3.5 LIMITATIONS TO WASTE REDUCTION
3-3
3-5
4.0 SOURCE REDUCTION
4.1 MATERIAL SUBSTITUTION 4-1
I 4 2
4.3
PROCESS AUTOMATION
IMPROVED OPERATING PRACTICES AND 4-2
HOUSEKEEPING 4-2

4.3.1 Improved Rinse Efficiency 4-3

4.3.2 Drag-out Reduction
4-3
5.0 RECYCLING AND RESOURCE RECOnRY 4-4
5.1 WASTE MATERIAL REUSE 5-1
5.2 MATERIAL RECYCLING
5-1
5.2.1 Process Bath Regeneration 5-1
5.2.2 Metal and Process Bath Recovery
5.2.3 Rinse Water Recovery 5-1
5-3
5.3 MATERIAL SUBSTITUTIONS 5-4

5-4
 TABLE OF CONTENTS (continued)
CHAPTER TITLE PAGE
6.0 TREATMENT ALTERNATIVES 6-1

6.1 WATER SUPPLY TREATMENT 6-1

6.2 ALTERNATIVE TREATMENT CHEMICALS 6-1
6.3 WASTE SEGREGATION 6-2
6.4 SLUDGE DEWATERING 6-2
6.5 ALTERNATIVE WASTEWATER TREATMENT-ION
EXCHANGE 6-2

7.0 ECONOMICS 7-1

7.1 SOURCE REDUCTION 7-1

7.1.1 Material Substitution 7-2

7.1.2 Rinse Efficiency 7-3
7.1.3 Drag-out Reduction 7-5
7.1.4 Equipment Cleaning Solution
Reduction 7-6

7.2 RECYCLING AND RESOURCE RECOVERY 7-7

7.2.1 Waste Material Reuse 7-7

7.2.2 Material Recycling 7-8

7.3 TREATMENT ALTERNATIVES 7-10

7.3.1 . Water Supply Treatment 7-10

7.3.2 Alternative Waste Treatment
Chemicals 7-11
7.3.3 Waste Segregation 7-11
7.3.4 Sludge Dewatering 7-12
7.3.5 Alternative Wastewater
Treatment-Ion Exchange 7-13

8.0 WASTE REDUCTION AUDIT PROTOCOL 8-1

8.1 TYPICAL BARRIERS TO A SUCCESSFUL

WASTE AUDIT 8-2
8.2 WASTE REDUCTION AUDIT PROCESS 8-3
8.3 IDENTIFYING HAZARDOUS WASTE SOURCES 8-5

8.3.1 Rinsing Systems 8-6

8.3.2 Chemical Drag-out 8-6
8.3.3 Chemical Bath Dumps 8-7
8.3.4 Equipment Cleanout 8-7
8.3.5 Spills 8-7
8.3.6 Industrial Waste Treatment 8-8
8.3.7 Samples 8-8
P

TABLE OF CONTENTS (continued)

CHAPTER TITLE PAGE
8.4 CHARACTERIZING WASTE STREAMS 8-8

8.4.1 Rinse System Effluent 8-9

8.4.2 Drag-out 8-9
8.4.3 Spent Chemical Baths 8-10
8.4.4 Equipment Cleanout 8-10
8.4.5 Industrial Waste Treatment Sludge 8-10

8.5 EVALUATING WASTE REDUCTION OPPORTUNITIES 8-11

8.5.1 Improving Rinse Efficiency 8-11

8.5.2 Rinse Water Recycling 8-13
8.5.3 Drag-out Reduction 8-13
8.5.4 Source Segregation and
Process Bath Maintenance 8-14
8.5.5 Process Bath Chemical Recovery 8-15
8.5.6 Waste Treatment Sludge Analyses 8-17
8.6 WASTE REDUCTION AUDIT CHECKLIST 8-17
9.0 SUMMARY OF PLANT AUDITS 9-1
9.1 WASTE AUDIT FINDINGS 9-2
9.2 WASTE AUDIT RESULTS 9-4
10.0 CURRENT REGULATORY ASPECTS OF HAZARDOUS
WASTE MANAGEMENT 10-1
11.0 LIST OF ACRONYMS 11-1
11.1 REFERENCES 11-2
APPENDIX A SUPPLEMENT: GUIDE TO WASTE MINIMIZATION IN THE
PRINTED CIRCUIT BOARD MANUFACTURING
INDUSTRY, by Jacobs Engineering Group,
Inc. for the U.S. Environmental
Protection Agency. A-1
APPENDIX B ORDER FORM FOR HAZARDOUS WASTE CONTROL LAWS
AND REGULATIONS B-1
APPENDIX C WHERE TO GET HELP c-1
APPENDIX D WASTE REDUCTION AUDIT CHECKLIST D-1
APPENDIX E STATUTES AND REGULATIONS AFFECTING
HAZARDOUS WASTE GENERATORS E-1
 TABLE OF CONTENTS
LIST OF TABLES AND FIGURES

Tables PAGE
TABLE 3-1 COMMON HAZARDOUS WASTES GENERATED BY
PRINTED CIRCUIT BOARD MANUFACTURERS 3-4

TABLE 4-1 DRAG-OUT LOSS REDUCTION TECHNIQUES 4-6

TABLE 7-1 CAPITAL COST FOR RINSE EFFICIENCY
EQUIPMENT 7-4
TABLE 7-2 MATERIAL RECOVERY TECHNOLOGY COSTS 7-9

Fisures PAGE
FIGURE 4-1 SLUDGE VOLUME GENERATION 4-5
FIGURE 5-1 MULTIPLE REUSE OF RINSEWATER 5-2

FIGURE 6-1 SLUDGE VOLUME VS. SLUDGE SOLIDS

CONCENTRATION 6-3

FIGURE 6-2 ION-EXCHANGE WASTEWATER TREATMENT 6-5

 CHAPTER 1.0

SUMMARY AND CONCLUSIONS

The objectives of the waste reduction study f o r the printed circuit board
manufacturing industry were to identify waste reduction technologies available to
the industry and to develop a waste reduction audit protocol that can be used by a
PC board manufacturer to assess its own waste reduction opportunities. The
emphasis of the study was to identify waste reduction technologies available to
small- to medium-sized manufacturing firms. To meet the objectives, PRC performed
waste audits a t three PC board manufacturing plants.

1.1 INDUSTRY DESCRIPTION

T h e PC board manufacturing industry uses production processes similar to

those of the electroplating a n d metal finishing industry. As a result, many of the
waste reduction technologies available to the electroplating and metal finishing
I L-

industries can be applied to the PC board manufacturing industry.

Typical hazardous waste streams generated by a PC board manufacturer are as

f 0110ws:

o Industrial waste treatment sludge

o Spent process baths
o Acids used for equipment cleaning
o Copper sulfate crystals

1.2 WASTE REDUCTION TECHNOLOGIES

Waste reduction technologies available to the PC board industry are classified

as follows:

o Source reduction
o Recycling and resource recovery

1-1
 o Alternative treatment

Source reduction includes waste reduction technologies designed to reduce the

volume of wastes initially generated. Source reduction is usually the least expensive
approach to minimizing waste. Many of the source reduction options available to
the PC board manufacturing industry require only housekeeping changes or minor
in-plant process modifications.

Recycling and resource recovery includes directly using a waste as a raw

material f o r another process or recovering valuable materials from a waste stream
before the waste is disposed of. Opportunities f o r both direct use of waste
materials a n d the recycling of materials from a waste stream a r e available to the
PC board manufacturing industry.

Treatment alternatives associated with waste reduction include the treatment of

waste streams to reduce their volume or hazard, source segregation to allow for
selective waste treatment, and treatment process modifications to reduce the volume
of the resultant waste stream.

There a r e many technologies within the three waste reduction categories that
are available to the PC board manufacturing industry. Examples of these
technologies a r e described as follows:

1.2.1 Source Reduction

o T h e use of non-chelated process chemistries as opposed to chelated

chemistries can reduce the volume of industrial waste treatment sludge.

o Recyclable process chemistries can be used in the PC board manufacturing

process.

o Reducing the volume of water used f o r rinsing operations will reduce the
volume of industrial waste sludge generated during wastewater treatment.
A variety of rinse water reduction techniques a r e available including:

- Using of spray rinse systems

- Creating agitation in the rinse tank by forced air or water, or

agitating a work piece rack in the rinse tank
- Using multiple stage counter-current rinse systems

1-2
 - Installing flow restrictors and flow control valves to regulate water
usage

o Reductions in drag-out loss can reduce the concentration of chemicals in

the wastewater and, therefore, reduce the volume of sludge generated
during wastewater treatment. Several drag-out reduction techniques are
available including:

- Operating process baths at the lowest possible chemical

concentrations
- Operating process baths a t higher temperatures
- Withdrawing work piece racks a t a slower rate
- Draining work piece racks f o r a longer period of time

- Capturing drag-out on a drainage board that drains back into the

process tank

- Adding wetting agents to process baths to reduce the surface

tension of the process bath solution and, therefore, reduce the
thickness of the drag-out film on the work piece

- Recovering process chemicals in a drag-out tank and replenishing

the process bath with the recovered solution

o Equipment cleaning solution wastes can be reduced through the use of

multiple stage cleaning lines.

1.2.2 Recycling and Resource Recovery

o Rinse water effluent from one rinse system can be reused as rinse water
influent to another rinse system.

o Material reuse techniques can be implemented. For example, spent acid

or alkaline cleaners can be used f o r pH adjustment in the industrial waste
treatment system.

o Regeneration of spent process bath solutions can be used to recycle

valuable etchants.

o Copper sulfate crystals, formed when various spent etchants a r e cooled,

can be used to replenish copper electroplating baths.

o Spent photoresist stripper wastes can be recycled by decanting off the

stripper solution to separate it from the polymer residue that forms as
the solution is used.

o Process bath chemicals a n d rinse water solutions can be recycled through

use of chemical recovery technologies, including:

1-3
 - Evaporation
- Reverse osmosis
- Ion exchange

0 Technologies, such as electrolysis, are available for recovering metals

from wastewater.

0 Rinse water can be recycled by using reverse osmosis or ion exchange

technologies.

1.2.3 Treatment Alternatives

0 Prior treatment of water supply to rinsing operations can reduce the

volume of sludge generated.

0 The use of alternative treatment chemicals such as caustic soda and

polyelectrolyte coagulants can reduce the volume of sludge generated.

0 Waste segregation can improve the efficiency of a waste treatment system

by separating various waste streams f o r selective treatment.

0 Sludge dewatering equipment that can increase solids concentrations in

sludge from 1 percent to 35 percent can cause a n 8-to-1 reduction in
sludge volume. Sludge dryers, which can increase solids content from 35
percent up to 90 percent, can reduce sludge volumes by approximately a
3-to-1 ratio.

0 Alternative treatment systems such as ion exchange, which do not use the
standard precipitation/ clarification method to remove pollutants, can
eliminate the generation of heavy metal sludge.

1.3 ECONOMICS

The costs associated with implementing various waste reduction technologies is

an important consideration for determining the feasibility of implementing a waste
reduction technique.

In general, source reduction techniques a r e the least expensive to implement.

Of ten housekeeping changes and minor process modifications can be accomplished
with little if a n y capital investment. Recycling a n d resource recovery technologies
and alternative treatment methods can vary in implementation costs. Many of these
technologies can be implemented f o r less than $1.000, while others can cost more
than $20,000.

1-4
 T h e cost of implementation must be evaluated in comparison to the benefits.
The benefits that can be obtained from waste reduction include reduced material
costs, reduced waste disposal costs, and reduced liabilities associated with handling
and disposing of hazardous wastes. The cost/benefit assessment for the various
waste reduction technologies is, therefore, plant specific.

In general, expensive waste reduction technologies a r e less applicable to small

companies than to large companies. This is primarily due to the limitations on
benefits that a small company can achieve. For example, a large f i r m may find that
a copper recovery unit is economically justifiable based on the amount of metal that
can be recovered, the amount of treatment chemicals that can be saved, and volume
of sludge that will no longer be generated. However, a small company may not be
able to justify metal recovery because i t does not generate enough waste to offer
significant savings. This limitation on small companies is not absolute, however.

L,
*Therefore, the feasibility of various waste reduction technologies should be
determined on a plant specific basis.

1.4 WASTE AUDIT PROTOCOL

c
A waste reduction audit is a n essential starting point for identifying areas
where hazardous waste reduction technologies can be incorporated into an existing
L plant’s process. An audit can identify housekeeping problems a n d operating
inefficiencies that cost little to correct. Also, a n audit can provide information

i
needed to assess the potential f o r implementing technologies that require significant
capital investments. The critical elements of a successful waste reduction audit
program are:

o Management commitment
o Personnel involvement
o Access to background data
o Resources to obtain additional data

L A company must overcome certain barriers to perform a successful audit and

- develop a waste reduction strategy. Not all waste reduction opportunities will be
apparent simply by obtaining data. Decisions to implement a waste reduction
technology will often require a certain level of risk. Many of the policies

1-5
 I

developed as part of a waste reduction strategy require modifications to standard

operating procedures. Furthermore, the impact of these changes on reducing waste
cannot always be determined until they are tested; inevitably some will fail.
Therefore, it is essential that management be committed to pursuing waste
reduction, be willing to experiment with various ideas, a n d be prepared to
experience failure as well as success.

For a waste audit to be successful, it must be comprehensive. A study of a

plant’s waste problem requires more than a characterization of the various waste
streams. The solution f o r reducing a particular waste stream often involves
modifying material inputs or production procedures. Therefore, a n audit must
examine raw material usage, production processes a n d schedules, a n d waste handling
methods together as one system.

. The waste reduction audit process can be broken down into several steps, as
f 01lows:

0 T h e audit team should prepare for the audit by discussing the plant’s
current waste generation problems a n d identifying the production
processes that contribute to waste generation.

0 T h e initial survey is performed to assimulate existing background

information on the plant’s operations. The auditors should compile
available d a t a on material flow rates, waste generation rates, a n d the
costs associated with material purchases and waste disposal.

0 Background d a t a a r t analyzed to identify potential waste reduction

technologies as well as additional data necessary to evaluate these
technologies.

0 A comprehensive plant assessment is performed to fill i n data gaps a n d to

obtain detailed information such as process bath operation parameters,
waste characteristics, a n d operational procedures. Usually some level of
sampling and analyses is necessary.

0 T h e final step in the audit process is the evaluation of waste reduction

opportunities. T h e data obtained during the audit is used to determine
the applicability of various waste reduction technologies, a n d economic
information is used to perform cost/benef it analyses on applicable
technologies.

The results of an audit d o not necessarily result in a definitive plan for

addressing all of the plant’s waste management problems. Experiments in modifying
process parameters or production procedures may continue. T h e results of the

1-6
 audit, therefore, are used to develop a waste reduction strategy that will be a n
ongoing effort.

1.5 INDIVIDUAL AUDIT FINDINGS

Data obtained during the three audits provided valuable information on the
barriers to waste reduction present in the PC board manufacturing industry as well
as information on waste reduction technologies available to the industry. Several
.
waste management characteristics common to the PC board industry were identified
and a r e listed as follows:

o T h e highest priority f o r a PC board manufacturing company is meeting its

requirements f o r discharge of treated wastewater to the local POTW. As
a result, waste reduction is a lower priority.
o PC board manufacturers a r e hesitant to implement waste reduction
L
technologies that require modifications to process bath operating
parameters and procedures.

o Chemical manufacturers emphasize their research a n d development on

products that are treatable in a plant’s industrial waste treatment system.
However, they d o not emphasize research and development of process
chemistries that reduce the volume of waste.

o PC board manufacturers a r e aware of their hazardous waste generation

rates, disposal costs, a n d waste handling costs but know little about
waste generation characteristics such as drag-out rates or rinse system
flow rates. This inhibits their ability to implement process modifications
intended to reduce waste generation.

L.

1-7
 CHAPTER 2.0

RE CO MME N D A TI 0 NS

The objectives of this study were to identify waste reduction opportunities

available to the PC board manufacturing industry and to develop an audit protocol
that could be used by PC board manufacturers to assess their individual waste
reduction opportunities. The results of this study can assist the industry in
reducing the volume of hazardous waste generated. Using the information obtained
during the study and the results presented in this report, PRC developed the
following recommendations:

o The au’dit protocol contained in Chapter 8.0 a n d the audit working papers
in Appendix A should be made available to the PC board manufacturing
industry.

o Training sessions should be held with PC board manufacturers using the

audit protocol. These sessions would provide PC board manufacturers
with a n opportunity to ask questions about waste auditing, which would
help overcome their reluctance in performing their own waste audit.
Examples could be presented that show how the forms are used during an
audit a n d what type of waste reduction opportunities can be identified.

o Process chemical manufacturers should be encouraged to devote some of

their research and development efforts to (1) study the impacts of their
process chemistries on hazardous waste generation, (2) assess the impacts
that various waste reduction technologies have on their process chemicals,
and (3) develop process chemicals that a r e amenable to various waste
reduction technologies.

2-1
 CHAPTER 3.0

INTRODUCTION

Planning Research Corporation (PRC) prepared this report to present the

results of a waste audit study of the printed circuit board industry. The study was
performed to identify opportunities for waste reduction in the printed circuit board
(PC board) industry and to develop a generic audit protocol that PC board
manufacturers could use to assess their specific waste reduction opportunities.

3.1 BACKGROUND
1
Technologies are now being developed that will enable industries to recover
valuable materials from their waste streams and to reduce or eliminate hazardous
waste genera'tion. These waste reduction innovations are becoming common to large
industrial operations with sufficient capital and staff capable of researching and
implementing waste reduction technologies. However, most smaller companies do not
have the in-house expertise or capital available to develop these technologies
themselves. Developing a model waste audit and then making it available to these
industries can effectively transfer information to smaller industrial operations on
how to achieve cost benefits by reducing the hazardous wastes they generate.

3.2 PURPOSE OF THE STUDY

California was the first state to ban landfill disposal of certain hazardous
wastes. In response to the state's land disposal phase-out mandate, the California
Department of Health Services (DHS)is implementing a broad program of hazardous
waste reduction. The program's emphasis is on small businesses that are unaware of
hazardous waste management issues and lack the expertise to address them. The
waste audit study for the printed circuit board (PC board) industry is part of this
program.

3-1
 I

I
The objectives of this waste audit study were (1) to obtain information on the
current waste management practices and problems that exist within the PC board
manufacturing industry, (2) to identify alternative waste reduction options available
to PC board manufacturers, and (3) to develop a generic audit protocol that can be
used by PC board manufacturers to assess their own specific waste reduction
opportunities. The results of the study are presented in this report.

3.3 PROJECT APPROACH

To identify waste reduction opportunities available to PC board manufacturers

and to develop the generic audit protocol f o r the industry, PRC conducted waste
audits a t three PC board manufacturing plants. PC board manufacturers in the
South Bay Area were surveyed a n d three were chosen primarily on the basis of
their interest in the program. The waste auditors then reviewed each company’s

existing manufacturing processes a n d waste handting procedures a n d identif ied

opportunities for waste reduction. Two separate visits to each plant were required
to perform the audits.

During the first visit to each piant, the auditors coilected background
information on production a n d waste handling operations. This information included
such d a t a as process flows, material inputs, waste outputs, production schedules,
material costs, and waste disposal costs. These visits included a thorough tour of
the plant. information gathered during the initial visit was reviewed a n d used to
plan the activities of the second visit.

The second visit involved a more detailed plant inspection. The auditors
reviewed various production a n d treatment processes with production personnel.
Flow rates f o r the various rinsing operations were calculated where necessary, and
spent chemical bath dump schedules a n d procedures were discussed. PRC observed
and asked questions on operational procedures performed by plant personne1. The
treatment processes used at each plant’s industrial waste treatment facility were
reviewed a n d treatment chemical feed rates a n d sludge generation rates were
determined.

3- 2
 The results of each waste reduction audit were presented to the company in a
written engineering report. The report described the audit process, information that
w3s obtained, and opportunities for hazardous waste reduction identified during the
audit. T h e report also included cost estimates for implementing plant modifications
and estimates for reductions in hazardous waste generation a n d associated cost
savings, where applicable.

Xnformation obtained during the three audits was used to develop this waste
reduction audit study report. This report is intended to:

o Identify the various waste reduction technologies available to PC board

manufacturers

o Present information on the costs associated with implementing some of

4 .
these techndlogies

o Describe the limitations and inhibiting factors to waste reduction present

i n the PC board manufacturing industry
4i
o Provide a generic audit protocol that can be used by PC board
manufacturers to assess their own waste reduction opportunities

3.4 WASTE GENERATING CHARACTERISTICS OF THE PC BOARD INDUSTRY

Printed circuit board manufacturing requires the use of process chemicals to

c clean, electroplate, electroless plate, a n d etch copper/f iberglass base material. This
material is used to develop circuit configurations a n d mounting holes. These
c
processes generate hazardous wastes* the most common sources of which a r e rinse
water effluent, spent process baths, and equipment cleaning chemicals. Table 3-1 lists
several types of hazardous wastes that a r e typically generated by a printed circuit
board manufacturer. Usually, rinse water effluent and many of the spent process
bath solutions a r e treated on-site before being discharged to a local publicly owned
L
treatment works (POTW). These on-site treatment systems often produce a heavy
metal sludge that is hauled off-site f o r either disposal or metal reclamation. Some
L, spent process baths a n d equipment clean-out solutions can also be containerized f o r
off-site treatment or disposal.

Several process operation and production management techniques are available

to the PC board manufacturing industry to reduce generation of hazardous waste.
i.
Many of these techniques have been developed by other industries, such as the
metal plating industry, a n d can be applied to the PC board industry because
production processes and waste characteristics are similar.

3-3
 TABLE 3-1

COMMON HAZARDOUS WASTES GENERATED

BY PRINTED CIRCUIT BOARD MANUFACTURERS

o Industrial waste treatment sludge - Sludge containing metals such as copper,

chromium, lead, and tin.

o Spent process bath chemicals - Contaminated or spent electroplating baths such

as acid/copper and tin/lead and other process baths such as photoresist
stripper, reflow oil, and etchants.

o Equipment cleaning materials - Nitric acid and fluoroboric acid containing

metals such as copper, tin, and lead.

o Copper crystals - Copper sulfate crystals generated in process baths such as

peroxide/sulf uric etchant baths.

3-4
 3.5 LIMITATIONS TO WASTE REDUCTION

It is important to identify limitations to waste reduction that PC board

manufacturers face as well as to identify waste reduction opportunities. An
understanding of these limiting factors is necessary so that they can be overcome.

Although many waste reduction technologies applicable to the PC board

industry require little capital investment, several resource recovery, recycling, and
alternative treatment technologies require significant capital investments. For
example, on-site process chemical or metal recovery systems (such as ion exchange
or electrolytic recovery) can cost over $20,000 to purchase and install. Often, the
savings to a small company does not warrant the cost of the system. Nevertheless,
many housekeeping and process modifications can be implemented for little or no
4. capital investment. These include improving the efficiency of the rinse systems and
reducing drag-out. Regardless of plant size, the main reason companies do not
implement waste reduction techniques is that management lacks a commitment to
L
pursuing waste reduction.

4
.
Implementing a waste reduction program requires commitment of management
and a willingness to test new ideas. Many of the waste reduction strategies require
modifications to standard operating procedures. Furthermore, how well these
changes will reduce waste cannot always be determined until they are tested;
inevitably some will fail. These failures can cost the company time and money,
which may hinder future efforts a t waste reduction. It is essential that
management be committed to pursuing waste reduction, be willing to experiment
with various ideas, a n d be prepared to experience failure as well as success.

People involved in implementing waste reduction programs have noted several

inhibiting factors. These barriers must be identified by those attempting to develop
c,
a waste reduction strategy for their company so that resistance can be recognized
and overcome. Several common barriers to waste reduction are as follows:

c
0 Lack of information about available waste reduction techniques and
the benefits that can be achieved.
L 0 Concerns for upsetting product quality.

0 The "If it ain't broke - don't fix it" attitude.

i
0 A reluctance to develop innovative ideas because of the fear of
f ailure.
.- 0 The attitude that a new technology will not succeed because it is
outside the company's normal range of expertise.

3-5
 CHAPTER 4 . 0

SOURCE REDUCTION

Source reduction technologies are designed to reduce the volume of

wastes initially generated by a plant. For the printed circuit board
industry, these technologies include reducing the volume of wastewater that
requires treatment and extending the life of chemical process baths.
Although some of these methods directly reduce the volume of hazardous waste
generated, most indirectly reduce this volume by reducing the volume of
industrial waste that requires treatment. Therefore, the volume of hazardous
waste sludge generated during the treatment of industrial waste is reduced.

Source reduction is usually the least expensive approach to minimizing

waste. Many of the source reduction options available to PC board
manufacturers only require housekeeping changes or minor in-plant process
modifications. The following six categories of source reduction were
identified for inclusion in the study:

o Product Reformulation
o Material Substitution
o Plant Modernization
. o Process Redesign
o Process Automation
o Improved Operating Practices and Housekeeping

Three of the categories, Material Substitution; Process Automation; and

Improved Operating Practices and Housekeeping, are discussed in Sections 4.1,
4 . 2 , and 4 . 3 respectively. The remaining three categories either do not
present significant waste reduction opportunities to PC board manufacturers
or, are considered broad categories that include waste reduction technologies
described throughout this report. These three categories are briefly
discussed in the following paragraphs.

4-1
 Product reformulation has only limited application to the PC board
manufacturing industry. The general design of a printed circuit board is the
same whether it is to be used in a computer or a household appliance. A
printed circuit board consists of an insulating material on which conducting
material is placed. The insulating material is usually fiberglass or
phenolic plastic. Conducting materials, which are metals such as copper, are
layered onto the fiberglass or plastic board.

The primary sources of hazardous waste are the processes used to layer
the conducting material onto the insulating material. Since the metals used
to produce circuit configuration on the board are chosen for conductive
properties, product reformulation by substitution of these metals is
unlikely. Process modification, however, is feasible and is discussed
.throughout this report.

Plant modernization and process redesign technologies available to the

PC board industry can be classified into several other waste reduction
categories. Many of the source reduction, recycling technologies and
alternative treatment technologies discussed in this report may be considered
plant modernization or process redesign. Therefore, these two categories are
addressed throughout Chapters 4.0,5 . 0 and 6 . 0 when describing various waste
reduction technologies.

4.1 MATERIAL SUBSTITUTION

Opportunities to reduce waste by substituting materials are available

to the PC board manufacturing industry. Most of these options involve
modifying the chemistry of the various process baths. Since the chemistry
requirements of each plant are different, these options can only be described
in general terms. Some are discussed in the JacobsflSEPA report.

4.2 PROCESS AUTOMATION

Little potential exists for a PC board manufacturer to reduce waste by

automating its manufacturing process. This is especially true for the small-
to medium-sized companies that run their production lines manually with only

4-2
 a few operators. A waste reduction technique that uses rinse water flow
controls may, however, be considered an automated operation. This technique
is discussed in the JacobsflSEPA Supplement under improved rinse efficiency.

One area where process automation could contribute to waste reduction

is in control of drag-out. An automated rack line could be set to remove
work piece racks at a slow rate and allow adequate drain time before the
rinse cycle. However, such a system is not likely to be financially feasible
because most process lines do not run continuously. Such an automated unit
would usually not be in operation and, therefore, would not replace manual
labor to the level necessary to warrant its consideration. Applicable drag-
out reduction techniques are discussed in Section 4 . 3 . 2 .

4.3 IMPROVED OPERATING PRACTICES AND HOUSEKEEPING

Source reduction options that involve improving operating efficiency

and housekeeping provide the most opportunities for waste reduction in the
PC board manufacturing industry. Technologies designed to reduce the volume
of rinse water used or to recover drag-out are available to the industry.
Many of these options require little, if any, capital investments.

The most significant source of hazardous waste in PC board

manufacturing is the treatment of wastewaters, which produces a hazardous
waste sludge. Most wastewater is.generated by rinsing operations. By
improving the efficiency of the rinse system and reducing the volume of
'L. process chemicals carried away in the rinse water (drag-out), hazardous waste
generation can be reduced. Another waste source that can be reduced by
improving operating practices is spent cleaning solutions generated during
equipment cleaning operations. These waste reduction technologies are
discussed in the Jacobs/USEPA Supplement.

4.3.1 Improved Rinse Efficiency

This is discussed in more detail in the JacobsflSEPA report.

4-3
4.3.2 Drag-out Reduction

Process chemical loss due to drag-out is the most significant source

of chemicals entering wastewater. Treatment of this wastewater is the major
source of hazardous waste because of the resulting sludge. Therefore, the
volume of sludge generated is proportional to the level of contamination in
the spent rinse water (Couture, 1984). Figure 4-1 illustrates the
relationship between metal concentration and sludge volume. The graph shows
the percentage of sludge per volume of water treated at various levels of
heavy metal concentration of the wastewater. The graph shows that 1000
gallons of wastewater with a heavy metal concentration of 100 mg/l will
produce approximately 90 gallons of sludge. If the same volume of wastewater
had a metals concentration of 500 mg/l, approximately 280 gallons of sludge
would be generated. The graph is based on data obtained from the metal
plating industry. Although the actual values may differ, the impact of metal
concentration on wastewater sludge volume should be similar for the PC board
manufacturing industry.

Table 4 - 1 summarizes the techniques available to the PC board

manufacturing industry to reduce process chemical drag-out. These techniques
are described in the JacobsflSEPA Supplement.

4-4
 20 -
E
GI
'0 0
0

>

0
3 I I I I I

100 200 ' 300 400 500

HEAVY METAL CONCENTRATION (mg/l)

FIGURE 4-1 -SLUDGE VOLUME GENERATION

a. Volume of sludge per volume of wastewater treated after 1

hour of settling. Treatment consists of lime neutralization.
(Source: U.S. EPA, Environmental Pollution Control
Alternatives: Sludge Handling, Dewatering, and
Disposal Alternatives f o r the Metal Finishing
Industry, October, 1982. )

4-5
 TABLE 4-1

DRAG-OUT LOSS REDUCTION

TECHNIQUES

1. Minimize bath chemical concentrations by maintaining chemistry a t the lower

end of operating range.

4. Maximize bath operating temperature to lower the solution viscosity.

3. Use wetting agents in the process bath to reduce the surface tension of the
solution.

4. Maintain racking orientations to achieve best drainage.

5. Withdraw boards a t slower rates and allow sufficient solution drainage before
rinsing.

6. Utilize drainage boards between process a n d rinse tanks to route drippage back
to process tanks.

7. Use drag-out tanks to recover process chemicals for reuse in process baths.

(Couture, 1984)

4-6
 CHAPTER 5.0

RECYCLING AND RESOURCE RECOVERY

5. WASTE MATERIAL REUSE

Figure 5-1 is a flow diagram illustrating the use of rinse water

recycling for an alkaline cleaning, mild acid etch, and acid cleaning line.
If each of the three rinse tanks are operated at the same flow rate, total
water use could be reduced by 67 percent.

Just as rinse water solutions can be reused, some spent chemical

process baths can also be used for other purposes. The most common use for
.a spent process bath is to use acid or alkaline cleaners for pH adjustment
during treatment of the industrial waste stream.

5.2 MATERIAL RECYCLING

Opportunities for material recycling include process bath regeneration,

process chemical and metal recovery and rinse water recovery. Material
recycling usually involves a process step that produces a residual. However,
the recycling process can significantly reduce the volume of the waste
material or can render the residual nonhazardous. For example, recovery of
process chemicals from rinse water effluent can produce a waste stream that
can either be reused for rinse operations or neutralized prior to discharge
to the sanitary sewer.

5.2.1 Process Bath Regeneration

PRC identified two types of process baths that can be regenerated by

PC board manufacturers. These are strong and mild acid etchants and alkaline
photoresist stripper. Spent process bath solutions can be regenerated to
recycle valuable etchants. PC board manufacturing requires the use of mild
and strong etchants. These etchants are considered spent when the copper
concentration reaches a level at which etching efficiency is inadequate. The

5-1
F I G U R E 5-1 -MULTIPLE REUSE OF RINSEWATER
 I

JacobsflSEPA Supplement has two examples describing how these etchants can
be recycled.

Another process bath that is commonly containerized for off-site

disposal is spent photoresist stripper. Stripper is used to remove
photoresist material from the board. This photoresist is a polymer material
that remains in the stripper tank in small flakes that slowly settle to the
bottom. These flakes become suspended in the stripper solution when
agitated. Therefore, when the sludge formed at the bottom of the stripper
tank builds up, the flakes begin to adhere to circuit boards when they are
cleaned in the stripper tank. The stripper solution is considered spent when
this occurs.

Two options are available to reduce the generation of this stripper

I-
waste. First, if the photoresist stripper line is set up as a multistage
process, the stripper would not have to be changed as often. The.suspended
L polymer flakes causing problems in the first tank would be removed in the
second tank. Therefore, the stripper waste in the first tank would not need
i. to be disposed of as frequently.

The second technique would be to decant and filter the stripper

L

solution out of the tank into a clean tank. This is feasible because the
stripper usually becomes spent as a result of the residue buildup long before
I.
it becomes spent as a result of a decrease in chemical strength.

L 5.2.2 Metal and Process Bath Recovery

The waste reduction and economic savings actually achieved through

metal recovery will depend on the individual manufacturing plant. Factors
that will determine whether metal recovery is economically justifiable
include the volume of waste that contains metals, the concentrations of those
metals in the waste, and the potential to recirculate some of the metal
salts. Many systems may not be economically feasible for small PC board
manufacturers because the savings from recovering process chemicals may not
be great enough to achieve an acceptable payback on their investment. Some
of these systems are described in the JacobsflSEPA Supplement.

5-3
5.2.3 Rinse Water Recovery

In addition to reusing rinse water effluent for rinse water influent,

PC board manufacturers can recycle rinse waters by treatment. Several of the
process bath recovery technologies discussed in the JacobsflSEPA Supplement
can be used strictly as rinse water recycling systems. RO and IE units can
be installed to treat the entire rinse water waste stream. Rinse water
recovery has an advantage over process bath recovery because the recycling
unit can treat all the waste streams together instead of treating only a
specific waste stream. Since process chemicals are not recovered, the
various waste streams need not be segregated.

The use of an RO or IE unit to recycle all rinse water waste streams

may require additional treatment. Several of the waste streams contain
organics. Therefore, a carbon filtration system may also be necessary to
remove the organics before the rinse water can be reused.

5.3 MATERIAL SUBSTITUTION

Material substitution is discussed earlier in Section 4.1.

Another material substitution option that may be available to a PC

board manufacturer is the use of recyclable materials. Chemical
manufacturers and suppliers, aware of their clients' increased concern for
industrial waste treatment and disposal, provide many process chemicals that
can be recycled or returned to the supplier. For example, some suppliers of
reflow oil, which is used to enhance the formation of a smooth film of solder
on the circuit board, provide a product that can be returned for recycling.
Non recyclable reflow oils are typically handled as a hazardous waste. PC
board manufacturers should be aware of current process chemical technologies
by participating in industry trade groups and maintaining contact with
chemical manufacturers.

5-4
 CHAPTER 6.0

TREATMENT ALTERNATIVES

Waste reduction treatment alternatives include the pretreatment of

process water and the treatment of waste streams to reduce their volume or
hazard. Source segregation and treatment process modifications are also
included in the discussion of treatment alternatives. Opportunities to
reduce waste by implementing treatment alternatives that are available to the
PC board manufacturing industry include pretreating process water, using
alternative waste treatment chemicals, segregating waste streams, dewatering
sludge, and using alternative wastewater treatment systems such as ion
exchange. This section describes the various treatment alternatives
available to PC board manufacturers. Additional details are in the
Jacobs/USEPA Supplement.

6.1 WATER SUPPLY TREATMENT

Natural minerals in water used for production processes can contribute

to the volume of waste generated. During treatment of wastewater, these
minerals will precipitate as carbonates and phosphates and will contribute
to the volume of sludge (EPA, 19828). How much these increase sludge volume
will depend on the hardness of the water in the area. In addition to the
direct effect on sludge volume, the presence of these minerals in the water
may reduce rinse water efficiency. Therefore, rinse systems may require more
water than would be necessary if the water were demineralized prior to use.

Deionized water systems can be installed to treat water prior to use

in production processes. It is difficult to estimate the level of sludge
reduction or water use reduction that can be achieved, however. It may be
possible to evaluate the effect of using deionized water by determining the
hardness of the incoming tap water and estimating the level of removal that
will occur in the treatment system.

6.2 ALTERNATIVE WASTE TREATMENT CHEMICALS

6-1
6.3 WASTE SEGREGATION

Segregating waste streams can effectively improve the efficiency of a

waste treatment system. This is discussed in the JacobsflSEPA Supplement.

6.4 SLUDGE DEWATERING

Increasing the solids content of industrial waste sludge can

significantly reduce the volume of sludge requiring off-site transport and
disposal. Typically, the sludge removed from a clarifier is approximately
3 percent solids by weight.' One plant visited by PRC used a bag filtration
process to increase the solids content of their sludge to 10 to 12 percent.
In this process, sludge from the clarifier flows by gravity into a series of
fine meshed bags and water is allowed to drain out of the sludge. Additional
increases in solids content will generally require some form of mechanical
dewatering to.significantly reduce sludge volume. For example, increasing
solids content from 3 percent to 35 percent can achieve an 8:l reduction in
sludge volume (Basanese, 1987). Figure 6-1 shows the reductions in sludge
volume that can be achieved by increasing the percent solids of the sludge.

Several techniques are available for dewatering sludge. Generally,

these systems are reserved for plants that generate more than 200 to 400
gallons of sludge each month, which is typical of a small PC board
manufacturing plant. However, mechanical equipment designed for lower volume
generators is becoming more common. These dewatering systems include filter
presses and sludge drying units.

6.5 ALTERNATIVE WASTEWATER TREATMENT-ION EXCHANGE

Ion exchange (IE) is discussed in the Jacobs/USEPA Supplement as a

technology that can be used to recover process bath chemicals and recycle
rinse waters. IE can also be used as a wastewater treatment alternative.
Unlike IE systems used for process chemical recovery, IE systems used for
wastewater treatment can treat the entire waste stream. Hazardous waste
volume can still be significantly reduced because the IE system eliminates
the generation of heavy metal sludge. One PC board manufacturer audited

6-2
 SLUDGE VOLUME (gals)

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during the study was able to eliminate all sludge generation by installing
an IE unit to replace the conventional precipitation/clarification treatment
system. The company now generates approximately 50 percent less hazardous
waste from its industrial waste treatment system. The hazardous waste
generated by the IE unit is in the form of spent ion resin. This IE system
has also allowed the company to successfully comply with local pretreatment
regulations. The previous system had been producing effluent that did not
meet the required pretreatment standards. Figure 6-2 is an illustration of
a typical IE system installed to treat rinse water wastes prior to discharge
to the local POW.

6-4
 WASTEWATERS
FROM ALL
I RINSE OPERATIONS EFFLUENT
TO POTW

EQUALIZATION
1
pH ADJUSTMENT
TANK
FILTRATION TANK
SYSTEM

ION EXCHANGE
CANISTERS

F I G U R E 6-2 - ION EXCHANGE WASTEWATER TREATMENT

 CHAPTER 7.0

ECONOMICS

The cost associated with various waste reduction technologies is key to

determining the feasibility of incorporating a waste reduction technique into a
company’s operations. Cost considerations include capital investments in equipment
and installation, possible production down-time during installation, costs for
operation and maintenance and potential impacts on product quality and production
time. These costs must be compared to potential benefits. The benefits in this
case include reduced waste handling a n d raw material costs. Ocher benefits,
- including reductions in potential liabilities associated with generating, storing, and
disposing of hazardous wastes, are virtually impossible to quantify.

Cost/benefit evaluations for implementing various waste reduction techniques a t

a specific plant will vary with plant size, production rates, raw material usage, and
waste generation characteristics and volumes. Although cost estimates for many of
the waste reduction methods described in this report can be developed, savings, in
terms of reduced material and waste handling costs, a r e plant specific.

This section contains information that can be used to assist in evaluating the
economics associated with various waste reduction technologies available to the PC
board manufacturing industry. The costs associated with many of the waste
reduction technologies a r e presented, and where possible, examples of the potential
savings these technologies can provide are given.

7.1 SOURCE REDUCTION

Source reduction techniques available to PC board manufacturers are generally

the most economically feasible. Many of these technologies only require proper
. training of production personnel or minor modifications to processes. Several
technologies, however, such as multi-stage rinsing and flow regulators d o require
considerable capital investment.

7-1
7.1.1 Material Substitution

Material substitution techniques to reduce the source of waste include the use
of non-chelator chemistries in place of process chemistries that contain chelators.
A variety of process chemicals a r e available that contain low or non-chelated
chemicals for plating, acid and alkaline cleaning, and various etching processes.
These types of process chemicals cost slightly more than chelated chemicals but, the
difference is too small to be considered a deciding factor when choosing between
the two types (Foggia, 1987). The main reason why most PC board manufacturers
do not use non-chelate process chemistries is because of the increased maintenance
costs associated with non-chelated process baths.

Non-chelated process baths usually require continuous filtration during the life
of ‘the bath, which requires the installation of a filter system to remove the solids
that will form in the bath. T h e costs of these filter systems will range from
approximately $400 to $1,000 f o r each tank using a non-chelated process chemistry.
These systems generally have a I to 5 micron filter with a control pump that can
filter the tanks contents once or twice each hour (Foggia, 1987). In addition to the
purchase and setup costs, filter replacement and maintenance costs will be incurred.

Expected savings of using non-chelated process chemicals include reduced

treatment costs and sludge handling costs. Another important advantage to using
these chemicals is that metals removal efficiency is usually improved. Therefore,
the treated effluent is more likely to meet POTW industrial waste effluent discharge
require men ts.

Although the specific savings associated with the use of non-chelated

chemistries can not be quantified, the following example illustrates the potential for
savings. One PC board manufacturer visited during the audit study used ferrous
sulfate to break down chelators prior to metals precipitation. The iron present in
the resultant sludge contributed approximately 32 percent of the total dry weight of
the sludge. Therefore, the elimination of the ferrous sulfate from the treatment
system would reduce sludge volume by approximately 30 percent, assuming that the
solids concentration remains the same.

7-2
 7.1.2 Rinse Ef f icleacy

Rinse water reduction techniques cover a wide range of costs. Use of

multistage, counter-current rinse systems a r e generally not applicable to small
companies because of cost and floor space limitations. Other options such as simple
rinse water flow rate reduction or a i r agitation a r e less expensive a n d may be
feasible f o r smaller shops. Table 7-1 presents the costs associated with purchasing
several types of rinse efficiency equipment.

A counter-current triple-rinse system requires the installation of two additional

rinse tanks a n d the associated piping. The cost of such a system can be about
$1,000 (Terran, 1987). Automated controls, such as pH meters, to control rinse
water flow can effectively reduce rinse water waste generation. A pH meter
equiped with the necessary control valves and solenoids could cost approximately
$700 per tank (Ryan, 1987).

Air spargers could be installed in existing rinse tanks f o r a modest cost.

Assuming the plant has a sufficient quantity of compressed air on-site that is
readily available, the costs of installing a i r spargers would be $100 to $125 per tank
for a 50 gallon capacity tank.

PC board manufacturers can also reduce their rinse water usage without
spending large amounts of money. By manually agitating work pieces in the rinse
water a n d allowing increased rinse water contact time, a plant can reduce the rate
of rinse water flow without significantly impacting rinse efficiency. Therefore,
water use c a n be reduced without a significant investment. T h e only necessary
..
requirements a r e purchasing flow restrictors and training personnel.

T h e savings associated with reducing rinse water usage are primarily from
reduced water a n d sewer fees. By increasing rinse efficiency, a process line can
reduce waste-water flows by as much as 90 percent (Watson, 1973). However, most
small or medium PC board manufacturing plants would not achieve such large
reductions. Improved rinse efficiency should also reduce sludge generation, although
. this is difficult to quantify before implementing a system.

7-3
 TABLE 7 - 1

CAPITAL COST FOR

RINSE EFFICIENCY EQUIPMENT

Eauioment DescriDtion

Riqse/Drip Tank S 350.00/ 50 gallon polyethelene tank

tank

Air Agitator S 50.00/ Air Spargers, Assumes

tank plant has sufficient
compressed air readily
available.

p H /Co n d u c t i v i t y Met e r $ 700.00/ Sensors, solenoids and

tank valves

Labor $ 57.00/ Installation of a i r spargers

per hr. requires approximately 2
hours per tank. A three-
stage counter-current rinse
system requires
approximately 5 to 8 hours
to install.

(Terran, 1987)

7-4
 T h e savings that can be achieved by instituting a rinse water reduction
program is illustrated in the following example. If a company spends approximately
$400 each month for water and sewer fees, a modest reduction in rinse water usage
of 10 percent can, theoretically, save the company 340 each month. If a two year
payback on investment is acceptable, the company could justify spending
approximately $1,000 to reduce its rinse water usage. This could be spent on
airspargers and flow restrictors. If more significant reductions are achievable
(perhaps 50 percent) a company could justify more advanced technologies such as pH
meters or counter-current rinse systems. Potential savings in sludge disposal costs
and treatment chemical use associated with reducing the volume of waste water
requiring treatment would also contribute to the payback on investment.

7.1.3 Drag-out Reduction

Most of the drag-out reduction techniques discussed in Section 4.3.2 do not

require any capital investment. These techniques do, however, require training of
personnel. For example, removing work piece racks a t a slower rate to reduce
drag-out or allowing the rack to drain over the process tank f o r a longer period of
time requires a conciencious operator. These procedures should not significantly
affect production.

Savings that can be experienced by using drag-out reduction techniques include

reductions in process chemical purchases, water a n d sewer use fees, and sludge
handling costs.

A f e w drag-out reduction techniques d o require capital expenditures. Rails

installed above process tanks can be used to hang work piece racks and allow drag-
out to drain back into the process tank. It should not cost more than a few
hundred dollars to equip all process tanks with these rails if P V C piping is used and
installation is performed by plant personnel. Use of a drag-out tank will require
the purchase of a n additional tank. This could cost approximately $350. Since
these tanks are not used as flow-through tanks, they could be setup without any
plumbing. Typically drag-out solutions are manually dumped or added to the process
. bath.

7-5
 I

Generally, the use of a drag-out tank can reduce both rinse water usage and
chemical losses by 50 percent or more (EPA, 1982a). Assuming that a chemical bath
processes 3,000 square feet of board each month, the total volume of drag-out loss
each month would be 12 gallons, with a drag-out rate of 15 ml/square foot of
board. If the rinse system following the process bath operates a t a flow rate of 10
gpm, for a total of 2 hours each day, water usage would be 24,000 gallons per
month based on 20 work days per month. A 50 percent reduction in chemical loss
and water usage achieved by installing a drag-out tank would reduce chemical losses
by 6 gallons per month and water usage by 12,000 gallons. If water a n d sewer fees
are each $0.50 per 100 cubic feet, a savings of 16 dollars per month could be
realized. Chemical savings would depend on the type of process chemical a n d the
amount of drag-out that could be returned to the process tank. There would also
be a savings in treatment chemicals realized by reducing rinse water effluent. If
the company spends approximately $1,000 each month on chemicals to treat 200,000
gallons of water, reducing wastewater generation by 12,000 could reduce treatment
chemical usage by $60 each month.

7.1.4 Equipment Cleaning Solution Reduction

A common hazardous waste stream generated by PC board manufacturers is

waste nitric acid generated from the cleaning of electroplating work piece racks.
Typically, racks a r e placed i n a nitric acid bath to clean-off the plated copper.
When the copper content in the bath gets too high to effectively clean the racks,
the nitric acid is containerized for disposal. Use of a cascade cleaning s y s t e m ( t h e
Jacobs/USEPA Supplement) can significantly reduce nitric acid waste generation.
The costs associated with setting up such a system are the cost of additional tanks
and the labor costs f o r their installation. The costs f o r setting up a cascade
cleaning line would be approximately $350 per tank. Labor costs of $55 a n hour f o r
4 hours would be $220. The savings associated with a cascade plating rack cleaning
line include reduced costs for nitric acid purchases a n d waste acid handling.

PRC visited one small PC board manufacturer who operates a five tank plating
rack cleaning line. The company generates approximately 15 gallons of waste nitric
acid in 6 months. By comparison, another small company that uses a single tank
for cleaning racks generates approximately 60 gallons each month. If this second
company could reduce that volume by 50 percent by installing a multistage cleaning

7-6
line, i t could realize a significant ravings in waste handling and material purchasing
cost. .4ssuming that waste disposal for the spent nitric is $50 per 55-gallon drum,
waste disposal costs could be reduced by $167 each 6 months. Since the cost of
technical grade nitric acid is approximately $3.50 per gallon, acid purchases could be
reduced by $630 each 6 months. Total savings would be $1600 each year. The total
cost of a five tank cleaning line would be $1620 which is the cost for the purchase
and installation of four additional tanks.

7.2 RECYCLING AND RESOURCE RECOVERY

Recycling a n d resource recovery costs range from making minor investments

for plumbing modifications to purchasing expensive systems for chemical recovery
units. Waste reduction alternatives include direct reuse of waste streams and
recycling of chemicals.

7.2.1 Waste Material Reuse

A waste material reuse option common among PC board manufacturers is the

recycling of rinse waters. T h e primary costs associated with rinse water recycling
is replumbing the rinse system to allow for reuse of rinse water effluent.
Depending on the design of the rinse water reuse system, storage tanks and pumps
may also be needed.

Implementing a system to reuse rinse water effluent from one rinse system f o r
feed water into another rinse system costs approximately $1,000. This includes $500
f o r contractor labor for 1 day and $500 for materials that includes piping materials
a n d a three-quarter horsepower pump, which would be adequate f o r a typical rinse
system. Assuming that both rinse systems a r e in the same process line and operate
a t the same flow rate, no storage tank capacity would be necessary.

T h e savings associated with reusing rinse water include water a n d sewer fees,
treatment chemicals, and sludge handling. If each individual rinse system used
24,000 gallons of water each month, the reuse of rinse water from one rinse system
could reduce water usage by 24,000 gallons each month. This equates to a savings
of $32 per month assuming water and sewer fees both equal $0.50 per 100 cubic
feet. Savings in treatment chemicals would be approximately $120 each month

7-7
assuming the company spends S1,000 each month to treat 200,000 gallons of
wastewater.

Other material reuse options, such as using spent acid or alkaline cleaners as
neutralizing chemicals in the waste treatment system, can be implemented at
practically no cost. The only fees associated with using spent process baths for
other purposes would be the purchase of storage containers for the material.

7.2.2 Material Recycling

Material recycling technologies range from simple decantation systems for

recovering photoresist stripper (see Section 5.2.1) to advanced recovery units such
as reverse osmosis and ion exchange (see Section 5.2.2). T h e process bath
regeneration techniques discussed in Section 5.2.1 generally require little capital
inwestment. The chemical recovery units described in Section 5.2.2 can cost tens of
thousands of dollars to implement.

The costs associated with implementing a chemical recovery technology depends

on a number of variables: the size of the unit, the space available, equipment
rearrangement, production down time, and the specific application. Table 7-2 cantains
cost data f o r several chemical recovery units. All of the examples shown in Table
7-2 are from electroplating plants. Although the specific materials recovered may be
different for a PC board manufacturing plant, the basic technology is transferrable
between these two industries. Although, the equipment costs will be representative
of what a PC board manufacturer would need to spend, the annual savings are
dependent on the wastewater metal concentrations and volume of wastewater treated
by the recovery systems.

One limiting factor f o r a small PC board manufacturing company is the volume

and chemical concentration of its various rinse water effluents. The examples in
Table 7-2 a r e all designed to recover a specific material from a single waste
generating source (for example, nickel salts from a nickel plating line). To achieve
savings in chemicals a n d sludge handling that will create a justifiable payback, the
waste stream must be fairly concentrated and continuous. For example the nickel
salt concentration of the effluent rinse water was 3000 mg;l a n d had a flow rate of

7-8
 TABLE 7 - 2

MATERIAL RECOVERY TECHNOLOGY COSTS

a.
Materials Equipment
Tech noloev Recovered costs
Evaporation Unit: Rinse water $47,000
Capacity of Chromic acid
approximately
20 gph.

.Reverse Osmosis Nickel salt $27,000

Unit: Capacity of plating chemicals
approximately 100 gph.

Ion Exchange Unit: Rinse water $38,000

Capacity of Chromic acid
approximately 20 gph.

Electrolytic Unit: Rinse water $25,000

Capacity of Copper
approximately 15 gph.

a. Equipment costs include equipment purchase, installation, and

materials.

Source: (United States Environmental Protection Agency, "Environmental Pollution

Control Alternatives - Reducing Water Pollution Control costs in the
Electroplating Industry," September 1987.)

7-9
100 gph. These types of parameters are generally not found in small PC b,aard
manufacturing plants. However, each company should evaluate its own conditions to
determining the feasibility of material recovery. The information necessary to
determine the feasibility includes waste stream generation rates a n d chemical
concentrations, and the value of materials to be recovered.

7.3 TREATMENT ALTERNATIVES

Although treatment alternatives usually produce a residual hazardous waste,

many of them can be used to reduce the amount of hazardous waste generated.
This can lead to a reduction in the associated costs f o r waste handling a n d disposal.
For the purpose of this study, treatment alternatives include process water
pretreatment, use of alternative chemicals, waste segregation, and sludge dewatering.

7.3.1 Water Supply Treatment

Deionizing the water used in the various rinse operations, can reduce waste
generation in two ways. First the deionized water improves rinsing. This may
contribute to reducing the volume of rinse water used. Second, prior treatment of
the rinse water will remove many of the natural contaminants that can find their
way into the industrial waste sludge after the wastewater is treated.

The treatment cost to deionize process water depends on the condition of the
water supplied to the plant. T h e cost is dependent on the concentration of total
dissolved solids (TDS) in the water (Prothro, 1987). For example, in the Santa
Clara Valley a plant supplied with surface water will spend approximately 2 cents
per gallon to pretreat process water. A plant supplied with ground water will
probably spend closer to 4 cents per gallon. A typical deionizing system, that
includes two 14 inch mixed bed deionizers, costs approximately $2,000 f o r equipment
and installation and will treat up to 5,000 gallons a day (Prothro, 1987).

It appears that deionization of the water supply f o r all process waters is

generally not cost effective. For example, a company that currently uses fresh
water a t the rate of 5,000 gallons per day may realize a 20 percent reduction in
fresh water usage through reduced rinse rates if the fresh water were pretreated in
a deionizer. The cost of treating the 4,000 gpd the company would now use would

7-10
 be over $1,60O/month, assuming a unit cost of $0.02 per gallon and a 5 day work
week. After giving consideration to the savings i n water and sewer fees (iS0.05 per
100 cubic feet for each, water and sewer) and the reduced wastewaier treatment
costs (20 percent of approximately $1,000 monthly), a company would need to
achieve a reduction in sludge disposal costs of approximately $1,475 just to offset
the additional treatment costs of the deionizing system. A typical plant of this size
L

is probably currently spending only $200 to $400 per month for sludge disposal.
Therefore, a savings of nearly $1,50O/month is not possible.

7.3.2 Alternative Waste Treatment Chemicals

T h e cost associated with using alternative treatment chemicals depends on the

plant. The characteristics of the plant’s waste stream will dictate the type and
amount of chemicals used and the relationship between treatment chemical use and
.sludge generation. Therefore, it is difficult to provide representative costs and
c
benefits associated with the use of alternative chemicals.

7.3.3 Waste Segregation

T h e level of redesign and process retrofitting involved with segregating wastes

is highly dependent on the plant layout, the process, and the waste streams being
segregated. For the purpose of this report we considered waste segregation,
rerouting a waste stream and providing a storage facility for the segregated
material. This type of segregation could be useful for holding waste streams f o r
batch treatment or f o r recovering materials from the segregated waste stream.

T h e level of effort necessary to segregate portions of a waste stream can vary

from simple rerouting of waste lines to construction of storage areas with holding
tanks. Costs f o r implementing these modifications range from a few thousand
dollars to hundreds of thousands of dollars. The following examples illustrate two
possible waste segregation system costs.

A simple form of segregation is to prevent a side stream from entering the

main waste stream by redirecting it to a separate storage tank. This could be used
to isolate waste containing chelators. Assuming the task only entails installing a
500-gallon storage tank, pumps, gauges, and necessary piping, equipment costs would

7-1 1
range between $2,000 and S4,000. In addition, installation costs may be as high as
100 percent of equipment costs.

It may be necessary to construct a larger storage area to contain multiple

types of segregated materials. Such a facility could consist of a 25 ft. x 25 f t .
concrete containment area, three 1000 gallon storage tanks, and associated piping,
pumps, a n d gauges. Equipment and materials, which includes plumbing, pumps,
gauges, a n d tanks, would cost between $20,000 and $30,000. In addition, installation
costs could reach 100 percent of equipment costs. This type of facility would allow
segregation of several waste streams for material recovery as well as batch
treatment.

7.3.4 Sludge Dewatering

. In the past, sludge dewatering technologies were only used by companies that
generated large amounts of sludge. A sludge reduction technology report prepared
by the EPA in 1982 estimated that if a company spent more than $16,500 annually
on sludge handling and disposal, the use of dewatering technologies could be
considered economical. Assuming that a PC board manufacturer spends $40 per
drum to have its sludge sent to a reclaimer, a company would need to generate over
400 55-gallon drums of sludge each year to warrant consideration of a sludge
dewatering unit. Now, however, small filter press dewatering units have been
designed f o r plants that generate approximately 10 to 50 gallons of sludge per week.
The costs for these units can still be considered high f o r a small company, however.

Small filter press units designed to handle from 0.75 gallons to 3.75 gallons of
sludge per load cost between $2,800 and 54,900. This assumes that the plant
already has a source of compressed air. Larger filter presses that can process from
4.5 to 11.25 gallons of sludge can cost from $7,000 to $9,500. These systems are
designed to process two loads per 8 hour shift. Therefore, the smallest unit can
handle 7.5 to 37.5 gallons of sludge per 5 day work week, while the larger unit can
handle f r o m 45 to 112.5 gallons per week. These units can increase solids content
f r o m 1 percent to approximately 35 percent, which represents an 8-to-I reduction in
sludge volume (Basanese, 1987).

7-12
 Sludge can be further dewatered to 85 to 95 percent solids by using sludge
dryers. Sludge dryers with a 1.5-cubic foot capacity, approximately 1 1.25 gallons,
can cost about $30,000. These units would achieve a 3-to-1 reduction in sludge
volume if the partially dewatered sludge was approximately 35 percent solids
(Basanese, 1987).

A company can develop its own sludge drying equipment f o r a significantly

lower investment. One small PC board manufacturer is planning to convert a small
cement mixer into a drying unit by lining the insides with ceramic and placing a
heating element in the middle. T h e unit costs approximately $500 to build.
However, since i t has not yet been put into operation, its effectiveness could not
be determined.

Savings associated with sludge dewatering are achieved i n reduced sludge

. handling costs. For example, a company that sends its sludge to a reclaimer pays
$40 per drum. If the company generated 10 drums per month, it could save
approximately $350 dollars each month by using a filter press to increase solids
content from 1 percent to 35 percent. This assumes a n 8-to-1 reduction in sludge
volume. A unit large enough to handle 2.5 drums per week would cost
approximately $10,000. T h e pay back on investment would be approximately 2.4
years if labor f o r operation and maintenance is excluded from the calculation.

7.3.5 Alternative Wastewater Treatment - Ion Exchange

Ion exchange systems can be used to treat the entire wastestream prior to
discharge to the POTW. When used for this purpose, the IE units d o not recover
process chemicals for reuse because all sources of wastewater a r e mixed prior to
treatment. T h e units can be used to recycle rinse water, however, by utilizing a n
activated carbon treatment system following IE treatment process. The costs for
operating an IE system will depend on the volume and chemical concentrations of
the wastewater.

One plant visited by P R C recently installed an I € system to replace it’s

. conventional precipitation/clarifier treatment system. The I € unit is dcsigned for a
treatment capacity of 12 to 14 gallons per minute. The unit does not generate any
sludge but does generate approximately two 55-gallon drums of spent I € resin each

7-13
 I

month. The old treatment system generated approximately four to six 55-gallon
drums of sludge per month.

The IE system was purchased a n d installed for approximately $16,000 a n d

required one week of production down time to install. The IE costs $1,000 per
month to operate compared to $1,500 per month f o r the old system. Operating
costs include material purchases and waste disposal. The IE requires less labor to
maintain according to the company, however, specific labor costs were not available.

According to the company, the I€ unit reduces material purchase and waste
disposal costs by $400 each month or $4,800 each year. This annual savings would
allow f o r a payback on investment of 3.3 years. The data does not include labor .

costs f o r operation a n d maintenance, which according to the company costs less

than it d i d f o r the old treatment system. Therefore, the payback period could be
evgn less.

7-14
 CHAPTER 8.0

WASTE REDUCTION AUDIT PROTOCOL

PRC developed a generic audit protocol that can be used by a PC board

manufacturer to assess its own waste reduction opportunities. This section
describes the generic protocol that can guide PC board manufacturers through an
internal waste reduction audit. T h e protocol discusses barriers to a successful
waste audit, describes the waste reduction audit process, a n d identifies the data
necessary to perform an assessment of the plant’s waste problems. The protocol
also includes a checklist that can be used to guide an audit team through an audit
of the plant.

By developing and implementing a comprehensive waste audit program, a

company can effectively assess its waste reduction opportunities. A waste audit is
an essential starting point f o r identifying areas where hazardous waste reduction
technologies can be incorporated into an existing manufacturing plant. An audit can
identify housekeeping problems a n d operating inefficiencies that cost little to
correct. The critical elements of a successful waste reduction audit program are:

o Management commitment
o Personnel involvement
o Access to background data
o Resources to obtain additional data

Full commitment of management is necessary to perform a comprehensive waste

reduction audit program. A commitment in terms of time, personnel, and financing
is essential. The waste reduction audit should be planned and administered with
input from the company’s senior managerial level. Without management support and
interest, the waste reduction audit becomes simply an exercise that achieves little
actual waste reduction.

8- 1
 Production personnel can be valuable sources of information and they should
be available f o r consultation during the audit. Often times, they can describe
actual operating activities in greater detail than supervisory or management
personnel. Also, because of their close involvement with the production line,
operational personnel may already have ideas of where waste can be reduced
through improved housekeeping and process modif icatioas. Finally, if plant
personnel a r e involved in the waste reduction program from the early stages,
awareness a n d cooperation during implementation of the program can be more easily
obtained.

Much of the data necessary to perform a waste reduction audit may already
exist. However, this information is not always readily available. Existing
background d a t a on production rates, material usage, a n d waste generation often
require research and data manipulation. For example, plant personnel may not be
aware of the cost of operating their industrial waste treatment system. However,
by reviewing treatment chemical purchases and sludge disposal invoices, estimating
man-hour requirements, and calculating sewer fees and discharge violation fines, the
auditors can quantify the cost of the existing treatment system. All available
background information must be identified and obtained to ensure a n accurate
understanding of the existing plant operations.

A waste reduction audit will inevitably identify areas where necessary

information is unavailable. These may include the flow rate f o r a process, the
chemical concentration in a rinse water solution, or the solids concentration in the
industrial waste sludge. To obtain this information, flow meters may be needed,
sampling and analyses may be required, and even a minor shut down in production
may be necessary. The audit team must have the resources available to them to
obtain this additional data.

8.1 TYPICAL BARRIERS TO A SUCCESSFUL WASTE AUDIT

Innovative thinking is usually required to identify appropriate waste reduction

techniques available to a company. Not all waste reduction opportunities are
a-pparent simply by gathering and analyzing data. Furthermore, potential results
cannot always be estimated. Therefore, decisions to implement waste reduction
technologies often require certain levels of risk. A company often must overcome

8-2
barriers to implementing waste reduction techniques that can prevent innovative
ideas from being tested. Several of these barriers are as follows:

o Lack of information about available waste reduction techniques and

the benefits that can be achieved.

o Concerns for upsetting product quality.

o The "If it ain't broke - don't fix it" attitude.

o A reluctance to develop innovative ideas because of the fear of

failure.

o The attitude that a new technology will not succeed because it is

outside the range of plant personnel expertise.

The audit team must recognize these barriers and be prepared to address them
during the audit. This is important to ensure that all potential waste reduction
opportunities a r e identified and assessed. Once again, management commitment to
the waste reduction program is essential for overcoming these barriers.

8.2 WASTE REDUCTION AUDIT PROCESS

For a waste audit to be successful it must be comprehensive. Although

addressing various waste generation problems one at a time or in a piecemeal
manner may provide some degree of waste reduction, this method overlooks the
main focus of a successful waste reduction audit, which is to view the
manufacturing plant as a single system and to identify the relationships between
material usage, production processes, and waste generation. This comprehensive
approach can lead to greater reductions in waste and increases in the economic
efficiency of the plant.

A comprehensive study of a company's waste problem requires more than a

characterization of the various waste streams. Waste reduction is achieved not only
at the point of waste generation, but also within the production process and even
at the point of choosing production materials. The solution for reducing a
particular waste stream often involves modifying material input or production
procedures. Therefore, an audit must examine raw material usage, production
processes a n d schedules, and waste handling methods together as one system.

8-3
 The waste reduction audit process can be broken down into several segments,
as described below:

o Audit team preparation

o Initial survey
o Background data analyses
o Comprehensive plant assessment
o Evaluation of waste reduction opportunities

If possible, the waste reduction audit should be undertaken by a team of plant

personnel. The team concept allows for a more thorough evaluation of the existing
operations and encourages discussion of innovative ideas. Since management
involvement is essential to the success of the audit, management personnel should
be encouraged to participate directly in the audit.

Audit team preparation involves planning the initial survey a n d becoming

familiar with waste reduction opportunities available to the PC board manufacturing
industry. The team should discuss the plant’s current waste generating problems
and identify the production processes that contribute to waste generation. This
waste reduction audit protocol provides background information to assist in planning
the waste audit and should be reviewed by the audit team.

The initial survey is performed to assimilate existing background information

on the plant’s operations. Various process lines should be reviewed to identify raw
material inputs and waste outputs. The auditors should obtain flow rates for rinsing
operations and spent process bath dump schedules. The existing waste handling
procedures should also be reviewed. Finally, the initial survey compiles economic
information such as raw material costs, energy costs, water and sewer fees, and
waste handling costs.

Next, the audit team should review the background information obtained during
the initial survey to direct future audit activities. Process flow diagrams should be
developed to identify the production processes and show incoming raw materials,
product flows, by-product flows, and waste flows. Operations that present
opportunities for waste reduction can then be identified. During this review

8-4
process, the audit team should begin to identify information needed to f u l l y assess
the various waste reduction opportunities.

The comprehensive plant assessment is performed to f i l l data gaps identified

during the review of the background information. The audit team should obtain
detailed information, such as process bath operation parameters, operator work
procedures, and waste characteristics during this step of the audit. Usually, some
sampling and analyses activities are needed to obtain this detailed information.

The final step in the waste reduction audit is to assess the feasibility of
implementing waste reduction alternatives. All relevant data obtained during both
the initial survey and the comprehensive assessment are used to determine which, if
any, waste reduction technologies can be incorporated into plant operations.
Economic information is used to perform cost/benef it analyses f o r the various
options.

Audit results will not necessarily result in definitive plans for implementing
waste reduction techniques. Experiments to modifying the process parameters may
still continue. For example, the audit team may decide to test various process
baths a t low concentrations to minimize the drag-out of process chemicals into the
rinse water waste stream. The results of the waste audit should be used to develop
a n ongoing waste reduction strategy.

The following subsections of this waste reduction audit protocol present

specific activities that should be included in the audit. Also, several waste
reduction technologies are described and the types of process information needed to
assess their applicability to a specific plant are identified.

8.3 IDENTIFYING HAZARDOUS WASTE SOURCES

The starting point f o r gathering background data is to identify a11 the

hazardous waste sources. Although the most common hazardous waste stream is
industrial waste treatment sludge, the industrial waste treatment process is not the
source of hazardous waste. The production activities that create the industrial
waste are. The various process steps associated with producing a printed circuit

8-5
board need to be identified and the material inputs and outputs should be described
in detail.

The various waste producing sources should be broken down by each distinct
process. It is not sufficient to identify the waste sources as rinsing operations and
spent process chemical baths. The auditors should separate the sources by their
function in the manufacturing process. For example, one source of waste will be
effluent from the rinse water system that follows an alkaline cleaning process. It
is necessary to divide the various waste sources in this manner so that the specific
operating parameters and waste characteristics for each source can be identified
later. Also, it is important to not overlook minor sources such as equipment
washout waste. The significance of these sources should be evaluated a f t e r all
relevant data has been obtained. The remainder of this section describes some of
the typical waste sources present a t a PC board manufacturing plant.

8.3.1 Rinsing Systems

The primary source of hazardous waste is the rinsing operations that follow
the process chemical baths. Generally, these wastes contain low concentrations of
process chemicals. Treatment of rinse water wastes produces a heavy metal sludge
that is a hazardous waste. Rinsing operations should be divided into separate waste
sources based on the type of process chemicals that are carried away in the rinse
system effluent. This is important for evaluating various rinse recycling a n d waste
segregation opportunities.

8.3.2 Chemical Drag-out

Drag-out from process baths is the source of chemicals entering the rinse
water effluent. Although the chemical drag-out ends up in the rinse system
effluent, drag-out still needs to be addressed as a separate source because potential
waste reduction opportunities f o r drag-out minimization can be independent of the
rinsing operations. Drag-out from each process chemical bath should be identified
as a separate waste source. This is important because various drag-out minimization
techniques may only be applicable to some of the processes. For example, increased
drainage time for work piece racks may not be feasible for some process chemistries

8-6
where quick oxidation may occur. Also, the use of drag-out tanks is usually only
applicable to process baths that operate a t an elevated temperature.

8.3.3 Chemical Bath Dumps

Chemical bath dumps should also be identified as hazardous waste sources.

Each process bath should be listed whether it is dumped into the industrial waste
stream or containerized for transport off-site. The approximate frequency of each
dumping should also be listed. The use of chelating chemicals or wetting agents
should be noted for each process bath. All of this information will be important
for determining the potential for extending the life of a process bath by modifying
its operating parameters, or segregating the various baths for selective treatment.

8.3.4 Equipment Cleanout

Equipment cleanout generally includes floor wash down, process bath tank
cleaning, electroplating rack cleaning, and any other activities associated with
cleaning the plant and the equipment. These wastes usually include rinse waters as
well as cleaning solutions such as nitric acid. The auditors should estimate the
frequency of these cleaning operations a n d determine their contribution to overall
waste generation.

8.3.5 Spills

Spills may also be a source of hazardous waste. These incidents may be

difficult to identify or remember. However, if spills are common they can
contribute significantly to the volume of hazardous waste and will usually be easier
to identify. Even if plant personnel d o not have any information on spills, this
source should still be kept in mind when developing a waste minimization plan.
Instituting requirements for reporting and documenting future spill incidents will
provide valuable historical information for identifying necessary maintenance or
operational changes.

8-7
8.3.6 Industrial Waste Treatment

The most common form of industrial wastewater treatment used by PC board

manufacturers is metals precipitation followed by settling and clarification. This
type of treatment generates a sludge that contains metals. Since usually only a
small percentage of the sludge solids generated are metal containing compounds,
there is also opportunity for waste reduction in the treatment system itself.
Therefore, the treatment system should also be reviewed and included as a
hazardous waste source.

8.3.7 Samples

Although a chemical product sample provided by a chemical supplier is

technically not a waste, unused samples need to be disposed of as if they were
waste material. Since these samples may not be wastes, they can be accumulated
without concern for violating any hazardous waste storage time requirements.
However, these materials must eventually be disposed of, and the costs could be
quite significant. The audit team should determine if unusable samples are
accumulating a t the plant or being f e d into the treatment system. T h e audit team
may identify the need to develop a policy on accepting chemical samples.

8.4 CHARACTERIZING WASTE STREAMS

Waste stream characterization should be performed during both the initial

survey and the comprehensive assessment of the manufacturing operations. The
initial waste characterization activities a r e performed to develop a qualitative
description of the various waste streams. For example, a qualitative description of
a rinse system effluent that follows a mild etchant process tank could be: "a
slightly acidic, aqueous solution containing low concentrations of peroxide and
sulfuric acid, discharged to the industrial treatment plant collection sump." Waste
characterization activities performed during the initial survey can usually be
accomplished a t the same time that the waste sources are identified.

Waste characterization activities performed during the comprehensive

assessment a r e considered quantitative and often will require sampling a n d analyses.
This is performed after the existing background data have been evaluated to

8-8
identify specific quantitative data needs. The waste characterization data that will
be necessary include operating concentrations for the process baths, metals
concentrations in various rinse system effluent streams, a n d percent water content
of the treatment sludge. For example, a quantitative description of a rinse system
that follows a mild etchant process tank could be: "an aqueous solution containing
peroxide and sulfuric acid with a pH of 4.5 discharging to the industrial treatment
plant a t a rate of 10 gallons per minute for a total of 150 minutes each day."

The remainder of this section describes the type of characterization data

needed for the various waste streams.

8.4.1 Rinse System Effluent

Each of the rinsing operations identified as waste generating sources should be

characterized. The information that is needed to evaluate waste reduction
opportunities include chemical concentration of the effluent, pH, flow rate, and
point of discharge. All of these characteristics of the effluent can be determined
in-house with the possible exception of the chemical concentration. However,
chemical concentration can of ten be determined stoichiometrically if accurate pH
readings are obtained.

8.4.2 Drag-out

Characterization of the drag-out includes chemical concentration and drag-out

volume. The chemical concentration of the drag-out can be obtained from the
operating parameter requirements used for the various process baths. Drag-out
volume is difficult to determine quantitatively. However, several activities can be
performed to estimate drag-out rate. Drag-out that could eventually drain from the
work piece rack and boards can be measured directly. The work piece rack should
be removed and drained the way it normally is with a typical load of boards. Then
instead of immersing the rack into a rinse tank, operating personnel can hold it
over a catch basin until the drainage stops. The volume of drag-out drained into
the catch basin can then be measured.

Drag-out that will normally adhere to a circuit board is usually in the range
of 10 to 15 ml/sf. BY estimating the square footage of board placed in a work

8-9
piece rack, the auditors can estimate the drag-out volume that will still be lost
after drag-out minimization techniques have been used. The measured volume plus
the estimated volume that adheres to the boards is the total drag-out from the
process bath.

8.4.3 Spent Chemical Baths

The level of characterization necessary for the various spent chemical process
baths depends on the potential alternative handling methods that may be available.
For example, a spent sulfuric acid cleaning bath that can possibly be used for pH
adjustment in the treatment system may not require much characterization data
except its pH. However, if process bath regeneration is a possible option, specific
data on the chemical concentration of the bath solution may be necessary.

84.4 Equipment Cleanout

The level of characterization necessary f o r equipment cleanout wastes is also

dependent on the potential waste reduction options available. For example, if a
nitric acid waste used to clean copper off of plating racks presents potential for
copper recovery a n d nitric acid regeneration, a laboratory analyses of the copper
content may be necessary. Alternatively, if extending the life of the nitric acid
cleaning solution is a potential waste reduction technique, on-site field testing of
the solution is all that may be necessary.

8.4.5 Industrial Waste Treatment Sludge

Characterization of the industrial waste treatment sludge is necessary to

determine the efficiency of the treatment system a n d to assess the potential for
dewatering the sludge. The characterization data includes metals content a n d solids
content. Also, analytical data that can be used to determine the contribution of
treatment chemicals to the sludge volume should be obtained. For example, if
ferrous sulfate is used to break down chelators found in the waste stream so that
copper can be precipitated out, the iron content of the sludge should be determined.
This data may be helpful for assessing waste segregation and treatment chemical
substitution techniques.

8-10
8.5 EVALUATING WASTE REDUCTION OPPORTUNITIES

The audit team should begin to identify and evaluate waste reduction
opportunities once sufficient background data are obtained. However, specific waste
reduction techniques should not be eliminated from further consideration until the
comprehensive plant assessment has been completed. Therefore, the evaluation of
waste reduction opportunities is a two-step process. First, a f t e r background data
are obtained, potential waste reduction technologies or procedures should be
identified and reviewed. This review process will identify the need for additional
data from the comprehensive plant assessment. Second, a f t e r completion of the
plant assessment, the potential waste reduction technologies or procedures can be
fully assessed.

The audit team should evaluate each of the waste reduction opportunities based
on two considerations: ( I ) the feasibility of implementation, keeping in mind the
production process parameters necessary to ensure product quality; and (2) the
payback of investment, considering cost of implementation and savings in material
usage a n d waste handling costs. Many waste reduction techniques do not require
capital investment. What is often required, however, are procedural changes that
usually require employee training and cognizance of the need for waste reduction a t
the plant.

Several techniques are available f o r evaluating the potential f o r waste

reduction in the various processes used a t a PC board manufacturing plant. The
remainder of this section discusses methods for determining the feasibility of
implementing several waste reduction technologies a n d procedures.

8.5.1 Improving Rinse Efficiency

Improving rinse efficiency is an effective means of reducing waste generation.

Even if the total weight of process chemicals carried away in the wastewater
effluent remains constant, reducing the volume of wastewater containing these
chemicals will also reduce the resultant sludge. This is most apparent at plants
that. use untreated water for rinse system feed water. In areas of elevated water
hardness, precipitation of natural water contaminants, such as carbonates and
phosphates, can produce sludge volumes in excess of the volumes associated with

8-1 1
metals removal. Also, the use of most treatment chemicals depends on the volume
of wastewater generated. These chemicals usually end up in the sludge. Savings
from reduced rinse water use can be obtained in water usage and sewer fees,
treatment chemical purchases, and sludge handling costs.

The following equation can be used to assist in determining the most efficient
rinse water flow rate for a single stage rinse system:
Q = D (Cp/Cn)
Q = rinse tank flow rate
D = drag-out rate

Cp = chemical concentration on process solution

Cn = allowable chemical concentration in rinse solution

(EPA, 1982a)

T h e effect on rinse water usage by using multiple stage rinse tanks can be
evaluated using another equation:

Q = [(Cp/Cn)l’n+ 1/n1 D
n = number of rinse tanks in series.

(EPA, 1982a)

T h e costs associated with reducing rinse water usage vary depending on the
method used. T h e costs incurred to reduce the rinse water feed rate may be
limited to those costs associated with the purchase a n d installation of flow
restrictors. Converting a single-stage rinse system into a multistage system may be
more costly, however. The purchase of additional tanks and the cost of associated
plumbing would be involved. Savings that can be realized from reduced rinse water
f l o w rates include direct reduction of water use and sewer fees and savings in
sludge handling costs due to a reduction in sludge generation.

Even if flow restrictors are installed in the systems, excessive volumes of

water may still be used because the water may be left on for too long. Automated
controls that monitor the chemical concentration in the rinse solution and open the
fresh water feed valve when the concentration gets too high should be considered.
One PC board manufacturer visited by PRC reported that its water use was cut by

8-12
two thirds by installing pH meters on all their rinse tanks. The meters are set so
that when the pH of the rinse solution reaches a level that is determined to
negatively affect rinse efficiency, the meter activates a solenoid which turns on the
feed water. When the pH returns to an acceptable level, the meter again activates
the solenoid a n d the water is turned off. T h e use of pH or conductivity meters is
a n effective means of controlling water use.

8.5.2 Rinse Water Recycling

Most PC board manufacturing plants generate rinse water effluent that can be
recycled f o r use in other rinsing operations. The most common means of recycling
rinse water is the use of an acidic rinse solution f o r rinsing operations that follow
a n alkaline cleaning process bath. The efficiency of the rinsing operation following
the alkaline bath may actually be improved because the neutralization reaction that
will occur aids in removing the alkaline film from the work piece surface.

The audit team should identify which rinse systems produce effluent without
contaminants that detract from the rinse water quality a t another rinse operation.
These can be tested on a batch process by holding the effluent from one rinse
system and using it as fresh rinse water on a trial basis. If potential recycling
opportunities a r e identified, the audit team should evaluate possible piping
modifications or process line configurations that will allow the company to take
advantage of rinse water recycling.

8.5.3 . Drag-out Reduction

Most drag-out reduction techniques require simple procedure modifications that

d o not involve capital investments. The volume of drag-out that can be reduced by
making these modifications cannot be accurately predicted. However, since capital
expenditures a r e not usually required, a company can experiment with several
techniques to determine how effective the modifications will be. This determination
can be accomplished by monitoring the process bath life, the rinse water effluent
concentrations, or the volume of sludge generated.

Members of the audit team should experiment with different work piece rack
withdraw1 methods and rates. They should try positioning the work piece in

8-13
different ways to improve drainage and experiment with removing the work piece
rack from the process bath at a slower rate to determine if drag-out can be
reduced. Finally, they should measure the volume of drag-out that can be
recovered by increasing drainage time allowed before placing the rack in the rinse
bath. The effectiveness of all these techniques can be measured volumetrically by
capturing the drag-out in a catch basin after it is removed from the process tank.

Wetting agents can also be used to reduce drag-out losses. Some PC board
manufacturers feel that the savings created by drag-out reduction d o not justify the
potential effects these wetting agents have on their product. Nevertheless, chemical
suppliers or other persons knowledgable on the use of wetting agents in PC board
manufacturing should be consulted. There may be applications that are appropriate
f o r a company. For example, wetting agents are commonly used in plating bath
solutions. With the aid of a chemical supplier, auditors can determine what
particular wetting agent provides the greatest reduction in surface tension of the
solution.

The audit team may also want to evaluate the process bath operating
parameters that a r e being used. It is possible that the operating concentrations can
be reduced. This will minimize drag-out losses. The audit team should realize that
the manufacturers’ recommendations come from the supplier who is selling the
chemicals. The recommendations may not address reducing drag-out loss or
extending process bath life. The audit team should attempt to develop a strategy
for testing the various process baths at reduced concentrations to determine the
most efficient concentration that will provide a quality product a n d also reduce
drag-out loss.

8.5.4 Source Segregation and Process Bath Maintenance

T h e chemistry of the various process baths should be reviewed by the audit

team. Knowledge of how these chemistries affect wastewater treatment a n d how
their process life can be extended should be evaluated. The audit team may be able
to identify source segregation techniques and process bath maintenance procedures
that can contribute to waste reduction. Audit team members may find helpful
information from chemical manufacturers and other PC board manufacturers.

8-14
 Th a dit te m sh uld identify which process baths cont in chelating tnts.
Although these chelated chemical baths a r e intended to enhance the metal etching,
cleaning, and selective electroless plating during production, they also cause waste
treatment to be more difficult and, thus, create a need to use more process
chemicals. For example, ferrous sulfate is commonly used to treat wastewaters that
contain chelators so that metal ions can be precipitated. T h e ferrous sulfate is
usually added to the wastewater to achieve a n iron-to-metal-ion ratio of 8:l. Since
the iron is also precipitated as a metal hydroxide sludge, this significantly adds to
the volume of sludge generated.

Non-chelated process chemicals a r e often available to replace the standard

chelated chemicals. The audit team should consult wit a chemical supplier to
evaluate possible material substitutions. Also, the potential for segregating waste
streams that contain chelators should be assessed. If this can be done, wastewaters
containing chelating agents can be treated separately and ferrous sulfate (or other
treatment chemicals used to breakdown chelators) will only be used during treatment
of a portion of the wastewater. It should also be noted that the use of non-
chelated chemistries may improve the metal removal efficiency of the treatment
system. Therefore, i t may be easier to comply with sewer discharge requirements.

Process bath maintenance is essential f o r getting the most use out of a

chemical process solution. Audit team members should survey other PC board
manufacturers to determine how long some of their electroplating a n d solder baths
can be maintained before dumping is necessary. It is possible that minor
adjustments in chemical additions or improved monitoring can increase the life of
several of the process baths.

8.5.5 Process Bath Chemical Recovery

Several technologies are available f o r recoveri g process chemicals from

wastewaters. These include reverse osmosis (RO), ion-exchange (IE), electrolytic
recovery (ER), a n d several others. T h e feasibility of implementing these recovery
techniques is dependent on a variety of parameters specific to the company. The
audit team should explore various recovery technologies and review case studies
supplied by equipment manufacturers to determine the feasibility of implementing a
recovery system.

8-15
 Manufacturers usually can supply a customer list so that audit team members
can discuss the effectiveness of these technologies with companies that use the
various types of equipment. The tendency for most companies is to disregard
recovery technologies because of the equipment costs or lack of widespread use
within the industry. However, the audit team must be prepared to invest time to
adequately investigate these possibilities before eliminating them from consideration.

One of the waste reduction options available to PC board manufacturers is

recovery of process chemicals from rinse waters. RO a n d I € systems can be used
to selectively recover chemicals from dilute waste streams. The recovered
concentrated solution, although usually still more dilute than the original process
chemistries, can be used f o r process bath makeup solution. Also, the effluent from
these systems can be recycled as rinse water. The cost considerations necessary to
determine the feasibility of such systems includes savings in process chemicals,
water usage a n d sewer fees, treatment chemicals, a n d sludge handling.

Elemental metal recovery is also a possible resource recovery technology that

can be used by PC board manufacturers. These systems can recover solid metal
from waste streams which can either be reused on-site (for example plated copper
used as a n anode in a n electroplating line) or sold as metal to a reclaimer. These
systems can be used to treat rinse water effluent a n d cleaning solutions such as
nitric acid. Savings can be experienced in reduced water usage (since wastewater
effluent may be recycled), recovery of nitric acid, reduction in treatment chemicals
used to remove metals from wastewater, reduced sludge handling costs, a n d pay
back from metal recovery.

The feasibility of implementing these various recovery technologies is

dependent on the volume and chemical concentration of the various waste streams
and the operating parameters of the various process lines. The audit team should
explore the potential of utilizing these technologies by contacting equipment
manufacturers and, more importantly, companies that have used them.

8-16
 8.5.6 Waste Treatment Sludge Analyses

Sludge characterization data can provide valuable information for determining

the efficiency of the existing treatment system and evaluating the potentiai for
sludge dewatering. The metals concentration of the sludge can provide information
on the efficiency of the treatment system, and the solids Concentration can provide
data for determining if sludge dewatering techniques may be beneficial.

Analytical data describing the metals content of the sludge can be used by the
audit team to assess the efficiency of the existing treatment system. If the
concentration of each metal in the sludge is known, the auditors can stiochiome-
trically calculate the total weight of contaminant metal compounds in the sludge.
The difference between the total dry weight of the sludge a n d the total dry weight
of contaminant metal compounds will indicate the d r y weight of non-metal
containing compounds in the sludge. This portion of the sludge is what may be
reduced by the company by improving the efficiency of the treatment system. For
.
example, if the company uses ferrous sulfate in the treatment system to breakdown
chelators, the total weight of iron compounds in the sludge is a n indicator of the
impact chelated process chemistries have on sludge volume. The cost of the ferrous
sulfate and the disposal of the additional sludge can provide economic data to
evaluate the benefits of using non-chelated process chemistries or segregating
chelated chemistries.

Sludge volume can be significantly reduced by increasing the solids

concentration. The solids content can be increased through mechanical dewatering
and sludge drying. The audit team can assess the cost effectiveness of
incorporating sludge dewatering techniques by comparing the savings on sludge
handling costs to the costs of purchasing and operating the dewatering equipment.

8.6 WASTE REDUCTION AUDIT CHECKLIST

This subsection describes how the waste reduction audit checklist presented i n
Appendix D can be used when performing a waste reduction audit at a PC board
manufacturing plant. The checklist contains: ( 1 ) tables for summarizing material
usage, waste generation, and production process data; (2) questions for identifying

8-17
potential waste reduction opportunities; and (3) tables for evaluating waste reduction
technologies identified during the audit.

The checklist should be reviewed by the audit team prior to beginning the
audit. The information requested in the data summary tables (Tables DZ.l,D2.2,D4.1,
u.2) should be obtained during the initial plant survey. The auditors should
then attempt to answer the checklist questions and begin filling in the waste
reduction technology tables during the background data review. During this portion
of the audit, team members will be able to identify additional data needs necessary
to answer the remaining checklist questions and complete the tables. These
additional data needs will be obtained during the comprehensive plant assessment.

After the plant assessment is completed, the audit team can determine the
feasibility of implementing the various waste reduction techniques identified during
the audit. T h e audit team should utilize the expertise of equipment suppliers and
process a n d treatment chemical suppliers to perform these evaluations. Finally,
eeooomic d a t a should be used to perform a cost/benefit analysis on those waste
reduction techniques that display potential for implementation. A cost/benefit
worksheet is provided a t the end of the checklist to aid in performing cost/benefit
analyses.

8-18
 CHAPTER 9.0

SUMMARY OF PLANT AUDITS

PRC performed waste reduction audits a t three PC board manufacturing plants.

The information obtained during these audits was used to: ( 1 ) identify waste
reduction technologies available to PC board manufacturers, and (2) develop a
generic waste audit protocol that can be used by PC board manufacturers to
perform their own audits.

Each of the three PC board manufacturing companies is considered small in

terms of size a n d average rate of circuit board production. Generally, these
companys maintain approximately 8,000 to 10,000 square feet of building space and
produce around 3,000 to 4,000 square feet of board each month.

T h e three companys a r e all prototype PC board manufacturers, specializing in

small jobs, usually 25 to 100 boards, with a quick turn-around. Because of this
type of manufacturing, production rates, material usage, a n d waste generation rates
fluctuate.

Performance of the three waste audits provided valuable information on the

potential for implementing waste reduction technologies into a PC board
manufacturing plant. The audits also provide information on the limitations to
waste reduction inherent to the industry. The audit team observed several waste
reduction techniques being used a t these plants and also identified potential waste
reduction opportunities that the plants have not yet employed. Potential waste
reduction opportunities available were presented in reports submitted to each ’

company. Although not completed as yet, management and production personnel will
be requested to review the report and offer their opinion on the feasibility of
implementing the recommended waste reduction technologies.
-_
This chapter summarizes the results of the three waste reduction audit studies.
Section 9.1 describes the observations of the industry’s existing waste management

9-1
philosophies and the obstacles to waste reduction that the industry faces. Section
9.2 describes recommendations for waste reduction developed for the three
companies. Appendix B contains copies of the waste audit reports submitted to each
company.

9.1 WASTE AUDIT FINDINGS

Although the companies audited are considered small PC board manufacturers,

the production methods, materials used and wastes generated are similar to larger
PC board manufacturers. Therefore, many of the observations made during the
audit can be applied to larger firms. When a n observation in this report is not
applicable to all sizes of companies, the applicable category or categories are
indicated.

The primary waste management concern of PC board manufacturers is meeting

wastewater effluent requirements f o r discharges to a POTW. Limitations on the
chemical concentrations that can be discharged to the sanitary sewer have increased
the demands on a plant’s industrial waste treatment system. In addition, the fines
and potential penalties associated with violating these discharge requirements have
become more severe in the last few years. As a result, PC board manufacturers
place a high priority on maintaining their industrial waste treatment system.

In response to this growing concern, process chemical manufacturers are

beginning to study the impact their products have on industrial waste treatment.
Much of the research and development these chemical companies perform relates to
the treatability of the chemistries once they enter the wastewater stream (Foggia,
1987). As a result, chelators used in many process chemistries are either being
eliminated from new products or being replaced with mild chelators. However, many
of these alternative process chemistries have not yet been universally accepted.

Although the emphasis is not placed on the industrial waste treatment may
have a positive impact on reducing hazardous waste generation because of the
reduction i n the use of chelators, negative impacts on hazardous waste generation
are possible. First, upgrading of industrial treatment systems may require large
capital investments, making capital unavailable for waste reduction technologies.
Second, if a company is able to meet its discharge requirements, it may be opposed

9-2
to instituting waste reduction techniques for fear of upsetting the treatment system.
For example, companies would be hesitant to use alternative treatment chemicals for
fear that the modifications could cause their effluent to exceed discharge standards.
Also, companies may avoid improving rinse efficiency, which would produce a more
concentrated waste stream, for fear of overloading the treatment system.

Another concern common to most PC board manufacturers is maintaining

process bath chemistries to ensure product quality. In general, plant personnel are
resistant to process modifications that have the potential to impact their process
baths. For example, all three companies audited use drag-out tanks following their
electro-plating lines. These companies, however, do not reuse the drag-out solution
to replenish their electroplating baths out of fear of contaminating their process
baths. Plant personnel typically believe that the potential cost associated with
spoiling a process bath exceeds the potential benefits from reusing the drag-out
solution. T h e companies are also hesitant to experiment with lower process bath
concentrations f o r fear of upsetting the product quality.

Although process chemical manufacturers have begun to study the impact of

these chemistries on wastewater treatment, no research has been conducted on the
impact of these chemistries on waste generation (Foggia, 1987). Many waste
reduction technologies available to the PC board industry require modifications to
process bath operating parameters or handling procedures. However, the information
necessary to assess the impacts of these technologies on the process baths and to
overcome the limitations the process baths present is not generally available from
chemical manufacturers. For example, chemical manufacturers do not provide data
describing the drag-out rates for specif ic process chemistries operated a t various
concentrations and temperatures. Also, many process baths cannot reuse drag-out
solutions because the chemistries a r e affected by drag-out. Research has not been
conducted to develop chemistries that can utilize drag-out reuse technologies.
Because of the increasing concern of PC board manufacturers over waste disposal
costs and liabilities, however, the chemical manufacturing industry is now beginning
to conduct research and development to address waste generation considerations.

. PRC did identify examples of chemical manufacturers addressing waste

reduction concerns. For example, many suppliers provide process chemicals that can
be returned to them when the chemicals become spent. This can reduce waste

9-3
treatment and disposal costs for a company. Also, one chemical manufacture
provides small waste treatment units for removing copper from its spent electroless
copper bath. If a municipality allows the discharge of chelators into the sewer, the
effluent can be directly discharged to the sanitary sewer (Stone, 1987). Chemical
suppliers indicate that they are beginning to direct their product development
efforts toward products that have less impact on waste generation.

Small PC board manufacturers have several common limitations to implementing

some waste reduction technologies. For example, because their floor space is
limited, small companies cannot feasibly use multiple stage counter-current rinsing.
Also, because these companies use manually operated work piece racks, control of
drag-out a n d proper rinsing is more difficult than if their production lines were
automated.

. Another common characteristic of smaller PC board manufacturing firms is

their overall lack of data pertaining to several process parameters. None of the
companies visited knew the flow rates through their various rinse systems. These
firms also did not know the drag-out rates for a n y of their process baths. Also,
they were not aware of which chemical concentration levels in the rinse solutions
would allow f o r acceptable work piece rinsing.

These same companies, however, were knowledgeable about d a t a directly related

to waste management costs. For example, data describing the volume of wastes
generated, waste disposal costs, and costs for operating the treatment systems were
all available. Therefore, i t appears that PC board manufacturers are aware of the
direct costs of waste treatment and handling but a r e not as aware of the production
processes that contribute to waste generation. This inhibits the ability to
implement process modifications intended to reduce waste generation.

9.2 WASTE AUDIT RESULTS

After completing each waste reduction audit, the auditors prepared a report
that described the plant’s waste generation and handling procedures and provided
recommendations f o r implementing various waste reduction technologies. This
section summarizes the waste reduction recommendations developed for the three

9-4
companies audited by PRC. Appendix B contains the audit reports written for each
company.

The three PC board manufacturing firms included in the waste audit study use
a variety of a waste management technologies. This allowed the audit team to
observe waste reduction at various levels of implementation. One of the companies
uses a n ion exchange unit f o r treating its wastewater while the other two
companies utilize conventional sludge generating treatment processes. One of the
firms visited by the audit team uses pH/conductivity meters for automatically
controlling water flow through its rinse systems. This company also uses other
water conservation techniques such as flow restrictors and pressure activated water
flow switches. Another plant does not use any of these water conservation
techniques and appears to operate its rinse tanks a t a n excessively high flow rate.
One of the companies treats its process water prior to use in the production
processes while the other two do not. Because of the treatment system the plant
uses, however, a comparison of sludge generation rates between the companies was
not possible. One of the plants utilizes a multiple tank electroplating rack cleaning
line, while the other two use a single tank f o r cleaning racks. The multiple tank
system produced significantly less nitric acid waste than the single tank cleaning
systems. Finally, one company uses a bag press sludge dewatering unit and was
able to increase the solids content of its sludge to approximately 35 percent. The
other company that generates an industrial waste treatment sludge does not utilize
any mechanical dewatering techniques a n d can only obtain a solids concentration of
approximately 11 percent in its sludge.

As discussed in Section 9.1, none of the plants visited pay close attention to
process chemical losses due to drag-out. The auditors observed production
personnel a t one plant quickly removing work piece racks from process baths and
allowing only a few seconds f o r drainage prior to rinsing. None of the companies
actively promoted drag-out reduction to employees by training them on proper work
piece rack handling procedures.

All three companies generate a hazardous waste stream that can potentially be
eliminated through material substitution. Reflow oil, which is used to form a
smooth, uniform film of solder on the printed circuit board, is containerized and
handled as a hazardous waste by each company. Several chemical suppliers now

9-5
provide reflow oil products that can either be returned to the supplier or treated
and discharged to the POTW when they become spent.

One plant was found to produce an excessive volume of sludge in its

wastewater treatment system. The process chemistries used by the company contain
chelators that require reduction with ferrous sulfate during wastewater treatment to
precipitate contaminant metals. The ferrous sulfate contributes to sludge volume
because iron precipitates as ferrous hydroxide during treatment. Analytical data on
the sludge indicated that the ferrous hydroxide contributed over 30 percent of the
solids in the company’s sludge. Therefore, the use of non-chelated process
chemistries and/or the segregation of chelated and non-chelated waste streams could
significantly reduce sludge generation a t this plant. Since the company spends over
$250 per month on ferrous sulfate purchases, these waste reduction options could
also save the company money on treatment chemical purchases.

Several waste reduction techniques were recommended to all three companies,

while other recommendations were unique to a company’s specific waste problem.
The following list describes the waste reduction recommendations developed for the
three firms included in this waste audit study.

Use recyclable or treatable reflow oil to replace product that

becomes a hazardous waste when spent.

Operate the rinse systems as batch rinse tanks instead of flow

through rinse tanks.

Reduce the flow rate through the rinse tanks.

Install flow restrictors and automated flow control devices as part

of each rinse system.

Train personnel on proper work piece rack withdrawal a n d drainage

procedures to minimize drag-out loss.

Operate process baths a t the lowest possible concentration and the

highest practical temperature.

Utilize multiple stage cleaning systems for cleaning electroplating

racks.

Recycle photoresist stripper waste by decanting or filtering the

contaminated stripper bath.

9-6
o Reuse acidic rinse water effluent as influent for rinse systems that
follow alkaline cleaning baths.

o Recycle rinse water through use of an alternative treatment

technology such as ion-exchange and activated carbon treatment.

o Segregate non-chelated waste streams from chelated waste streams.

o Dewater sludge to increase solids concentration a n d decrease sludge

vo 1ume.

9-7
 CHAPTER 10.0

CURRENT REGULATORY ASPECTS

O F H A Z A R D O U S WASTEMANAGEMENT

A variety of Federal, State, a n d local laws, regulations and ordinances

influence hazardous waste management. Some of these requirements directly
promote waste reduction by increasing the costs of other options, such as treatment
or disposal. These requirements include the State of California’s land disposal
restrictions a n d standards set for generators; transporters; a n d owners or operators
of treatment, storage or disposal (TSD) facilities. Other requirements indirectly
affect waste reduction because they command the immediate attention of a waste
generator or TSD owner/operator due to potential regulatory enforcement actions
and fines. Compliance with these requirements is given a higher priority, in terms
of capital investments and time, than waste reduction. Examples of these
requirements include: pretreatment requirements set by local POTWs that receive
treated effluents from industrial waste treatment systems; and local ordinances that
regulate the storage of both hazardous materials a n d wastes. Appendix E khtifies
several environmental regulations that affect PC board manufacturers.

The restrictions on the land disposal of many wastes has increased the cost of
hazardous waste disposal. The land disposal restrictions that affect PC board
manufacturers have been in effect f o r several years. For example, the restrictions
on the land disposal of liquid wastes containing toxic metals and/or acids began on
January 1, 1984 (Section 66905 CAC). These restrictions have caused increases in
disposal costs, since these wastes now require some f o r m of treatment prior to land
disposal. T h e impact of increased waste disposal costs should have a positive
impact on the implementation of waste reduction technologies.

California’s hazardous waste management laws and regulations affect the

generation, transportation, treatment, storage, and disposal of hazardous wastes.
!Man-y of the permitting requirements, including training, contingency plans, and
record keeping, are applicable to plants that store hazardous wastes for more than

10-1
 90 days. Businesses that store wastes for 90 days or less, therefore, face fewer
requirements, However, several manufacturers feel the 90-day accumulation limit
places constraints on their waste management practices.

Several PC board manufacturers have stated that waste transport fees are based
on a minimum pick up of ten to fifteen 55-gallon drums. Quantities less than these
are charged a higher transport rate. Many small PC board manufacturers have trouble
meeting the 90-day accumulation restriction while also attempting to accumulate
enough drums to minimize waste transport costs. Implementing waste reduction
technologies would cause even more difficulty in meeting the 90-day accumulation
limit. Alternatively, since the 90-day accumulation time begins when lOOkg of
hazardous waste or 1 kg of extremely hazardous waste are accumulated, quantities
less than these a r e not subject to the 90-day accumulation limit. Therefore, for small
quantity generators, these accumulation restrictions may encourage waste reduction.

As previously stated in Section 9.1, the primary waste management concern of

PC board manufacturers is meeting wastewater effluent requirements for discharges to
the local POTW. Limitations on the chemical concentrations that can be discharged
to the sanitary sewer have increased the demands on the plant’s industrial waste
treatment system. In addition, the potential fines a n d other penalties associated with
violating these discharge requirements have become more severe in the last few years.
As a result, PC board manufacturers place a high priority on maintaining their
industrial waste treatment systems. The emphasis these businesses place on
pretreatment requirements, causes waste reduction to be a lower priority.

Another statutory requirement that has become a priority for PC board

manufacturers is the recent passage of California’s citizens right-to-know legislation.
The state law requires local governments to implement hazardous material storage
programs to regulate industry (Chapter 6.95, CHSC). These regulatory programs may
affect PC board manufacturers in two ways: (1) compliance with the local programs
will often require investments to upgrade the plants and will require time f o r the
plants to develop their permit applications and hazardous material management plans;
and (2) since the local programs permit fees are based on the type and quantity of
- hazardous materials stored at a plant, decisions on source segregation and batch
treatment of wastes and the storage and use of hazardous materials will be influenced
b y these local ordinances. The impact of the first item may be a reduction in the

10-2
capital and time PC board manufacturers are able to allocate to address waste
reduction. The second item could both discourage and encourage waste reduction.
Segregation of materials and batch treatment may require additional storage tanks.
This could increase a business' storage permit fees and its exposure to liability
costs due to spills or other releases. Alternatively, storage permit fees may
encourage plants to reduce their material inventories and waste generation to
minimize their permit costs.

Because the cost of waste handling and disposal has increased in recent years,
waste reduction has become more attractive to businesses. Alternatively, because
other waste management regulations impose enforceable regulatory requirements and
fines f o r non-compliance, waste reduction receives a lower priority than these other
regulations. The businesses included in the waste reduction audit study all showed
an interest in waste reduction. However, they all placed a higher priority on local
wastewa'ter effluent discharge requirements and hazardous material storage
requ remen ts.

10-3
 CHAPTER 11.0

LIST OF ACRONYMS

DHS - California Department of Health Services

EDTA - Ethylenediaminetetraacetic acid
IE - Ion Exchange
PC - Printed Circuit
POTW - Publicly Owned Treatment Works
RO - Reverse Osmosis

11-1
 11.1 REFERENCES

Basanese, John, 1987, West General Associates, personal communication with

Tom Adkisson, Planning Research Corporation (February 1987).

Campbell, Monica, and William, Glenn, 1982, Profit from Pollution Prevention -
A Guide to Industrial Waste Reduction and Recycling. Pollution Probe
Foundation, Toronto, Ontario.

Couture, Stephen D., 1984, Source Reduction in the Printed Circuit Industry
Proceedings -- The Second Annual Hazardous Materials Management
Conference, Philadelphia, Pennsylvania, June 5-7, 1984.

EPA 1982a, Control and Treatment Technology for the Metal Finishing Industry-
In-Plant Changes.

EPA 1982b, Environmental Pollution Control Alternatives:

Sludge Handling, Dewatering, and Disposal Alternatives f o r the Metal Finishing
Industry.

Foggia, Mike, 1987, Shipley Company, Inc., personal communication with

Tom Adkisson, Planning Research Corporation (January 2 1, 1987).

Mifchel, George D., 1984, A Unique Method f o r the Removal and Recovery of Heavy
Metals from the Rinse Waters in the Metal Plating and Electronic
Interconnection Industries. Proceedings -- Massachusetts Hazardous Waste
Source Reduction, Clinton, Massachusetts.

Prothro, John, 1987, Culligan Industrial Water Treatment, personal communication

with Tom Adkisson, Planning Research Corporation (March 16, 1987).

Ryan, William M., 1987, William M. Ryan Company, personal communication w i t h

Tom Adkisson, Planning Research Corporation (January 14, 1987).

Stone, Phil, 1987, Shipley Company, Inc., personal communication with

Tom Adkisson, Planning Research Corporation (February 24, 1987).

11-2
Terran, Alex, 1987, Advanced Process Machinery, personal communication with
Tom Adkisson, Planning Research Corporation (January 14, 1987).

Watson, Micheal R., 1973, Pollution Control in Metal Finishing. Noyes Data
Corporation, Park Ridge, New Jersey.

11-3
 APPENDIX A

SUPPLEMENT

GUIDE TO WASTE MINIMIZATION IN THE PRINTED

CIRCUIT BOARD MANUFACTURING INDUSTRY

Wth Worksheets for Conducting a Waste Minimization

Assessment of a Printed Circuit Board Manufacturing Facility

Jacobs Engineering Group Inc.

Pasadena, California 91101-3063
under subcontract to Radian Corporation

Contract 68-02-4286

Project Officer

. .Lis.a M. Brown
Waste h4”ation, Destruction and
Disposal Research Division
Risk Reduction Engineering Laboratory
Cincinna~Ohio 45268

This study was conducted in cooperation with

California Department of Health Services
Toxic Substances Control Division
Alternative Technology Section
Sacramento, California 95814
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268

A- 1
 APPENDIX B

State of C a l l f o r n l r H e a l t h and Welfare Agency Department of HOJlth Servlcsr

ORDER FORM FOR CALIFORNIA HAZARDOUS WASTE CONTROL

LAWS AND REGULATIONS

Copies of hazardous waste control laws and regulations administered by the California Depafiment of Health Services
may be ordered by completing the form below and mailing it with the applicable payment to:
Department of General Services, PublicationsSection
P.O. Box 1015
North Highlands, CA 95660
(916) 973-3700
The laws and regulations are not identical, so both are generally needed to obtain complete information.

The laws (Chapters 6.5 through 6.98, Division 20, California Health and Safety Code) were enacted by the Legislature.
Recent history indicates that the laws change to some extent each year, usually effective January first. To keep up to
date with the laws, reorder them each year, because no amendment service is available.

The regulations (Chapter 30, Division 4, Title 22, California Code of Regulations) were adopted by the Department
of Health Services within the scope of the DHS’ authority under the laws. The regulations may change a t any time
during the year according to specified administrative procedures. Therefore, continuous amendment service is
available by subscription. The amendment sewice is useful only in conjunction with the complete regulations
(i.e., Division 4, Title 22, CCR).

I. Please check all applicable boxes and complete all applicable blanks.

0 Please send me copy(ies) of Item No. 7540-958-10 16-6,Hazardous Waste $

-
Control Law (Chapters 6.5 6.98, Division 20, Health and Safety Code), a t $25.00 per
copy, including postage, taxes, and handling costs.

0 Please send me copy(ies) of the regulations (Division 4, Title 22, Califomia $

-
Code of Regulations [CCRJ ) at $8.48 per copy, including postage, taxes, and handlingcosts.
(Item Number 0030-0224-7)
0 Please accept my subscription(s) to the continuous amendment service for the $
regulations (Division 4, Title 22, CCR) at $12.00 per subscription per year, including postage
and handling costs. The complete regulations must be ordered separately by checking the
applicable box. (Item Number 22-04-00) \

Make check or money order for the total amount payable to: State of Califomia.

TOTAL AMOUNT $

I I. Please print or type your mailing address and telephone number below; then sign and date the form.

Nz,me/Company Name

_ _ _ _ ~ ~

Address

City State Zip

Telephone Number (In case we need to contact you about your order)

OHS a400 ( 2 1 8 9 1
B- 1
 Ga
APPENDIX C

WHERE TO GET HELP: CALIFORNIA STATE AGENCIES LOCAL AGENCIES

M R C E N C Y SERVICES AIR REU)URCES BOAR0 ALR QUMIfy WAINTENANCE DISTRICTS

Spills (24-hour) 800/852-7550 1102 0 S t r e e t 1: Bay Area 415/771-6000
Emergency Planning 916/427-b287 Sacrsllento, CA 95814 2: Lake County 707/263-7000
916/322-2990 3: b r t h b a s t Unfd 707/443-3093
4: Northern Sierra 916/265-1398
5: S a r t a Comty 916/225-5674
HEALTH SERVICES 6: South Coast 818/572-6200
Toxic Substances Control HIGHWAY PATROL

Informat i o n Transport 916/327-3310

EPA I O number 9l 6/324-1781

Manifest 916/324-1781
O i l (Used) RbCycUng 916/324-1807 WASTE MNACEWNT BOARD
Hazardous Wsste 1020 Ninth Street, 1300
Exchange 9l6/324-1807 Sacremento, CA 95814
Recycling 916/324-1807
fr amp0rt 916/324-2430 916/322-3330
Oil (Used) Recycling BOo/S53-2962
Reqional Of lices

901 P S t r e e t
Sacrwento, CA .95814
916/322-3132
Water U u a l i t y 916/44S-9552
Lhderground Tanks 916/324-1262
AIR PawTIm CONTROL DISTRICTS
haador Comty 209/223-6406
WATER OUALITY CUNTROL BMRDS B u t t e County 916/891-2882
Calaveras Comty 209/754-6460
.on 1 707/ 976-2220 Colusa County 916/458-5891
.on 2 415/464-1255 E l Doredo Comty 916/621-5897
.on 3 805/549-3147 fresno County 209/445-3239
.on 4 213/6 20-4460 Glenn Comty 916/934-465 1
.on 5 7: Great Basin l h f d619/872-8211
iacranento) 916/361-5600 Imperial Cornty 6 19/33943 14
Kem County 80~/861-3682
'remo) 209/445-5116 Kings Comty M9/584-1411
Region 1 , TSCP ledding) %6/224-4845
10151 C r o y d m Uay .on 6 Lassen County 9l6/257-8311
Sacramento CA 95827 M8derp County 209/675-7823
(916) 845-7700 iauth Lake Tahoe) 916/S4&3481 hriP.8 COUl?ty 209/966-3689
rictorville) 619/2416SB3 bdocino h t y 707/463-4354
Region 1, TSCP .on 7 619/346-7491
(Suryeillapce, Enforcemmt 8 .on 8 714/782-4130 k r c e d County 209/38 5-7 391
S i t e Mitigation only) .on 9 619/265-5114 bdoc Comty 916/233-3939
5545 East Shields Avcnuc 8: Honterey Bay Unfd 408/443-1135
Fresm, CA 93727 "them Sanoma 707/43 3-5 911
(209) 445-5938 Placer County 9l6/889-3159
Socr.rsnto h t p 916/386-6650
Region 2, TSCP Ssn Bemardlno Cnty 619/243-8200
700 Heinz Avenue, BLdg. F
Berkeley, CA 94710 S.n M q COmty 619/694-3307
(415) 540-2122 San Jaquin County 209/468-3473
Son Luis Qispo Cnty 805/549-5912
-.m. 3. TSCP
.R- -e a.i-.
1405 North Sen Fernando Blvd.
Santa Barbara County BOW967-4872
S i s k i y w Comty 9 16/84 2- 80 29
Burbank, CA 91504 Stanislaus County 209/525-4152
(818) 567-3000 Sutter Comty 916/74 1-7500
R e g i o n 4, TSCP Tehara County . 416/527-4504
- . Uest
245 ._B r d a v . Suite 360 Tulare Comty 209/733-6438
Long Beach 90802 . Twlclnne County 209/5 33-5693
(213) 560-5950 Ventura Cornty 805/654-2667
Yolo-Solano County 9l6/666-8146
916/74 1-6484
-
Yuba Courty

*EnvirorrPental Hanagment Dist.

c-1 Awust 1989

 U. S. E P A R M N T OF TRANSPORTATION

WHERE TO GET HELP: Informntion b t l i n e : 2 0 2 / 3 6 6 4 8 8

Southern Cnlifomia: 818-005-7110
FEDERAL AGENCIES bbrthern California: 916/551-1300

U. S o COAST QURO u. s. PLBLIC HEKTH SERVICE

The U. S. Environmental National Response Center National Health Informntion

800/424-8002 800/3364797
Protection Agency has writ-
t e n s e v e r a l r e p o r t s which
will help you reduce, recy-
c l e or reuse hazardous
waste.
You can order the following
set for 6152 from t h e Na-
tional Technical Information
Service, Springfield, Vir-
ginia, 22161 (703/ 487-
46SO). The order number is
PB87-114328. Volume 1 is
t h e E x e c u t i v e Summary &
Fact Sheet
Minimization of Hazard-
ous Waste, Vob. 1-3.
You can order the following
three Waste Minimization
Audit R e p o r t s from NTIS.
Or you c a n o r d e r t h e ex-
ecutive summaries from Region 1 Region 2
John P. Kennedy hildiq 26 federal Plaza
EPA/ATD/HWERL, 26 W e s t Boston, t4& 02203 New York, NY 10278
St. Clair Street, Cincinnati, 617/565-3715 212/260-2525 .
Ohio, 4526R Region 4
Region 3
841 Cheakut Street 345 Courtlnnd Street
Case Studies of Corrosive Philadelphia, PA 19107 Atlanta, GA 30365
a n d Heavy Metal Waste 215/597-9800 404/347-4727
Minimization Audit at a Region 5 Region 6
.
S p e c i a l t y Steel Manufac- 2M South b u b o r n Stremt 1445 Reas Averue
turing Complex, (NTIS Q l i C . g d * f L 60604 b l l a s , TX 75202
PB88-10718O/GAR). 31Y353-ZW 214/655-6444

Region7 . Region 8
Case Studies of Minimiza- 726 Minnesota Averue 999 Eighteenth Street
Raneas City, KS 66101 Denver, CO 80202 -
t i o n of Solvent Waste
from Parts Cleaning and
* 91 3/236-2800 303/293-1603 -
from Electronic Capacitor Region 9H Region 10
215 f r m n t Street 1200 Sixth Averue
Manufacturing Operations, S.n F n n c i e c o , CA 94105 Seottle, WA 98101
(NTIS PB87-227013). 415/9?417960 206/442-5810

EPA t b t l i n e s
Case Studies of Minimiza-
t i o n of C y a n i d e Wastes RUU/Superfmd: 800/424-9346
f r o m Electroplating Oper- Small Business (Labudamnn: 800/368-5888 .
Title 111: 8OO/S 35-0 202
ations, (NTIS PB87-
229662). +%?qion 9 Information
Asbwtos: 415/974-7551
You'll find EPA (and other) b r g e n c y Rbsponse: 415/974-8131
offices listed to t h e right. Industry Aid: 415/974-7473
Radon: 41 S/97&8076

c-2
California Department of Health Services
Toxic Substances Control Program Regional Offices

Region 1 -Sacramenb
Toxic Substances Conml Program
10151 b y d o n Way
Sacramento, CA 95827
(916) 855-7700

Region 1 -Fresno
(Surveillance and Enforcement
and Site Mitigation only)
Toxic Substances Control Program
5545 East Shields Avenue
Fresno, CA 93727

Region 2 -Berkeley
Toxic Substances Control Program
700 Heinz Ave, Bldg. F
Berkeley, CA 94710
(415) 540-2122

1405 North San Fernando Blvd.

Burbank,CA 91504
(818) 567-3000

Region 4 -Long Beach

Toxic Substances Control Program
245 West Broadway, Suite 360
Long Beach, CA 90802
(213) 590-5950

c-3
E
WASTE REDUCTION TECHNICAUFINANCIAL ASSISTANCE PROGRAMS
The EPA's Office of Solid Waste and Emergency Response has set up a telephone call-in service to
answer questions regarding RCRA and Superfund (CERCLA):
(800) 242-9346 (outside the District of Columbia)
The following states have programs that offer technical and/or financial assistance in the areas of
waste minimization and m m e n t .

Alabama Connecticut D e p m e n t of Economic

Hazardous Material Management and Development
Resources Recovery Program 865 Brook Street
University of Alabama Rocky Hill,CI' 06067
P.O. Box 870203 (203) 2584200
T u s c a l ~ ~ AL
a , 35487-0203
(205) 348-8401 Georgia
Hazardous Waste Technical
Alaska Assistance Program
Alaska Health Project Georgia Institute of Technology
Waste Reduction Assistance Program Georgia Technical Research Institute
431 West Seventh Avenue, Suite 101 Envimnmental Health and Safety Division
Anchorage, AK 99501 O'Keefe Building, Room 027
(907) 276-2864 Atlanta, GA 30332
(404) 894-3806
Arkansas
Arkansas Industrial Development Environmental Protection Division
Commission Georgia Department of Natural Resources
One State Capitol Mall Floyd Towers East, Suite 1154
Little Rock, AR 72201 205 Butler Street
(501) 371-1370 Atlanta, GA 30334
(404)656-2833
California
Alternative Technology Division Illinois
Toxic Substances Control Program Hazardous Waste Research and
California Department of Health Services Information Center
P.O.Box 942732 Illinois Department of Energy and Natural
Sacramento, CA 94234-7320 Resources
(9 16) 324-1807 1808 Woodfield Drive
Savoy, IL 61874
Connecticut (217) 333-8940
Connecticut Hluardous Waste
Management Service Illinois Waste Elimination Research Center
Suite 360 Fritzker Department of Environmental
900 Asylum Avenue Engineering
Hartford,CI' 06105 Alumni Building, Room 102
(203) 244-2007 Illinois Institute of Technology
10 West 35th Street
Chicago, IL 60616
(313) 5674250

c-4
Indiana Maryland
Environmental Management and Maryland Hazardous Waste Facilities Siting
Education Program Board
Young Graduate House, Room 120 60 West Street, Suite 200 A
Purdue University Annapolis, MD 21401
West Lafayette, IN 47907 (301) 974-7281
(317) 494-5036
Maryland Environmental Services
Indiana Department of Environmental 2020 Industrial Drive
Management Annapolis, MD 21401
Office of Technical Assistance (301) 974-728 1
P.O. Box 6015
105 South Meridian Street Massachusetts
Indianapolis, IN 46206-6015 Office of Safe Waste Management
(317) 232-8172 Department of Environmental Management
100 Cambridge S e t , Rm. 1094
Iowa Boston, MA 02202
Center for Industrial Research and Service (617) 727-3260
205 Engineering Annex
Iowa State University Source Reduction Program
Ames, IA 50011 Massachusetts Department of Environmental
(515) 294-3420 Quality Engineering
1 Winter Street
Iowa Department of Natural Resources Boston, MA 02108
Air Quality and Solid Waste (617) 292-5982
Protection Bureau
Wallace- State Office Building Michigan
900 East Grand Avenue Resource Recovery Section
Des Moines, IA 50319-0034 Depamnent of Natural Resources
(515) 281-8690 P.O. Box 30028
Lansing, MI 30241
KanSaS (517) 373-0540
Bureau of Waste Management
Department of Health and Environment Minnesota
Forbes Field, Building 740 Minnesota Pollution Conml Agency
Topeka, KS 66620 Solid and Hazardous Waste Division
(913) 296-1590 520 Lafayette Road
St. Paul, MN 55155
Kentucky (612) 296-6300
Division of Waste Management
Natural R e s o w and Environmental Minnesota Technical Assistance F’mgram
Protection Cabinet University of Minnesota
18 Reilly Road 420 Delaware SE
Frankfort, KY 40601 P.O. Box 197 Mayo
(502) 564-6716 Minneapolis, MN 55455
(612) 625-9677
Louisiana
Department of Environmental Quality Minnesota Office of Waste Management
Office of Solid and Hazardous Waste 1350 Energy Lane, Suite 201
P.O.Box 44307 St. Paul,MN 55108
Baton Rouge, LA 70804 (612) 649-5750
(504) 342-1354

c-5
Missouri Governor's Waste Management Board
State Environmental Improvement and 325 North Salisbury Street
Energy Resources Authority Raleigh, NC 27611
225 Madison (919)733-9020
P.O. Box 744
Jefferson City, MO 65102 North Carolina Technical Assistance Unit
(314) 751-4919 Hazardous Waste Section
North k l i Department
~ of Environment,
New Jersey Health and Natural Resources
New Jersey Hazardous Waste Facilities 401 Oberlin Road
Siting Commission P.O. Box 2091
28 West State Street, Room 614 Raleigh, NC 27602
Trenton, NJ 08608 (919) 733-2178
(609) 292-1459
Ohio
Hazardous Waste Advisement Program Division of Solid and Hazardous Waste
Bureau of Regulation and Classification Management
Division of Hazardous Waste Management Ohio Environmental Protection Agency
New Jersey Depaxtment of Environmental 1800 Watemark Drive
Protection Columbus, OH 43215
401 East State Smet, CN 028 (614)644-3020
Trenton, NJ 08625
(609) 292-8341 Ohio Technology Transfer Organization
77 South High, 26th Floor
Risk Reduction Unit Columbus, OH 43266-0330
Division of Science and Research (614)466-4286
New Jersey Department of Environmental
Protection Oklahoma
401 East State Street, Industrial Waste Elimination Program
6th Floor, CN 409 Oklahoma State Department of Health
Trenton, NJ 08625 P.O. Box 53551
(09)984-6070 Oklahoma City, OK 73152
(405) 271-7353
New York
Department of Energy Conservation Oregon
Division of Hazardous Substances Regulation Oregon Hazardous Waste Reduction
Bureau of Hazardous Waste Program Program
Development Department of Environmental Quality
50 Wolf Road, Room 231 811 Southwest Sixth Avenue
Albany, NY 12233-7253 Portland, OR 97204
(518) 457-3273 (503)229-5913
North Carolina Pennsylvania
Pollution Prevention mgram Pennsylvania Technical Assistance Program
Department of Environment, Health, and Williams Street Building #lo1
Natural Resources University Park, PA 16801
P.O. Box 27687 (814)865-0427
512 North Salisbury Street
Raleigh, NC 27611 Center of Hazardous Material Research
(919)733-7015 University of Pittsburgh
320 William Pi# Way
Pittsburgh, PA 15238

C-6
Bureau of Waste Management Pennsylvania Virginia
Department of Environmental Resources Office of Policy and Planning
P.O. Box 2063 Virginia Department of Waste Management
Fulton Building 11th Floor, M o m Building
3rd and Locust Streets Richmond, VA 23219
Harrisburg, PA 17120 (804) 225-2667
(717)787-6239
Washington
Rhode Island Hazardous Waste Section
Ocean State Cleanup and Recycling Program 4224 Sixth Avenue SE
Rhode Island Department of Environmental (Rowesix Bldg. 4)
Management Lacy, WA 98503
83 Park Street (206)459-6322
Providence, RI 02908-5003
(401) 277-3434 Wisconsin
Bureau of Solid Waste Management
Center for Envimnmental Studies Wisconsin Department of Natural Resources
Brown University P.O.Box 7921
P.O.Box 1943 101 South Webster Street
135 Angell Street Madison, WI 53707
Providence, FU 02912 (608) 266-2699
(401) 863-3449 ~

Wyoming
Tennessee Solid Waste Management Program
Center for Industrial Services Wyoming Department of Environmental
106 Student Services Quality
University of Tennessee Herchler Building, 4th Floor
Knoxville, TN 37996 West Wing
(615) 974-3018 122 West 25th Street
Cheyenne, WY 82002
(307)777-7752

c-7
 APPENDIX D

WASTE REDUCTION AUDIT

CHECKLIST

FOR

PRINTED CIRCUIT BOARD

MANUFACTURING PLANTS

D
 TABLEOFCONTENTS

Section Title Pane

D1.O GENERAL INFORMATION D- 3

D2.0 RAW MATERIAL A N D HAZARDOUS WASTE DATA D-3

D3.0 RAW MATERIAL USAGE/HANDLING D-9

D4.0 PRODUCTION PROCESSES d-11

D4.1 SOURCE REDUCTION D-11

D4.2 RECYCLING A N D RESOURCE RECOVERY D-2 1

D5.0 ALTERNATIVE TREATMENT D-24

D6.0 ECONOMIC DATA D-29

D- 1
 LIST OF TABLES

Table Title Pane

D2.1 RAW MATERIAL DATA D-4

D2.2 HAZARDOUS WASTE DATA D-7

D3.1 SUMMARY OF RAW MATERIAL USAGE/HANDLING

WASTE REDUCTION OPPORTUNITIES D-10

D4.1 RINSE SYSTEM INFORMATION D-12

D4.2 PROCESS BATH INFORMATION 0-13

D4.3 POTENTIAL PROCESS CHEMISTRY REPLACEMENT D-14

D4.4 RINSE SYSTEM FLOW R A T E DATA D-15

D4.5 DRAG-OUT LOSS R A T E DATA D-17

D4.6 EQUIPiMENT CLEANOUT PROCESS DATA D-19

D4.7 SUMMARY OF SOURCE REDUCTION

OPPORTUNITIES D-20

D4.8 RINSE WATER RECYCLING DATA D-2 1

D4.9 POTENTIAL SPENT ACID/ALKALINE BATH

REUSE OPPORTUNITIES D-22

D4.10 RESOURCE RECOVERY EQUIPMENT EVALUATION

DATA D-23

D4.11 SUMMARY OF RECYCLING AND RESOURCE

RECOVERY OPPORTUNITIES D-24

D5.1 ALTERNATIVE WASTEWATER TREATMENT

CHEMICALS D-25

DS.2 WASTE SOURCE SEGREGATION OPPORTUNITIES D-26

D5.3 SLUDGE DEWATERING DATA D-27

D5.4 ALTERNATIVE TREATMENT TECHNOLOGY

DATA D-28

D5.5 SUMMARY O F ALTERNATIVE TREATMENT WASTE

REDUCTION OPPORTUNITIES D-28

D6.1 ECONOMIC DATA SUMMARY SHEET D-29

D6.2 COST/BENEFIT ANALYSIS WORKSHEET D-32

D-2
 WASTE REDUCTION AUDIT
CHECKLIST

This checklist can be used to perform a waste reduction audit a t a printed

circuit (PC) board manufacturing plant. Plant personnel performing the audit should
review the checklist prior to beginning the audit. In addition, Chapter 8 of the
report titled Waste Audit Study - Printed Circuit Board Manufacturers, prepared for
the California Department of Health Services Alternative Technology Section,
describes waste reduction techniques available to PC board manufacturers and
provides guidance on how to perform a waste reduction audit.

D1.O GENERAL INFORMATION

Company
Company Address:

Contact Person:
Phone Number:

Number of Employees:
Hours of Operation Per Day:

Square Footage of Board Produced Per Month:

Percentage of Double Sided:
Percentage of Multiple Layer:
(Breakdown by Number of Layers):

D2.0 RAW MATERIAL AND HAZARDOUS WASTE DATA

Fill out tables 2.1 and 2.2 before continuing the checklist. List information on
all raw materials used a t the plant-in Table D2.1. List information on all hazardous
waste generated a t the plant a t Table D2.2. The tabulated information will assist
auditors in completing this checklist.

D-3
 T A B L E D2.1
RAW M A T E R I A L DATA

r 1

COST/ ANNUAL ANNUAL DISPOSAL

- r SUPPLIER UNIT USAGE COST METHOD

Process Chemicals:

o Cleaners

D-4
 T A B L E D2.1 (continued)
RAW M A T E R I A L D A T A

t 1
LNNUAL IISPOS A L
M A T E R I .4LS SUPPLIER :OST

~ o Solvents

Wastewater
Treatment
Chemicals: I
o pH Adjustors
I
i I
I

1o Precipitants
I

D-5
 T A B L E D2.1 (continued)
R A W M A T E R I A L DATA

COST/ ANNUALIANXUALIDISPOSAL 1

-TT-i
METH D

o Coagulants

D-6
 T A B L E D2.2
H A Z A R D O U S WASTE D A T A

ANNUAL ANNUAL
QUANTITY DISPOSAL DISPOSAL DISPOSAL
WASTE GENERATED METHOD COST/UNIT COSTS

o Industrial
Treatment Sludge

o Spent Process Baths

l

o Equipment
Cleaning
Solutions
1

o Off-Specification
Mat e r ia Is

o Unused Samples

I I I I I

D-7
 T A B L E D2.2 (continued)
H A Z A R D O U S WASTE D A T A

ANNUAL ANNUAL
DISPOSAL DISPOSAL
WASTE COST / U N IT COSTS
o Spill Clean-up
Materials

2
o Others .

D- 8
I
D3.0 R A W MATERIAL USAGE/HANDLING

Many wastes a r e generated by degradation of raw materials a n d by spills. This

section is designed to help determine if these waste streams can be reduced.

Are off-specification material wastes generated because the material has exceeded
its shelf life? Yes No
How often is a n inventory performed to identify a n accumulation of materials?

Does the company utilize a first-in first-out material usage policy to prevent
materials from being deteriorating in storage? NoYes
Does the company minimize inventory to prevent material degradation d u e to
prolonged storage? Yes No

D o e r the plant accept samples from chemical suppliers? Yes No

Do unused samples become waste? Yes No
Has a person been designated f o r approving the acceptance of samples?
Yes No
Are suppliers required to take back unused samples they provide?
Yes No

Does the plant generate wastes due to spills during material handling or storage?
Yes No
If yes, describe the frequency of these spills.
How often is the storage area inspected to check the integrity of containers a n d
their proper storage?
Are personnel trained to ensure proper handling and storage of materials?
Yes No
Is spill containment provided to minimize the amount of clean-up materials used to
contain a n d clean-up spills? Yes No

Describe spill containment used in material storage areas.

D-9
Summary of Raw Material Usage/Handling Waste Reduction Opportunities:

Complete Table D3.1- to identify potential techniques for reducing waste

generation associated with raw material storage and handling. Implementation
potential should be based on technical constraints and limitations due to the plant’s
size a n d layout. Economic limitations will be evaluated in Section 6.0.

TABLE D3.1

SUMMARY OF R A W MATERIAL USAGE/HANDLING

WASTE REDUCTION OPPORTUNITIES

Waste Reduction Currently Used Implementation Potential

Techniaue (Yes/No) High Medium Low None

O f f Spec Materials:

o Improved Inventory
o First-in First-out
Policy

o Reduce Quantities
Stored

Unused Samples:

o Designate Sample
Acceptor

o Return to Suppliers

Material Spills:

o Increased Inspections
o Improved Training
o Spill Containment

D-10
D4.0 PRODUCTION PROCESSES

Fill out Table D4.1 and D4.2 before continuing the checklist. List information
about a11 rinse systems associated with the process lines in Table D4.1. List
information about each process bath in Table D4.2.

D4.1 SOURCE REDUCTION

Material Substitution:

Has the company attempted to replace all chelated process chemistries with non-
chelated process chemistries? Yes -. No

Additional treatment chemicals a r e often required to breakdown chelators and

precipitate metals during wastewater treatment. These chemicals contribute to
sludge volume.

Does the plant have access to a Publically Owned Treatment Works (POTW)?
Yes No
Does the POTW have a pretreatment program for industrial waste discharges?
Yes No
Has the company attempted to replace all process bath chemicals that, when spent,
are handled as hazardous waste with chemicals that can either be recycled or
treated and discharged to the POTW when their process baths become spent?
Yes No

Many chemical manufacturers now provide chemical products that can be

returned for recycling or treated on-site in the plant’s treatment facility. Examples
of these include peroxide/sulfuric etchants, electroless copper baths, reflow oil, and
electroplating rack stripper materials.

D-11
 TABLE D4.1
RINSE SYSTEM INFORMATION

RINSE SYSTEM RINSEWATER NUMBER COUNTER PROCESS BATH (S) ESTIMATED

IDENTIFICATION FLOWRATE OF TANKS CURRENT PRECEEDING RINSE DAILY WATER
NUMBER (Yes/No) SYSTEM SYSTEM USAGE
(Yes/Nol
 TABLE D4.2
PROCESS BATH INFORMATION
.
PROCESS BATH/ CHEMICAL PROCESS DRAG-OUT METHOD FREQUENCY CONTAINS
IDENTIFICATION CONSTITUENTS BATH VOLUME/ OF OF DUMPS CHELATORS
NUMBER AND VOLUME FULL RACK DISPOSAL (Yes/No)
CONCENTRATIONS IN TANK LOAD
I
I

U
c.
w
 List all process chemistries in Table D4.3 that were identified as containing
chelators or require handling as hazardous waste when spent. Contact chemical
suppliers to inquire about the availability of non-chelated chemicals or treatable and
recyclable chemicals to replace chemicals on the list. Discuss maintenance
considerations and the effects on other processes that replacement with these
chemistries would entail.

TABLE D4.3

POTENTIAL PROCESS CHEMISTRY REPLACEMENT

Present Advantage/
Chemistries Used Potential ReDiacements Disadvantaae

Improved Rinse Efficiency:

Does the plant have the available space to install multiple counter-current rinse
tanks a t any of the rinsing stations? Yes No
Have the flow rates used on all the rinse systems been determined based on rinsing
needs of the particular process chemistry? Yes NO
To determine the required rinse water flow rate for each single stage rinse system,
use the following equation:

D-14
 'Q = D(Cp/Cr)
where Q = Rinse water flow rate
D = Drag-out rate (see drag-out loss reduction in this
worksheet for methods to calculate drag-out).
Cp = Chemical concentration in process bath
Cr = Allowable chemical concentration in rinse bath

* (Equation taken from EPA report titled Summary Report - Control and
Treatment Technology for the Metal Finishing Industry - In - Plant Changes,
January 1982.)

To determine the flow rate required to operate multiple stage counter-current rinse
systems use the following equation:

Where N = number of rinse tanks in the counter-current rinse system.

* (Equation taken from EPA report titled Summary Report - Control and
Treatment Technology for the Metal Finishing Industry - In - Plant Changes,
January 1982.)

Complete Table D4.4 for all rinse systems used a t the plant.

TABLE D4.4
RINSE SYSTEM FLOW RATE DATA

Present Water Required Mu 1ti ple Cou n te r-C u rre n t

-Rinse Tank Flow Rate Flow Rate Rinse Flow Rate

I D-15
Y
Does the plant utilize flow restrictors, flow control meters, or other devices
intended to regulate the flow of water through all the rinse tanks?
Yes No

Agitation improves rinse efficiency so that less water is needed to do the job.
Do all the rinse systems utilize forced a i r or forced water as a means of agitating
the rinse solution? Yes No
If no, a r e workpiece racks agitated manually while submersed in the rinse solution?
Yes No

Does the sum of each rinse system’s estimated daily water usage approximate the
average daily volume of wastewater treated? Yes -N o
If no, rinse water lines are most likely being left on even when the process line is
not in operation. Automated flow controls or increased training of personnel in
watet conservation should be considered.

Drag-out Reduction:

Drag-out loss of process chemicals is a significant source of waste generation.

Process chemical drag-out carried away in the rinse water effluent contributes to
sludge volume when the contaminants are removed during industrial waste treatment.
In addition, the greater the drag-out volume entering the rinse system, the greater
the volume of water required to perform adequate rinsing.

T h e volume of drag-out from process baths can be calculated by sampling the

rinse water solution after a full work piece rack has been rinsed. The rinse tank
must not have its water turned on during the sampling, however. The following
equation can be used to calculate drag-out:

(Crl x (Vr)
Vd =
CP

Where Vd = Volume of drag-out loss

Vr = Volume of water in the rinse tank
Cp = Concentration of chemicals in process bath
Cr = Concentration of chemicals in rinse water

The chemical chosen f o r analysis in the rinse water sample should be one that
(1) can be quantified in the process solution and (2) will not break down in the
D-16
rinse solution to a level where comparison of the concentration in the rinse with its
concentration in the process bath is invalid. The values obtained for drag-out can
be used to assess rinse efficiency techniques, drag-out reduction techniques, a n d
resource recovery techniques.

Drag-out can also be measured volumetrically by utilizing a drainage pan to

catch all the drag-out that will drain from the circuit boards a n d the work piece
racks. After all free liquid has drained from the work piece rack, the volume of
liquid can be measured. Although this method will not allow measurement of the
volume of drag-out that forms a thin film on circuit board surface, it can be used
to assess effectiveness of slower work piece withdrawal a n d longer drainage time.

Complete Table D4.5 describing drag-out loss d a t a f o r each process tank.

TABLE D4.5
DRAG-OUT LOSS RATE DATA

Present Potential Drag-out Minimization

Process T a n k Drag-out Rate Technolow Emdoved

I I I
I
Has a n optimal removal rate a n d drainage time f o r work piece racks been
determined for each process bath? Yes No
Are personnel trained to consistently follow proper work piece rack removal rates
a n d drainage times? Yes No

D-17
Are personnel retrained periodically to assure these procedures are followed?
-Yes No

Can any of the chemical process baths be operated at a higher temperature without
adversely affecting production quality? Yes No
Process baths operated at elevated temperatures will have less drag-out then when
operated a t room temperature.

Are process baths operated at the lower end of the manufacturers suggested range
of operating concentrations? Yes No
Are fresh process bath solutions operated at a lower concentration than replenished
process bath solutions? Yes No
T h e lower the concentration in the process bath, the lower the volume of drag-out
loss.

Is there space between process bath tanks and their associated rinse tanks that
allows process chemicals to drip onto the floor? -Yes No
If yes, drain boards can be used to direct drainage back into the process tank.

Do process baths that operate a t elevated temperatures utilize drag-out tanks as the
initial rinse following the bath? Yes No
If yes, is the drag-out tank solution added back to the process tank?
-Yes No
Has the company studied the possibility of using the drag-out solution for process
bath replenishing? Yes No

Cleaning Solution Reduction:

Cleaning solution wastes can be reduced by using multiple stage cleaning

systems. Multiple stage cleaning can include any process where several solutions
a r e used to clean equipment. The first solution is used for initial cleaning and is a
previously used solution. The proceeding solution can be fresh cleaner. When the
first solution becomes too contaminated to adequately perform initial cleaning, it is
removed from the cleaning process for disposal. The second solution then becomes
the first. This method of equipment cleaning produces significantly less cleaning
solution waste. The more cleaning solution stages used, the less volume of solution

D-18
required for each cleaning stage. Therefore, less waste is generated when the first
solution is disposed.
Does the plant utilize multiple stage cleaning lines f o r all equipment cleaning
opera t ions? -Yes No

List the equipment cleaning operations used a t the plant in Table D4.6 and
describe how each has or can incorporate some method of a multiple cleaning line.
This can be done by using multiple cleaning tanks or if the cleaning solution is
used to clean-out a tank, using multiple cleaning steps with each step using a less
contaminated solution.
TABLE D4.6
EQUIPMENT CLEANOUT PROCESS DATA

, Cleanina Process Potential MultiDle Staae Cleanina Omions

Summary of Source Reduction Opportunities:

Complete Table D4.7 to identify potential source reduction techniques that can
be implemented into the plant’s production processes. Implementation potential
should be based on technical constraints and limitations due to the plant’s size and
layout. Economic limitations will be evaluated in Section 6.0.

D-19
 TABLE D4.7
SUMMARY OF SOURCE REDUCTION OPPORTUNITIES

Waste Reduction Currently Used Implementation Potential

Techniaue (Y/N) Hiah Medium Low None

0 Nonchela ted
Process Chemistries

0 Treatabie or
Recyclable Process
Chemistries

0 Multiple Rinse Tanks

0 Reduced Rinse Water

Flow Rates

0 Flow Restrictors

0 Control Meters

0 Work Piece Rack

Agitation

0 Turbulence Agitation .

0 Slower Work Piece

Removal Rates

0 Longer Work Piece

Drainage

0 Elevated Process Bath

Temperatures

0 Reduced Process
Bath Concentrations

0 Drain Boards

0 Drag-out Tanks

0 Multiple Stage
Equipment Cleaning Lines

D-20
DJ.2 RECYCLING AND RESOURCE RECOVERY

Does the plant generate rinse water effluents from rinse operations that follow mild
and/or strong acid etching a n d cleaning processes?
Yes NO
If yes, a r e the rinse solutions recycled f o r use in rinse systems following alkaline
cleaning baths? . Yes No

Evaluate the potential for recycling the rinse water effluent from each rinse
system f o r reuse as rinse water influent to another rinse system. T h e most likely
candidates would be the effluent from a rinse system following acidic cleaning
processes being used as the influent to a rinse system that follows a n alkaline
cleaning line. Other possibilities include rinse effluent following a mild acid
cleaning line used a s influent for a system following a strong acid cleaning or
etchihg line. In List required flow rates f o r each recycling combination of rinse
systems i n Table D4.8 a n d determine the need f o r holding tanks, replumbing, and
process line rearrangement.

TABLE D4.8
RINSE WATER RECYCLING DATA

Rinse System Effluent Rinse System Influent Other

Flow Rate Flow Rate Consider at ions

1
~ ~~

I I

D-2 1
Does the plant generate spent alkaline and/or acidic baths that can be used f o r
elementary neutralization in the industrial waste treatment process?
Yes No

Evaluate the potential for reusing spent process baths f o r other purposes such
as elementary neutralization during waste treatment. In Table D4.9 list the acidic
or alkaline spent process baths generated and identify a wastewater treatment
neutralization process that could use this material. Consult with process chemical
and treatment system representatives to evaluate the potential for reusing these
spent process baths.

Process Bath/pH/ Neutralization Process/pH

Volume Per Month Volume Per Month

1
I

II I
I I

Does the plant generate waste streams that contain valuable process chemicals or
metals? Yes No
If yes, does the plant currently utilize any recycling technologies to recover
valuable process chemicals or metals? Yes No

Recovery unit equipment representatives should be consulted to evaluate the

feasibility of using chemical recovery technologies. However, when discussing these
technologies with equipment representatives, waste characterization data will be
needed. Fill out Table D4.10 to develop the necessary data. Potential recovery
technologies include reverse osmosis, ion-exchange, electrolysis, and evaporation.

D-22
 TABLE D4.10
RESOURCE RECOVERY EQUIPMENT EVALUATION DATA

Does .the plant utilize treatment technologies to recycle rinse water?

Yes No
If no, has the plant assessed the potential for developing a closed loop rinse water .

system? Yes No

Does the plant generate copper sulfate crystals? Yes No

If yes, a r e the crystals recycled into the copper electroplating solution or treated
to recover copper? Yes No
If no, the plant should assess the potential for regenerating copper electroplating
baths with copper sulfate crystals generated in the copper etchant baths.

Does the plant use a n alkaline stripper to clean photoresist material off of printed
circuit boards? Yes No

Is the stripper decanted or filtered periodically to remove polymer flakes and

increase the useful life of the stripper? Yes No

D-23
Summary of Recycling and Reuse Recovery Opportunities:

Complete Table D4.1 I to identify potential recycling and resource recovery

techniques that can be implemented into the plant’s production process.
Implementation potential should be based on technical constraints and limitations
due to the plant’s size and layout. Economic limitations will be evaluated in
Section 6.0.

TABLE D4.11
SUMMARY OF RECYCLING AND RESOURCE RECOVERY OPPORTUNITIES

Recycling
Recovery Currently Used Implementation Potential
Techniaue (Y/N) High Medium L o w None

.Rinse water reuse

Use of spent
a1kaline/acidic
baths f o r
neutralization

Process chemical or
metals recovery

- Reverse osmosis
- Ion exchange
- Electrolysis
- Evaporation
- Others

Rinse water
recycling

Copper sulfate
crystal reuse

Photoresist stripper
decantation

D5.0 ALTERNATIVE TREATMENT

Natural non-hazardous contaminants, such as phosphates and carbonates, can

contribute to, and thereby expand, the total volume of sludge generated as

D-24
waste during industrial waste treatment. In addition, these natural contaminants
often require greater quantities of rinse water to do the job. Therefore,
pretreating process rinse waters can reduce hazardous waste generation and rinse
water usage.
Does the plant pretreat water prior to its use in production processes?
Yes No
I f no, consult with equipment manufacturers to determine the treatment unit size
necessary to treat the water used in various production processes and to identify
other considerations necessary to assess the potential for pretreating water.
Analysis of an untreated water sample may also provide information necessary to
determine the effectiveness of pretreating process water. Process chemical
manufacturers may be able to assist auditors in determining potential improvements
i n production and waste treatment.

Has'the plant evaluated the use of alternative treatment chemicals (such as caustic
soda instead of lime or polyelectrolytes instead of alum or ferric chloride) to
identify those that generate the lowest volume of sludge? - Yes - No

In Table D5.1 list treatment chemicals presently used io treatment systems and
consult with chemical suppliers to identify alternative treatment chemicals that may
decrease current sludge volume. Plant may decide to experiment with alternative
treatment chemicals and monitor sludge generation.

TABLE D5.1

ALTERNATIVE WASTEWATER TREATMENT CHEMICALS

Chemical Presently Substitute 96 Change in Sludge Volume

Used/Cost Chemical/Cost (estimated or observed)
I

I
I

I I

D-25
Does the plant use chelators in any of the process baths? Yes NO
As stated in Section 4.1 of this checklist, wastestreams that contain chelators often
require additional treatment. This additional treatment will cause a greater volume
of wastewater treatment sludge to be generated.
Are additional treatment steps, such as adjustment of pH to below 2 or ferrous
sulfate reduction required to treat chelated waste streams? Yes No
If yes, are waste streams that contain chelators segregated from other waste
streams prior to treatment? Yes No

Are waste streams that only require neutralization segregated from waste streams
that require metal removal? Yes No

In Table D5.2 list all separate waste sources that normally a r e mixed prior to
treatfient and/or off-site disposal. For each source, auditors should identify what
treatment steps a r e needed before waste can be discharged. Auditors should then
evaluate the impact separate treatment of these waste sources will have on waste
volume. Mixing of wastewater may interfere with the efficient treatment of
separate waste streams and, therefore, cause additional treatment chemicals to be
used. This can generate additional wastewater treatment sludge.

TABLE D5.2
WASTE SOURCE SEGREGATION OPPORTUNITIES
r
Necessary Treatment Potential f o r
Waste Sou rce Prior to Discharee SeDarate Treatment

I 1
I I

1 I

I 1 I I
Is the solids Concentration of the industrial waste sludge less than 30%?
- Yes No
If yes, has the plant considered dewatering sludge to reduce its volume?
- Yes No
If the solids content of the sludge is above 30 percent, has the plant considered
using sludge dryers to further reduce sludge volume? Yes No

Based on the volume and solids concentration of sludge, the auditors should
identify the type of dewatering units that are pertinent to their application.
Equipment suppliers should be consulted. Fill-in Table D5.3 with the information
obtained on sludge dewatering technologies.

TABLE D5.3
SLUDGE DEWATERING DATA

Source of Solids Volume Generated Applicable De w a t e r i n g

, Sludge Content Each Month Tech noloaies

Does the plant operate a n industrial waste treatment facility?

Yes No
If yes, does the treatment facility produce a wastewater treatment sludge that is
handled as a hazardous waste? Yes No
If yes, has the plant evaluated the use of an alternative treatment systems that
produce less residual waste than the existing treatment facility?
Yes No

Complete Table D5.4 with available data on the plant’s industrial waste
streams. After assembling available wastewater characterization data, auditors
should consult with equipment manufacturers’ representatives to evaluate the
feasibility of utilizing alternative wastewater treatment systems that do not generate
a sludge residue. Applicable technologies include reverse osmosis and ion-exchange.
D-27
 TABLE D5.4
ALTERNATIVE TREATMENT TECHNOLOGY DATA

Potential
Wastewater Volume Chemical Alternative
,Stream GPM GPD Ana lvses Data Treatment Comments
I

Summary of Aiternative Treatment Waste Reduction Opportunities:

Complete Table D5.5 to identify potential alternative treatment techniques that

can be implemented by the plant. Implementation potential should be based on
technical constraints a n d limitations due to the plant’s size and layout. Economic
limitations .will be evaluated in Section 6.0.

TABLE D5.5

SUMMARY OF ALTERNATIVE TREATMENT W A S T E

REDUCTION OPPORTUNITIES

Alternative
Treatment Currently Used Implementation Potential
Tec hn iaue iY/N) Hiah Medium Low None

Process water
pretreatment

Alternative
treatment
chemicals

Waste stream
segregation

Sludge dewatering

Alternative
wastewater
treat men t -
D-28
D6.0 ECONOMIC DATA

Complete Table D6.1 before continuing the checklist. Table D6.1 provides
space for summarizing economic information on material purchase costs, waste
disposal costs, and waste reduction equipment purchase costs. The data listed in
the table can then be used by the plant to perform cost benefit analyses on waste
reduction opportunities identified during the audit.

Cost/benefit analysis worksheets should be completed for each waste reduction

technique identified as having a high, medium or low implementation potential. A
copy of the cost/benefit analysis worksheet is provided at the end of this checklist.
The worksheet is intended to aid the auditors in developing rough estimates of
projected costs, savings, and payback periods associated with each waste reduction
technology. They do not take into account amoritization, depreciation, or tax
f actois.
TABLE D6.1
ECONOMIC DATA SUMMARY SHEET

MATERIALS PURCHASE COSTS

Materia 1 Cost /Un i t Cost/Mont h

Water Fees
Treatment Chemicals

Process Chemicals

D-29
 TABLE D6.1 (continued)
ECONOMIC DATA SUMMARY SHEET

WASTE DISPOSAL COSTS

1

Waste Cost / U n it Cost /Mon th

Sewer Discharge
Hazardous Wastes
- Industrial Treatment Sludge
- Nitric Acid Waste
- Photoresist Stripper Waste
Others

WASTE REDUCTION EQUIPMENT PURCHASE COSTS

Equipment Descr i D t ion Cost

Process Tanks
Storage Tanks
Conductivity Meters
Flow Restrictors
Plumbing Materials
Pumps I I
- Water
Sludge Dewatering Equipment
Material Recycling/Recovery Units

D-30
 TABLE D6.1 (continued)
ECONOMIC DATA SlihIhfARY SHEET

Other Equipment Descr iDtion w

D-3 I
 TABLE D6.

COST/BENEFIT ANALYSIS WORKSHEET

WASTE REDUCTION TECHNIQUE:

CAPITAL COSTS

- Equipment
- Installation
- Production Downtime
- Construction Materials
Other
Implementation Costs

ANNUAL OPERATING COST SAVINGS FROM IMPLEMENTATION:

Estimate the material savings that can be achieved by implementing the identified
waste reduction techniques. Then using the cost data for these materials calculate
the a h u a l savings in material purchases.

Water Use
Sewer Fees
Power
Chemical .Usage
-

Waste Handling
-

Labor
Misc.
Total Annual Savings

Does the estimated savings justify a n investment in this waste reduction technique?
Explain.

D-32
I...... .
.-. _.........

APPENDIX E
STATUTES AND REGULATIONS AFFECTING
HAZARDOUS WASTE GENERATORS
CONTENTS

Subject Paqe
E.l Introduction . . . . . . . . . . . . . . . . . . . . . E-2
E.2 Generator Standards . . . . . . . . . . . . . . . . . E-2
E.2.1 Determination of Waste Classification . . . . . E-2
E-2.2 EPA Identification Number . . . . . . . . . . E-3
E.2.3 Uniform Hazardous Waste Manifest . . . . . . . E-3
E.2.4 Reports . . . . . . . . . . . . . . . . . . . . E-4
E.2.5 Packaging. Labeling and Marking Requirements . E-4
E.3 Recyclable Hazardous Wastes . . . . . . . . . . . . . E-4
E.4 High BTU Wastes . . . . . . . . . . . . . . . . . . . E-4
E.5 "Lab Packs" . . . . . . . . . . . . . . . . . . . . . E-4

E.6 Other State and Federal Statutes and Regulations . . . E-5

E.5.1 Federal Clean Water Act . . . . . . . . . . . . E-5
E.5.2
E.5.3 California Proposition 65 . . . . . . . . .. .. .. E-5
Federal Occupational Safety and Health Act E-5

E.7 Solvent Wastes: Land Disposal Restriction . . . . . . E-6

E.8 Summaries of.Pertinent Statutes. Regulations and

Ordinances ...................... E-6

E.9 Regulatory Agencies and Information . . . . . . . . . E-6

TABLES
E-1 Recyclable Hazardous Wastes . . . . . . . . . . . . . E-7
E-2 Restricted Hazardous Wastes. . . . . . . . . . . . . . E-8
E-3 Solvent-Containing Hazardous Wastes for Which Land
Disposal Restrictions Were Proposed by EPA . . . . . . E-9
E-4 Summary of General Requirements . . . . . . . . . . . E-11
E-5 Selected Codes and Regulations Relevant to
Hazardous Waste Generation and Management . . . . . . E-13

E-1
I ’

October 19, 1988

APPENDIX E
STATUTES AND REGULATIONS AFFECTING HAZARDOUS
WASTE GENERATORS

.E.1 Introduction
California generators, transporters and treatment, storage and/or
disposal facility operators must comply with laws for handling
hazardous materials and wastes. The California Department of
Health Services (DHS) is the state agency responsible for
controlling and monitoring hazardous waste management. This
appendix will discuss some of the federal, state, and local laws,
regulations and ordinances that apply to generation,
transportation, treatment, storage, and/or disposal of hazardous
waste.
Summaries of relevant requirements appear in Tables E-4 and E-5.
Persons involved in regulated activities should become familiar
with the requirements. If needed, additional help can be obtained
from the agencies listed elsewhere in this report. Contact those
sources for details and updated information.
E.2 Generator Standards
Article 6, Chapter 30, Division 4, Title 22, Califcrrnia Code of
Regulations (CCR) details requirements with which all generators of
hazardous waste must ordinarily comply. These requirements include
the following:
- Determine if each generated waste is hazardous.
- Obtain an EPA Identification Number.
- Prepare a manifest for all off-site shipments of hazardous
waste.
- Prepare and submit biennial reports covering generator
activities of the previous year with respect to hazardous
waste.
- Comply with requirements for generators who accumulate
hazardous wastes outsite, pending off-site shipment within
90 days.

- Ship hazardous wastes off-site within 90 days or obtain a

hazardous waste storage facility permit from DHS and comply
with other requirements applicable to facility operators.

E-2
 October 19, 1988
- Ensurethat prior to shipment off-site, all wastes conform
with DHS and Department of Transportation regulations for
proper packaging, labeling, and marking.
- Payapplicable fees to the California State Board of
Equalization for hazardous wastes generated.
The generator is responsible for meeting other requirements that
might not be specified in this appendix.
E.2.1 Determination of Waste Classification
The generator of a waste must determine if the waste is hazardous.
To-do this, the generator must determine if the waste is specif-
ically listed as a hazardous waste (Article 9, CCR), and/or if it
is a characteristic hazardous waste (ignitable, corrosive, toxic,
reactive) (Article 11, CCR). Certain wastes are also classified as
Itextremelyhazardous wastes.11 These are listed in Article 9, CCR
and their characteristics are identified in Article 11, CCR.
E.2.2 EPA Identification Number
Any generator of hazardous waste must obtain from EPA or DHS an EPA
Identification Number. This number must be used on all official
documents involving waste generation, transportation, treatment,
storage, and/or disposal. This number must also appear on all
required reports. A generator shall not offer his hazardous waste
to a transporter or to an operator of a treatment, storage, and/or
disposal facility who does not have an EPA Identification Number.
E.2.3 Uniform Hazardous Waste Manifest (luManifestll)
A generator who offers for transportation a hazardous waste f o r
treatment, storage and/or disposal off-site must prepare a manifest
before shipping the waste off-site. The manifest is a multicopied
document that allows the generator and the DHS to track shipments
of hazardous waste. The manifest also provides the DHS with data
on waste generation throughout the state.
The generator must designate on the manifest one facility which is
permitted to handle the waste described on the manifest. A copy of
each manifest must be sent to the DHS, and another copy must be
maintained by the generator for at least three years.
The manifest includes a waste minimization certification. 'ILarge-
Quantity" generators must certify "...that I have a program in
place to reduce the volume and toxicity of waste generated to the
degree I have determined to be economically practicable . . . . I 1 (This
language appears as Item 16 on the Uniform Hazardous Waste
Manifest.) llSmall-Quantityllgenerators must certify that they have
made good-faith efforts to minimize waste generation. The
generator must also certify that he or she has chosen the safest
method of treatment, storage, and/or disposal.
E-3
 October 19, 1988

E. 2.4 Reports
A generator who ships (currently) 5 tons or more of his hazardous
waste off-site during the calendar year shall prepare and submit a
.biennial report to the DHS by March 1 of each even numbered year.
The report covers generator activities with respect to hazardous
wastes during the previous calendar year. A separate report must
be sent annually to the California State Board of Equalization for
taxation purposes.
E.2.5 Packaging, Labeling and Marking Requirements for Generators
Hazardous waste must be packaged in accordance with DHS and
Department of Transportation (DOT) requirements prior to shipment
to a treatment, storage and/or disposal facility. Marking and
labeling must also be in accordance with DOT guidelines. A
hazardous waste label must be affixed to all hazardous waste
containers.
E.3 Recyclable Hazardous Wastes (Recyclable Materials)
If a hazardous waste such as a spent solvent can be recycled and
used on-site, it might be exempt from many of the above listed
requirements, as well as from DHS permit requirements. The
recycling must generally be done continuously without storing the
waste prior to reclamation. The recycled material is not consid-
ered a waste. Other conditional exemptions for recycling of
hazardous waste also exist (Section 25143.2, California Health and
Safety Code [CH&SC]) .
The DHS' regulations provide a list of recyclable hazardous wastes
and suggest methods for recycling them. If a llrecyclablellwaste is
disposed of, the DHS may require the generator to explain why the
waste was not recycled. The generator must respond. (See Section
25175, CHtSC and Sections 66763 and 66796, CCR).

E.4 High BTU Wastes

By 1990, any hazardous waste that is to be disposed and that has a
heating value greater than 3000 Btu/lb must be incinerated or go
through an equivalent treatment process. Also, in 1990, hazardous
wastes destined for disposal and containing volatile organic
compounds in concentrations exceeding standards to be determined by
DHS must be incinerated or be disposed by an equivalent treatment
process.
E.5 #@LabPacks1'
Most laboratory-generated waste is disposed of in lab packs. Lab
packs are steel drums containing small containers of compatible
hazardous wastes. The small containers in the drum are packaged in
chemical adsorbent. The drum is then sealed and sent to a
E-4
 October 19, 1988

hazardous waste landfill. As of July 8 , 1989 certain waste

chemicals in lab packs are restricted from landfills. Most of
these are listed in Table E-2.
If a lab pack includes a hazardous waste that contains any of the
elements/compounds at or in excess of any of the limits listed in
Table E - 2 , it cannot be disposed on land on and after July 8 , 1989.
E.6 Other State and Federal Statutes and Regulations
There are many federal statutes and regulations requiring compli-
ance. Many of these federal laws are the same as California laws.
Some of these federal and state laws are discussed below.
E.6.1 Federal Clean Water Act
The Federal Clean Water Act (CWA) mandates the establishment of
pretreatment standards for discharges to "publicly owned treatment
worksll (POTW). Institutions that are connected to public sewers
must comply with the CWA pretreatment standards. This could result
in not allowing certain compounds down the drain even if diluted
(e.g. fomaldehyde cannot be discharged to a POTW even in minute
quantities with abundant dilution).
The CWA has also established the National Pollutant Discharge
Elimination System (NPDES) program which regulates discharges to
surface waters. The California State Water Resources Control Board
and its 9 regional boards carry out the NPDES program in
California.
E.6.2 Federal Occupational Safety and Health Act
The Federal Occupational Safety and Health Act (OSHA) and State.
occupational safety laws regulate chemical handling on public and
private locations. OSHA's "Right-to-Know" provision requires
employers to train their employees about hazardous substances they
handle. The law applies to paid employees but not necessarily to
other individuals. The OSHA "Right-to-Knownfiprovisions (and state
8tRight-to-Know11
laws) have increased the awareness of chemical
hazards and they have given impetus to the creation of hazardous
waste management programs.
There is currently pending in the California Legislature a bill
called the I8Student-Right-To-Knowlf bill which would require educa-
tional institutions to develop a safety program for students who
handle hazardous materials.
E.6.3 California Proposition 65
Proposition 65 requires private employers to post warnings for
persons handling carcinogenic compounds, and restricts all
discharges of carcinogenic compounds. This is a new law that at
E-5
 October 19, 1988
present does not affect public institutions. However, state
legislation is pending that will require public institutions to
comply.
E.7 Solvent Wastes: Land Disposal Restriction

The 1984 Hazardous and Solid Waste Amendments (HSWA) to RCRA

mandated the November 8, 1986 federal restriction on the land
disposal of halogenated and non-halogenated solvent wastes.
Restricted solvent wastes are numbered F001-F005 as defined in
Section 261.31, Title 40, Code of Federal Regulations. On
November 7, 1986, EPA announced a conditional extension on the
implementation of the restriction. According to the modified
restriction, solvent wastes were prohibited from land disposal
starting on November 8, 1986, unless one or more of the following
conditions applies:
The generator of the solvent waste is a small quantity
generator of 100-1000 kg/month of hazardous waste.
The waste contains less than 1 percent total of F001-F005
solvent constituents.
The solvent waste is generated due to cleanup or other reme-
dial action taken under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) of 1980, as
amended.
However, the solvent wastes listed in Items 1 to 3 above are
restricted from land disposal effective November 8, 1988.
E.8 Summaries of Pertinent Statutes, Regulations and Ordinances
Table E-5 contains a list of federal, state and local statutes,
regulations and ordinances that are relevant to hazardous waste
generators. The list includes requirements for raw material
handling, waste disposal, air quality control, and discharges to
sewers.
E.9 Regulatory Agencies and Information
Appendices G through J identify the regulatory agencies that may be .
contacted with questions on the management of hazardous wastes.
Appendix F has Form DHS 8400 (6/87). This form can be used to
obtain copies of California hazardous waste control laws and
regulations.

E-6
 October 19, 1988
TABLE E-1
RECYCLABLE HAZARDOUS WASTES

0 Commercial chemical products including unused laboratory grade

products.
0 Solvents, used or contaminated, including:
- perchloroethylene,
Halogenated solvents such as trichloroethane,
methylene dichloride, chloroform, carbon
tetrachloride, and Preons;
- methanol,
Oxygenated solvents, such as acetone, methyl ethyl ketone,
ethanol, butanol, and ethyl acetate; and
- Hydrocarbon solvents, 8uch as hexanes, Stoddard, benzene,
toluene, xylenes, and paint thinner.
0 Used or unused petroleum products, including motor oils,
hydraulic fluids, cutting lubricants, and fortified weed oils.
0 Pickling liquor.
0 Unspent acids, such as hydrochloric, hydrofluoric, nitric,
phosphoric, and sulfuric, in concentrations exceeding 15%.
0 Unspent alkalis, including: hydroxides and carbonates of
sodium, potassium, and calcium; and acetylene sludge.
o Unrinsed empty containers of iron or steel used for pesticides
or other hazardous chemicals:
- Pesticide containers: and
- Other hazardous chemical containers.

E-7
 October 19, 1988
TABLE E-2
RESTRICTED HAZARDOUS WASTES

Element/Compound Concentration L i m i t
of Restriction
1. Liquid hazardous wastes containing
free cyanides -> l o o 0 mg/ 1iter
2. Liquid hazardous wastes containing
one or more of the following:
Arsenic and/or arsenic compounds -> 500 mg/liter

Cadmium and/or cadmium compounds -> 100 mg/liter

Chromium VI and/or chromium VI compounds -> 500 mg/liter

Lead and/or lead compounds -> 500 mg/liter

Mercury and/or mercury compounds -> 2 0 mg/liter

Nickel and/or nickel compounds -> 134 mg/liter

Selenium and/or selenium compounds -> 100 mg/liter

Thallium and/or thallium compounds -> 130 mg/liter

3. Liquid hazardous wastes with a pH less

than or equal to 2.0
4. Liquid hazardous wastes containing
polychlorinated biphenyls (PCBs) -> 50 mg/liter

5. Liquid hazardous wastes containing

halogenated organic compounds (i.e.
chlorinated solvents) ->lo00 mg/kg

E-8
 October 19, 1988
TABLE E-3
SOLVENT-CONTAINING HAZARDOUS WASTES HAVING
EPA LAND DISPOSAL RESTRICTIONS

Waste code Description

FOOl The following spent halogenated solvents used in

degreasing: tetrachloroethylene, trichloroethylene,
methylene chloride, l,l,l-trichloroethane, carbon
tetrachloride, and chlorinated fluorocarbons; spent
solvent mixtures/blends used in degreasing contain-
ing, before use, a total of 10 percent or more (by
volume) of one or more of the above halogen solvents
or those solvents listed in F002, F004, and F005;
and still bottom from the recovery of these spent
solvents and spent solvent mixtures.
F002 The following spent halogenated solvents:
tetrachloroethane, chlorobenzene 1,1,2-trichloro-
1,2,2-trifluoroethane, ortho-dichlorobenzene, and
trichlorofluoromethane; all spent solvent mixture/
blends containing before a total of 10 percent or
more (by volume) of one or more of the above
halogenated solvents or those solvents listed in
F001, F004, and F005; and still bottoms from the
recovery of these spent solvents and spent solvent
mixtures.
F003 The following spent nonhalogenated solvents: xylene,
acetone, ethyl benzene, ethyl ether, methyl isobutyl
ketone, n-butyl alcohol cyclohexanone, and methanol:
all spent solvent mixtures/blends containing solely
the above spent nonhalogenated solvents; and all
spent solvent mixtures/blends containing, before
use, one or more of the above nonhalogen solvents,
and a total of 10 percent or more (by volume) of one
or more of the solvents listed in F001, F002, F004,
and F005; and still bottoms from the recovery of
these spent solvents and spent solvent mixtures.
F004 The following spent nonhalogenates solvents:
cresols and cresylic acid and nitrobenzene; all
spent solvent mixtures/blends containing, before
use, a total of 10 percent or more (by volume) of
one or more of the above nonhalogenated solvents or
those solvents listed in F001, F002, and F005: a
still bottoms from the recovery of these spent
solvents and spent solvent mixtures.
E-9
 October 19, 1988
TABLE E-3 (continued)

Waste code Description

F005 The following spent nonhalogenated solvents:

toluene, methyl ethyl ketone, carbon disulfide,
isobutanol, and pyridine; all spent solvent
mixtures/blends containing, beofre use, a total of
10 percent or more (by volume) of one or more of the
above nonhalogenated solvents or those solvents
listed in F001, F002, and F004; and still bottoms
from the recovery of these spent solvents and
solvent mixtures.

A November 8, 1986 at 40 CFR 268.30(b).

E-10
 October 19, 1988
TABLE E-4
SUMMARY OF GENERAL REQUIREMENTS
ACTIVITY REQUIREMENT AGENCY

Waste Shipments of waste must be accompanied DHS

Generation by a minifest.
Prepare biennial report concerning the DHS
volume of waste generated.
If wastes are temporarily stored on DHS, county
site, the generator must comply with hazardous
handling procedures, personnel material
requirements, etc. regulators

Generators disposing of Itrecyclable DHS

wastesn1might be asked to provide
justification for not recycling.
New Process If the new process or process modifi- DHS
or Process cation involves treatment of a
Modification; hazardous waste, a treatment, storage
Material and/or disposal (TSD) permit might be
Substitution necessary. In some cases material
substitution may constitute process
modification.
Process must comply with fire codes Local fire
occupational health requirements. department,
Cal/OSHA

On-site In general, a treatment, storage DHS

Treatment and/or disposal facility permit is
required. DHS may grant variances
for activities that are adequately
regulated by other agencies or for
wastes that are insignificantly
hazardous.
On-site Same as above; however, some on-site DHS
Recycling recycling activities are categorically
exempt from permit requirements.
Off-site Commercial (i.e., off-site) recycling DHS
Recycling activities generally require a TSD
permit.
Commercial recyclers must submit an DHS
annual facility report.

E-11
 October 19, 1988
TABLE E-4 (continued)
SUMMARY OF GENERAL REQUIREMENTS
ACTIVITY REQUIREMENT AGENCY
Some resource recovery facilities are DHS
eligible for Series IA1, IB1, or I C '
resource recovery facility permits in
lieu of TSD permits.
Disposal In California, several classes of DHS
hazardous waste are restricted from
land disposal.
A national land disposal restriction EPA
program is being implemented.
Disposal facilities must have a TSD DHS
permit and comply with technical and
financial regulations,
Air Pollution
Industrial All devices emitting air pollutants Local APCD/
must be permitted or exempted. AQMD

If changes in equipment or procedures Local APCD/

result in an increase of any pollutant AQMD
above a specified level, a permit is
required.
If certain designated toxic air Local APCD/
contaminants are emitted, the AQMD
generator must comply with rules
established under the toxic air
contaminant program.
If there is an increase in an EPA Region
lmattainmentpollutant1@by a IX
significant amount (generally
25 to 40 tons/yr), a permit
may be necessary.
Water Pollution

Industrial Discharge of industrial waste to Local sewer

sewer requires a sewer permit. agency

Discharge of waste to land requires Regional

a discharge permit. Water Quality
Control Board

Discharge of waste to public waters Regional

requires an NPDES permit. Water Quality
Control Board

E-12
 TABLE E-5
SELECTED STATUTES, REGULATIONS AND ORDINANCES RELEVANT TO
HAZARDOUS WASTE GENERATION AND MANAGEMENT *
Cateqory Regulation/Rule Description
Air quality SCAQMD Rule 4 4 2 Restrict discharge of
SBAQMD Rule 317 organic materials into
MBUAPCD Rule 4 1 6 the atmosphere from
BAAQMD Regulation 8 , equipment in which
Rule 3 5 solvents are used.
KCAPCD Rule 4 1 0
SLOCAPCD Rule 407 H ( 1 )
VAPCD Rule 6 6
SCAQMD Rule 4 4 3 Requires coatings and
solvents to be labeled
to indicate their
photochemical reacti-
vity.
SCAQMD Rule 1 1 1 3 Establish VOC
SBAQMD Rule 3 2 3 standards for archi-
MBUAPCD Rule 4 2 6 tectural and specialty
BAAQMD Regulation 8 , architectural coat-
Rule 3 ings.
KCAPCD Rule 4 1 0 . 1
SLOCAPCD Rule 407 H ( 3 )
SCAQMD Rule 1 1 4 1 . 1 Establish operating
requirements for coat-
ings and inks manu-
facturing.
BAAQMD Regulation 8, Deals with the storage
Rule 5 of organic liquids.
MBUAPCD Rule 4 2 9 Deal with organic
KCAPCD Rule 4 1 3 liquid loading.
SBAQMD Rule 322 Prohibit photochem-
SOLCAPCD Rule 407 H ( 2 ) ically reactive metal
surface coating
thinners and reducers.
SBAQMD Rule 324 Deal with the dispo-
KCAPCD Rule 4 1 0 . 2 sal and evaporation
BAAQMD Regulation 8 , of solvents.
Rule 39
SLOCAPCD Rule 407 H ( 4 )

E-13
Category Requlation/Rule Description
Solvent CCR Title 23, Addresses underground
storage Chapter 3, Sub- storage of solvents.
chapter 16
CH&SC Division 20, Regulates underground
Chapter 6.7 storage of hazardous
substances.
CCR Title 22, Regulates the use
Div. 4, Ch. 30, and management of
Article 24 containers.
CCR Title 22, Sets requirements for
Division 4, Chapter generators of hazardous
30, Article 6 wastes including
restrictions on how long
wastes can be accumulated
without the storage
facility being permitted.
CHtSC Section Definition
- -
~~ of llstorage
25123.3 facility1', including
auality and time limits
Ior qualification as a
storage facility.
CHtSC Division 20 Requires local government
Chapter 6.95 . agencies to implement
hazardous material manage-
ment programs requiring
local businesses to submit
business plans and
inventories for the storage
and handling of hazardous
materials.
CCR Title 22, Require generators of
Division 4, hazardous waste to store,
Chapter 30, label, and manifest
Section 66470 to hazardous wastes properly.
Section 66515
Hazardous CCR Title 22, Lists specific elements,
Materials Division 4, compounds, and generic
and Wastes Chapter 30, materials that are
Section 66680 potentially hazardous
wastes when they are no
longer useful. For
example, llsolventsll
are
E-14
Category Requlation/Rule Description
listed as potentially
hazardous based on the
ignitability criterion.
40 CFR Part 268 Sets forth federal regula-
tions that restrict the
disposal of spent solvents.
and solvent-containing
wastes.
CCR Title 22, List the criteria for
Division 4, determining whether a waste
Chapter 30, is considered hazardous or
Section 66693 to extremely hazardous, using
Section 66723 criteria for ignitability,
toxicity, corrosivity, and/
or reactivity.
CH&SC Sec. 25180 Identify penalties for
to Section 25196 non-compliance with
hazardous waste control
laws and regulations.
Wastewater Clean Water Act Water quality control for
discharge 32 U.S.C. 1251 waste water disposed in
et seq. surface waters, municipal
sewers, and injection well.
Safe Drinking Water quality control for
Water Act. waste water disposed in
4 0 CFR 141 surface waters, municipal
sewers, and injection well.
NPDES regulations Regulations on the
40 CFR 122 reduction of pollutant
discharges into the waters
of the United States.
CCR Title 23 State regulations govern-
Subchapter 9 ing the discharge of waste
waters to surface waters.
Includes provisions for
issuance of permits and
setting effluent
limitations.
’ Local municipal Discharge requirements set
codes addressing by local POTWs restricting
discharges to the concentrations of pol-
POTWS lutants in waste waters
discharged to sanitary
sewers.
E-15
Cateqory Regulation/Rule Description
Waste CH&SC Section Authorizes DHS to provide
treatment, 25175 a listing of recyclable
recycling, hazardous wastes found by
or disposal DHS to be economically and
technically feasible to
recycle. Also authorizes
fee penalties for failure
to do so, as specified.
Title 22, CCR List for CH&SC Section
Section 66796 25175 provides a list of
recyclable wastes and
suggests methods for
recycling them.
Title 22, CCR Specifies method for
Section 66763 CH&SC Section 25175 if
and CH&SC a I1recyclablet1
hazardous
Section 25175 waste is disposed,
authorizes DHS to request
that the generator
explain why the waste was
not recycled. The
generator must respond.
DHS can assess penalties
for failure to comply.
CH&SC, Section Exempt recyclable
25143.2 (b), (c) materials from hazardous
and (e) waste control require-
ments if they meet
certain conditions.
CH&SC Section Specifies penalties for
25180-25196 generator non-compliance
with the regulations.
CH&SC Sections Specifies penalties for
25180-25196 facilities with permits,
non-compliance with the
regulations.
CH&SC Section Requires incineration
25155.5 (a) or equivalent treatment
of hazardous wastes
with greater than
3000 Btu/lb. Existing
law becomes effective
postponed to 1990.

E-16
Cateqory Requlation/Rule Description
CH&SC Section Requires incineration
25155.5 (b) or equivalent treatment
of hazardous wastes
containing volatile
organic compounds in
concentrations exceeding
standards to be .
determined by DHS.
Existing law becomes
effective in 1990.
CHbSC Section Prohibits discharge of
25208.4 any liquid hazardous
waste into a surface
impoundment located
within 1/2 mile of a
potential source of
drinking water.
Contains important
exemption provisions.
CH&SC Section Requires annual certifica-
25202.9 tion by hazardous waste
generators who operate
onsite TSD facilities
that they have a waste
minimization program in
operation. Further, they
must certify that the
treatment, storage, or
disposal methods minimize
threats to human health
and environment.
CH&SC Section Requires generators
25244.4 to submit a report
every two years on
waste reduction status.
CH&SC Section Would prohibit land
25179.6 disposal of all
untreated hazardous
wastes with specified
exceptions. Effective
1990.

40 CFR Part 165 Recommended procedures

for the disposal and
storage of pesticides
and pesticide
containers.

E-17
Category Regulation/Rule Description
32A CFR Part 6 5 0 Hazardous and toxic
materials management
(bibliography and
tables).
Land CH&SC Section Specifies land
disposal 2 5 1 2 2 . 7 and disposal restrictions.
Title 2 2 CCR Lists therein
Sections 66900- restricted hazardous
66935 wastes which include
wastes containing
more than 1 0 0 0 mg/kg
of halogenated
organic compounds.
4 0 CFR Section Prohibits land dis-
2 6 4 . 3 1 4 (b) posal of bulk or non-
containerized liquid
hazardous waste or
hazardous waste con-
taining free liquids.
RCRA Section Prohibits land disposal
3 0 0 4 ( e ) (1) of most solvents unless
treatment levels (2 ppm
for most constituents)
are met.
4 0 CFR Section Prohibits land disposal
268.3 of dilute waste waters
containing solvents
and having 1% or less
total organics.
4 0 CFR Section Prohibits land disposal
2 6 5 . 3 1 4 and of bulk or non-
CCR Title 2 2 , containerized liquid
Div. 4 , Ch. 3 0 , hazardous wastes or
Sec. 67422 hazardous wastes
containing free liquids.
General 40 CFR Part 4 4 6 EPA guidelines and
standards for Paint
formulating industry.

E-18
Abbreviations:
APCD - Air Pollution Control District
AQMD - Air Quality Management District
BA - Bay Area
Btu - British thermal unit
CCR - California Code of Regulations
CFR - Code of Federal Regulations
CH6rSC- California Health and Safety Code
DHS - Department of Health Services
KC - Kern County
MBU - Monterey Bay Unified
NPDES- National Pollutant Discharge Elimination System
POW - Publicly Owned Treatment Works
RCRA - Resource Conservation and Recovery Act
SB - Santa Barbara
SC - South Coast
SLOC - San Luis Obispo County
TSD - Treatment, Storage, or Disposal
VOC - Volatile Organic Compounds
V - Ventura
* The generator should contact the appropriate local, state, or federal
authority for complete, detailed, and updated regulatory information.
Source: Jacobs Engineering Group, Inc. 1987; and ESE, 1987.

E-19