Dear Matthew:
The EPA, as specified in RCRA (Resource Conservation and Recovery Act),
has established four characteristics to evaluate and identify waste as
hazardous or non-hazardous. These characteristics include ignitability,
corrosivity, reactivity, and TCLP (toxicity characterstic leaching
procedure) results. (Accepted methods used to test waste for the above
for characteristics, and definitions of the above characteristics, are
published by the EPA's Office of Solid Waste in SW-846 "Test Methods for
Evaluating Solid Wase, Physical/Chemical Methods". This document can be
obtained from the Government Printing Office (202-783-3238).) Often it
is possilbe to minimize testing parameters for a waste, such as router
dust, if it is clear that the waste will not meet the Agency's
definition of ignitability, corrosivity, and reactivity. The TCLP test
however, must often be performed. THe TCLP test is used to identify and
quantify a specific (and changing) list of compounds commonly used in
industry and agriculture and known to be hazardous; and to simulate
climatic leaching of these compounds expected to occur in landfills.
The TCLP parameters are often segrated into catagories including metals,
volatile organics, semi-volatile organics, and herbicides and
pesticides. Again, considering router dust, you can assume with some
certainty that this material will not contain volatile and semi-volatile
compounds (at least those on the TCLP list), nor herbicides and
pesticides. Of the eight listed TCLP metals (arsenic, barium, cadmium,
chromium, lead, mercury, selenium, and silver), typically only lead
would need to be tested. The regulatory level for lead is 5 mg/L
(ppm). Thus if a TCLP test performed on your router dust exhibits a
concentration greater than 5 mg/L lead in the TCLP extract, the router
dust would be considered hazardous and must be managed in compliance
with RCRA. If the concentration of lead does not exceed 5 mg/L, it can
be managed as non-hazardous industrial waste. It is always a good idea
to consult your solid waste disposal service when disposing of "suspect"
material. You should also know the landfill has the right to refuse
waste and/or specify the testing parameters of the waste prior to
acceptance.
The cost of testing can vary. Our laboratory charges $135 per sample
for TCLP - lead only testing. We are certified in MN and WI, and by
reciprocity in SD, IA, and SC. The EPA does not currently have a
national certification program, but you can recieve a list of state
certified laboratories from the ACIL (202-887-5872) or your state
regulatory agency.
In testing router dust, it has been our experience that most samples
pass the TCLP for lead. However, you also mentioned gold may be
present. There are provisions with RCRA regarding precious metal
reclaiming, that may expempt a defined "hazardous" waste from some of
the rules depending upon the precious metal content. Please feel free
to call me or Frank Pernat (612-479-6525) if you have additional
questions. GOOD LUCK!
Regards,
Ted Stern
CIRCUIT RESEARCH CORP. (CRC)
Matthew Mahlau wrote:
>
> Is there any special consideration required for disposing of the dust
> collected from drilling/routing?
>
> In addition to the fiberglass dust there are copper, tin-lead and gold
> metal particles. Is this classified as hazardous waste?
>
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