Rockwell Collins Avionics and Communications Division - Cedar Rapids, IA
Rockwell Collins, Inc. purchases 50,000 gallons of printed circuit board etchant material annually for use in the manufacturing of printed circuit boards. This material removes copper from circuit board laminates and places the copper in solution. The supplier of the etch has sub-contracted its recycle for many years through pricing contracts for the purchase of new/recycled materials. The etch is broken down into copper oxide (which is sold as a feed stock to smelters) and the remaining product is re-blended to create new/recycled etch for reuse in the facility. The only other alternative to this type of treatment has been to deep well inject the waste due to the ammonia content. This alternative is not within the waste hierarchy established by the EPA and Rockwell.
Prior to May 1995, Rockwell Collins, Inc. recycled its printed circuit board etchant, but because of the way it was handled at the recycler it was still considered hazardous waste. The material was delivered to a recycler who transformed the spent etchant as described above which then sold the etch as a commercial product. In May 1995, a market was found that utilized printed circuit board etchants as a raw product in the manufacture of atacamite (an insoluble naturally occurring copper salt). This copper salt is an interesting replacement for animal feed nutrient supplements because of the insolubility it possesses in aqueous environments. The copper salt will not degrade over time resulting in lower dosing of feed blends and ultimately reducing the cost of the feed to the end user. In acidic solution (in the stomach of an animal), the copper salt is completely soluble and is readily absorbed by the animal resulting in superior performance over copper sulfate. The process has been approved under the use/reuse exemption requirements specified at Title 40 CFR Part 261. With this exemption, the etchant is no longer managed as hazardous waste and does not require a hazardous waste manifest to ship the product.
By redefining the way the material is handled and no longer managing the material as hazardous waste, Rockwell, on an initial investment of less than $1,500, has reduced the generation of hazardous waste by over 450,000 pounds annually.