Dangerous Waste Regulations Compliance, Circuit Board Manufacturer Issaquah, Washington

In 2000, G-Logics was retained by a circuit-board manufacturer located in Issaquah,
Washington to assist with responding to an Administrative Order issued by the Washington State
Department of Ecology (Ecology). Ecology requested an analysis of the circuit board
manufacturing operations to identify appropriate modifications that would provide a higher
level of control and response to "upset" conditions.

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After reviewing several documents and pertinent
sections of the Dangerous Waste Regulations,
G-Logics
recommended a meeting with Ecology to
provide a better understanding of the regulatory
requirements and an appropriate course of action
for our client to follow. Based on the outcome of
this meeting and the requirements of the
Administrative Order, G-Logics assisted our client
with performing a Failure Mode and Effect Analysis
(FMEA) on their circuit-board manufacturing
operations. This analysis was inclusive of
hazardous-material operations within their main

plating area, the precious metal plating room, and the waste-treatment room. The
analysis included a thorough review of the following plant operations:

  • Potential problems with equipment design,
    construction, and operation
  • Maintenance practices
  • Equipment compatibility
  • Equipment integrity
  • Monitoring needs for prompt detection of
    releases
  • Inspection schedule for equipment
  • Hazardous material storage areas
  • Secondary containment requirements
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The completed analysis identified several areas where our client could improve their existing
systems to reduce the potential for upset conditions and/or the possible release of
hazardous materials to the environment. These improvements included increased
inspections, equipment modification/repairs, the use of secondary containment, and the

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installation of some additional equipment. Identified timelines for these improvements were included with a submittal to Ecology.

With the submittal of their completed analysis and a timeline of identified improvements, Ecology found our client to be in compliance with the Administrative Order. These positive results also yielded waste-disposal and process cost-savings to our client, provided insight for their design of a planned new facility, and eliminated the threat of non-compliance fines by Ecology.

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