Molex Incorporated

Letter from William Gidley (Nebraska DEC) to David Doyle (EPA)

State of Nebraska Department of Environmental Control
Randolph Wood Director
Suite 400, The Atrium 1200 "N" Street P.O. Box 98922
Lincoln, Nebraska 68509-8922
Phone (402) 471-2186

E. Benjamin Nelson Governor
Mr. David Doyle USEPA Region VII Air, RCRA and Toxics Division
726 Minnesota Avenue
Kansas City, KS 66101

Re: Molex XL Project

Dear Mr. Doyle:

This letter is in response to your request for input regarding the need for additional organics monitoring requirements for the Molex sludges in the proposed XL project. This Department has reviewed the data submitted to you by Molex. In all three sludges, the only organic that appears to be present in significant concentrations is bis (2-ethylhexyl) phthalate. It is likely this is a result of contamination by plastic packaging, production or treatment equipment. Low concentrations of DEHP are often found in organic analyses of wastewaters as well due to contamination.

As you may be aware, bis (2-ethylhexyl) phthalate, more commonly known as di (2-ethylhexyl) phthalate, or DEHP, is a widely used plasticizer found in products used throughout society. Because of it's common use DEHP is present throughout the environment at low concentrations. Because of its physical and chemical properties however, normal exposures experienced by the general public have not constituted a health threat. NDEQ reviewed various exposure pathways and concentrations for DEHP and has concluded that the amount contained in the Molex sludges should pose no health risk under the proposed method of handling.

Based on our review of risks associated with DEHP, process knowledge, and the fact that Molex will be conducting semiannual organics analyses on the wastewater discharge, NDEQ believes there is no need to include additional organics analysis in the Molex XL project. If you have any questions regarding this matter, feel free to call me or Brian Gorman at (402) 471-4217.

Sincerely,

William C. Gidley, Supervisor RCRA Section Air/Waste Management Division WCG/bg

cc: Paul Eckerson

Molex Incorporated

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