Molex Incorporated

Report of Industrial User-Compliance Sampling Inspection

June 24, 1998

MEMORANDUM SUBJECT: Transmittal of Inspection Report

FROM: Joe Joslin, Environmental Engineer Environmetnal Monitoring & Water Compliance Branch, ENSV

TO: Paul Marshall, Pretreatment Coordinator NPDES & Facilities Management Branch, WWPD

This memorandum transmits the report of the following Industrial User-Compliance Sampling Inspection (IU-CSI) performed by the Environmental Monitoring and Water Compliance Branch, Environmental Services Division. Also, we request that you complete and return the attached Satisfaction Survey.

NPDES
Pretreatment Activity Areas of Facility Number Number Non-Compliance
Molex, Inc.
NEO 1 31776 WJF25 None
Upland Facility
Lincoln, NE

Attachments:

cc: Wolfgang Brandner, WWPD/NFMB Air & RCRA Compliance (ARCM) and Environmental Monitoring-& Water Compliance (EMWC)

Satisfaction Survey Complete this survey for each activity and return iE 'to either ARCM'or Emwc.

Facility:

Name of Reviewer:

Facility ID:

Branch/Division: Activity #:

Satisfaction

1. Did you receive the report in a timely manner? Y or N
Comment:

2. Was the report complete? Y or N
Comment:

3. Is there any information you consider not required for purposes of compliance determination and case developments?
Comment:

4. Was the report understandable, logical, and organized?
Comment:

5. Was the data properly supported, cited, or referenced?
Comment:

Provide an overall ranking for the report. Use a scale of 1 to 5, 5 being the best and 3 being average.

Circle one: 2 3 4 5
Provide any additional comments you may have below.

REPORT OF INDUSTRIAL USER-COMPLIANCE SAMPLING INSPECTION AT MOLEX, INC.
UPLAND FACILITY LINCOLN, NEBRASKA NPDES
PRETREATMENT PERMIT NO.: NE0131776
APRIL 27-30,1998 AND JUNE 1, 1998
BY U.S. ENVIRONMENTAL PROTECTION AGENCY Region VII Environmental Services Division

INTRODUCTION
At the request of the U.S. Environmental Protection Agency (EPA), Water, Wetlands, Pe5ticides Division (WWPD), Water Compliance Branch, an Industrial User-Compliance Sampling Inspection (IU-CSI) was conducted at Molex, Inc., Upland Facility in Lincoln, Nebraska on April 27-30, 1998. This narrative report and attachments present the results of the inspection.

PARTICIPANTS
Molex, Inc.: Paul Eckerson, Chemist Ron Phillips, Safety Environmental Engineer Robert E. Keller, Industrial Engineer Nebraska Department of Environmental Quality (NDEQ): Christopher J. Helms, Compliance Specialist U.S. Environmental Protection Agency: Joseph Joslin, Environmental Engineer

INSPECTION PROCEDURE
Facility personnel were not notified prior to the inspection. Upon arriving at the facility on April 27, 1998, 1 requested an audience with Mr. Paul Eckerson. I introduced myself to Mr. Eckerson and presented my credentials. Mr. Eckerson accompanied me to install the pretreatment effluent sampler. On April 28, Messrs. Helm, Phillips, Eckerson and I made a walk-through inspection of the plating operation, the pretreatment facilities including the sludge handling area and performed a review of the record keeping. The IU-CSI consisted of the collection of samples, a review of facility records and the inspection of facility records. A follow-up inspection involving Messrs. Phillips, Keller and myself was made on June 1, 1998 specifically to review the events of the transdraw accidental release to the sanitary sewer which occurred on September 4, 1997. The corrective actions taken subsequent to the accidental release were reviewed and the physical changes made to equipment were inspected.

FACILITY DESCRIPTION
Molex, Inc., Upland Facility is located at 700 Kingbird Road, Lincoln, Nebraska in a new facility occupied in 1996. The company manufactures electrical connectors by forming the metal parts of the connector from brass, phosphor bronze and beryllium-copper strip or wire, performing electroplating of copper, tin, tin/lead, nickel and gold using reel to reel and vibratory systems. Plastic housings are molded on-site and the units assembled.

Currently there are 8 reel to reel plating lines and two loose part vibratory plating systems in operation. City water treated by a reverse osmosis (R.O.) unit is used to supply all rinses and plating baths. Treated R.O. water is stored in four 800 gallon tanks from which it is distributed to the plating lines. R.O. reject water is discharged to the sanitary sewer, bypassing wastewater treatment and the final effluent sampling stations. Besides a centralized treated water supply, there is also centralized storage and distribution of copper and nickel plating solutions, sodium hydroxide electrocleaning solution, heated rinse water and precious metal dead rinse.

The Upland facility has installed segregated waste treatment systems for copper, nickel and tin/lead wastes. Therefore, waste streams are collected in separate and respective storage tanks prior to treatment. There are waste storage tanks for tin rinses, tin/lead rinses, nickel rinses, copper rinses, and electrocleaner rinses. Tin and tin/lead rinses are combined and treated together. Electrocleaner rinse is combined with the tin/lead rinses to provide a source of sulfate to insure the lead sulfate precipitation process will occur, other-wise incomplete tin/lead precipitation can happen resulting in high discharge values of lead. Copper rinses are combined with fume scrubber water for treatment. Nickel rinses are treated separately.

All plating areas have a fume collection and scrubbing system. There is one system on the reel to reel- plating area and one in the vibratory tin area. Both are wet scrubbing systems using untreated city water. Scrubber water is collected in the copper rinse collection tank for treatment.

Gold metal rinses are batch treated by plating out the precious metal and transferring the remaining wastewater to the treatment system for final pH adjustment. Lab wastes are segregated by designating certain areas in the lab for specific analyses. Drains for each laboratory area enters the respective rinse storage tank for treatment.

The wastewater treatment system consists of three parallel segregated systems, one for copper, one for nickel and one for tin/lead. Layout/flow schematic is included as Attachment 1. All three are identical in design. The primary difference in each system is the pH levels used for metal precipitation. Wastes from each respective storage tank enter a primary neutralization tank-, a secondary pH adjustment tank, a flocculation tank, a clarifier, and dual alternating sand filter system. Sand filter backflush returns to the respective rinse storage tank. Clarified effluent from all three segregated treatment systems then enters a common final pH adjustment system. The final pH adjustment tank acts as the final effluent sampling location as well. A second effluent sampling station has been constructed outside the building for use by the city sampling crews. An effluent flow meter has been installed on the discharge from the pH adjustment tank.

Clarifier sludges remain segregated and are de-watered in separate plate and frame filter presses. Filtrate is also returned to the respective rinse storage tank. Dewatered nickel sludge is bagged as a wet cake. Dewatered tin/lead and copper sludges are batch run through a common drier, but still baked separately. The drier has a dust collection humidifier that generates a small waste stream which returns to the copper rinse storage tank. The segregated sludges are shipped off as a hazardous waste for metal recovery and recycling.

SAMPLING PROCEDURES
An ISCO Model 1580 HS automatic wastewater sampler was installed to collect samples at the pH adjustment tank. The intake tubing, sampler pump tubing and the 3 gallon sample collection container were rinsed with effluent. The sampler was iced each day at the beginning of each 24-hour sampling period. At the time the sampler was serviced at the completion of the first day, a grab sample was collected for on-site determination of temperature and pH. No other pH, measurements were made due to pH meter failure. The automatic sampler, for no apparent reason, failed to collect samples for the second day of sampling. The composite samples were split each day with Molex and nitric acid preserved using the sample preservative used for the EPA aliquot.

All samples were held on ice until they could be returned to the EPA Laboratory by the sample collector. Sample chain-of-custody procedures were used for all samples. All analyses were completed at the EPA Region VII Laboratory.

TRANSDRAW RELEASE INVESTIGATION
On June 1, 1998, a follow-up inspection was made at Molex. This visit concerned a previous release to the sanitary sewer. On September 4, 1097, Molex, Inc., Upland Facility, had an accidental discharge of approximately 900 gallons of Transdraw B- 19, a combination of mineral spirit (90%) and animal fat (IO%), which has a flash point of 105'F. Mr. Keller told me that Molex thought they had a second release on October 4, 1997, but on investigation Mr. Keller said there was a discrepancy in the volume gages and no Transdraw could be detected in the sewer by the City of Lincoln, who was called to investigate. However, a court petition filed in December 1997 alleges another 900 gallon discharge on October 4, 1997 (Attachment 2).

According to Mr. Keller, the release to the sanitary sewer on September 4, 1997, was due to a broken pipe nipple which allowed Tansdraw to leak to the floor of the boiler room and flow to the floor drains leadincy to the sanitary sewer. Since the Transdraw is continuously re-circulated it was continuously pumped and leaked until discovered.

The corrections initially taken are summarized in a letter from Molex to Rudy Fiedler, NDEQ, dated September 19, 1997 (Attachment 3). On October 4, broken pipe couplings were found along with some evidence of Transdraw on the wall and leading to the floor drain. Since the City of Lincoln could not find Transdraw in the sewer and the gages had discrepancies, Molex concluded that minimal, if any, Transdraw was discharged.

To reduce the potential for any release, the Transdraw pumping system was redone in keeping with the summary Narrative of Tower Draw (B- 1 9) pump moved to Flammable Storage Building (Attachment 4). The pumps and warning system were physically inspected on June 1, 1998 and were found to be constructed as described. As a redundant guard against the piping in the basement of the stamping room leaking to the sanitary sewer, it was suggested that floor plugs be placed in all the drains in the boiler room and the stamping material feed room where the Transdraw piping is suspended from the ceiling. During the inspection it appeared these drains could be kept plugged except when the floor might be washed.

FINDINGS & CONCLUSIONS
The following findings were noted during the review of sampling data, pretreatment facility operation and facility records. A complete summary of review is given in the IU-CSI checklist for the facility which was completed at the time of this inspection (Attachment 5).

1. A review of Molex's record keeping shows no deficiencies in pretreatment record keeping.

2. A review of the wastewater treatment processes for copper, nickel and tin/lead shows the three systems operating effectively with a separate plate filter press used to de-water the sludge. Operation of three systems allows chemical feed rates and treatment tank pH to be adjusted for maximization, flocculation and precipitation.

3. The data available (Attachment 6) from two days of sampling was compared to the discharge limits found in the pretreatment permit (Attachment 7). No sample data values exceeded the limits of the pretreatment permit.

4. A combination of plating strip connectors in very small tanks and using a creative countercurrent 4 rinse tank system has allowed water use to be substantially diminished. Since the wastewater volume is not only reduced but is also segregated into one of three categories (nickel, copper, tin/lead), treatment of the wastewater non-rally results in low concentration of metals in the effluent.

5. On August 25 and September 2, 1997, Molex experienced exceedances of their lead limit. The measured values were 1.049 mg/l and 0.74 mg/l respectively, while the permit limits lead to 0.69 mg/I. The exceedances were due to insufficient sulfates being generated to cause effective lead precipitates. High levels of copper, 12.93 mg/I, and pH, 1 1.4, were discharged on March 1998 which exceeded the pretreatment limits. Molex attributed the discharge to a failure of the electronic process controller which caused improper pH measurements that resulted in excess sodium hydroxide addition causing copper to go back into solution. The controller was repaired. These non-compliance reports are included as Attachment 8.

RECOMMENDATIONS
None.

Joseph Joslin
Environmental Engineer
Activity Number: WJF25
Date:

Attachments:
1. Treatment System Layout/Flow Schematic (I large page) - Not Available
2. Court Order - Not Available
3. Molex letter to NDEQ dated September 19, 1997 (2 pages) - Available
4. Transdraw (B 19) Pump Move (2 pages) - Available
5. Industrial User Inspection Checklist (6 pages) - Not Available
6. Raw Data-Analysis Request Report (5 pages) - Not Available
7. Pretreatment Permit (4 pages) -Available
8. Non-Compliance Reports (3 pages) - Not Available

ATTACHMENT 3
MOLEX

September 19, 1997
Rudy Fielder; Acting Supervisor Permits and Compliance Section Department of Environmental quality
Suite 400,
The Atrium 1200 'N' Street PO Box 98922
Lincoln, Nebraska 68509-8922

Dear Mr. Fiedler;

The following verbiage is being provided to you to inform you of our corrective action and internal procedures being put into place to prevent a repeat of the spill that occurred on September 4, of this year. We realize that the incident happened, and are taking the necessary steps to correct the problems. It is Molex's intention to do whatever is needed to be in compliance with this issue. Please feel fell free to call me at (402) 475-1700 ext. 8257

CORRECTIVE ACTION:

a. Replacement and isolation of the fitting: At the time of the incident a 1/2" black pipe nipple was found to be broken causing the Transdraw B-19 material to flow freely onto the floor and into the floor drains. We feel that the cause of the breakage was due to either vibration caused by the constant pumping action or the fitting was damaged from some type of physical downward force by someone possibly stepping on the incoming line. The broken nipple was replaced the same day the spill occurred by our maintenance personnel. To eliminate the vibration to the fitting isolation dampners have been added to isolate the line into the building. Guarding will be installed to preclude the possibility of downward force being applied to the line.

b. Containment barrier: At the time of the incident the Transdraw B-19 was flowing from the broken nipple down to a series of floor drains located within 5-6 away. To prevent the Transdraw B-19 material from reaching the drains a containment barrier will be installed to eliminate a flow path to the drains. The containment barrier would also act as a collection pool were the fluid would collect and create an ideal location for a monitoring sensor to be placed.

c. Monitoring and alarm sensors: Because of the makeup of the Transdraw B-19 material, we continually pump it throughout a closed loop system and then back to the storage tank to deep the animal fat from separating and settling out. Which means that if a line were to break the pump would continue to pump material out of the damaged line. To prevent the pump from running if a leak occurs, a excess flow valve would be installed on the line or pump to immediately shut down the pump therefore stopping the flow of the Transdraw B-19 material. As mentioned above an additional backup a second sensor would be located in the containment area to detect any fluid being collected. Our plan is to have both of these sensors tied directly into our Honeywell security system. This would provide continual monitoring and alarm capabilities if a problem would occur. All sensors would be included in our P..,NL pro-ram for periodic inspection. We are in contact with a Honeywell representative at this time to determine types of sensors and installation dates. As an interim measure we are monitoring the arm periodically throughout the day and night via. a walk through and check by our maintenance personnel until full implementation of the above corrective actions are completed. This measure has been added to our Preventative Maintenance Program.

Again! If you have any questions or need further clarification don't hesitate to call.

Thank you,

Robert E. K (Industrial Engineer)

ATTACHMENT 4

MOLEX
Narrative of Tower Draw (B-!() pump move to Flammable Storage Building Mainelli Mechanical, Commonwealth Electrical alone, with Wright Construction were contracted after a pooling, of information between Molex , State and Local representatives from various entities, (State Department of Environmental Quality, Lincoln Lancaster Health Department and Lincoln Lancaster Wastewater Treatment).

This pooling, of information took place at Molex on October 6th 1997, to determine the best solution for a corrective action to insure that (1) there would not be another discharge of B-19 into the sanitary sewer line, and (2) if a line was to break the B- 1 9 would be contained and captured in a small area utilizing, a dual float system for redundancy to stop the pumps electrically as well as send a signal to our security monitor for 24 hour coverage ( Honeywell Security) who would in turn notify us by phone of the breakage.

Wright Construction layed/formed a cement block wall in one comer of the flammable storage building with a single steel door for access to this room containing the pumps, disconnect switches and associated black iron pipe used for plumbing. The door has a single block high threshold to insure that the two float sensors (set at 1/2 - 3/4 of an inch from the floor surface) will have sufficient B 19 to activate them. The addition of this small room does not disturb the design or integrity of the original flammable storage building, which is rated a Class I . Division I., because the top of the "pump room" was left open to the ceiling of the building,. The pumps have explosion proof motors and all wiring, is per NEC for Class I, Division I wiring, group A,B,C, or D.

The walls and floor were lined with a PVC membrane up to approximately 30 inches above the floor level, to contain any B-19 in the event of a leak and to prevent it from escaping into the building, or migrating to surrounding soil.

There are two pumps for redundancy, at least one pump must run continuously for circulation purposes (continuous circulation is needed to keep the B-19 material from separating through the Stamping Department and back to the 10,000 gallon storaoe tank located in the lower level of the flammable storage building, and to enable the material handlers to draw and dispense the B-19-as needed to our punch presses located on the upper level of the manufacturing facility. The pumps are set on pedestals off the floor to facilitate plumbing and keep them "high and dry".

While there are electrical source disconnects in the room with the pumps, their supply source is located in the main building, Phase H motor control center. The float switch if activated, will drop out the circuit to these motor controllers and send a signal to Honeywell Security.

One of the pressure switches (if pressure drops due to line breakage anywhere in the plumbed system) will activate a relay contact and send a signal to Honeywell Security as well as shut down the pumps. If the other pressure switch is made, it will set off a local alarm (a red strobe light located on the exterior of the flammable storage building). These pressure switches are set to the same pressure and are plumbed to the common main/discharge piping.

At the pumps, there is a ball valve at the input and discharge side of each pump for isolation (also a check valve for each pump to insure that the pump does not lose pressure). Each pump has an analog, installed pressure c7auac to monitor the system pressure which is presently set at 30 P.S.I.. Pressure is set or controlled by a relief valve mechanical setting on each pump as well as by a ball valve set to regulate flow from intake to discharge side of each pump.

At the base of the 10,000 gallon tank there is a check valve and main shutoff. Just above this is another mechanical pressure relief valve on the return line to the tank and another ball valve ahead of it.

ATTACHMENT 7

NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY AUTHORIZATION TO DISCHARGE UNDER THE STATE OF NEBRASKA PRETREATMENT PROGRAM in compliance with the provisions of the Federal Water Pollution Control Act, as amended (33 U.S. C. 1251et. seq. as amended to date), the Nebraska Environmental Protection Act (Neb. Rev. Stat. 8 1-1501 et. M., as amended to date) and the Rules and Regulations promulgated pursuant to these Acts, Molex Inc. (Upland Facility) Lincoln, Nebraska is authorized to discharge from a facility located at Portion of Lot 63 and Lot 4, Block 1, Grassland Industrial Park, NEI/4, SW/4, Section 10, Township 10 North, Range 6 East, Lancaster County, Nebraska also known as 700 Kingbird Road to receiving waters named Salt Creek via the Lincoln Nebraska (Theresa Street) Wastewater Treatment Facility in accordance with effluent limitations, monitoring requirements and other conditions set forth in Parts L II, and Appendix A/B hereof.

This permit shall become effective on November 2, 1997. This permit and the authorization to discharge shall expire at rnidnight November 1, 2002.

Pursuant to a Delegation Memorandum dated January 30, 1995 and signed by the Director, the undersigned hereby executes this document on behalf of the Director. Signed this 30th day of September, 1997 W. Rice Assistant Director

PART I Page 2 of 4
Effective: 11/02/97
Permit Number NEO 13 1776

A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning November 2, 1997 and listing through November 1, 2002, the pcrmittee is authorized to discharge from the outfall designated as 001: pretreatment system discharge. Such discharges shall be monitored and limited as specified below:

FINAL EFFLUENT MONITORING REQUIREMENTS LIMITA'TIONS EFFLUENT UNITS Daily Daily Measurement Sample PARAMETERS Minimum Max Frequency Type pH S.U. 5.5 9.5 MONTHLY Grab (00400) EFFLUENT UNITS Monthly Daily Measurement Sample PARAMETERS Average Max Frequency Type Flow MGD Report Report Monthly Calculated or (50050) Metered Cadmium, Total mg/l 0.07 0.11 Semiannually Composite (4) (01027) Chromiurn, Total mg/l 1.71 2.77 Semiannually Composite (4) (01034) Copper, Total mg/l 2.07 3.38 Monthly COn2pOSitC (4) (01042) Lead, Total mg/l 0.43 0.69 Monthly Composite (4) (01051) Nickel, Total mg/l 2.38 3.98 Monthly Composite (4) (01067) Silver, Total mg/l 0.24 0.43 Semiannually Composite (4) (01077) Zinc, Total mg/l 1.48 2.61 Monthly Composite (4) (01092) Cyanide, Total mg/l 0.65 1.20 Semiannually Grab -(00720) -I70(l) mg/l Report 2.13 Semiannually Grab/ Composite (3) (78141) Sample taken in compliance with the monitoring requirements specified above shall be taken at the following locations: at a sample point prior to the introduction of sanitary, noncontact cooling water and other non-categorically defined dilution flow k(see NDEQ Title 12 1, Chapter 2 or 40 CFR, Part 43 3 for a definition of metal finishing waste Footnotes: See Part 1, B. B.

FOOTNOTES

1. Total Toxic Organics (TTO) - These compounds are listed in Appendix B of this permit. The permittee shall analyze for total toxic organic parameters using the methodologies set forth in 40 CFR, Part 136, Appendix A, Methods 624 and 625 or 1624 and 1625. The T70 value reported shall be the summation of all compounds found to be present at concentrations greater dm 0.01 milligrams per liter. A copy of the 'TT0 lab analysis shall be submitted with the DMRS.

2. Following the completion of an initial TT0 analysis, the permittee may present the Department with justification for a reduction in the test frequency or the number of compounds to be tested for on subsequent TTO scans. The Department may allow the permittee to certify compliance with the TTO effluent limitation as set forth in 40 CFT, Part 433.

3. The GC/MS Fraction-Acid Compounds and the GC/MS Fraction-Base/Neutral Compounds sample type shall be composite. The GC/MS Fraction-Volatile Compounds sample type shall be a grab.

4. A production day composite shall be defined as the period of time during any calendar day that categorically d finishing wastes (see NDEQ Title 121, Chapter 2 or 40 CFR, Part 433) are dischaged through the outfall(s) being monitored. All composite samples shall meet the requirements set forth in Appendix A, Section C.1. Of this permit.

A. OTHER REQUIREMENTS

1. Sludge shall be disposed of or utilized in a manner approved by the Department. 2. There shall be no discharge of pollutants which: a) create a fire or explosion hazard in the POTW, b) cause corrosive damage to the POTW, c) cause obstruction to the flow in the collection system, d) cause interference or pr upset at the treatment facility including slug loads, e) contain heat in amounts that can inhibit biological activity at the POTW, or f) result in the presence of toxic gases, vapors or fumes within a POTW in a quantity that may cause acute worker health and safety problems.
3 . a) If sampling performed by the permittee indicates a permit effluent limit violation, the permittee shall notify the NDEQ and the city (addresses and telephone numbers are listed below) within 24 hours of becoming aware of the violation. The permittee is responsible for maintaining updated telephone numbers. b) The permirtee shall submit a noncompliance report within five days after becoming aware of'the permit violation. c) The permittee shall resample the effluent and have it analyzed. d) The permittee shall submit the results of the repeated analysis to the NDEQ and the city within 30 days after becoming aware of the violation.
4. If the analytical results for a given parameter are below the minimum limit (ML), these results should be reported as zero. The ML is defined as the level at which the entire analytical system gives recognizable mass spectra and acceptable calibration points.
5. The permitted shall analyze wastewater parameters using the approved methods listed in 40 CFR, Part 136, as adopted in NDEQ Title 121 - Effluent Guidelines and Standards, Chapter 8.
6. Monitoring results obtained during the calendar year shall be summarized and reported on a Discharge Monitoring Report form postmarked no later than the 28th day of the month following the completed reporting period.

The reports are due on January 28, April 28, July 28 and October 28. Signed copies shall be submitted to: Nebraska Department of Environmental Quality Permits and Compliance Section P.O. Box 98922 Lincoln NE 68509-8922 Telephone Number: (402) 471-4239 and Mr. Lyle Christensen, P.B. Lincoln Wastewater Systems 2400 Theresa Street Lincoln, NE 68521 Telephone Number: (402) 441-7961

Molex Incorporated

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