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Molex Incorporated

RCRA Compliance Inspection Report

DCN: RZ3-SAI-R07013-01-IS-01159
RCRA COMPLIANCE EVALUATION INSPECTION REPORT
FOR MOLEX INCORPORATED
1400 W. BOND CIRCLE
LINCOLN, NEBRASKA 68521

EPA I.D. No. NED085825321

JUNE 1995

Submitted to:
U.S. ENVIRONMENTAL PROTECTION AGENCY REGION VII
726 MINNESOTA AVENUE
KANSAS CITY, KANSAS 66101

Submitted by:
SCIENCE APPLICATIONS INTERNATIONAL CORPORATION
104 WEST NINTH STREET, SUITE 104
KANSAS CITY, MO 64105

EPA CONTRACT NO. 68=W4-0005
EPA WORK ASSIGNMENT NO. R07013 SAIC
PROJECT NO. 05-5029-07-2968
RCRA COMPLIANCE EVALUATION INSPECTION REPORT ENVIRONMENTAL PROTECTION AGENCY REGION VII
Facility: Molex Incorporated 1400 W. Bond Circle Lincoln, Nebraska 68521
EPA Identification Number: NED085825321
Date of Inspection: December 1, 1994

Inspectors: Scott Kinderwater Mary Wesling
Science Applications International Corporation
20 California Street, Suite 400
San Francisco, California 94111
(415) 399-0140

Facility Representative: Paul Eckerson, Plating Supervisor/Chemist Report Prepared by: Scott Kinderwater and Mary Wesling
Report Date: June 9, 1995

TABLE OF CONTENTS

Section I. INTRODUCTION

II. PARTICIPANTS

III. INSPECTION PROCEDURES

IV. FACILITY DESCRIPTION

V. FINDINGS AND OBSERVATIONS
A. Waste Streams
B. Records Inspection
C. Visual Inspection
D. Sampling Report and Recommendations
E. Recommendations for the CEI

VI. SUMMARY

VII. ATTACHMENTS
1. Photograph Log and Photographs (not included)
2. CEI Checklist for Plating Facilities (includes Inspector's Notes)
3. Letters of Credential
4. Notice of Preliminary Findings
5. Receipt for Documents
6. Confidential Business Information Forms
7. Letters Dated December 20, 1990 and January 14, 1991
8. Wastewater Treatment Flow Diagram
9. Uniform Hazardous Waste Manifests

I. INTRODUCTION
On December 1, 1994, under Contract No. 68-W4-0005 with the U.S. Environmental Protection Agency (EPA), Scott Kinderwater and Mary Wesling, representing Science Applications International Corporation (SAIC), conducted an unannounced Resource Conservation and Recovery Act (RCRA) Compliance Evaluation Inspection (CEI) at Molex Incorporated (Molex), located at 1400 W. Bond Circle, Lincoln, Nebraska (EPA Identification No. NED085825321). The CEI was conducted under the authority of Section 3007 of RCRA, as amended, to evaluate the facility's compliance with the required applicable RCRA standards found in 40 Code of Federal Regulations (CFR) Parts 260 through 270 and Part 279. EPA is responsible for ensuring that generators, transporters, and treatment, storage and disposal facilities are in compliance with RCRA Subtitle C regulations as they apply to the universe of F006 wastes and electroplating activities associated with, but not limited to, electroless plating, anodizing, coasting, chemical etching and milling, and printed circuit board manufacturing. This CEI report represents the findings of an inspection of Molex that focused on electroplating operations as referenced above. The inspection, as designed, did not evaluate in detail any process operations unrelated to electroplating (e.g., industrial furnaces, boilers, and various other manufacturing operations). This narrative report and attachments present the results of the inspection. Photographs were taken to document this inspection and are included as Attachment 1 of this report. A compliance checklist for generator facilities, with the inspectors' notes from the inspection, is included as Attachment 2.

II. PARTICIPANTS
Molex Incorporated
Paul Eckerson, Plating Supervisor/Chemist
Greg Eden, Human Resources Manager
Iain MacDonald, General Manager
Site Address: 1400 W. Bond Circle Lincoln, Nebraska 68521
Phone number: (402) 475-1000
Science Applications International Corporation (for U.S. EPA Region VII)
Scott Kinderwater
Mary Wesling

III. INSPECTION PROCEDURES
This inspection consisted of an opening meeting, document review, visual inspection of the facility and a closing meeting. We arrived at the facility at 10:45 a.m., and requested to see the environmental compliance officer. We met Mr. Paul Eckerson and proceeded to hold an opening meeting to explain the purpose of the inspection. Present for the opening meeting were Mr. Kinderwater, Ms. Wesling, Mr. Eckerson and Mr. Greg Eden, Molex Human resources Manager. Mr. Iain MacDonald, Molex General Manager, was present for a portion of the meeting only. We stated to Mr. Eckerson that we are employees of SAIC, a contractor to EPA Region VII. and have been instructed by EPA to conduct an unannounced RCRA compliance evaluation inspection to determine Molex's compliance with the hazardous waste regulations. During out initial meeting, we presented our letters of credential issued by EPA Region VII, which authorizes us to conduct inspections as representatives of EPA (Attachment 3). We informed Mr. Eckerson that we have been trained and authorized to handle RCRA confidential business information (CBI), and that pursuant to 40 CFR Part 2, Molex could claim any information discussed or provided as a result of the inspection as CBI. We presented the form entitled "United States Environmental protection Agency Confidentiality Notice." We informed Mr. Eckerson that photographs would be taken to document the inspection and that representative samples of waste streams, soils and surface waters may be collected if we deemed it necessary. We explained that, at the end of the inspection, Molex would be given the opportunity to claim information as confidential. Molex declined to claim an information as CBI.

At the closing meeting, after the physical inspection was concluded, we discussed the results of the inspection with Mr. Eckerson and presented those results on a "Notice of Preliminary Findings" form (Attachment 4). We explained that the results discussed are preliminary and may change during further review of our notes while preparing the inspection report. We also prepared a "Receipt for Documents and Samples" form (for documents copied) for Mr. Eckerson's signature. This form is included as Attachment 5. The completed "Confidentiality Notice" form and "Request for Confidential Treatment" form (indicating Mr. Eckerson's decline for confidential treatment) are included as Attachment 6.

IV. FACILITY DESCRIPTION
According to Mr. Eckerson, Molex manufacturers small parts and components from raw material received as coils. A press is used in the manufacture of the Molex product. A lubrication oil is used in the pressing process which generates D001/D018 oily waste. Molex has an air permit which includes emissions from evaporation of this lube oil. The parts are sent through an electro-cleaner prior to beginning the plating process. Wastewater from the plating process is piped to the wastewater treatment system.

Molex uses a variety of small parts plating operations at the Lincoln plant including reel-to-reel plating and barrel plating. The plating processes are electroplating, acid activation, base metal plating (copper or nickel), gold plating, gold stripping, tin or tin/lead plating, and then rinsing as a final step after all electroplating.

According to Mr. Eckerson, neither cadmium nor chromium is used in Molex processes. The plating operation tanks, all approximately 100 gallons or less, are arranged in six lines and sit on a coated concrete floor which slopes slightly to a secondary containment trench. The containment trench is lined concrete. The trenches capture drip from the tanks and drain to a wastewater treatment system. Molex operates a wastewater treatment system that uses a lamella, a sand filter, a clarifier and a final neutralization tank. The resultant wastewater is discharged to the sanitary sewer under a pretreatment permit monitored by the city of Lincoln. A hazardous waste sludge (F006), generated from the wastewater treatment, is dried in a sludge dryer. The dryer reduces the moisture content of the sludge to approximately 10 percent, and volume by 67 percent. This dried sludge is sent to a reclamation facility once a year under contract for reclamation of gold in the waste. According to Mr. Eckerson, Molex operated as a large quantity generator until 1990 when the sludge dryer was installed. Prior to installation of the sludge dryer in 1990, Molex was generating greater than 2,200 pounds of hazardous sludge cake per month. This volume has since been decreased to less than 2,200 pounds (1,000 kg), as described below. On December 20, 1990, Mr Eckerson sent a letter to the Nebraska Department of Environmental Control/RCRA Division in an attempt to determine how long or how much F006 sludge may accumulate on site before shipping off for reclamation. According to that letter, as a result of the 1990 changes in Molex's process, the sludge no longer contained economically significant amounts of gold. For that reason Molex installed a sludge dryer. By drying the sludge, the bulk is reduced and, consequently, the weight percent of gold increased. The letter contained no quantification of the changes in bulk or weight percent of gold. The Nebraska Department of Environmental Control responded on January 14, 1991 and determined that since the F006 sludge meets the definition of a material utilized for precious metal recovery, Molex must meet notification requirements (40 CFR 266.70(a)(1)) and keep an inventory showing the amount of material stored at the beginning of a calendar year, at the end of the year, and generated in that calendar year (State of Nebraska, Title 128 - Chapter 26.006, and 40 CFR 266.70(c)). Molex appears to be handling the waste properly. See Section VI. of this report for further clarification. (Both letters are included in Attachment 7.)

Mr. Eckerson stated that Molex notified as a small quantity generator in 1991. Based on calculations from information provided to the inspectors by the facility, Molex generated approximately 900.3 kilograms per month (kg/mo) of hazardous waste, including 607.9 kg/mo F006 wastewater treatment sludge and 292.4 kg/mo D001-D018 spent solvent.

V. FINDINGS AND OBSERVATIONS
A. Waste Streams
During the inspection, it was determined that the following hazardous waste streams are generated at Molex.

1) Wastewater treatment sludge (F006): As described in Section IV, a wastewater treatment sludge is generated in the "segregated system" wastewater treatment. A flow diagram of this segregated system was supplied by Molex (Attachment 8). Ultimately, hazardous sludge is collected at the filter press, dried and then stored in one-cubic-yard bags. According to Mr. Eckerson, this waste has been tested and contains gold, lead, copper, nickel, and zinc. This gold-containing waste is held for up to one year at which time it is shipped to Sipi Metals of Chicago, Illinois, for recovery of precious metals. According to a determination made by the State of Nebraska, Department of Environmental Control (DEC) (see Attachment 7), the waste stream meets the definition of a material utilized for precious metal recovery (Title 128-Chapter 26.006). According to Mr. Eckerson, 16,049 pounds of bagged dried sludge were generated between September 21, 1993 and October 5, 1994. This roughly corresponds to 1,337 pounds of sludge or 607 kilograms generated per month.

2) Spent solvent/oily waste (D001/D018): Molex generates spent solvent hazardous waste and oily waste from a parts cleaner used in machinery (i.e., forklift and truck) maintenance which is manifested to Safety Kleen. According to Mr. Eckerson, D001/D018 waste is also generated from the press process in the manufacture of the small parts. When we asked for an estimate of D001/D018 waste generated, we were supplied with the manifest log. Based on the log, Molex generated approximately 956 gallons (292 kg/mo) of solvent waste from September 21, 1993 through September 23, 1994. 3) Complex cyanide is generated from the acid gold process. Cyanide moves to an anode in a potassium gold cyanide step, is treated with sodium hypochlorite, and off-gassed and vented to the atmosphere as CO2 and N2. Molex has an air permit which includes this emission. The process does not generate any sludge or other resultant hazardous waste. Molex also generates approximately 350 gallons (106 kg/mo) of nonhazardous used oil per year which is shipped to Capitol Oil for road-bed construction.

B. Records Inspection
Uniform hazardous waste manifests and land disposal restriction (LDR) forms were reviewed. Examples are included in Attachment 9 of this report. Manifests 00371 and IL 3023967 were reviewed; they include the receiving facility's signature. Manifest 00371 shows shipment of 180 gallons of petroleum naphtha (D001/D018) to Safety Kleen; manifest IL 3023967 shows shipment of 11 cubic yards of F006 waste (discussed in Section V.A.) on October 24, 1994. No violations were noted.

Training records were reviewed and discussed with Mr. Eden. The records indicated no potential violations. The facility's contingency plan was briefly reviewed and no potential violations were noted. Inspection logs for the used oil and solvent 90-day storage areas were reviewed and found to be adequate. No potential violations were noted.

C. Visual Inspection
Mr. Eckerson accompanied us on the visual inspection of the plating plant, the F006 accumulation area within the plating plant, the hazardous waste storage areas, and a visual inspection of the outside perimeter of the facility. Just prior to the visual inspection, Mr. Iain MacDonald, the general manager of Lincoln operations for Molex, briefly attended the meeting.

We inspected the plating plant first. Six lines of tanks (<100 gallons each) were observed. All tanks were in good condition. General housekeeping was excellent. The tank lines are located on a coated concrete floor which slopes slightly toward lined concrete trenches underneath the tank lines. All wastewater is collected within trenches that drain to a wastewater treatment tank.

The trench shown in Photo No. 1 is beneath the gold reel-to-reel plating line. The wastewater treatment system (no photographs taken) was observed but not inspected. Molex operates a wastewater treatment system that uses a lamella, a sand filter, a clarifier, a final neutralization tank, and a hot-air sludge dryer. The resultant wastewater is discharged to the sanitary sewer and the sludge is collected in the nearby sludge dryer. After drying, the sludge is placed in a one-cubic-yard bag in the adjacent accumulation area. Molex uses a segregated system approach for wastewater treatment; their diagram of this "segregated system for wastewater treatment" is included as Attachment 8 of this report.

Next, we inspected the hazardous waste stored at the accumulation area in the plating plant. The bag shown in Photo No. 2 contains F006 waste. The lid was raised to allow us to observe the contents of F006 waste stored at the accumulation point; the one-cubic-yard bag was full (Photo No. 3). when full, the bags are moved to a storage area in the warehouse.

A gold-stripping bath is located adjacent to the F006 waste stored at the accumulation area and is shown in Photo No. 4. The potassium cyanide bath is secondarily contained. When we noted that there is no berm between the potassium cyanide bath and the F006 waste, Mr. Eckerson stated that the potassium cyanide is not reactive with the F006 waste.

We inspected the hazardous waste storage area. Hazardous waste and housekeeping waste are stored in the warehouse. Product and supplies are also stored in the warehouse adjacent to the plating room. Photo No. 5 shows a one-cubic-yard bag of F006 waste stored on a shelf above Molex product. The area is not bermed, but the waste is in a dry state and stored in sealed bags that are in good condition. Solvents and waste solvents are stored in a separate fire-resistant room in the warehouse.

The waste solvent storage area is in an isolated fire-resistant room. Molex employee Gene Boetthler manages the spent solvent hazardous waste. One 55-gallon drum containing approximately 25 gallons of spent D001/D018 solvent was observed (Photo No. 6). There was neither a hazardous waste label attached to the drum nor was there an accumulation start date indicated. The drum was open in that a vent pipe was rising out of the drum. Mr. Boetthler removed the vent pipe and plugged the hole during the inspection.

Finally, we inspected the entire outside perimeter of the Molex plant. No hazardous waste storage was observed outside the plant. There was no indication of any disposal of waste to land. According to Mr. Eckerson, groundwater monitoring wells have been installed on the Molex property to monitor groundwater pollution from an offsite source.

D. Sampling Report and Recommendations
No samples were collected during the inspection. Uniform hazardous waste manifests and observations of waste on site at the time of the inspection indicate that Molex has properly identified their waste.

E. Recommendation for the CEI
Based on discussions with Mr. Eckerson and the other facility representatives, the physical inspection, and document review, it was determined that Molex does generate hazardous waste and is regulated by the State of Nebraska as an EPA (Small Quantity) Generator. It was also determined that sampling of the waste streams at Molex was unnecessary.

At the conclusion of the CEI, two potential violations (one containing two parts) were noted and discussed with Mr. Eckerson during the closing meeting when he was presented the "Notice of Preliminary Findings" form (Attachment 4). Upon further consideration while preparing this report, one of the potential violations listed in the Notice of Preliminary Findings form has been eliminated.

40 CFR 262.34(d)(2) A container holding hazardous waste must always be closed during 40 CFR 265.173 storage, except when it is necessary to add or remove waste. A drum in the waste solvent storage area was not closed in that a vent pipe was rising out of the drum (Photo No. 6)

40 CFR 262.34(a)(2) Hazardous waste containers must be labeled or marked clearly with 40 CFR 262.34(a)(3) the words "hazardous waste" and the accumulation start date must be clearly marked. One 55-gallon drum containing waste solvent did not have a hazardous waste label or and accumulation start date (Photo No 6).

VI. SUMMARY
At the end of the inspection and document review, we met with Mr. Eckerson to discuss the results of the inspection, the report schedule and the potential violations. We explained that we had identified two potential violations, one of which contains two citations (discussed above and included in Attachment 4 of this report). We told Mr. Eckerson that the results of the inspection are preliminary and may change as a result of further consideration during the preparation of this report.


As previously stated in Section V.B. of this report, Molex accumulates F006 waste on site as recyclable waste that is sent to a reclamation facility for recovery of economically significant amounts of gold. As long as they comply with the requirements specified for recyclable materials in 40 CFR 261.6(a)(2)(iv), 266.70(a) and 266.70(b)(1) and (2), Molex may extend the onsite accumulation time for this waste stream beyond what is allowed for generators who do not send the waste for precious metals recovery. Therefore, the potential violation discussed in the closing meeting (see Attachment 4) regarding storage time has been eliminated from the findings of this CEI.

The Molex facility is well managed; clean and orderly operations were observed during the inspection, and the hazardous waste management staff exhibited knowledge of the regulations for which they were evaluated. Molex has been successful in their attempts to limit the amount of hazardous waste that is generated.


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