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Molex Incorporated

Letter from Paul Eckerson (Molex) to EPA Water Docket

July 11, 1995

To: Regulatory Reinvention Pilot Projects
Water Docket Mail Code 4101,
US EPA 401 M Street, S.W.
Washington D.C. 20460

From: Paul Eckerson
Molex Inc.
1400 West Bond Circle
Lincoln, Nebraska 68521

Subject: Application for XL Project

Molex is a multinational company that operates several plating facilities world wide. We are in the process of designing a new facility world wide. We are in the process of designing a new facility to replace our current one in Lincoln. The goal of the new waste water treatment system is to reduce our mass loading to production ratio significantly, while trying to be as cost effective as possible. The current regulations do not encourage the approach that we feel can best achieve our goals.

The basis for this project is to show how changing the current regulations can be the financial incentive the electroplating industry needs to use technologies that reduce environmental impact. Typically, electroplating facilities produce multiple waste streams that are brought together for mass treatment. Some waste streams, such as cyanide, are segregated because it is the most cost effective way to achieve the necessary results. Having multiple metals in a waste stream for treatment is not the best case situation when attempting to remove them. The optimum conditions for the removal of each metal is often different. This requires the system to be operated at conditions that give the best average results for all metals. An example is our situation where we are trying to remove copper and nickel. This is a ph sensitive process with the ph producing the lowest solubility for copper being 8.8 and nickel 10.3. Operating at either ph will produce an effluent of about 0.5 PPM for that metal but about 1.5 - 2.0 PPM for the other. By running the process at ph 9.5, results for both metals will run about 1.0 - 1.5 PPM on average. The result of removing metals together is a sludge (F 006) that must be processed if the metals are to be reused. The cost of this processing usually offsets the value of the metals unless there is significant precious metals present. The processing of these sludges usually requires large amounts of energy which contributes to pollution as well. By not integrating the different waste streams, and treating each separately, significant reductions in mass loading can be achieved. When treating each metal separately, optimum conditions can be employed to produce the best results possible. This should be at least a 50% reduction. The really big reduction comes from the fact that the streams are segregated. Example: A 10 gallon per minute (GPM) waste stream which contains a 2 GPM Nickel containing solution, 2 GPM copper stream, 3 GPM Lead stream, and 3 GPM of solution not containing any of these metals. If mass treatment of these metals produced a 10 GPM effluent of 1 PPM Nickel, and by segregation the process improvement produced a 2 GPM effluentof 0.55 PPM the net effeccct of nickel in the total effluent would be a 10 fold improvement. A 5 fold improvement just from the fact that the stream was segregated for treatment. The cost of the segregated waste treatment system is considerably higher as an initial investment. A system can be designed and built that can have a 20 year useful life. Annual savings, though small, over 20 years can offset the additional cost. Cost reductions from the cost of disposal of the sludge are the most significant. Pure metal sludges have significant value and can be used directly by smelters that are making products that contain that metal. They do not require processing which reduces pollution as is required with mixed sludges. The pure sludges can be sold direct to processors as opposed to paying for disposal.

Here lies the problem with the regulations. Multiple sludges require multiple shipments to different locations every 90 days by licensed hazardous waste haulers. This greatly increases shipping costs and paper work. We currently only ship sludge once a year because we qualify under Subpart F--Recyclable Materials Utilized for Precious Metal Recovery. If all our waste streams were segregated, we would generate 4 sludges, 3 of which would not contain precious metal and would have to be shipped every 90 days for 13 required shipments per year. Subpart F 266.70 Applicability and Requirements (a). The regulations of this subpart apply to recyclable materials that are reclaimed to recover significant amounts of precious metals. This should be expanded to include any recyclable material that has significant value. Significant value is the difference between something being a waste and a valuable by-product. When industry is willing to invest in technologies that produce valuable by-products, they do not have the incentive to dispose of them in a manner that is a danger to the environment. For this reason, regulations which are designed to prevent this are really not necessary.

By reclassifying these valuable by-products, which would still be F 006 materials, from hazardous waste to hazardous material, significant savings can be made without endangering the environment. These materials could be sent by common carrier (with appropriate labels) at significantly lower rates than hazardous waste haulers. The requirement of shipping every 90 days would not apply. Material could be shipped in convenient quantities as is necessary and hopefully with less paper work. Another source of savings, although hard to quantify, would be the possibility of altering an industry's generator status. By not producing hazardous waste, this may prevent the industry from being a large quantity generator, thus avoiding all the addition regulatory requirements. This would be the case if we were to design a new fully segregated system. We currently dispose of our tin rinses to the POTW after ph adjust because it is not regulated. If we removed this and recycled it, it would increase our generator quantity to the large quantity status, something we want to avoid. By making the proposed changes in the regulations, we feel we can cost justify installing and operating a segregated waste treatment system and greatly improve our mass loading on the local POTW. This can be accomplished without endangering the environment. It will also reduce secondary pollution from the refining process required to treat the otherwise integrated waste. A secondary issue is that a segregated system would make it cost justifiable to recycle a portion of our water. This type of system would have a great deal of flexibility in meeting any future changes that may be required. New technologies that arise could be more easily incorporated as well. Molex is prepared and financially capable of installing a fully segregated waste treatment system and monitoring it to evaluate the financial and environmental results. Hopefully, this can demonstrate to our industry that this is a cost effective approach to achieving better environmental results. Molex will ensure that each composite sample is analyzed for the following parameters on a quarterly basis:

Constituent Analysis
Nickel Total
Lead Total
and TCLP leachable
Copper Total
Zinc Total
Tin Total
Chlorine Total
Moisture Content Total

Molex will ensure that each composite sample is analyzed for the following parameters on a semi-annual basis:

Constituent Analysis
Chromium Total and TCLP leachable; and total and TCLP leachable hexavalent chrome.
Cadmium Total and TCLP leachable
Cyanides Total and complexed/amenable
Mercury Total and TCLP leachable
Arsenic Total
Barium Total and TCLP leachable
Selenium Total and TCLP leachable
Silver Total and TCLP leachable
Gold Total
Sulfides Total
Antimony Total
Beryllium Total
Thallium Total
Heating Value BTU/lb
Total Organic Carbon (TOC)

In the event that TOC, in any set of composite samples collected, exceeds 500 ppm (by weight), then Molex will ensure that such set of samples is also analyzed for the following additional parameters: TCLP organic constituents listed in Table 1 of 40 C.F.R. Part 261.24, with the exception of (a) the insecticides endrin, lindane, methoxychlor and toxaphene and (b) the herbicides 2,4-D and 2,4,5-TP (Silvex). If TOC in any set of composite samples exceeds 500 ppm (by weight), Molex will also demonstrate to EPA and NDEQ that the samples do not include greater than a 500 ppm total concentration of organic compounds listed in Part 261, Appendix VIII.


October 30, 1996 -Introductions/Purpose of Meeting/Review Agenda Doyle/EPA -Present Status of Molex Proposal Doyle/EPA Others -Discuss Project Implementation Mechanism(s) Bunch/EPA Kovar/NDEQ -Review/Discuss Details of Project All -Future Activities/Involvement of Stakeholders EPA Region 7 EPA Headquarters NDEQ LLCHD City of Lincoln Molex -Summarize Meeting/Action Items Bernard-Drakey/EPA



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