Molex Incorporated

Letter of warning from Nebraska DEC to Mike Driscoll (Molex) and 6/25/97 RCRA Compliance Evaluation Inspection Report

State of Nebraska
Department of Environmental Control
Randolph Wood Director
301 Centennial Mall South P.O. Box 98922
Lincoln, Nebraska 68509-8922
Phone (402) 471-2186

E. Benjamin Nelson Governor
September 13, 1991

Return Receipt Requested
Mike Driscoll
Molex Incorporated
1400 West Bond Circle
Lincoln, Nebraska 68521

RE: Hazardous Waste Compliance Evaluation Inspection DEC/EPA ID Number NED085825321

Letter of Warning

Dear Mr. Driscoll:

Enclosed a copy of an Inspection Report from a RCRA Compliance Evaluation Inspection conducted at the above-referenced facility on June 25, 1991.

The results of this inspection have identified several areas of non-compliance. The violations and associated regulatory citations (Nebraska Revised Statute §81-1505(13)(a), 40 Code of Federal Regulations (CFR) and Title 128 - Rules and Regulations Governing Hazardous Waste Management in Nebraska) are as follows:

1. Failure to conduct annual training in hazardous waste management for employees in all related positions (Title 128-Chapter 24, 003 as referenced by Chapter 19, 004.01E).

2. Failure to retain and make available for inspection hazardous waste manifests (Title 128-Chapter 17, 002.08).

3. Failure to include an evacuation plan in the Contingency Plan (Title 128-Chapter 28.003.06 as referenced by Chapter 19, 004.01E).

Under Nebraska Revised Statute §81-1508 each of these violations is punishable by fines up to $10,000 per day of violation or injunctive relief. The actions giving rise to the above violations, if continuing, should cease immediately. These violations are to be corrected within 30 days of receipt of this letter. You are required to submit documentation of all corrective actions planned. the corrective actions an/or a schedule of corrective actions planned must be submitted by September 30, 1991.

Be advised that meeting the above requirements does not prevent the Department from pursuing civil, administrative or criminal enforcement. In addition, any decision to take one type of action does not preclude another type of action.

I'm enclosing copies of the appropriate pages of Title 128, 40 CFR and the Nebraska Environmental Protection Act. If you have any questions or comments please contact Lorraine Cope or myself at (402) 471-4217.

Sincerely,

David Wisch
RCRA Unit Supervisor Hazardous Waste Section
Land Quality Division
DW/LC/dhp/sf Enclosures

cc: Mike Sanderson, US EPA Region VII

NEBRASKA DEPARTMENT OF ENVIRONMENTAL CONTROL HAZARDOUS WASTE SECTION RCRA COMPLIANCE INSPECTION MOLEX INCORPORATED
1400 WEST BOND CIRCLE
LINCOLN, NEBRASKA 68521

June 25, 1991

EPA/DEC ID # NED085825321

PARTICIPANTS
Molex:
Mike Driscoll - Plating Manager
NDEC: Lorraine Cope - Program Specialist

INTRODUCTION
This inspection was conducted to determine whether Molex Incorporated is in compliance with Title 128 - Rules and Regulations Governing Hazardous Waste Management in Nebraska established under the Resource Conservation and Recovery Act (RCRA) of 1976, as amended. This inspection was carried out on June 25, 1991, without prior notification. Molex notified as a generator and transporter of hazardous waste on July 25, 1985.

On arrival at the facility, I requested a meeting with the plant contact person, Mr. Mike Driscoll. After presenting my credentials and explaining the reason and nature of the inspection. Mr. Driscoll explained the manufacturing processes employed at Molex, their waste streams generated, and their current waste management practices.

We continued with a tour of the processes and Hazardous Waste generation and storage areas. An exit interview was conducted with Mr Driscoll in which I summarized my findings. The land disposal restrictions, hazardous waste manifests and training records could not be located the day of the inspection. Mr. Driscoll signed for a copy of the Official Notice.

PROCESS DESCRIPTION
Molex manufactures electrical connectors and employs approximately 200 people in 3 shifts. Molex Inc. employs 3 major manufacturing operations in producing electronic products. The stamping operation uses 22 machines in stamp various types of metals to be plated. The plating operation was electroplating techniques to plate the stamped product with various types of metals. The molding operation uses polymer compounds to make various plastic housings for electrical connections. Molex assembles these components at a plant at 4309 Progressive Avenue in Lincoln, Nebraska and at other plants.

WASTE STREAMS
1. Waste Cyanide Stripping and Cleaning Bath Solutions (F009) Source: Electroplating operations where cyanides are used. Quantity generated: About 20 drums every 3 months. Place of Disposition: On site treatment with sodium hypochlorite to neutralizes cyanide. Gold is precipitated with zinc or aluminum treatment. Remaining sludge is added to F006 waste.

2. Waste sludge from electroplating operation (F006) Source: Sludge from treatment of non-cyanide electroplating solution. Quantity generated: Approximately 10,000 pounds every 4 months. Place of Disposition: Sipi Metals - Chicago, Illinois (ILD005121439) Transporter: ESG Watts (ILD045376100).

3. Petroleum Spirits (D001) Source: Four parts washers in tooling and maintenance sections. Quantity generated: Approximately 700 pounds every 6 weeks. Place of Disposition: Safety Kleen - Omaha, NE (NED981495724). Transporter: Safety-Kleen - Elgin, IL (ILD051060408).

4. Used Oils (waste machine lubricating oil) Source: Generated from stamping machines. Quantity generated: 1200 gallons/year. Place of Disposition: Capitol Oil in Omaha, Nebraska.

5. Scrap Metal - All waste metal generated during the stamping operations is sent to Duling Metals in Chicago, Illinois.

6. Scrap plastic moldings - Most waste molding is reused on-site. The remaining is thermoset plastic resin which can not be recycled and is sent to Lincoln/Lancaster Sanitary Landfill (12,000 pounds per year). A focused approach to waste minimization in processing and improved manufacturing operations have resulted in a 50% reduction in six months.

7. Non-hazardous solid waste - All non-hazardous solid waste is compacted and sent to Lincoln/Lancaster Sanitary Landfill. The cardboard is recycled.

OBSERVATION AND COMPLIANCE DETERMINATIONS
1. A generator storing hazardous waste on-site must provide annual personnel training. (title 128-Chapter 24, 003 as referenced by Chapter 19, 004.01E). Molex could not produce documentation of personnel training for the emergency response coordinators.

2. The generator shall retain on file the signed copies of the manifest for 3 years after the date of the shipment (Title 128-Chapter 17, 007.08 On the day of the inspection the hazardous waste manifests could not be located.

3. The contingency plan must include an evacuation plan for personnel (who work in areas where there is a possibility that evacuation could be necessary (Title 128-Chapter 28, 003.06 as referenced by Chapter 19, 004.01E). The contingency plan submitted NDEC in June, 1987 by Molex did not include the evacuation plan.

Inspection Notes
1. The NDEC letter of January 14, 1991 (Attachment A) to Molex concerning the regulatory status of the electroplating waste sludges apparently requires further clarification. In Volume 50 of the Friday, January 3, 1985, Federal Register page 648 is the background discussion for 40 Code of Federal Regulations Part 266.70 - Precious Metal Recovery. (Title 128, Chapter 26.006 is based on 40 CFR Part 266.70). "Manifest requirements are necessary to create a paper trail to track wastes from the generator to the reclaimer". Also this Federal Register entry states, "that wastes to be recycled are exempt from all but the following requirements". The following is a summary of the regulations appropriate to your gold recycling, taking into account the tracking requirement and the exemption:

A. At least 75% of the material generated within one calendar year must be shipped for recycling.

B. The gold must be shipped on a Hazardous Waste Manifest. However it may be listed as a non-RCRA regulated material as this material is not subject to the labeling, dating, open container or weekly inspection requirements.

C. If the gold is shipped as a hazardous waste on a hazardous waste manifest then the gold must be labeled and dated to comply with the appropriate Department of Transportation (DOT) requirements.

2. On June 26, 1991, the day after the facility inspection Mr. Driscoll notified Lorraine Cope that the Hazardous Waste Manifests had been located.

3. On July 1, 1991 NDEC received a revised Contingency Plan from Molex.

Attachments

A. NDEC letter of January 14, 1991

B. Inspection report

C. Official Notice

D. Photographs

1. A super sack of gold for precious metal recovery.

2. Super sacks of gold for precious metal recovery.

Molex Incorporated

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