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Molex Incorporated

Memo from David Doyle (EPA) to Paul Eckerson (Molex)

October 18, 1995

From: David Doyle
EPA Region VII

To: Paul Eckerson Molex, Inc.

Attached are my initial comments concerning the Project XL proposal that you submitted to EPA on July 11, 1995. I have not been able to contact the Nebraska Department of Environmental Quality's hazardous waste staff to ask my questions concerning their review of this proposal yet so may have to add some additional questions after I have talked to them. Please review these comments and let me know how you would prefer to discuss them. I suggest that we consider having a teleconference call early next week. By then I should also have any issues with the NDEQ resolved. I can be reached at (913) 551-7667.



1) Page 2 of the proposal indicates that "Cost reductions from the cost of disposal of the sludge are the most significant". Is in fact Molex presently disposing of the wastewater sludge? The proposal implies that the wastewater sludge is or has been reclaimed at a commercial reclaimer rather than disposed. Please explain further.

2) Is Molex presently or has the facility in the past considered to be a large quantity or small quantity generator pursuant to the RCRA regulations?

3) Page 3 of the proposal indicates that reclassified F006 waste could be sent off-site, presumably to a reclamation facility, by common carrier. Has Molex determined whether in fact a common carrier, rather than a licensed hazardous waste transporter, would or could transport this material?

4) Please explain how shipping reclassified F006 waste as a hazardous material would reduce the paper work burden on the company. Would Molex continue to use hazardous waste manifests?

5) Since tin is not a hazardous waste constituent that causes F006 to be a listed hazardous waste, how would the recycling of tin rinses cause Molex to become a large quantity generator of hazardous waste?

6) Please be more specific on how a segregated wastewater treatment system would justify the cost of recycling a portion of the wastewater.

7) Please explain in detail why Molex believes that segregating and treating wastewaters separately will be cheaper than the present method(s) of sludge handling. How much savings does Molex anticipate occurring on an annual basis?

8) The proposal states that Molex would like to reclassify the F006 hazardous waste sludges from the segregated waste streams as "recyclable materials". Presently this waste is regulated pursuant to 40 CFR Part 266.70. Explain which, if any, regulatory provisions under RCRA is Molex proposing apply to this material.

9) Your proposal indicates that the Nebraska Department of Environmental Quality (NDEQ) is a proponent of this proposal. Is Molex aware of any other stakeholders or interest groups supporting or interested in this proposal? Stakeholders may include communities near the project, local or state governments, other businesses, environmental and other public interest groups, or other similar entities.

10) One of the selection criteria for XL projects that is specified in the May 25, 1995 Federal Register is that the project test innovative strategies for achieving environmental results and that it also protect the environment by preventing the generation of pollution rather than by controlling pollution once it has been created. Explain how the Molex proposal addresses both of these criteria.

11) The selection critera also states that the projects should have clear objectives and requirements that will be measurable in order to allow EPA and the public to evaluate the success of the project and enforce its terms. Also, the project sponsor should be clear about the time frame within which results will be achievable. Please explain how Molex plans to address each of these criteria.

12) The selection criteria states that the project must be consistent with Executive Order 12898 on Environmental Justice and it must protect worker safety and ensure that no one is subjected to unjust or disproportionate environmental impacts. Please explain how the proposal addresses these items. A copy of Executive Order 12898 is enclosed for your reference.

13) Which precious metal(s) is presently contained in your wastewater sludge to allow the sludge to be considered a recyclable material pursuant to 40 CFR 266.70 and state regulations at Title 128 Chapter 7.010?

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