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Molex Incorporated

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


From: Paul Eckerson Molex, Inc.

To: David Doyle EPA Region VII

In regards to reclassifying the F006 waste sludges, the material will be hazardous, but it will not be a waste. We would like the material classified for what it is, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, solid, n.o.s. ID# 3077 or HAZARDOUS SUBSTANCE, solid n.o.s. ID# 9188.

The term "waste" implies that the material has no significant value in its current state. "Disposal" implies the material is not going to be reused. I concur with the typical definition. We will not be disposing any material. We will be sending the material to companies that use these materials as feed stocks for creation of new products. On many occasions in the past, I've asked the question, "What is significant value." The answer I received from the regulator agencies was "If the facility you ship the material to pays you for it, it has significant value; if you pay them, it is disposal." The important issue here is that the material has enough value that we will not have any motivation to dispose of the material in an environmentally destructive manner.

The premise for this project proposal is that with regulatory changes, companies can be encouraged to use technologies that will not produce materials without the value that are hazardous. This will help to promote recycle of materials as opposed to disposal. This should reduce the requirements of a regulatory agency to prevent harmful disposal and promote Resource Conservation and Recovery.

A Frequency of shipments is not definite. It will depend on storage space availability, shipping rates, and quantity requirements of the processor. Under current law we would have to ship to three different locations every 90 days. This may well be a satisfactory situation. It may be more cost effective to ship at longer intervals. One year would be the maximum time that we would be financially motivated to store material. Thank you for your response. Hopefully we were able to answer your questions. Feel free to contact us as is necessary.

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