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Molex Incorporated

Letter from Paul Eckerson (Molex) to David Wisch (Nebraska DEC)

Dave Wisch Nebraska
D.E.C. Lincoln Ne. 68509

Dec. 20, 1990

In reference to our conversation of today, I will describe our present situation. We generate a sludge cake that contains nickel, copper, tin, lead, and gold. Typically the cake is only 25% solids. This material is manifested and shipped very 90 days to Sipi Metals in Chicago. We are charged a process fee per pound and are credited for the materials reclaimed. We have been generating approximately 10,000 pounds of sludge per 90 days. The value of the material reclaimed has exceeded the processing fees. Due to improved drag-out procedures and planned process changes the sludge value will not continue to offset the process fees in the near future. We have purchased a sludge dryer to reduced the moisture content to approximately 10%. This will reduce the sludge volume approximately 67% and the process fees proportionally. This will insure that sludge value will exceed the process fee. We intend to install the dryer within the next two weeks.

The amount of sludge generated per month will be well below the 1000 kg/month definition for a small quantity generators. We are currently classified as a large quantity generator. Our sludge is classified as F 006 (hazardous waste). Title 128 Chapter 4 002.03C states that this material is "solid waste" when reclaimed. It is not clear to me how long or how much sludge we may legally accumulate on site between shipments. Shipping fees by licensed haulers is a flat fee regardless of quantity and it is significant. For this reason we are interested in reducing the frequency of shipments.

I would like your interpretation of the state regulations so that we may comply accordingly. Estimations indicate that we will be generating between 10,000 and 15,000 pounds of sludge annually. Your assistance in this matter will be appreciated.


Paul Eckerson Molex Inc.
1400 W. Bond Lincoln Ne. 68521

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