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Texas Instruments

Texas Instruments Incorporated

David Bond
EPA Region 6
Dallas, Texas
Dear David,

I would like to thank you for meeting with us regarding the TI XL Project. We found it a very beneficial and illuminating discussion. I have enclosed the additional information that we agreed to provide during the meeting which included 1) The Texas Instruments locations that would be participants in the program, 2) the updated list of recyclers, and 3) a discussion of why the proposed contaminated media rule would not adequately address our excavated materials management issues.

The other issues were unilaterally agreed to be further discussed if the EPA preliminarily approved the project to progress to negotiations stage.

Thanks and Regards,

Tim Yeakley
Corporate ESH
Texas Instruments
TI XL Project Repurification Stakeholders
ROMIC Environmental Technologies Corporation
2081 Bay Road
East Palo Alto, CA 94303-1316
(416) 324-1638
EPA ID# CAD009452657
Attn: Ron Tressen

USPCI/Laidlaw Environmental Services
4303 Profit Drive
San Antonio, TX 78219
(210) 304-8000
EPA ID# TXDO52649027
State ID# 31905
Attn: Lynn Crane

Hydrite Chemical Company
411 N. Main Street
Cottage Grove, WI
EPA ID# WID000808824
Attn: Mark Hoyord
(414) 782-1450 EXT 730


Texas Instruments Incorporated

Texas Instruments

Although TI supports EPA's efforts to provide more flexible management requirements for the handling of contaminated media, as contemplated by the proposed HWIR-media rulemaking published at 61 Fed. Reg. 18780 (April 29, 1996), TI does not believe that these rules, as proposed, provide the necessary relief to enable a company to handle on-site activity that can result in the disturbance of soil and water in the most environmentally-responsible manner in all circumstances. Specifically, the excavated materials management component of TI's proposed Project XL proposal seeks to exclude from the universe of hazardous waste media containing constituents below conservative risk based levels, such as the State of Texas' Risk reduction Standard 2 levels, that is disturbed on side and can be re-used as a resource at that same facility. One example of particular interest to TI is the situation where, because of TI's conservative approach to waste classification, soils which contain extremely low levels of solvents are deemed by TI under today's rules to be listed wastes (F001-F005 or F039), would not meet the criteria for characteristic hazardous wastes and are below risk based action levels. TI does not believe this type of media should be subject to RCRA regulation or require the case-by-case exit determination contemplated by the proposed bright line approach.

The HWIR-media rule focuses on the management of contaminated media in the remediation context generally, which TI agrees requires greater scrutiny and procedural safeguards than does media proposed to be re-used on site which but for application of the listed and contained-in rules, would not be considered hazardous wastes. It is this second category of media that TI proposes to address in its resource management program. The troublesome aspects of a case-by-case approach to making a contained-in determination with respect to the media for a company such as TI relates primarily to the time and paperwork that would be entailed in adhering to the procedures outlined in the proposed rulemaking. Moreover, given the nature of the media TI wants to include in Project XL in order to allow on-site re-use and avoid unnecessary classification and disposal as a hazardous waste, the approach the proposed rule contemplates seems to be inefficient use of both agency and industry resources.

TI would continue to support further development of the contaminated media HWIR-rule, with a preference for the unitary approach for media that exceed health-based risk levels. However, TI does not believe that the complexity and detail of the rule is appropriate for the media that TI proposes to handle under Project XL.

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