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Molex Incorporated

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

Paul Eckerson Molex, Inc.
700 Kingbird Road
Lincoln, NE 68521

Dear Mr. Eckerson:

As you know, on November 3, 1997, the U.S. Environmental Protection Agency (EPA) published in the Federal Register, a notice requesting public comment on the implementation of the Molex, Inc. Project XL proposal. In response to this Federal Register notice, EPA received several comments from the public expressing their concerns in regards to this project. One comment, from an attorney representing the Natural Resource Defense Council (NRDC) and the Environmental Defense Fund (EDF), expressed concern that little if any pertinent analytical data existed for the wastewater treatment sludges generated either historically or presently by Molex. This commentor believes that if EPA were to approve the XL Project proposal without requiring additional analysis of these sludges, and if the sludges contained significant concentration s of regulated organic constituents, these sludges could pose a risk to human health and the environment. EPA believes that based on these comments, it would be prudent to make some changes to your project proposal. It is my present recommendation that rather than adding additional sampling and analysis to the draft Final Project Agreement (FPA) and conducting this additional sampling and analysis after the FPA is signed, that this sampling and analysis instead be conducted prior to the FPA being finalized and the project implemented. EPA is thereby requesting that Molex consider conducting the following sampling and analysis program as soon as possible.

(1) Collect grab samples from each of the three wastewater sludges (nickel, copper, and tin/lead) present generated by Molex that are subject to the project proposal.

(2) For each of these grab samples, conduct the following analysis: Total Volatile Organic Analysis ("VOAs") (Method SW 824OB), Semi-Volatile Organic Analysis ("Semi-VOAs") (Method SW 8250A), and Carbonyl Compounds Analysis (Method 8315).

(3) The grab samples should be collected in a manner that does not promote the volatilization of the sludge's organic content.

If the results of this analysis indicate that the sludges contain little if any organic constituents of concern, we will most likely proceed to implement the project as proposed. If the sludges do contain significant quantities of these constituents, EPA, Molex and NDEQ will then have to discuss how these findings might affect the implementation of this project. If you have any alternative proposals or ideas besides conducting this sampling and analysis process that you believe would address the comments from EDF, or have any questions concerning this letter, feel free to call me and we can discuss it. I can be reached at 913-551-7667.


David Doyle
Environmental Engineer Air, RCRA and Toxics Division

cc: Bill Gidley Nebraska Department of Environmental Quality
Annette Kovar Nebraska Department of Environmental
Quality Brian Gorman Nebraska Department of Environmental Quality

bcc: Bob Richards, CNSL Jamie Bernard-Drakey, RGAD ARTD: DDoyle: cschmaltz: 2-11-98: Disk 1: molex.sam ges 5/15/98



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