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Molex Incorporated
Memo from Paul Eckerson (Molex) to David Doyle (EPA)
TO: DAVID DOYLE,
U.S. EPA
OCT. 18, 1995
FROM: PAUL ECKERSON,
MOLEX INC.
SUBJECT: QUESTIONS CONCERNING XL PROJECT PROPOSAL
1) CURRENTLY WE SEND THE SLUDGE IN FOR RECLAIM. IT IS INCINERATED AND THE METAL INGOTS ARE ANALYZED FOR COPPER AND GOLD CONTENT. MOLEX IS COMPENSATED FOR THESE MATERIALS. THE METAL IS PROCESSED FURTHER AT ANOTHER FACILITY.
2) MOLEX WAS A LARGE QUANTITY GENERATOR. WE ADDED SLUDGE DRYING CAPABILITY AND WERE THEN ABLE TO BE A SMALL QUANTITY GENERATOR. WE RECENTLY SUBMITTED AN APPLICATION TO BE A LARGE QUANTITY GENERATOR DUE TO OUR INCREASE IN PRODUCTION.
3) F006 MATERIAL BY DEFINITION IS HAZARDOUS WASTE AND MUST BE SHIPPED BY AN APPROVED HAZARDOUS WASTE HAULER. IF AS PROPOSED THE MATERIAL WAS RECLASSIFIED AS HAZARDOUS MATERIAL IT COULD BE SENT BY COMMON CARRIERS THAT ARE HAZMAT APPROVED.
4) HAZMAT APPROVED CARRIERS ARE FAR LESS EXPENSIVE THAN HAZARDOUS WASTE HAULERS. MOLEX WOULD NOT USE HAZARDOUS WASTE MANIFESTS IF THE MATERIAL WAS NOT CLASSIFIED AS HAZARDOUS WASTE. IF MANIFESTING IS CURRENTLY REQUIRED FOR HAZARDOUS MATERIAL, THEN WE WOULD MANIFEST. REGARDLESS WE WILL BE MAINTAINING RECORDS OF VOLUMES GENERATED, STORED, SHIPPED, PROCESSORS, FINANCIAL CONTRACTS, TRANSACTIONS AND NET RESULTS RELATIVE TO PAST PRACTICES. ONLY IF MANIFESTING WAS NOT REQUIRED, WOULD PAPER WORK BE REDUCED.
5) RECYCLING THE TIN WILL CAUSE IT TO BE F006 BECAUSE IT WOULD CONTAIN SOME LEAD FROM THE TIN-LEAD PLATING PROCESS. CURRENTLY WE DO NOT TREAT THE PURE TIN PROCESSES. IN THE NEW FACILITY THE PURE TIN AND THE TIN-LEAD WOULD BE PROCESSED TOGETHER AND THE PRESENCE OF THE LEAD WOULD MAKE IT F006. ADDING THE TIN THAT WAS PREVIOUSLY NOT TREATED WOULD ADD TO THE SLUDGE VOLUME AFFECTING GENERATOR STATUS.
6) SOME OF OUR PLATING PROCESSES CONTAIN SIGNIFICANT ORGANIC ADDITIVES SOME DO NOT. TO REUSE WATER THESE ORGANICS MUST BE REMOVED. IT IS NOT COST EFFECTIVE TO DO SO. BY SEGREGATING THE PROCESS, THE STREAMS THAT DO NOT CONTAIN SIGNIFICANT ORGANICS BECOME POSSIBLE CANDIDATES FOR COST EFFECTIVE WATER RECYCLE.
7) THE COST SAVINGS ASSOCIATED WITH A SEGREGATED SYSTEM HOPEFULLY IN 15-20 YEARS OF OPERATION WILL BE EQUAL TO OR LESS THEN A NONSEGREGATED SYSTEM. WE ANTICIPATING AN ADDITIONAL COST OF 150,00.00 TO SEGREGATE. THIS IS NOT THE ONLY IMPEDANCE FOR THIS DECISION. FOLLOWING IS A LIST OF EXPECTED SAVINGS AND SOME INTANGIBLES THAT HAVE AFFECTED OUR DECISION.
A) RECYCLING NICKEL HYDROXIDE. WE NOW PAY $.50 PER POUND IN RECYCLING FEES BUT RECEIVE NO COMPENSATION FOR THE NICKEL. THE PURE NICKEL HYDROXIDE CAN BE SOLD FOR $.75 PER POUND. A $1.25 DIFFERENCE. WE EXPECT TO GENERATED ABOUT 6000 POUNDS PER YEAR. THIS RESULTS IN A $9000.00 SAVINGS ANNUALLY.
B) RECYCLING TIN AND TIN-LEAD. WE NOW PAY $.50 A POUND TO DISPOSE OF ABOUT 3000 POUNDS OF TIN-LEAD WITHOUT COMPENSATION. A LOSS OF $1500.00 ANNUALLY. WE EXPECT TO GENERATE 12000 POUNDS OF TIN AND TIN-LEAD WHICH WE WILL RECEIVE $.25 PER POUND, OR $3000.00 ANNUALLY. AN ANNUALLY NET SAVINGS OF $4500.00
C) THE GOLD AND COPPER RECOVERY WILL PROBABLY BE IMPROVED AS THE PROCESS FEES ARE USUALLY LOWER WHEN DEALING WITH PURER MATERIALS. WE CANNOT QUANTIFY THIS PRESENTLY. WE WILL ATTEMPTED TO DOCUMENT THIS, IF IT IS IN FACT TRUE.
D) SIGNIFICANT IMPROVEMENT IN EFFLUENT QUALITY WILL BE POSSIBLE. IF THE LIMITS ARE REDUCED IN THE FUTURE WE WILL LIKELY NOT HAVE TO MAKE ADDITIONAL INVESTMENTS IN BETTER TECHNOLOGIES TO MEET THESE REQUIREMENTS.
E) IF NEW TECHNOLOGIES FOR TREATMENT ARISE THEY CAN BE MORE EASILY INCORPORATED INTO A SEGREGATED SYSTEM.
F) NON-COMPLIANCE SITUATIONS CAN BE MORE READILY AVOIDED WITH THE BETTER CONTROL. THIS REDUCES OUR LIABILITY.
G) A MORE RELIABLE SYSTEM WILL HOPEFULLY REDUCE LABOR COSTS. H) IT IS A GOAL OF OUR NEW FACILITY TO BE "STATE OF THE ART." IF WE ARE REQUIRED TO SHIP THE SLUDGES EVERY 90 DAYS TO EACH OF THE DIFFERENT PROCESSOR LOCATIONS BY LICENSED HAZARDOUS WASTE HAULERS (13 SHIPMENTS PER YEAR AS OPPOSED TO THE CURRENT ONE) MOST OF THE SAVINGS WILL BE CONSUMED IN ADDITIONAL FREIGHT COSTS.
9) THE LOCAL POTW IS A STAKEHOLDER WHO IS INTERESTED AND SUPPORTS THIS CONCEPT. THEY HAVE INVESTED IN AN ANAEROBIC DIGEST SYSTEM AND CURRENTLY LAND APPLY THE SLUDGE THAT IS GENERATED. BY REDUCING OUR MASS LOADING WE WILL BE REDUCING THE AMOUNT OF METALS THAT THEY WILL BE LAND APPLYING. THESE ARE REGULATED AS THEY HAVE THE POTENTIAL TO BE INTRODUCED INTO THE FOOD CHAIN. IN THIS REGARD IT DOES IMPACT THE GENERAL POPULATION.
10) THIS STRATEGY IS INTENDED TO PRODUCE SIGNIFICANTLY BETTER ENVIRONMENTAL RESULTS THROUGH LOWER EFFLUENT DISCHARGE CONCENTRATIONS. THIS IS LESS POLLUTION. THE SLUDGE THAT IS GENERATED WILL HAVE SIGNIFICANT VALUE AND FOR THAT REASON THERE WILL NOT BE ANY MOTIVATION FOR IMPROPER DISPOSAL. THE RECYCLING OF THIS MATERIAL SHOULD REQUIRE LESS ENERGY WHICH IS A FORM OF POLLUTION PREVENTION.
11) ALL OF OUR OBJECTIVES WILL BE MEASURABLE AND WE FULLY INTEND TO DO SO. EFFLUENT QUALITY IMPROVEMENT AND COST SAVINGS WILL BE THE PRIMARY CRITERION MEASURES. A TWO YEAR PERIOD WOULD BE MORE THAN ADEQUATE TO DETERMINE THE EXTENT OF THE SUCCESS OF THE PROJECT.
12) CONCERNING ENVIRONMENTAL JUSTICE, THIS PROJECT SHOULD HAVE LITTLE EFFECT ON CURRENT WORKER SAFELY AT OUR LOCATION. SAFETY DURING SHIPMENT WILL NOT BE CHANGED AS THE MATERIAL WILL STILL BE IDENTIFIED AS TO ITS SPECIFIC HAZARDS. ENVIRONMENTAL IMPACT WOULD BE REDUCED LOCALLY. DUE TO THE REDUCTION IN METALS THAT ARE LAND APPLIED. THE IMPACT DUE TO PROCESSING WOULD BE SHIFTED TO DIFFERENT LOCATIONS BUT SINCE THESE FACILITIES ARE REGULATED AND PERMITTED THE IMPACT SHOULD REMAIN CONSTANT IF NOT IMPROVE DUE TO THE FACT THAT PROCESS IS MORE SPECIFIC OR REFINED.
13) GOLD IS IN THE SLUDGE THAT WE CURRENTLY GENERATE. THIS ALLOWS IT TO BE CONSIDERED RECYCLABLE MATERIAL PURSUANT TO 40 CFR 266.70. THIS EXEMPTION STILL REQUIRES IT TO BE CLASSIFIED AS HAZARDOUS WASTE FOR GENERATOR STATUS AND TRANSPORTATION PURPOSES. WITH SEGREGATION >99% OF THE SLUDGE GENERATED WILL NO LONGER BE EXEMPT PER 266.70. I HOPE THIS HAS ANSWERED YOUR QUESTIONS CONCERNING THIS PROPOSAL. FEEL FREE TO CONTACT ME FOR ANY ADDITIONAL INFORMATION OR CLARIFICATIONS THAT YOU MAY FEEL ARE NECESSARY. YOUR EFFORT AND SUPPORT IN THIS MATTER IS GREATLY APPRECIATED.