Project XL Progress Report Molex Incorporated On March 1 6, 1 995, the Clinton Administration announced a portfolio of reinvention initia- tives to be implemented by the U.S. Environmental Protection Agency (EPA) as a part of its efforts to achieve greater public health and environmental protection at a more reasonable cost. Through Project XL, which stands for excellence and Leadership, EPA enters into specific proj ect agreements with public or private sector sponsors to test regulatory, policy, and procedural alternatives that will produce data and experiences to help the Agency make improvements in the current system of environmental protection. The goal of Proj ect XL is to implement 50 proj ects that will test ways of producing superior environmental performance with improved economic efficiencies, while increasing public participation through active stakeholder processes. As of October 1999, 15 XL projects are in the implementation phase and 3 5 XL proj ects are under development. EPA Proj ect XL Progress Reports provide overviews of the status of XL proj ects that are implementing Final Proj ect Agree- ments (FPAs). The progress reports are available on the Internet via EPAs Proj ect XL web site at http://www.epa.gov/Project XL. Or, hard copies may be obtained by contacting the Office of Reinvention's Proj ect XL general information number at (202) 260-7434. Addi- tional information on Proj ect XL is available on the web site or by contacting the general information number. Background Molex Incorporated (Molex) is a multinational company that operates 47 facilities world- wide, in manufacturing, electroplating, metal stamping, and plastic molding. Its products include fiber optics. Molex electroplates coatings of nickel, copper, and tin and lead metals on substrate materials for a variety of manufacturing purposes. The process generates large volumes of wastewater containing metal contaminants, which are subsequently captured in wastewater treatment systems and become a Re- source Conservation and Recovery Act (RCRA) hazardous waste. Molex previously operated a wastewater treatment system that combined the wastewater streams from nickel, copper, and tin and lead plating processes. Molex XL Project" Lincoln, Nebraska Major Milestones July 11, 1995 Molex XL Proposal Submitted s August?, 1998 Nebraska DEQ Temporary Variance Issued s August 11, 1998 Final Project Agreement Signed August 7, 2000 Expiration of Nebraska DEQ Temporary Variance ------- MolexXL Project 12-31-99 These waste streams were treated in a single wastewater treatment process that generated a hazardous mul- tiple-metal waste material from which only one of the metals could be recovered, with the rest disposed. Molex switched to a process that segregates the wastewater streams from the plant's multiple electroplating processes and treats each one separately. Therefore, Molex recovers metal contaminants separately, reduces the amount of metal that would otherwise be disposed of in RCRA-regulated landfills or released to the environment at secondary smelters, and reduces metal-contaminant levels in the effluents discharged from the facility's wastewater treatment systems to Lincoln's publicly owned treatment works (POTW). In its XL proposal, Molex requested a variance from hazardous waste regulations in order to reduce the costs of storing and shipping these wastes to make it more economical to recover metals from electroplating waste streams. Molex believes that its new segregated wastewater treatment system results in superior environmental perfor- mance through a reduction in the amount of metals discharged to Lincoln's POTW, as well as through an increase in metals recycling. Operational process lines were changed to generate separate treatment sludges for nickel, copper, and tin/lead that are classified as hazardous waste under the Nebraska Department of Environ- mental Quality (NDEQ) Hazardous Waste Management Program. Through these operational process changes, the Molex XL project seeks to provide superior environmental performance by • reducing the amount of metals loading in the effluent discharged to Lincoln's POTW, • increasing the level of metals reclamation or recycling, and • reducing the amount of material that would otherwise require landfill disposal. The segregated treatment system, however, costs more to operate than a combined treatment system. Addi- tionally, the segregated system results in increased costs from compliance with current regulations for handling the resultant sludges. By providing the facility with a temporary variance from classifying nickel, copper, and tin/lead sludges as a solid waste, the Molex XL proj ect is helping to financially justify the continued operation of the segregated system. This temporary variance, which was issued by NDEQ on August 7,1998, allows Molex to handle the storage and shipment of these non-precious mono-metals sludges at substantially reduced costs for 2 years. The variance expires on August 7,2000. Molex estimates that the recovery of non-precious metals under the former combined processing system cost approximately $14,500 annually. Under the new system, Molex anticipates receiving an annual income of more than $7,600 from the sale of the separated, non-precious metals-bearing sludges, and benefiting from a net annual savings in waste management costs of more than $22,000. The Experiment The Molex proj ect tests whether regulatory flexibility through a variance from hazardous waste regulations will lead to a reduction in the costs of storing and shipping these wastes, and an increase in the rate of metals recovery from the multiple waste streams the proj ect generates. The Flexibility As an incentive to achieve superior environmental performance at Molex's Lincoln facility, EPA and the NDEQ are providing more flexible and cost-effective processes for regulatory management. The statutory programs, and the EPA offices administering the programs, affecting the Molex XL proj ect are • Resource Conservation and Recovery Act (RCRA) programs administered by EPA's Office of Solid Waste; • Pollution Prevention Act (PPA) programs administered by EPA's Office of Prevention, Pesticides, and Toxic Substances; and • Federal Water Pollution Control Act (FWPCA) programs administered by EPA's Office of Wastewater Management. ------- MolexXL Project 12-31-99 EPA, pursuant to RCRA Section 3005(b), has authorized NDEQ to carry out Nebraska's Hazardous Waste Management Program in lieu of the Federal program. Under this authority, NDEQ issued a variance to Molex granting the facility a temporary exemption from the classification as hazardous waste of segregated sludges generated during wastewater treatment. Without this variance, the sludge materials would be subj ect to NDEQ generator requirements for storage and shipment of hazardous wastes. Sludges from the former combined treatment system at Molex's Lincoln facility contained copper, nickel, tin, lead, and gold. The sludges' gold content allowed Molex to handle the combined treatment sludge as recyclable materials from which precious metals are reclaimed, under Title 128, Rules and Regulations Governing Hazardous Waste Management in Nebraska, Chapter 7, Section 010. Sludges generated at the upgraded facility, however, do not contain precious metals and no longer qualify under the recyclable pre- cious metal exclusion. By obtaining approval from the NDEQ under RCRA to classify its segregated process sludge as a "partially reclaimed" material rather than as a hazardous waste, Molex can ship the sludges using common carriers, rather than hazardous waste carriers that are subj ect to additional regulations for transportation, storage, and disposal (TSD) facilities under RCRA. Additionally, Molex is permitted to ship the hazardous materials on an as-needed basis, rather than every 90 days as required for hazardous waste. The temporary variance from NDEQ, which will remain in effect for 2 years and will expire August 7,2000, allows Molex sufficient time to demonstrate that segregation and separate treatment of various waste streams results in a significantly reduced metals content in the wastewater effluent. Data gathered will also be used to demonstrate whether the segregated system produces a recyclable sludge with market value. Ultimately, information gained through the sampling program may result in modified national or state performance standards. This XL proj ect supports RCRA, PPA, and Nebraska Hazardous Waste Management Program's goals of resource recovery and conservation. Specifically, the proj ect results in recycling of mono-metal sludges by recycling facilities, which will decrease the need for mining of ores or other virgin materials. This will result in the conservation of mineral resources and a reduction in the amount of materials that would otherwise be sent to a landfill. The Molex XL project also supports the goals of the FWPCA and Nebraska Surface Water Quality Stan- dards to restore and maintain the chemical, physical, and biological integrity of the nation's and state's waters. Specifically, the proj ect reduces the amount of metals being loaded into the City of Lincoln's POTW, thus reducing metals discharged from the POTW into surface waters and the amount of metals- bearing sludges that are ultimately sent to a landfill. Additionally, the reduced loading gives the POTW a reserve treatment capacity, reducing the need to replace or enlarge the publicly financed facility. Promoting Innovation and System Change Proj ect XL provides EPA opportunities to test and implement approaches that protect the environment and advance collaboration with stakeholders. EPA is continually identifying specific ways in which XL proj ects are helping to promote innovation and system change. The innovations and system changes emerging from the Molex XL proj ect are described below. Using a RCRA Solid Waste Variance to Encourage Recycling. Under the RCRA regulations, regulated entities may petition EPA to exempt or exclude materials from classification as a solid or hazardous waste. Molex is testing the use of a solid waste variance for RCRA-listed wastes to encourage metals recycling and reduce solid waste generation. The environmental performance and economic feasibility of the Molex proj ect could serve as a benchmark against which other potential requests for temporary variances may be measured. ------- Molex XL Project 12-31-99 Project Commitment Summary This table and the environmental performance section that follows summarize progress in meeting the commit- ments described in the FPA and temporary variance for the Molex Facility in Lincoln, Nebraska. Commitment Status Waste Analysis and Reporting Conduct and submit results of initial waste analysis on each of the three sludges (nickel, copper, and tin/ lead) for toxicity characteristic leaching procedure (TCLP), toxic metals, pH, and moisture content, in accordance with the variance and Attachment B of the FPA. Analytical results were included in the initial baseline report, which was submitted to NDEQ and EPA on November 17, 1998. Conduct and submit results of waste analysis on each of the three sludges for chlorine, sulfides, antimony, beryllium, thallium, heating value, and total organic carbon (TOC), in accordance with the FPA. Analytical results (with the exception of TOC) were submitted to EPA on September 15, 1998. If waste analysis indicates that TOC exceeds 500 parts per million (ppm) (by weight), submit data that prove that samples do not include greater than a 500 ppm total concentration of organic compounds, in accordance with the FPA. Analytical results on TOC were included in the first quarterly report, which was submitted to NDEQ and EPA on December 4, 1999. Conduct waste analyses on each sludge shipment prior to reclamation of total copper, nickel, lead, tin, zinc; of pH; and of moisture content, in accordance with the variance and FPA. Commencing in 1999, waste analyses will be con- ducted prior to each shipment. Provide an initial Baseline Report describing (1) the performance of the combined treatment system for the most recent 12-month period prior to implemen- tation of the segregated treatment system, and (2) productivity estimates of the segregated treatment system, in accordance with the variance and FPA. The initial Baseline Report was submitted to NDEQ and EPA on November 17,1998. Submit quarterly reports to EPA and NDEQ every 3 months after submitting the initial baseline report describing current data for the segregated treatment system, in accordance with the variance and FPA. First quarterly report: December 4,1998 Second quarterly report: March 4,1999 Third quarterly report: May 27,1999 Fourth quarterly report: August 7,1999 Provide a final report in accordance with the terms outlined in the variance and FPA. The final report is due December 15,2000. Maintain records of test results, waste analyses, and other variance conditions. During 1998, Molex began implementing a records management system supporting terms of the variance. Notify the NDEQ of the name, address, and facility contact for each facility to which material is sent for reclamation, and a description of anticipated pro- cessing. In 1999, Molex began to notify NDEQ of each facility that receives material for reclamation. ------- Molex XL Project 12-31-99 Commitment Status Waste Recordkeeping, Storage, and Transfer Maintain nonhazardous waste manifests identifying each specific shipment. Accumulate the nickel and copper sludges for no longer than 1 80 days before shipment, and store and transfer the tin/lead sludge in accordance with vari- ance provisions. Beginning in 1 999, Molex began to maintain nonhaz- ardous waste manifests for each shipment. Storage conditions specified in the variance are being met by Molex, with shipment of the segre- gated sludges to begin in 1 999. EPA Commitments Determine need for additional sampling. After the submittal of the fourth quarterly report, EPA will determine whether additional sampling and analysis will be necessary for the duration of the temporary variance. Environmental Performance This section summarizes progress in meeting the environmental performance described in the FPA and temporary variance for the Molex Facility in Lincoln, Nebraska. Note about the Baseline Data: In its Baseline Report Molex (1) collected data on the combined treat- ment system for the most recent 12-month period prior to implementation of the segregated treatment system, and (2) provided productivity estimates of the segregated treatment system. For the combined treatment system, the report presented data on the concentration and mass of metals in the effluent dis- charged to Lincoln's POTW, the volume of sludges generated and stored on site, the volume of sludges shipped to the recycler, and an analysis of the sludges. The report also estimated the productivity of the segregated treatment system. It is important to note that sludge volumes between the combined treatment process and the segregated treatment process are not strictly comparable, because the combined treatment sludges were dried, but the segregated treatment sludges were not. This section compares the estimated sludge generation rates from the Baseline Report, and actual sludge generation rates of the segregated treatment system. Total Generation of Sludge In the Baseline Report, Molex estimated that the segregated treatment system would gener- ate atotal of 71,328 pounds of sludge, but actual generation rates based on the Quarterly Reports indicate that actual sludge generation rates were 10.3% higher (78,709 pounds) than the estimated baseline for the segregated system. Based on the Quarterly Reports, it is estimated that the segregated treatment system has resulted in a 65% reduction in the concentration of total metals in the effluent discharged by the POTW. Reduction in the Concentration of Total Metals in the Effluent 1999 Actual 65% 20 40 60 80 100 Percent Reduction of Total Metals Concentration * This information is based on Moiex's quarterly reports, which cover project performance from 8/7/98-8/7/99 ------- Molex XL Project 12-31-99 Copper Sludge Generation and Loading In the Baseline Report, Molex estimated that 13,376 pounds of copper sludge would be gener- ated with the segregated treatment system. How- ever, actual generation rates were 59% higher (21,242 pounds) than the estimated baseline. Based on the Quarterly Reports, and since this sludge is recycled, it is estimated that the use of the segre- gated system has resulted in decreased copper concentrations in the POTW's effluent by 66%. * 1999 Actual Baseline Estimate Copper Sludge Generation Rates For the Segregated Treatment System 21,242 13,376 10000 20000 30000 40000 50000 Pounds of Copper Sludge *This information is based on Molex's quarterly reports, which cover project performance from 8/7/98-8/7/99 Reduction in the Concentration of Copper in the Effluent •1999 Actual 66% 0 20 40 60 80 100 Percent Reduction of Copper Concentration *This information is based on Moiex's quarterly reports, which cover project performance from 8/7/98-8/7/99 Nickel Sludge Generation and Loading In the Baseline Report, Molex estimated that 45,089 pounds of nickel sludge would be gener- ated with the segregated treatment system. How- ever, actual generation rates were 8.5% higher (48,928 pounds) than the estimated baseline. Based on the Quarterly Reports, and since this sludge is recycled, use of the segregated system has resulted in decreased nickel concentrations in the POTW's effluent by 67%. •1999 Actual Baseline Estimate Nickel Sludge Generation Rates For the Segregated Treatment System 48,928 45,089 0 10000 20000 30000 40000 50000 Pounds of Nickel Sludge *This information is based on Molex's quarterly reports, which cover project performance from 8/7/98-8/7/99 Reduction in the Concentration of Nickel in the Effluent '1999 Actual 67% 20 40 60 80 Percent Reduction of Nickel Concentrations 'This information is based on Molex's quarterly reports, which cover project performance from 8/7/98-8/7/99 100 ------- Molex XL Project 12-31-99 Tin/Lead Generation and Loading In the Baseline Report, Molex estimated that 12,863 pounds of tin and lead sludges would be generated with the segregated treatment system. However, actual generation rates were 34% lower (8,539 pounds) than the estimated baseline. Based on the Quarterly Reports, and since this sludge is recycled, use of the segregated system has resulted in decreased concentrations of tin (98%) and lead (29%) in the effluent being discharged by the POTW. Tin/Lead Sludge Generation Rates For the Segregated Treatment System * 1999 Actual Baseline Estimate 12,863 8,539 0 10000 20000 30000 40000 50000 Pounds of Tin/Lead Sludge 'This information is based on Molex's quarterly reports, which cover project performance from 8/7/98-8/7/99 Reduction in the Concentration of Tin/Lead in the Effluent Tin Lead 98% 29% 0 20 40 60 80 100 Percent Reduction of Tin and Lead Concentrations 'This information is based on Moiex's quarterly reports, which cover project performance from 8/7/98-8/7/99 Sludge Recycling In the Baseline Report, Molex estimated that it would be able to recycle 71,328 pounds of metals sludges in a year. However, the Quarterly Reports indicate that between August 1998 and August 1999, a total of 78,709 pounds of sludge were sent to the recycler, a 10.3% increase. Stakeholder Participation Volume of Sludge Shipped to Recycler Actual Amount From 8/7/98-8/7/99 As Reported in the Four Quarterly Reports Anticipated Amount in Baseline Report 78,709 71,328 25000 50000 75000 100000 Pounds per Year Molex worked to ensure that stakeholders were involved in the environmental design and impact assessment of its XL proj ect and had an opportunity to participate fully in proj ect development. The organizations directly involved in negotiating the FPA included Molex, EPA, NDEQ, the Lincoln-Lancaster County Health Depart- ment, and the City of Lincoln. Meetings were held on August 24,1996, and October 30,1996, to discuss the Molex XL proj ect proposal and develop the FPA. EPA received stakeholder comments on the implementation of the Molex XL project following notification to the public on November 3,1997. While recognizing the potential benefits of Project XL, organizations such as the Environmental Defense Fund and the World Resources Company expressed concern with specific aspects of the Molex XL proj ect. The issues of concern included apparent weaknesses in the administrative record with respect to baseline practices and historical records; determination of the com- ------- MolexXL Project 12-31-99 modity-like nature of the various sludges; and the adequacy of follow-up waste testing, particularly with respect to TOC content. In response to these concerns, EPA gathered additional data required for the administrative record, conducted further analysis of the economic value of the generated sludges, and requested thatMolex implement a more comprehensive sampling and analysis program. Meeting agendas and documents pertaining to FPA negotiations are available to the public through the State of Nebraska, EPA Region 7, and EPA Headquarters' Offices and are accessible via the Internet on the Proj ect XL homepage. The public has been notified since initiation of this proj ect and invited to participate, and will continue to be informed through report dissemination during implementation of the proj ect. Six-Month Outlook NDEQ and EPA will continue to review analytical data and periodic reports provided by Molex in accordance with requirements in the temporary variance and the FPA. Among the factors to be considered in any final variance determination following the expiration of the existing 2-year temporary variance are • the degree of processing the material has undergone and the degree of further processing that is required, • the value of the material after it has been reclaimed, • the degree to which the reclaimed material is like an analogous raw material, • the extent to which an end market for the reclaimed material is guaranteed, and • the ability to handle the reclaimed material in a manner that minimizes loss. Project Contacts • Paul Eckerson, Molex, (402) 475-1700. • David Doyle, U.S. EPA, Region 7, (913) 551-7667. • Mitch Kidwell, EPA Headquarters, (202) 260-2515. • Bill Gidley, NDEQ, (402) 471-4217. • Brian Gorman, NDEQ, (402) 471-4253. • AnnetteKovar, NDEQ, (402) 471-3585. • Beth Mann, Lincoln/Lancaster County Health Department, (402) 441 -623 5. • Lyle Christensen, City of Lincoln, (402) 441-7967. Information Sources The information sources used to develop this progress report were (1) the September 7,1999, Molex FPA and (2) individual contacts with direct stakeholders. Glossary Baseline: The measure by which future environmental performance can be compared. Delisting: The process of excluding from regulations a waste that the U. S. EPA has defined as hazardous, if it can be shown that the waste no longer threatens human health and the environment. Disposal: The discharge, deposit, injection, dumping, or placing of any solid or hazardous waste on or in the land or water. ------- MolexXL Project 12-31-99 Effluent: Treated or untreated wastewater that flows out of a treatment plant, sewer, or industrial outfall. Generally refers to wastes discharged into surface waters. Electroplating: The electrodeposition of an adherent metallic coating upon an electrode for the purpose of securing a surface with properties or dimensions different from those of the base metal. Federal Water Pollution Control Act (FWPCA): The FWPCA of 1972 established the foundation of the current National Pollutant Discharge Elimination System (NPDES) program. This legislation and its subsequent amendments in 1976 and 1987 were enacted to address the direct connection between effluent (a point source) or runoff (a nonpoint source) and the water bodies that receive them. The 1976 amendment affirmed a legal agreement to control the growing problem of toxic discharges. In 1987, Congress amended the FWPCA again through the Clean Water Act (CWA) to address the inability of permits to meet the CWA goal of protecting swimming, fishing, and fish propagation. These amendments strengthened the ability of states to establish water quality standards. Final Proj ect Agreement (FPA): The FPA outlines the details of the XL proj ect and each party's commitments. The proj ect's sponsors, EPA, state agencies, Tribal governments, other regulators, and direct participant stakeholders negotiate the FPA. Hazardous Waste: By-products of society that can pose a substantial or potential hazard to human health or the environment if improperly managed. Under the RCRA program, hazardous wastes are specifically defined as wastes that possess at least one of four characteristics (ignitability, corrosivity, reactivity, or toxicity), or appears on special EPA lists. Listed Wastes: Wastes that are considered hazardous under RCRA because they meet specific listing descrip- tions. Media: Specific environments-air, water, soil-which are the subject of regulatory concern and activities. Multi-media: Several environmental media, such as air, water, and land. Pollution Prevention Act (PPA): The Act that focuses on enhancing industry, government, and public attention on reducing the amount of pollution through cost-effective changes in production, operation, and raw- materi- als use. Pollution prevention also includes other practices that increase efficiency in the use of energy, water, or other natural resources, and protect our resource base through conservation. Practices include recycling, source reduction, and sustainable agriculture. Publicly Owned Treatment Works (POTWs): Publicly owned facilities that receive and treat sewage and/or wastewater from residences, commercial activities, and industries. Reclamation: Restoration of materials found in the waste stream to a beneficial use that may be for purposes other than the original use. Recycling: The separation and collection of wastes, their subsequent transformation or remanufacture into usable or marketable products or materials, and the subsequent purchase of those products made from recy- clable materials. Resource Conservation and Recovery Act (RCRA): RCRA gives EPA the authority to control hazardous waste from "cradle-to-grave." This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA also sets forth a framework for the management of nonhazardous wastes. RCRA enables EPA to address environmental problems that could result from underground tanks storing petroleum and other hazardous substances. RCRA focuses only on active and future facilities and does not address abandoned sites. ------- Molex XL Project 12-31-99 Sludges: Any solid, semisolid, or liquid wastes generated from a wastewater treatment plant, water supply treatment plant, or air pollution control device. Substrate: Material upon which electroplating coatings are deposited. Transportation, Storage, and Disposal (TSD) Facilities: Facilities engaged in the treatment, storage, or disposal of hazardous waste. Toxicity Characteristic Leaching Procedure (TCLP): A laboratory procedure designed to predict whether a particular waste is likely to leach chemicals into groundwater at dangerous levels. Variance: Government permission for a delay or exception in the application of a given law, ordinance, or regulation. Wastewater: The spent or used water from a home, community, farm, or industry that contains dissolved or suspended matter. Water Pollution: The presence in water of enough harmful or obj ecti enable material to damage the water's quality 10 ------- |