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

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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.

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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.

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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.

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 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

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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

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 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-

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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.

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 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.

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      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

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