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HADCO to Atlantic States Legal Foundation

February 28, 1996
Atlantic States Legal Foundation, Inc.
658 West Onondaga Street
Syracuse, N.Y. 13204

Attn: Mr. Samuel Sage, President

Dear Mr. Sage:

As we discussed, HADCO Corporation, in July, 1995 submitted a proposal for consideration under EPA's initiative Project XL. In November, it was announced that HADCO's proposal was one of eight initial proposals selected nationwide for implementation. HADCO's goal is to enhance the recycling of copper bearing material from printed wiring board manufacturing facilities. Once achieved, our goal will result in both reduced mobile air emissions and material landfilled. A copy of HADCO's original proposal, along with a summary of this, is enclosed for your review.

Essentially, the proposal seeks an expedited delisting, or some type of regulatory variance, for the wastewater treatment residue, so that HADCO can ship this material directly to a copper smelter for recycling. Please not it is HADCO's intent to ship this material directly to a major copper smelter located in Quebec province (Noranda). This regulatory flexibility would eliminate the cost and administrative burden associated with exporting this material as a "hazardous waste". Noranda has determined by testing that these materials are NOT a hazardous waste in Canada, which confirms our test using EPA's criteria and protocols for characteristic hazardous waste. Shipping this material direct to Noranda, and eliminating the need to ship this material as a hazardous waste, is expected to reduce the current cost of recycling. HADCO then plans to invest these savings into sludge drying equipment to further reduce the volume of what is directly shipped to the smelter, and to commence recycling a copper bearing dust (generated by sawing, drilling and edge trimming of circuit board laminate stock). This copper bearing dust is currently landfilled.

As part of the XL initiative, HADCO is seeking the input and participation of parties that may have interest in this type of project. As HADCO has facilities in several different states, we are looking for participation from groups that are located in the same geographic region as the facilities. Atlantic States Legal Foundation was suggested by EPA Counsel as a group that may desire to participate as a "stakeholder", in consideration of the fact that HADCO has a facility located in Owego, N.Y. Your review of the attached, and any comments or suggestions you have, would be greatly appreciated.


The next step in the Project involves the development of a Final Project Agreement (FPA), which will outline the specific terms and conditions for the actual implementation of the direct recycling. Attached is an EPA document "Principles for the Development of Project XL Final Projects Agreements". Your input at this phase is considered important, as HADCO desires to have the participation of organizations such as Atlantic States Legal Foundation, Inc.

Please feel free to contact myself at (607) 687-2415, x5232 at your earliest convenience. I look forward to hearing from you, and I hope that Atlantic States can participate in this project.

Perry Walter
Environmental Specialist


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