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February 28, 1996
New York Public Interest Research Group (NYPIRG)
9 Murray Street
New York, New York 10007

Attn: Mr. Chris Myers

Dear Mr. Myers:

Since we have been having a little difficulty connecting over the phone, I though it would be easier and more convenient for the both of us if I dropped you a brief letter on what I desired to discuss with you.

Last year, HADCO Corporation submitted a proposal for consideration under EPA's initiative Project XL. Project XL is a regulatory initiative of EPA to test new approaches to environmental management. Utilizing different apporaches, it is EPA's goal that greater environmental benefit will be realized, while reducing regulatory burdens and costs. HADCO's proposal 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 note 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. NYPRIG 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 NYPIRG.

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 NYPIRG can participate in this project.

Perry Walter
Environmental Specialist


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