HADCO

EPA to HADCO Letter (to Lee Wilmot)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20640

OFFICE OF POLICY, PLANNING AND EVALUATION

AUG 14 1996

Lee Wilmot
Corporate Safety, Health & Environmental Manager
HADCO Corporation
12A Manor Parkway
Salem, NH 03079

Dear Mr. Wilmot:

EPA has reviewed the latest Final Project Agreement (FPA) revision, including your August 5, 1996 submittal. HADCO, EPA, States, and stakeholders have invested a great deal of time and energy in coordinating this project and developing this FPA. EPA believes that an XL pilot to test the direct recycling of HADCO's WWTP sludge makes sense. However, we have concluded that the FPA, in its current form, does not meet the basic XL criterion for demonstrating superior environmental performance. The FPA also poses other, though less serious, problems with regard to other XL criteria. We believe that these can be addressed through more information than HADCO's efforts to date.

In its original proposal, HADCO suggested several means to achieve XL's superior environmental performance criterion. These include benefits from reduced transportation of waste, installation of sludge driers, and recycling of copper dust. Each of these poses potential problems for EPA. EPA does not believe that the benefits associated with sludge driers and reduced transportation costs are substantial relative to what would otherwise occur absent an XL project. While recycling of copper dusts could produce significant environmental benefits innovatively, the FPA does not specify the necessary implementation steps or provide an adequate means to identify the potential benefits and risks.

As in all XL projects, it is the responsibility of the project sponsor to demonstrate, as transparently as possible, the superior environmental benefits anticipated from the project. However, we would like to suggest an approach that would allow us to move forward. We propose that HADCO a) submit an analysis up front regarding potential cost savings if the delisting/variance is granted (which is useful also in satisfying the XL criterion regarding quantification of anticipated cost savings), and b) submit options for environmentally beneficial projects into which a portion of these cost savings could be invested.

Some examples of generic environmental benefits that HADCO might explore are: substituting a toxic chemical used at a HADCO facility with a nontoxic chemical; wastewater segregation; on-site solvent recovery; a "green lights" energy efficiency initiative; or accelerated compliance with a new environmental regulation (i.e., new CAA MACT rules). If HADCO prefers to pursue environmental benefits included in its original proposal, it must offer a clear analysis of these benefits that includes a method for EPA, States and stakeholders to very and quantify such benefits.
As you know, another important XL criterion is stakeholder involvement. We request that HADCO provide a summary of its efforts to date to involve local stakeholders in the NH, CA and NY negotiations, as well as a plan to involve stakeholders in the implementation phase of the project. While EPA is encouraged that HADCO has been able to identify a number of national and local stakeholders who have participated in stakeholder negotiation meetings, we would like to understand the geographic distribution and level of participation of the stakeholders. Also, to maintain a complete public record and to be better able to respond to inquiries regarding this process, EPA will need the full addresses and phone and fax numbers of involved stakeholders.

Finally, EPA would like data demonstrating potential transferability of the project to be printed circuit board industry. You have stated that metal hydroxide sludge generated by the printed circuit board industry is currently landfilled or disposed of by some other means, rather than being recycled. If data exist to verify this assumption, their incorporation into the FPA would further support EPA's approval.

EPA would like to proceed with internal routing of the FPA for concurrence, but cannot do so until the FPA clearly defines the project's anticipated superior environmental performance. Quantification of the potential cost savings, elaboration on potential transferability, and clarification of the extent of stakeholder involvement in the FPA negotiations and project implementation will also strengthen the project. With mutually agreeable changes in place, EPA would proceed with public notice of your intent to sign the FPA.

Please fee free to contact Lisa Hunter of my staff at (202) 260-4744, Joan Jouzaitis of EPA Region 1 at (617) 565-9000, or contact me personally. All of us at EPA look forward to resolving these issues quickly.

Sincerely,

/s/ Jon
Jon Kessler, Director
Emerging Sectors and Strategies Division
for the HADCO Project XL Team

cc: Jouzaitis, Region 1
Donnelly, Region 2
Linder, Region 9
Marschener, NHDES
Moroukian, NYSDEC
Nadler, NYSDEC
Murchison, CaDTSC
Hunter
Forehlich
Lund
Gardiner

HADCO

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