Jump to main content.

Project XL Logo


Lee Wilmot to Jon Kessler RE: HADCO XL FPA (Attachments: letter to Richard de Seng, et al. 10/29/96)

State of New Hampshire
6 Hazen Drive, P.O. Box 95, Concord, NH 03302-0095
603-271-3503 FAX 603-271-2867
TDD Access: Relay NH 1-800-735-2964

September 23, 1996

Ms. Lisa C. Lund
Deputy Assistant Administrator for Project XL
Office of Policy, Planning and Evaluation
U.S. Environment Protection Agency
401 M Street, SW (2126)
Washington, D.C. 20460

Dear Ms. Lund:

I am writing this letter to express my deep concern over the lack of clear EPA regional consensus and direction on a draft Final Project Agreement (FPA) involving the Project XL initiative for HADCO Corporation (HADCO). HADCO's project involves facilities in three EPA regions (I, II, IX) and three different states (New Hampshire, New York, California); EPA Headquarters, and various stakeholder groups in those states. HADCO's application was one of the first pilot projects accepted into the Project XL process last November for seeking an expedited delisting process for a listed hazardous waste sludge. Since that time, HADCO has conducted numerous stakeholder meetings, video and teleconferences seeking the resolution of issues prior to submitting a final FPA to EPA Headquarters in August.

Upon reaching what was generally believed to be a consensus position among the parties during the last XL teleconference call on August 1, 1996, HADCO received a "back to square one" type letter dated August 14, 1996 from Jon Kessler, Director of the Emerging Sectors and Strategies Division requesting additional basic items in the FPA (Attachment 1). The issues associated with the requested items are of a kind that EPA should have been asking about very early in the project selection process or certainly during the many meetings that followed over the past year.

My staff informs me that Region IX is expressing the most difficulty in agreeing to the final FPA as currently written. Therefore, I am requesting your immediate assistance in resolving the outstanding issues to allow the FPA to reach the signing stage. The actual implementation of the FPA will require HADCO to conduct significant data and information collection to substantiate the merits of the proposed environmental benefits and cost savings associated with their Project XL proposal.

If we cannot get beyond the FPA signing, a year's worth of effort will have been lost by everyone before the initial attempt is made to demonstrate whether or not this XL project has the environmental benefits listed in the FPA. Given the intent of Project XL and other initiatives designed to enhance environment performance, it would seem to me that we are now vulnerable to the criticism of snatching defeat from the hands of victory. It would be a shame and perhaps a fatal loss in the credibility of government's efforts to apply common sense to meeting our various responsibilities.

Please do not hesitate to call me (603 271-4974) or Ken Marschner of our Waste Management Division (603 271-2943) should you have any questions about my comments. We expect the successful conclusion to this FPA process and the entire XL project and ask for your assistance in reaching this goal.


/s/ Robert W. Varney
Robert W. Varney


Attachment 1

cc: Lee Wilmot, HADCO w/o attachment
Joan Jouzaitis, EPA-New England w/o attachment
Kate Donnelly, EPA Region II w/o attachment
Steve Linder, EPA Region ix w/o attachment
Larry Nadler, NY DEC w/o attachment
Gary Murchison, CA EPA w/o attachment

Local Navigation

Jump to main content.