HADCO

Jon Kessler (EPA) to Larry Bolch
Larry W. Boldt
Regional Manager
Southern Water Treatment Co., Inc.
2806 White Horse Road
Greenville, SC 29611

Dear Mr. Boldt:

Thank you for your electronic mail message to Administrator Browner on January 14, 1997, regarding HADCO Company's proposal under our Project XL program. You asked whether Project XL might be applicable to your company and what you can do to have F006 sludge de-listed as a hazardous waste under the Resource Conservation and Recovery Act (RCRA).

I applaud your work toward pollution prevention through your sludge take-back and recycling program. Your specific ideas on how the Regulatory System can be improved to encourage additional activities of this kind are welcomed. This spirit of innovation would serve as a solid basis for developing a proposal under the Project XL program. EPA seeks XL applications from regulated entities that propose plans for superior environmental benefits in exchange for any regulatory flexibility that would be needed to implement such plans. I have included an informational package that describes the application process and general information on the program and current XL projects. Representatives from your company should feel free to contact EPA to discuss project ideas or XL program concepts prior to developing an XL proposal.

With regard to F006 sludge, EPA is considering alternative means to handle such wastes from two different perspectives. First, HADCO's XL project will test an alternative to EPA's traditional hazardous waste de-listing process by using a more tailored set of testing protocols to determine whether the waste may safely be sent directly for reclamation. If EPA determines that this may be appropriate for HADCO's sludge, HADCO may be granted a "conditional delisting" -- a delisting that will be granted and remain in effect only on the condition that such waste is in fact recycled. The purpose of this and all XL projects is to determine whether such an approach is successful and, if so, whether this approach should be transferred to other regulated entities outside of XL. EPA will thus consider transferring the conditional-delisting concept to other entities handling F006 sludges once the results of HADCO's projects can be evaluated.

Second, a federal advisory committee made up of local and national stakeholders, EPA and State/local regulators, and private-sector members of the Metal Finishing Sector under EPA's Common Sense Initiative (CSI) is also considering a variety of issues pertaining to F006 sludges. EPA is committed to considering the recommendations pertaining to F006 sludges that arise from this group in order to develop a common sense approach to handling these materials.

For more information on the work being conducted by the CSI Metal Finishing Sector, please contact Ms. Doreen Sterling at (202) 260-2766. If you have further questions pertaining to Project XL or F006 sludges, please feel free to contact Lisa Hunter of my staff at (202) 260-4744, or any of the contacts listed in the enclosed package. Thank you for your interest in the environment.

Sincerely,

Jon Kessler, Director
Emerging Sectors and Strategies Division

Enclosure

HADCO

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