HADCO

Audubon to HADCO

Audubon Society of New Hampshire

3 Silk Farm Road, Concord, NH 03301-8200
phone 603/224-9909 . fax: 603/226-0902

May 17, 1996

Lee Wilmot
Manager, Corporate SAFETY,
Health, and Environmental Affairs
HADCO Corporation
12A Manor Parkway
Salem, NH 03079

Dear Lee,

The Audubon Society of New Hampshire is pleased to be participating as a stakeholder in HADCO's Project XL. We have reviewed draft 4 of your "Final Project Agreement" and the following are our comments as you proceed with the task of re- drafting.

Our expertise as an organization does not extend very far into such matters as the chemical composition and treatment of industrial sludge. We do, however, wish to comment on an overarching public policy component of your proposal.

It seems clear to us that HADCO should not be seeking an unconditional delisting of its F006 sludge material. We agree with the general direction of the conversation at the April 17 stakeholder's meeting in Salem that a conditional delisting would best serve both HADCO's and the public's interest.

HADCO is clearly making a good faith effort here to find a way to both reduce costs and environmental hazard, and to more efficiently turn an industrial waste into a useful by-product. It is our view that this good faith effort will be undermined by an insistence on unconditional delisting. The consequence of such an insistence will likely be a public perception that the Project XL process is being used to short-circuit the more onerous usual delisting process, and that HADCO could, one delisting is obtained, simple withdraw from Project XL, reaping the economic benefits without providing the promised environmental results.

We have no doubt that this is not the intention of HADCO. But if a conditional delisting will provide -- as we believe it will -- economic benefits equal to those obtainable from an unconditional delisting, and if public support and enthusiasm for the effort can be improved and sustained by seeking a conditional delisting -- and, speaking for our organization, it will -- then we believe the proper course is clear. There is simply too much the uninitiated public does not know about the arcane topic of hazardous waste for there to be easy comfort in suddenly calling a formerly hazardous waste something else.

Thanks for including us in this innovate undertaking, Lee. We congratulate HADCO for its leadership in trying something new.

Sincerely yours,

/s/
Kirk Stone
Environmental Affairs Director

HADCO

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