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Lucent Technologies

Letter to Maslany from Hennelly

July 31, 1997

Tom Maslany,
Division Director Water Protection Division
U.S. Environmental Protection Agency, Region III
841 Chestnut Street Building
Philadelphia, PA 19107

Dear Mr. Maslany:

Thank you, and please thank the Regional and Headquarters members of the EPA project working group, for the very productive meetings held earlier this week.

While this project has had its ups and downs, we feel we're very much back on track to complete what our president, Curt Crawford, began nearly two years ago at the White House. We believe it is very important for Project XL that as many of the original XL companies as possible complete signed FPA's. We believe the time has come for companies to internalize the values of Superior Environmental Performance into their business planning. It's an idea whose time has clearly come.

Yet, we in the business community need a critical mass of companies to get through processes such as XL in order to jump start the long term engine that will move us to sustainability. The success of the first year of our EMS under Project XL has clearly demonstrated the superior progress we can make. We believe that together as a project team, we can help this model reach its full potential and transfer its lessons and strengths broadly.

In the short time we had Tuesday, we only briefly covered the substantive elements of our matrix, which would be the basis of our expanded FPA. We did not address at all (and I understand you barely touched on them Monday) the questions that will need to be explored as we implement not just the consolidated permit concept but also the key matrix programs such as the new regulatory integration, water trading, maintenance of air and waste gains and other elements. We did not have time to address the details of what might be required to implement the requested flexibilities. That would take several hours.

What I would like to suggest as an immediate next step is that we meet as an entire working group in Philadelphia or Washington to brainstorm, prioritize and detail the expanded program. We have a great deal of additional information that I think would be very helpful to you. Your perspectives and experiences as well as those of the state regulators would be of great help to us and perhaps would help us to refine or prioritize our project. Most importantly, I believe a session like this. on the substance of our project.would be mutually beneficial and provide us both helpful perspectives on environmental innovation.

I have attached a very rough potential agenda just to illustrate what we might cover in such a workshop. XL is very important to us for many substantive reasons. But most importantly, it is a program and a set of SEP values to which our most senior Microelectronics management made a business-wide commitment.

We began it at the White House. We have committed significant time and monetary resources to following through on these values. We await your suggest about when when we might schedule a workshop and to working with you to complete this critical effort.

Again, thanks for your help and courtesy.


Debra Sabatini Hennelly


cc: Erik Meyers
Bob Barkanic
Andrew Neblett

Microelectronics XL Project
A Project Workshop Agenda Ideas Purposes of the Workshop:

1. Review and understand expanded FPA elements (from the matrix)

2. Identify and discuss the details, performance and implementation of the SEP issues and flexibilities associated with each element.

3. Begin identifying and discussing the critical questions associated with each element.

4. Prioritize the programs (there are several ways to do this).

5. Brainstorm the FPA and the structure of the elements within it. Rough Agenda 8:30 AM Welcome, Introductions, review of agenda 8:45 Overview of project elements 9:00 Overview of flexibilities & efficiencies 9:15 The key programs: detail, issues, questions, precedents, flexibilities, priorities, schedules for implementation, FPA structure

A. The consolidated permit concept (facility specific/business-wide) 1. Existing permits/requirements 2. Issues related to facility specific consolidation 3. Issues related to business-wide consolidation

B. Maintaining environmental performance gains/continuous improvement, production unit factors 1. The Microelectronics record 2. Issues for future performance 3. New measures 4. Programs & flexibilities to achieve commitements

C. CAPs, trading (air, water)

D. The integration of pollution prevention, DfE and Life Cycle Management into normal business planning (elements that include: the product family life cycle analyses, integration of product design, the Texas pollution prevention analysis, indicators of success)

E. The integration of worker safety (the SMS - Safety Management System)

F. Transferability initiatives (supplier/contractor/small business programs) Microelectronics XL Project A Project Workshop Agenda Ideas (con't)

G. Integration of new regulations into the EMS, pollution prevention, facility upgrades and expansions, DfE 11:00 Basic SEP commitments unrelated to key elements (air, water, waste) 11:30 Programs that develop success measures & performance indicators that are new to XL (P2 & DfE measures, SEP indicators) 12:00 PM Lunch 1:00 Reporting & Accountability programs

A. Setting an electronic reporting standard

B. Coordinating with Center for Environmental Information & Statistics

C. Dealing with accountability in an EMS where Objectives & Targets are the standards 1:45 Structure of the FPA

A. General FPA design brainstorming (we have ideas, but they need review and discussion)

B. Questions answerable and programs achievable in the short term (facility specific consolidated permit, Allentown NPDES, potential Allentown copper trading program)

C. Questions answerable and programs achievable in the long term (new reg integration, business-wide consolidated permit, maintaining gains in the face of growth, moving to sustainability) 2:30 Stakeholder involvement, community participation, transparency and ease of understanding for the public 3:15 Next steps, followup 4:00 Adjourn

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