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Lucent Technologies

Mesquite SEP Proposal

Lucent Microelectronics

XL Project One Page Program Description

Integration of New Regulations

Note: This is a SEP proposal which would be applicable to the Mesquite facility. The lessons learned would be applicable to all Lucent facilities.

Microelectronics proposes to create and test a system to optimize efficient integration of new regulations into the EMS and business planning cycles, which should, overall, speed and make less contentious the implementation process for new rules/regulations.

The first example of application of this concept will be to integrate a new directive from the Texas State Legislature into the operations of Lucent's Mesquite, Texas facility. The State of Texas, like many areas of the country, is struggling with attaining the air quality standards as required by the 1990 Clean Air Act Amendments. Until the current session of the Legislature, Texas state law exempted all NOx sources in operation prior to the passage of the Clean Air Amendments in 1990. However, in the face of growing concern over attainment of current standards, let alone new stricter requirements, the 1997 Legislature passed a law requiring the TNRCC to look at voluntary phase-out of the prior exemptions.

The Lucent Mesquite facility has four oil burners that supply heat and hot water to the manufacturing plant. These burners, which are seldom used, emit a total of 1.7 tons of NOx per year. They currently are exempted from any permitting requirements. As a superior environmental performance element in the Lucent XL Project, the Mesquite facility will design a program and schedule to voluntarily combine these emissions into its facility-wide consolidated permit and manage and control these emissions as any other environmental aspect identified under the EMS. In so doing the Company will demonstrate the efficacy of the EMS in identifying and managing all environmental impacts, regulated or not, and demonstrate how the EMS can ease implementation of new regulations.

Flexibility Required: The flexibility and efficiency associated with a consolidated permit is requested to achieve this SEP element.

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