Lucent Technologies

Critical Elements Matrix

Lucent Technologies, Microelectronics Group

XL Elements Phasing Summary--

DRAFT Draft:

September 8, 1997

Element Number FPA Category/Proposed Element

SUPERIOR ENVIRONMENTAL PERFORMANCE ELEMENTS

SEP-1 Energy Use/Greenhouse Gas Reductions
Microelectronics will reduce energy use between 1997-2000 by roughly 6.67% even as the company grows, and reduce annual greenhouse gas emissions between 1997 and 2000 by 50,000 mt/year.

SEP-2 VOC Reduction (Mesquite)
Microelectronics will work with the TNRCC to reduce VOC emissions beyond the 15-20 tpy reduction program now under way.

SEP-3 VOC Reduction (Reading)
Microelectronics will use the funds saved as a result of the sludge de-listing in Reading to reduce VOC emissions by as much as 50-60 tpy.

SEP-4 Voluntary inclusion Mesquite NOx source as test of new reg integration
The Mesquite facility is in full air compliance. However, as a test of new techniques to optimize integration of new regulations, Microelectronics will evaluate a TNRCC program to voluntarily comply with the performance intent of BACT requirements on Texas boilers which presently are grandfathered from NOx BACT regulations.

SEP-5 Water conservation and reduction of loadings
Microelectronics will form a cross location Microelectronics Water Team and reduce business-wide water consumption by 20% (actuals, FY96) in FY98 and reduce total loadings by up to 50%. Microelectronics will improve the 7% reduction of 1996 by focusing on four technology areas: 1)Generation & Distribution of Sft, DL, and Ultra-Pure Water in Allentown, Orlando and Reading; 2) Physical Plant Operations in Allentown; 3) Manufacturing process at all facilities; and, 4) Wastewater Treatment Plant & Effluent Management in Reading. Examples of projects include optimization of IX, RO and chemical processes and recycling of high purity bleeds. Recycling of bleed and degasification effluent would occur at Allentown and save an estimated 457,000 GPD. Recovery of process effluents for secondary uses such as soft water, cooling towers, and scrubbers would save about 300,000 GPD at Orlando.

SEP-6 Wastewater Reduction (Reading)
Microelectronics will reduce water usage at Reading by about 38,000 gpd. This will be accomplished through optimization of chemical processes, alternative treatment or handling approaches and a recycle of treated effluent for lime mixing at the waste treatment plant.

SEP-7 Elimination of Non Process CFCs
Microelectronics will develop by 4Q FY98 a strategy to eliminate the use of non-process CFCs by 2003 and include in 1999 SSO.

SEP-8 Acid Reuse & Reduction
By 4Q FY 98 Microelectronics will quantify acid usage and associated processes by location and develop reuse/reduction projects for inclusion in FY99 program.

SEP-9 Chemical Use Reduction
By 3Q FY98, compare all chemicals now in use at Microelectronics against the Chemicals on Reporting Rules (CORR) list and other global lists and determine strategy for chemicals with constraints. Determine method for automating process.

Element Number FPA Category/Proposed Element

SEP-10 Chemical Tracking Systems
By 4Q FY98, Microelectronics will improve chemical tracking systems across all facilities, particularly by use of the SAP/Oracle system, to more accurately and consistently identify business-wide chemical use. Microelectronics will prepare evaluation of tracking system impact on chemical management processes.

SEP-11 80% PFC Emissions Reduction
Microelectronics will reduce the emissions of PFCs and PFC by-products throughout Microelectronics worldwide through source reduction, substitution, recycle or, as a last resort, destruction. Actions include: 1) 1Q FY98 identify costs associated with modifying existing exhaust systems to accommodate emission reduction equipment; 2) 1Q FY98 beta-test Air Products C2F6 recovery system; 3) 3Q FY98 evaluate chemical alternatives and abatement; 4) 3Q FY98 work with World Semiconductor Council to promote world-wide semiconductor industry PFC emissions redutions; 4) 3Q FY98 prepare and submit PFC emission data; 5) identify choices for PFC emission reduction.

SEP-12 70% Waste Paper Recycling
Microelectronics will recycle at all locations, at least 70% of waste paper.

SEP-13 Manufacturing Waste Reduction
Microelectronics will attempt to maintain or reduce environmental gains even as the company grows. This is a stronger concept than the production unit continuous improvement concept pioneered by Intel. It is the maintenance of absolute numbers, which requires significant continuous improvement if growth is significant. For example, in 1987, Microelectronics generated 45.85 million pounds of manufactured process waste. In 1995, the Division generated 16.1 million pounds. In 1996, despite a 16% growth rate in business activity, Microelectronics kept manufactured wastes at 16.7 million pounds, an increase of less than 3.75%. At the same time, as indicated earlier, production unit metrics will be developed. However, the committed goal is maintenance of absolute gains.

SEP-14 Decommission Waste Management Equipment
Though frequently overlooked by the system, decommissioned equipment represents a significant potential for environmental contamination. By 3Q FY 98, Microelectronics will develop a consistent process for managing the decommissioning of equipment business-wide. Included will be an evaluation component to allow reporting on the Microelectronics XL website. Implementation of the system will be included in FY99 program.

SEP-15 Air Emissions Gains
Microelectronics will attempt to maintain environmental gains even as the company grows. This is a different concept than production unit continuous improvement pioneered by Intel. It is the maintenance of absolute numbers, which requires significant continuous improvement if growth is significant. In 1987, Microelectronics had toxic air emissions of 5.78 million pounds. In 1996, those emissions were 0.044 million pounds despite a very large growth rate. At the same time, as indicated earlier, production unit metrics will be explored. However, the goal is maintenance of absolute gains.

SEP-16 Covering Non-regulated Substances/Issues
There are no bounds on what can be included in the annual process of identifying Significant Environmental Aspects and then developing Objectives & Targets and Environmental Protection Plans. Therefore, goals for non-regulated issues, and the continuous improvement of those goals, would be included.

Element Number FPA Category/Proposed Element

SEP-17 1.5 million gpd avoidance of water consumption (Allentown)
Allentown uses about 3.5 million gallons per day of city water (17% of total daily supply). Approximately 0.1 MGD is used by the facility for domestic purposes and discharged to the City treatment works. Most of the remaining 3.4 MGC is purified for use within the facility by using water softening deionization, and other processes. Cooling tower evaporation/carryout and other miscellaneous losses amount to about 0.2 MGD. Discharge to the Lehigh River is about 3.2 MGD, 1.7 MGD of this as treated manufacturing effluent from the on-site waste treatment plant (WTP). Microelectronics proposes to implement through the EMS a water improvement and conservation program using the specific projects listed on Attachment A. The result of all these projects would be a reduction in water usage by 50%.

SEP-18 Total Loadings Reduction of up to 10,000 lbs/day to the Lehigh River
Microelectronics will reduce hydrochloric acid and sodium hydroxide, WTP effluent flow and TDS discharge by up to 50%.

SEP-19 Reduce Hazardous Waste (Mesquite)
Microelectronics Mesquite has reduced hazardous waste by 50% as part of Texas Clean 2000. Microelectronics Mesquite will work through XL and the EMS to reduce hazardous waste further.

SEP-20 Explore Transboundary Issues (Matamoros)
Through the EMS, and the inclusion of Matamoros in XL, Mesquite and the TNRCC will work to identify and manage these issues.

SEP-21 Design SEP Indicators
Microelectronics will create a broad range of SEP/continuous improvement indicators specific to its company and covering regulated and non-regulated issues. Such indicators are designed to allow a more accurate measure of whether a company is achieving its goals and continuously improving its environmental performance on a production unit basis. This allows regulators and the community to understand whether a company is improving even as production increases. This disclosure is a significant incentive for companies to achieve continuous improvement, which itself is a significant SEP accomplishment. Intel has developed a production unit measure for air. Microelectronics may use a similar measure for air, or may develop a new indicator. Additionally, Microelectronics will work for the implementation of the project to create and test indicators for water quality, water use, chemical and waste recycling and reuse and other Aspects. Microelectronics with regulators also will work to create a single Group-wide indicator, though this may prove to be technically impossible. The exercise will add valuable insight into the form and use of SEP indicators. Many of these indicators, particularly those related to pollution prevention, will be piloted at the Mesquite facility.

SEP-22 Pollution Prevention/DfE Program
During the development of the EMS, in which various regulators participated under Project XL, it was decided to include product and process design staff directly on key EMS committees. This allows regulators direct input to product and process designers, the lack of which was an issue in the Intel project. It also allows full integration of pollution prevention/DfE into the EMS system. This directly adds product and process design changes as methods for meeting EMS Objective & Targets. Specific tasks are establishing Microelectronics DfE Executive Team by 1Q FY98, conducting Life Cycle Analyses on 2 product families by 2Q FY98, developing and institutionalizing Process Environment & Safety Evaluation tools by 2Q FY98, and developing the DfE tool platform by 4Q FY 98.

Element Number FPA Category/Proposed Element

SEP-23 Pollution Prevention/DfE Measurement & Evaluation
There is no question that pollution prevention/DfE are the most efficient and effective ways to eliminate pollution and other environmentally undesirable effects of economic activity. Yet, pollution prevention/DfE represent "avoidance" rather than a "fix". While that is good, it has been tough to measure and, therefore, it has been difficult to show the results of a pollution prevention/DfE program (hence penalizing P2/DfE as an approach). Microelectronics proposes to develop one or more metrics or processes to measure the results of pollution prevention efforts, testing it on Microelectronics' own programs.

SEP-24 Pollution Prevention/DfE Risk Minimization
The PESE program would look both to the past and to the future protection of the environment and workers. A Quality Improvement Team will design a database tool to evaluate the environmental and worker safety issues associated with Microelectronics manufacturing processes. The immediate benefits are changes to how Microelectronics equipment is operated. The long term benefits would lie both in process changes and in more effective identification of environmental "Aspects" associated with equipment and manufacturing processes. Such knowledge would be integrated into process design and result in fundamental DfE changes.

SEP-25 Pollution Prevention/DfE Life Cycle Management
In the electronics industry, continual and fast moving technology advances that many times occur in only small components of larger systems make end of product considerations extremely important. Product recycling and eventually product take-back may dramatically improve environmental results. Microelectronics will form a Quality Improvement Team (QIT) to integrate these considerations into the pollution prevention/DfE program.

SEP-26 Pollution Prevention Assessment (Mesquite)
Microelectronics will work with TNRCC to complete a full pollution prevention assessment for all media at the Mesquite facility in early 1998.

SEP-27 Worker Safety Management
Microelectronics will develop a SEP worker safety program similar to the EMS to reduce worker exposure to environmental and other hazards. The goal is by the Year 2000 to have 95% of Microelectronics products, services, operations and facilities covered by the Safety Management System (SMS). Business-wide, as well as facility-specific Objectives & Targets will be established.

SEP-28 Gas Cylinder Handling Guidelines
By 3Q FY 98 Microelectronics will form a Quality Improvement Team to investigate and prepare a guidance to aid users of hazardous gases and liquids in deployment of consistent programs to handle containers and improve processes for dealing with potential leaks. A success measurement metric will be developed.

SEP-29 Environmental Awareness Employee Training
Since few environmental programs outside pollution prevention are successful unless they are implemented by knowledgeable workers who understand environmental management and ethics, Microelectronics will work with employees to implement Behavior Management and Environmental Awareness Training at all Microelectronics facilities. Four pilots will be conducted and all employee positions covered by 4Q FY98. Additionally, ISO 14001/environmental awareness training will be incorporated into the Microelectronics International University curriculum by 4Q FY98.

Element Number FPA Category/Proposed Element

SEP-30 Continuous Improvement Objectives & Targets
Because Microelectronics will use the Objectives & Targets (Group Level and Facility Specific) from its EMS, which are updated and expanded annually, as the basis for its traditional SEP elements, it introduces the opportunity for continuous improvement in SEP programs.

SEP-31 Transferability/International Facilities
The Microelectronics XL project will bring in for the first time international as well as domestic facilities because: 1) the Objectives & Targets will be included by reference in the FPA; 2) because the EMS is being made applicable to all Microelectronics facilities; and, 3) regulators sit on the committees and attend the meetings at which Facility Specific and Group Objectives & Targets are considered.

SEP-32 Supplier/Contractor/Small Business Management & Assistance
Microelectronics will create incentives for supplier adoption of EMS and SEP programs, including reviewing the Microelectronics list of approved suppliers. Additionally, all on-site contractors will be required to have specific EH&S plans for activities on Microelectronics property.

SEP-33 Trading Options
This is included as a SEP item rather than a flexibility/efficiency (though some flexibilities may be required) because a net environmental benefit would be sought within the same media and same pollutants for such a program. The program to be developed through the EMS only under the XL project would test trading on three levels: 1) within Microelectronics; 2) within Lucent; and, 3) within non-related facilities in a local ecosystem. The trading would be contingent upon both parties having not just an ISO 14001 EMS, but an EMS that meets minimum Microelectronics standards (most importantly in the community involvement arena), which would be developed through the EMS.

SEP-34 Integrating New Regulations
Over the implementation of the FPA, Microelectronics will create and test ways to better integrate the new regulation process into normal EMS and business planning cycles. If such a system can be crafted (this will take time with regulators and the community), it should reduce costs to business by allowing regulations to be considered during times of normal facility upgrade and expansion. It should speed the integration process by allowing the earliest possible consideration of potential regulations in the product and process design and business planning cycles.

SEP-35 Drive to Sustainability and the "Permitless" Company
This concept would drive the company to performance goals that fall below regulatory thresholds for all media, essentially eliminating the necessity for regulatory involvement at such facilities. As experience is gained, such goals would be considered as Objectives & Targets.

SEP-36 Accountability, Reporting, and Enforcement Models
This is probably a combination of SEP, "flexibility" and "efficiency". These issues have been discussed in all other XL projects, but would be particularly important here, where a new consolidated, continuous improvement permit is being developed. The issue to be tested is simply how would a business-wide EMS permit be administered.

Element Number FPA Category/Proposed Element

SEP-37 Enhanced Electronic Reporting (Mesquite)
Electronic Reporting is very important to simplification, consolidation and transparency of reporting. This effort will focus not just on the reports going to the public but on a specialized internal system to get critical information, including that related to pollution prevention/DfE, to all workers.

SEP-38 Transparency across Environmental Programs
Because regulators are involved on the EMS committees and in the EMS meetings that develop the Objectives & Targets, and the community is involved in the LEAGs which give input on SEP, Significant Environmental Aspects and Objectives & Targets, they can influence continually the direction of SEP at Microelectronics.

SEP-39 Community Involvement/Website
The proposed new Microelectronics Project XL website will advance significantly public disclosure and interactive communications about environmental management. The site will publish Objectives & Targets, XL reports, performance reports, LEAG minutes and other project documentation. Additionally, its interactive capability will allow continuing community comment, take questions and allow "chats" about the Microelectronics XL project. It will also have e-mail "blast" capabilities to facilitate community notice.

SEP-40 Transparency of Environmental Programs to Employees
By 1 Q FY98, Microelectronics will move environmental documentation to its Intranet to foster employee knowledge of all aspects of the EHS, SHS, PESE including reporting.

SEP-41 Internal Audit Protocols
Microelectronics will develop and install computerized programs to foster improved internal performance and better monitor business-wide compliance with all rules and regulations and SEP programs.

SEP-42 LRQA Audits
Microelectronics will continue semi-annual LRQA audits, in addition to internal, employee conducted audits to ensure SEP compliance and will report results related to SEP programs.

FLEXIBILITY ELEMENTS

F-1 Continuous Improvement Approval of EMS: On the path to a "permitless" company (see element #33), Microelectronics requests that all permits (all media) for domestic facilities be consolidated over a period of time into a single Microelectronics-wide, consolidated, multi-media permit beginning first at the facilities and ultimately moving business-wide. This would require the consolidation of all Federal and state permits (all media) into a single permit based upon its Objectives & Targets. Objectives & Targets would be developed in conjunction with regulators annually, providing essentially an annual review of the permit, a significant improvement over the present system of multi-year renewals.

Element Number FPA Category/Proposed Element

F-2 Streamlined process for incorporating new flexibilities/efficiencies
As Microelectronics, regulators and community members (through the LEAGs or website) are jointly identifying Significant Environmental Aspects and developing Objectives & Targets and Environmental Protection Plans, there will arise probably fairly frequently opportunities to get a "bigger bang for the environmental protection buck." For example, it may be appropriate for the Allentown Facility to partner with a non-Lucent facility in the same city to achieve larger reductions of an air or water pollutant. It is important to identify a process less complex than a new XL process as this happens and as the group as a whole decides it is necessary. Achieving it will require work and discussion not just during both FPA finalization and implementation. Microelectronics already is beginning the process of identify and cataloging all the relevant Federal, state and local permits. It is unclear yet whether this will require flexibilities or efficiencies, but probably it will require both because, for example, of the need to adjust renewal requirements.

F-3 Consolidation of reporting requirements: Lucent proposes a consolidation of business-wide reporting requirements to simplify them for the company and the public, to make the job of regulators easier and to make reports more consistent across the business. There are three levels of action which may require flexibilities and efficiencies: 1) consolidation of requirements; 2) simplification of requirements; and, 3) consistency of requirements. There is some precedent in other XL projects and other EPA initiatives for the first two. Microelectronics is presently studying these. Relative to the third, consistency, Microelectronics proposes not only to make the requirements consistent, where possible, business-wide, but also make the requirements fit with other EPA efforts, such as the Center for Environmental Information and Statistics (Microelectronics would propose it develop a model for the Center), in order to make easier and more timely the provision of state, regional or national environmental data.

F-4 Sludge de-listing, Reading & Allentown

F-5 Flexibility on NPDES concentration limits in Allentown

F-6 Rolling NPDES in Allentown

F-7 Consolidation of permits in Mesquite

Element Number	FPA Category/Proposed Element
	SUPERIOR ENVIRONMENTAL PERFORMANCE ELEMENTS
SEP-1	Energy Use/Greenhouse Gas Reductions Microelectronics will reduce energy use between 1997-2000 by roughly 6.67% even as the company grows, and reduce annual greenhouse gas emissions between 1997 and 2000 by 50,000 mt/year.
SEP-2	VOC Reduction (Mesquite) Microelectronics will work with the TNRCC to reduce VOC emissions beyond the 15-20 tpy reduction program now under way.
SEP-3	VOC Reduction (Reading) Microelectronics will use the funds saved as a result of the sludge de-listing in Reading to reduce VOC emissions by as much as 50-60 tpy.
SEP-4	Voluntary inclusion Mesquite NOx source as test of new reg integration The Mesquite facility is in full air compliance. However, as a test of new techniques to optimize integration of new regulations, Microelectronics will evaluate a TNRCC program to voluntarily comply with the performance intent of BACT requirements on Texas boilers which presently are grandfathered from NOx BACT regulations.
SEP-5	Water conservation and reduction of loadings Microelectronics will form a cross location Microelectronics Water Team and reduce business-wide water consumption by 20% (actuals, FY96) in FY98 and reduce total loadings by up to 50%. Microelectronics will improve the 7% reduction of 1996 by focusing on four technology areas: 1)Generation & Distribution of Sft, DL, and Ultra-Pure Water in Allentown, Orlando and Reading; 2) Physical Plant Operations in Allentown; 3) Manufacturing process at all facilities; and, 4) Wastewater Treatment Plant & Effluent Management in Reading. Examples of projects include optimization of IX, RO and chemical processes and recycling of high purity bleeds. Recycling of bleed and degasification effluent would occur at Allentown and save an estimated 457,000 GPD. Recovery of process effluents for secondary uses such as soft water, cooling towers, and scrubbers would save about 300,000 GPD at Orlando.
SEP-6	Wastewater Reduction (Reading) Microelectronics will reduce water usage at Reading by about 38,000 gpd. This will be accomplished through optimization of chemical processes, alternative treatment or handling approaches and a recycle of treated effluent for lime mixing at the waste treatment plant.
SEP-7	Elimination of Non Process CFCs Microelectronics will develop by 4Q FY98 a strategy to eliminate the use of non-process CFCs by 2003 and include in 1999 SSO.
SEP-8	Acid Reuse & Reduction By 4Q FY 98 Microelectronics will quantify acid usage and associated processes by location and develop reuse/reduction projects for inclusion in FY99 program.
SEP-9	Chemical Use Reduction By 3Q FY98, compare all chemicals now in use at Microelectronics against the Chemicals on Reporting Rules (CORR) list and other global lists and determine strategy for chemicals with constraints. Determine method for automating process.

Element Number	FPA Category/Proposed Element
SEP-10	Chemical Tracking Systems By 4Q FY98, Microelectronics will improve chemical tracking systems across all facilities, particularly by use of the SAP/Oracle system, to more accurately and consistently identify business-wide chemical use. Microelectronics will prepare evaluation of tracking system impact on chemical management processes.
SEP-11	80% PFC Emissions Reduction Microelectronics will reduce the emissions of PFCs and PFC by-products throughout Microelectronics worldwide through source reduction, substitution, recycle or, as a last resort, destruction. Actions include: 1) 1Q FY98 identify costs associated with modifying existing exhaust systems to accommodate emission reduction equipment; 2) 1Q FY98 beta-test Air Products C2F6 recovery system; 3) 3Q FY98 evaluate chemical alternatives and abatement; 4) 3Q FY98 work with World Semiconductor Council to promote world-wide semiconductor industry PFC emissions redutions; 4) 3Q FY98 prepare and submit PFC emission data; 5) identify choices for PFC emission reduction.
SEP-12	70% Waste Paper Recycling Microelectronics will recycle at all locations, at least 70% of waste paper.
SEP-13	Manufacturing Waste Reduction Microelectronics will attempt to maintain or reduce environmental gains even as the company grows. This is a stronger concept than the production unit continuous improvement concept pioneered by Intel. It is the maintenance of absolute numbers, which requires significant continuous improvement if growth is significant. For example, in 1987, Microelectronics generated 45.85 million pounds of manufactured process waste. In 1995, the Division generated 16.1 million pounds. In 1996, despite a 16% growth rate in business activity, Microelectronics kept manufactured wastes at 16.7 million pounds, an increase of less than 3.75%. At the same time, as indicated earlier, production unit metrics will be developed. However, the committed goal is maintenance of absolute gains.
SEP-14	Decommission Waste Management Equipment Though frequently overlooked by the system, decommissioned equipment represents a significant potential for environmental contamination. By 3Q FY 98, Microelectronics will develop a consistent process for managing the decommissioning of equipment business-wide. Included will be an evaluation component to allow reporting on the Microelectronics XL website. Implementation of the system will be included in FY99 program.
SEP-15	Air Emissions Gains Microelectronics will attempt to maintain environmental gains even as the company grows. This is a different concept than production unit continuous improvement pioneered by Intel. It is the maintenance of absolute numbers, which requires significant continuous improvement if growth is significant. In 1987, Microelectronics had toxic air emissions of 5.78 million pounds. In 1996, those emissions were 0.044 million pounds despite a very large growth rate. At the same time, as indicated earlier, production unit metrics will be explored. However, the goal is maintenance of absolute gains.
SEP-16	Covering Non-regulated Substances/Issues There are no bounds on what can be included in the annual process of identifying Significant Environmental Aspects and then developing Objectives & Targets and Environmental Protection Plans. Therefore, goals for non-regulated issues, and the continuous improvement of those goals, would be included.

Element Number	FPA Category/Proposed Element
SEP-17	1.5 million gpd avoidance of water consumption (Allentown) Allentown uses about 3.5 million gallons per day of city water (17% of total daily supply). Approximately 0.1 MGD is used by the facility for domestic purposes and discharged to the City treatment works. Most of the remaining 3.4 MGC is purified for use within the facility by using water softening deionization, and other processes. Cooling tower evaporation/carryout and other miscellaneous losses amount to about 0.2 MGD. Discharge to the Lehigh River is about 3.2 MGD, 1.7 MGD of this as treated manufacturing effluent from the on-site waste treatment plant (WTP). Microelectronics proposes to implement through the EMS a water improvement and conservation program using the specific projects listed on Attachment A. The result of all these projects would be a reduction in water usage by 50%.
SEP-18	Total Loadings Reduction of up to 10,000 lbs/day to the Lehigh River Microelectronics will reduce hydrochloric acid and sodium hydroxide, WTP effluent flow and TDS discharge by up to 50%.
SEP-19	Reduce Hazardous Waste (Mesquite) Microelectronics Mesquite has reduced hazardous waste by 50% as part of Texas Clean 2000. Microelectronics Mesquite will work through XL and the EMS to reduce hazardous waste further.
SEP-20	Explore Transboundary Issues (Matamoros) Through the EMS, and the inclusion of Matamoros in XL, Mesquite and the TNRCC will work to identify and manage these issues.
SEP-21	Design SEP Indicators Microelectronics will create a broad range of SEP/continuous improvement indicators specific to its company and covering regulated and non-regulated issues. Such indicators are designed to allow a more accurate measure of whether a company is achieving its goals and continuously improving its environmental performance on a production unit basis. This allows regulators and the community to understand whether a company is improving even as production increases. This disclosure is a significant incentive for companies to achieve continuous improvement, which itself is a significant SEP accomplishment. Intel has developed a production unit measure for air. Microelectronics may use a similar measure for air, or may develop a new indicator. Additionally, Microelectronics will work for the implementation of the project to create and test indicators for water quality, water use, chemical and waste recycling and reuse and other Aspects. Microelectronics with regulators also will work to create a single Group-wide indicator, though this may prove to be technically impossible. The exercise will add valuable insight into the form and use of SEP indicators. Many of these indicators, particularly those related to pollution prevention, will be piloted at the Mesquite facility.
SEP-22	Pollution Prevention/DfE Program During the development of the EMS, in which various regulators participated under Project XL, it was decided to include product and process design staff directly on key EMS committees. This allows regulators direct input to product and process designers, the lack of which was an issue in the Intel project. It also allows full integration of pollution prevention/DfE into the EMS system. This directly adds product and process design changes as methods for meeting EMS Objective & Targets. Specific tasks are establishing Microelectronics DfE Executive Team by 1Q FY98, conducting Life Cycle Analyses on 2 product families by 2Q FY98, developing and institutionalizing Process Environment & Safety Evaluation tools by 2Q FY98, and developing the DfE tool platform by 4Q FY 98.

Element Number	FPA Category/Proposed Element
SEP-23	Pollution Prevention/DfE Measurement & Evaluation There is no question that pollution prevention/DfE are the most efficient and effective ways to eliminate pollution and other environmentally undesirable effects of economic activity. Yet, pollution prevention/DfE represent "avoidance" rather than a "fix". While that is good, it has been tough to measure and, therefore, it has been difficult to show the results of a pollution prevention/DfE program (hence penalizing P2/DfE as an approach). Microelectronics proposes to develop one or more metrics or processes to measure the results of pollution prevention efforts, testing it on Microelectronics' own programs.
SEP-24	Pollution Prevention/DfE Risk Minimization The PESE program would look both to the past and to the future protection of the environment and workers. A Quality Improvement Team will design a database tool to evaluate the environmental and worker safety issues associated with Microelectronics manufacturing processes. The immediate benefits are changes to how Microelectronics equipment is operated. The long term benefits would lie both in process changes and in more effective identification of environmental "Aspects" associated with equipment and manufacturing processes. Such knowledge would be integrated into process design and result in fundamental DfE changes.
SEP-25	Pollution Prevention/DfE Life Cycle Management In the electronics industry, continual and fast moving technology advances that many times occur in only small components of larger systems make end of product considerations extremely important. Product recycling and eventually product take-back may dramatically improve environmental results. Microelectronics will form a Quality Improvement Team (QIT) to integrate these considerations into the pollution prevention/DfE program.
SEP-26	Pollution Prevention Assessment (Mesquite) Microelectronics will work with TNRCC to complete a full pollution prevention assessment for all media at the Mesquite facility in early 1998.
SEP-27	Worker Safety Management Microelectronics will develop a SEP worker safety program similar to the EMS to reduce worker exposure to environmental and other hazards. The goal is by the Year 2000 to have 95% of Microelectronics products, services, operations and facilities covered by the Safety Management System (SMS). Business-wide, as well as facility-specific Objectives & Targets will be established.
SEP-28	Gas Cylinder Handling Guidelines By 3Q FY 98 Microelectronics will form a Quality Improvement Team to investigate and prepare a guidance to aid users of hazardous gases and liquids in deployment of consistent programs to handle containers and improve processes for dealing with potential leaks. A success measurement metric will be developed.
SEP-29	Environmental Awareness Employee Training Since few environmental programs outside pollution prevention are successful unless they are implemented by knowledgeable workers who understand environmental management and ethics, Microelectronics will work with employees to implement Behavior Management and Environmental Awareness Training at all Microelectronics facilities. Four pilots will be conducted and all employee positions covered by 4Q FY98. Additionally, ISO 14001/environmental awareness training will be incorporated into the Microelectronics International University curriculum by 4Q FY98.

Element Number	FPA Category/Proposed Element
SEP-30	Continuous Improvement Objectives & Targets Because Microelectronics will use the Objectives & Targets (Group Level and Facility Specific) from its EMS, which are updated and expanded annually, as the basis for its traditional SEP elements, it introduces the opportunity for continuous improvement in SEP programs.
SEP-31	Transferability/International Facilities The Microelectronics XL project will bring in for the first time international as well as domestic facilities because: 1) the Objectives & Targets will be included by reference in the FPA; 2) because the EMS is being made applicable to all Microelectronics facilities; and, 3) regulators sit on the committees and attend the meetings at which Facility Specific and Group Objectives & Targets are considered.
SEP-32	Supplier/Contractor/Small Business Management & Assistance Microelectronics will create incentives for supplier adoption of EMS and SEP programs, including reviewing the Microelectronics list of approved suppliers. Additionally, all on-site contractors will be required to have specific EH&S plans for activities on Microelectronics property.
SEP-33	Trading Options This is included as a SEP item rather than a flexibility/efficiency (though some flexibilities may be required) because a net environmental benefit would be sought within the same media and same pollutants for such a program. The program to be developed through the EMS only under the XL project would test trading on three levels: 1) within Microelectronics; 2) within Lucent; and, 3) within non-related facilities in a local ecosystem. The trading would be contingent upon both parties having not just an ISO 14001 EMS, but an EMS that meets minimum Microelectronics standards (most importantly in the community involvement arena), which would be developed through the EMS.
SEP-34	Integrating New Regulations Over the implementation of the FPA, Microelectronics will create and test ways to better integrate the new regulation process into normal EMS and business planning cycles. If such a system can be crafted (this will take time with regulators and the community), it should reduce costs to business by allowing regulations to be considered during times of normal facility upgrade and expansion. It should speed the integration process by allowing the earliest possible consideration of potential regulations in the product and process design and business planning cycles.
SEP-35	Drive to Sustainability and the "Permitless" Company This concept would drive the company to performance goals that fall below regulatory thresholds for all media, essentially eliminating the necessity for regulatory involvement at such facilities. As experience is gained, such goals would be considered as Objectives & Targets.
SEP-36	Accountability, Reporting, and Enforcement Models This is probably a combination of SEP, "flexibility" and "efficiency". These issues have been discussed in all other XL projects, but would be particularly important here, where a new consolidated, continuous improvement permit is being developed. The issue to be tested is simply how would a business-wide EMS permit be administered.

Element Number	FPA Category/Proposed Element
SEP-37	Enhanced Electronic Reporting (Mesquite) Electronic Reporting is very important to simplification, consolidation and transparency of reporting. This effort will focus not just on the reports going to the public but on a specialized internal system to get critical information, including that related to pollution prevention/DfE, to all workers.
SEP-38	Transparency across Environmental Programs Because regulators are involved on the EMS committees and in the EMS meetings that develop the Objectives & Targets, and the community is involved in the LEAGs which give input on SEP, Significant Environmental Aspects and Objectives & Targets, they can influence continually the direction of SEP at Microelectronics.
SEP-39	Community Involvement/Website The proposed new Microelectronics Project XL website will advance significantly public disclosure and interactive communications about environmental management. The site will publish Objectives & Targets, XL reports, performance reports, LEAG minutes and other project documentation. Additionally, its interactive capability will allow continuing community comment, take questions and allow "chats" about the Microelectronics XL project. It will also have e-mail "blast" capabilities to facilitate community notice.
SEP-40	Transparency of Environmental Programs to Employees By 1 Q FY98, Microelectronics will move environmental documentation to its Intranet to foster employee knowledge of all aspects of the EHS, SHS, PESE including reporting.
SEP-41	Internal Audit Protocols Microelectronics will develop and install computerized programs to foster improved internal performance and better monitor business-wide compliance with all rules and regulations and SEP programs.
SEP-42	LRQA Audits Microelectronics will continue semi-annual LRQA audits, in addition to internal, employee conducted audits to ensure SEP compliance and will report results related to SEP programs.
	FLEXIBILITY ELEMENTS
F-1	Continuous Improvement Approval of EMS: On the path to a "permitless" company (see element #33), Microelectronics requests that all permits (all media) for domestic facilities be consolidated over a period of time into a single Microelectronics-wide, consolidated, multi-media permit beginning first at the facilities and ultimately moving business-wide. This would require the consolidation of all Federal and state permits (all media) into a single permit based upon its Objectives & Targets. Objectives & Targets would be developed in conjunction with regulators annually, providing essentially an annual review of the permit, a significant improvement over the present system of multi-year renewals.

Element Number	FPA Category/Proposed Element
F-2	Streamlined process for incorporating new flexibilities/efficiencies As Microelectronics, regulators and community members (through the LEAGs or website) are jointly identifying Significant Environmental Aspects and developing Objectives & Targets and Environmental Protection Plans, there will arise probably fairly frequently opportunities to get a "bigger bang for the environmental protection buck." For example, it may be appropriate for the Allentown Facility to partner with a non-Lucent facility in the same city to achieve larger reductions of an air or water pollutant. It is important to identify a process less complex than a new XL process as this happens and as the group as a whole decides it is necessary. Achieving it will require work and discussion not just during both FPA finalization and implementation. Microelectronics already is beginning the process of identify and cataloging all the relevant Federal, state and local permits. It is unclear yet whether this will require flexibilities or efficiencies, but probably it will require both because, for example, of the need to adjust renewal requirements.
F-3	Consolidation of reporting requirements: Lucent proposes a consolidation of business-wide reporting requirements to simplify them for the company and the public, to make the job of regulators easier and to make reports more consistent across the business. There are three levels of action which may require flexibilities and efficiencies: 1) consolidation of requirements; 2) simplification of requirements; and, 3) consistency of requirements. There is some precedent in other XL projects and other EPA initiatives for the first two. Microelectronics is presently studying these. Relative to the third, consistency, Microelectronics proposes not only to make the requirements consistent, where possible, business-wide, but also make the requirements fit with other EPA efforts, such as the Center for Environmental Information and Statistics (Microelectronics would propose it develop a model for the Center), in order to make easier and more timely the provision of state, regional or national environmental data.
F-4	Sludge de-listing, Reading & Allentown
F-5	Flexibility on NPDES concentration limits in Allentown
F-6	Rolling NPDES in Allentown
F-7	Consolidation of permits in Mesquite

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