HADCO

Lee Wilmot to Jon Kessler RE: HADCO XL FPA (Attachments: letter to Richard de Seng, et al. 10/29/96)
HADCO

17 October 1996
Mr. Jon Kessler, Acting Director
Emerging Sectors and Strategies Division
Office of Policy Development
U.S. Environmental Protection Agency
401 M Street, SW
West Tower, 1013 Mail Code 2111
Washington, D.C. 20460

RE: HADCO Project XL Final Project Agreement

Dear Mr. Kessler:

I'm writing in reply to your letter dated October 4, 1996, which we understand supersedes your August 14th letter.

1. Commitment to Recycle Copper Dusts

HADCO and EPA's XL team for our project in Regions 1 and 2 have agreed on revised Final Project Agreement (FPA) language which clarifies HADCO's commitment to utilize cost savings derived from alternative management of our wastewater treatment sludges to recycle non-RCRA copper dusts. This language is found in the last paragraph of the FPA preamble, in paragraph 31, and in Appendix A paragraphs I.B.2 and II.A.

Regarding copper dust quantities and copper content, HADCO has determined that our Derry and Hudson, NH facilities are currently generating at a combined 103 ton/year rate. We estimate that our Owego, NY facility generates an equivalent amount. The Salem, NH facility generates an estimated 10 tpy. The copper content is variable depending on both the process source, and to some degree the facility. We recently completed a three month trail collection with a potential recycling broker, who determined that the Derry dust was just under 10% copper, and our Salem facility's dust was 33% copper. This data is not included in the FPA, as it varies with our production (note that our September, 1995 XL summary to you showed over 150 tons/year), and much of this data will be determined in the performance of the project. We believe that any data will vary with time.

2. Stakeholder Process in Regions 1 and 2

HADCO directly invited both by person and telephone contact, and by letter the following stakeholders to participate in our FPA process:

Region 1
Merrimack River Watershed Council Lawrence, MA

HADCO CORPORATION.12A MANOR PARKWAY.SALEM, NEW HAMPSHIRE 03079.603/898-8000
Mr. Jon Kessler
17 October 1996
Page 2

Clean Water Action Portsmouth, NH
Sierra Club of New Hampshire Merrimack, NH
Baldwin & deSeve Concord, NH
New Hampshire Citizen Action Concord, NH
Conservation Law Foundation Boston, MA
Audubon Society of NH Concord, NH
Appalachian Mtn Club Gorham, NH
Town Health Officers Derry, Hudson and Salem, NH
NH Wildlife Federation Concord, NH

Copies of our February 26, 1996 letters are attach. (NOTE: These letters confirmed an October 29, 1995 letter to AMC, Baldwin & deSeve, MRWC, Audubon, Citizen Action and CLF, also attached.) Our invitation to NHWF was sent on March 13, 1996.

Region 2
Based on Region 2XL team recommendations, we invited the following stakeholders to participate:

Atlantic States Legal Foundation, Inc. Syracuse, NY
New York Public Interest Group (NYPIRG) New York, NY
Tioga County Enviro. Health Director Owego, NY

Copies of our February 28th and April 22nd letters are attached.

In addition to these direct letters and personal contact, we utilized legal notices in local papers. These notices summarized HADCO's XL proposal and solicited stakeholder participation in the FPA development process. The notice was reviewed by EPA prior to publication. Prior to HADCO's first stakeholder meeting in New Hampshire on March 18, 1996, the notice was published on March 11, 1996 in the Manchester Union Leader, the Nashua Telegraph, and the Concord Monitor, and on March 13th in the Derry News (all NH newspapers). Additional meetings were held on April 17th, June 19th, and July 18th.

In Region 2, the first stakeholder meeting was held on April 16, 1996, and the legal notice was published in the Binghampton (NY) Press & Sun-Bulletin on April 10, 1996.

Copies of these legal notices (or affidavits of same are attached.

Stakeholders who attended the first and subsequent meetings based on general awareness and/or legal notice of these meetings included the following:

Region 1
World Resources Corp McLean, VA
Teradyne Nashua, NH
PDL Industrial Prod'ts Nashua, NH
M/A Com Inc. Lowell, MA Also represented IPC

Mr. Jon Kessler
17 October 1996
Page 3

Region 2
Loral Federal Systems Owega NY (Now Lockheed Martin)

In addition, resident Ruth Holmes of Canterbury, NH called and asked for information. A copy of the March 13, 1996 letter to her is also attached, as well as her March 18th fax response.

Not all of the invited stakeholders attended all meetings. Some did not attend any meetings. To document discussions and provide a communication continuum, attendance was documented at all meetings; meeting minutes were published; and both minutes and the next draft of FPA revisions were mailed to all initial invited and all attending stakeholders. A list of these dated 6/18/96 is attached. Copies of attendee registers, meeting minutes and next meeting notices are enclosed. Stakeholder meetings were held via video conference for New Hampshire and New York stakeholders by simultaneous meetings at Derry and Salem, NH and Owego, NY on 6/19/96 and 7/18/96. Several stakeholders participated actively in the FPA development, and the final FPA draft reflects substantial stakeholder input.

Finally, we have described our planned stakeholder involvement approach during the project implementation phase in paragraph 35 of the draft FPA.

We believe that the above information, coupled with the attached documents, provides sufficient confidence to you and other stakeholders in both our project's environmental benefits, as well as the openness of our stakeholder process. Should you have any further requests, please contact me to 603/896-2424 or via email at lwilmot@hadco.com, or via fax at 603/890-1298.

Sincerely,

/s/
Lee R. Wilmot
Manager, Corporate SAFETY
Health & Environmental Affairs

cc: EPA
Region 1 - J.Jouzaitis
Region 2 - K.Donnelly
Washington - L.Hunter, L.Lund, M.A. Froehlich, D.Gardiner
NH DES
Ken Marschener
NYS DEC
Larry Nadler
HADCO
D.Saporito, R.Blanchette, M.Duquette, P.Walter
Orr & Reno, PA
David Marshall

HADCO

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