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Dow Chemical Company, Freeport Texas

Letter from Russell Harding to Jon Kessler

STATE OF MICHIGAN
JOHN ENGLER, Governor
DEPARTMENT OF ENVIRONMENTAL QUALITY
HOLLISTER BUILDING, PO BOX 30473, LANSING MI 48909-7973
RUSSELL J. HARDING, Director

January 18, 1996

Mr. Jon Kessler
Office of Policy, Planning and Evaluation
U.S. Environmental Protection Agency, MC 2111
401 M Street, S.W.
Washington, DC 20460

Dear Mr. Kessler:

The Dow Chemical Company (Dow), Michigan Division is submitting a Michigan Division Project XL for your approval. The Michigan Department of Environmental Quality (MDEQ) and Dow have worked together to develop this project, and have jointly identified key stakeholders and communicated this project to them.

The proposed Michigan Division Project XL proposal involves a multimedia approach to waste management with specific objectives resulting in overall reductions of emissions to environmental media, as well as reductions of waste generated. To achieve these goals, Dow will be seeking more effective alignment of its work processes and resources. To accomplish this, environmental regulatory agencies, such as the MDEQ and the U.S. Environmental Protection Agency (EPA), need to be able to exercise appropriate flexibility in the application of environmental rules, regulations and performance-based permitting, consistent with the principles of Project XL.

The MDEQ viwes the Michigan Division Project XL as an excellent opportunity to improve pollution prevention pracices at the Midland facility with significantly reduced emissions to the environment. We and Dow would like to pursue this type of innovative, alternative approach to accomplish increased environmental protection.

The MDEQ strongly supports the Dow Chemical Company, Michigan Division Project XL proosal and urges a prompt EPA approval. If you have any questions or need assistance on this matter, please contact Mr. Paul Zugger, Chief of the Environmental Assistance Division, MDEQ, at 517-335-2419.

Thank you for your consideration of this important matter.

                      Sincerely,

                      Russell J. Harding
                      Director
                      517-373-7917

cc: Mr. Alex Pollock, Dow Chemical Company
Mr. Paul D. Zugger, MDEQ
Mr. Robert Basch, MDEQ

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