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DuPont Petrochemicals
Letter from Dan Pearson to David Gardiner
TEXAS NATURAL RESOURCE CONSERVATION
COMMISSION
Protecting Texas by Reducing and Preventing Pollution
March 14, 1996
Mr. David Gardner
Assistant Administrator
Office of Policy, Planning & Evaluation
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Dear Mr. Gardner:
The Texas Natural Resource Conservation Commission (TNRCC) has reviewed and fully supports the Project XL proposal submitted by E.I. DuPont de Nemours for its Victoria facility. This proposal seeks an exemption from the "mixture and derived from rules" for a listed hazardous waste multi-source landfill leachate stream. This regulatory flexibility will allow this waste stream to be bio-treated concurrently with non-listed hazardous waste, without creating additional listed waste, and will eliminate the need for deep-well injection of this waste. The project demonstrates that equivalent environmental benefits can be achieved without the burden imposed by current regulations.
DuPont and the TNRCC recognize that the proposed Hazardous Waste Identification Rule has been published and that this rule was proposed for the primary purpose of exiting similar low-risk wastes from the Subtitle C system. However, DuPont would like to take a proactive stance and move ahead with its voluntary commitment to "drive toward zero emissions" without further delaying the environmental benefits associated with the facility's overall construction projects.
DuPont has a commendable record of environmental compliance in Texas and has undertaken voluntary initiatives to reduce the waste it generates. As a member of the TNRCC's Clean Industries 2000 program, DuPont Victoria has committed to reducing its TRI emissions by at least 60% by the year 2000 -- from 1987 levels. This represents TRI emissions reductions totaling 18 million pounds with reductions of nitric acid, ammonia, cyclohexane, ethylene and vinyl acetate.
The TNRCC appreciates this largely voluntary effort and the efforts by DuPont towards overall environmental citizenship. We would encourage approval of the DuPont Project XL by the EPA.
Sincerely,
Dan Pearson
Executive Director
DP:ecg
TEXAS NATURAL RESOURCE CONSERVATION
COMMISSION
Protecting Texas by Reducing and Preventing Pollution
March 14, 1996
Mr. David Gardner
Assistant Administrator
Office of Policy, Planning & Evaluation
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Dear Mr. Gardner:
The Texas Natural Resource Conservation Commission (TNRCC) has reviewed and fully supports the Project XL proposal submitted by E.I. DuPont de Nemours for its Victoria facility. This proposal seeks an exemption from the "mixture and derived from rules" for a listed hazardous waste multi-source landfill leachate stream. This regulatory flexibility will allow this waste stream to be bio-treated concurrently with non-listed hazardous waste, without creating additional listed waste, and will eliminate the need for deep-well injection of this waste. The project demonstrates that equivalent environmental benefits can be achieved without the burden imposed by current regulations.
DuPont and the TNRCC recognize that the proposed Hazardous Waste Identification Rule has been published and that this rule was proposed for the primary purpose of exiting similar low-risk wastes from the Subtitle C system. However, DuPont would like to take a proactive stance and move ahead with its voluntary commitment to "drive toward zero emissions" without further delaying the environmental benefits associated with the facility's overall construction projects.
DuPont has a commendable record of environmental compliance in Texas and has undertaken voluntary initiatives to reduce the waste it generates. As a member of the TNRCC's Clean Industries 2000 program, DuPont Victoria has committed to reducing its TRI emissions by at least 60% by the year 2000 -- from 1987 levels. This represents TRI emissions reductions totaling 18 million pounds with reductions of nitric acid, ammonia, cyclohexane, ethylene and vinyl acetate.
The TNRCC appreciates this largely voluntary effort and the efforts by DuPont towards overall environmental citizenship. We would encourage approval of the DuPont Project XL by the EPA.
Sincerely,
Dan Pearson
Executive Director
DP:ecg