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PCS Nitrogen, L.P.


July 3, 1997
Mr. J. Darrell Evers
Manager of Special Projects
PCS Nitrogen Fertilizer, L.P.
P.O. Box 307
Geismar, LA 70734

Dear Mr. Evers:

I am pleased to inform you that EPA has considered your XL proposal for alternative use of phosphogypsum, and that we stand ready to work with you, the State of Louisiana, and appropriate stakeholders to develop a Final Project Agreement (FPA). The FPA should detail the expectations of EPA, PCS Nitrogen, and other project partners. If all partners are satisfied and sign the FPA, the signed agreement will constitute acceptance as a full-fledged XL project.

Project XL was created to test innovative environmental management strategies for the 21st century, and through this process to foster excellence and leadership in environmental protection. We are offering you the opportunity to participate in the next phase of XL project development because we believe your proposal shows good potential to accomplish these goals. We hope you share our excitement at the prospect of working together to forge a partnership that leads to a new era of environmental protection.

EPA requires development of and adherence to a thorough plan for stakeholder involvement. This plan should be the first order of business as PCS Nitrogen moves forward in the XL process. In this plan, you should be sure to include participants from environmental, community and industry groups as well as agricultural representatives from organizations such as extension services or farm bureaus. We advise you to refer to the May 23 Federal Register notice for a complete discussion of stakeholder plans under the XL process.

In addition, EPA will not grant permission for full commercialization of Gyp-Post without first reviewing the results from a study phase designed to determine in more detail the environmental impacts from Gyp-Post use. This phase would a lower-volume, time-constrained study and should include research on variables such as agricultural application rates and market penetration potential that are necessary to complete a risk assessment according to EPA's radiation risk determination methodologies. Although PCS Nitrogen will be responsible for completing this risk assessment, we are prepared to assist you in setting up the study to ensure that it meets EPA's data needs.

EPA is at this time assembling a staff team to work with PCS Nitrogen and with stakeholders on development of the project . That team will be lead by Adele Cardenas of Region 6 (214-665-7210) and Nancy Birnbaum of my staff (202-260-2601). They will be contacting you shortly to commence work. We are pleased to be working with you in a process that holds such promise for environmental innovation.

J. Charles Fox
Associate Administrator
Office of Reinvention

cc: Jerry Clifford, Action Regional Administrator, EPA Region 6
Randy R. Ferrara, PCS Nitrogen Fertilizer
Lisa Lund, Deputy Associate Administrator, USEPA

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