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Union Carbide

Letter from W.T. Gray, Jr. to EPA


September 22, 1995

Regulatory Reinvention Pilot
FRL-5197-9, Water Docket, Mail Code 4101
U.S. Environmental Protection Agency
401 M. Street, S.W.
Washington, DC 20460

RE: Project XL Application

Dear Sir/Madam:

In response to questions concerning our Project XL application, I would like to restate our commitment to continuous improvement in environmental performance through the process outlined in the Project XL application for the Union Carbide Corporation Taft Plant.

Our XL proposal is innovative in that it establishes a multi-stakeholder based work process for developing cleaner, cheaper, smarter alternatives to existing command and control regulations. It is cleaner in that, if granted additional regulatory flexibility, Union Carbide's objective would be to exceed overall levels of environmental performance required under existing regulations. Possible examples include: innovative pollution prevention initiatives, reducing chances of spills and worker exposure, and identifying more effective environmental metrics to measure performance. The alternatives identified in our Project XL applications have a broad applicability to both large and small facilities.

We are looking forward to working with the agency, the State of Louisiana, and our mulit-stakeholder group during the development and implementation of our Project XL agreement.

We appreciate the agency's willingness to consider regulatory flexibility alternatives such as Project XL. Please let us know if there are further questions.


W.T. Gray, Jr.
Taft Plant Manager

cc: John Kessler
Dan Fiorino

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