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Berry Corporation
Letter from FDEP to Berry XL Project Team, Re: Meeting Minutes
Department of Environmental Protection
MEMORANDUM
TO: Berry XL Project Team
FROM: Jacki McGorty
904-921-9717
MCGORTY_J@EPIC9.DEP.STATE.FL.USDATE: February 14, 1997
SUBJECT: Items from meeting on 2/6/97 - 217/97
A meeting of the Berry XL Team was held on February 6 and 7, 1997, at the Berry citrus
processing facility in LaBelle. In attendance at the meeting were: Ernie Caldwell, Michelle Glenn, Abdul "Doc" Ahmadi, Richard Thompson, Jacki McGorty, Marc Harris and Bryan Womack.Ernie reviewed progress to date on the draft COP. Sections on General Plant Maintenance and the Feed Mill have been prepared and submitted to the SF District of the DEP for comment. 'I'he meeting focused an the development, coordination, application and implementation of the COP. Several decisions were made and action items discussed.
DECISIONS & ACTION ITEMS:
1. Marc and Bryan are to develop schedule for development and review of COP. This schedule will be ready by 2/19/97.
2. The draft COP needs to broaden in scope to include permitting requirements. Specifically the COP needs to incorporate parameters for monitoring and reporting. Marc and Bryan will review existing permits and incorporate requirements into COP. DEP (SF District) will play a key role in reviewing and commenting on this portion of the COP. DEP will request assistance from EPA if necessary. If assistance from EPA is requested, a concurrent review will be the objective in order to keep the project on schedule.
3. The draft COP also needs to include standard permitting language and references for regulatory compliance. Jacki and Peggy Highsmith (Acting SF District Director) will discuss with legal counsel the best way to include language and references. Suggestions were made to include language in a preamble and references as footnotes and in the Reference Section of each portion of the COP.
4. In order to show movement on the project, several documents will be developed and will be made available on the XL Website. (Jacki will work with DEP staff to link the XL Website with a potential DEP Compliance Website).
Marc and Bryan are going to write a report on accomplishments of the project to date. Some of these accomplishments include using wetland water irrigation, installation and use of a new feed mill dryer which has reduced VOCs, and stakeholder involvement. The report will focus on answering the question, how has regulatory flexibility facilitated greater environmental results. Jacki will work with Marc and Bryan to incorporate performance measurements, as specified in the Performance Partnership Agreement between DEP and EPA, into the report.
- Jacki will develop a Fact Sheet on the Berry XL Project using a summary sheet which was reviewed at the meeting.
- Ernie will develop a matrix of the Berry permits and their monitoring and reporting requirements.
- Michelle will develop a Question and Answer Sheet similar to the ones she has developed for other projects.
5. Dee Stewart had prepared an administrative record for the FPA portion of the Project. The need for an administrative record for the COP portion of the project was discussed. Jacki will maintain the administrative record. Michelle is to send criteria of what the administrative record should include.
A question still to be resolved is EPA's role in being a signatory to the COP. As all programs effecting Berry have been delegated to the state, EPA may not need to be a signatory. On the other hand, EPA may need to sign because the programs are delegated and the XL project provides a different approach than the delegation and therefore could jeopardize the delegation. An option suggested was EPA could write a letter of concurrence in support of the project. Jacki and Peggi will discuss this with legal counsel.
7. Another question to be resolved is who will be taking the lead on the project from the DEP? Jacki will clarify the roles of the DEP Executive Office and the SF District through consultation with Peggy.
8. Due to 1-12R dealing with releases and Community-Right-To-Know, the issue of notifying and including DCA in the project were discussed. Jacki is to obtain more information regarding the requirements of 1-12R. If it is necessary to notify and include DCA, Ernie will discuss involvement with DCA.
The next meeting is scheduled for February 19 in Tampa. Jacki will inform participants about specifics for meeting.