Berry Corporation

Selection Letter

Virginia B. Wetherell, Secretary
Florida Department of Environmental Protection
3900 Commonwealth Boulevard
Tallahassee, Florida 32399-3000

Dear Ms. Wetherell:

I am pleased to inform you that your proposal to conduct a Project XL pilot at the Berry Corporation facility in LaBelle, Florida, has been selected to enter the project development phase of the XL process. Project XL was developed to test innovative strategies and, through this process, nurture "eXcellence and Leadership" in environmental protection. We believe that your proposal shows the potential to accomplish those goals. We are excited to begin working with the Florida Department of Environmental Protection (FDEP) and Berry to forge a partnership that leads to a new era of environmental protection.

The next step in establishing this partnership is to work toward developing and signing a Final Project Agreement (FPA). If completed to the satisfaction of FDEP, Berry, EPA, and the other project partners, this agreement will consist of the details of the project and the expectations of each partner. Enclosed is a document, Principles for Development of Final Project Agreements, which describes the principles important to EPA regarding the process of creating the FPA, as well as the substance that the Agency will look for within the FPA. Please note from the Principles document (page 4) that it will be the responsibility of FDEP/Berry very soon to issue a public notice to the local community of your intent to pursue this project.

I would like to draw your attention to three points regarding the FDEP proposal that arose during our review process, to which the Agency will pay particular attention during the FPA development phase:

The FPA should be very specific regarding the environmental benefits to be derived from the project. The several potential environmental projects that have previously been discussed with FDEP should be fleshed out in sufficient detail in your proposed FPA.

Beyond the combination of permits, the most promising aspect of this proposal is the opportunity to design an environmental management system which incorporates a holistic approach to environmental protection. The Agency will look forward to learning from this project's attempt to incorporate the latest thinking on pollution prevention and source reduction up-the-pipeline and in-the-plant in your proposed Comprehensive Operating Plan (COP).

We understand from discussions during the review phase that the new international environmental management standards of ISO 14000 may serve as guideposts in the design of the COP. As ISO 14000 is of particular interest to EPA, I urge FDEP to fully describe the linkage of ISO 14000 and the COP in the FPA.

You will be contacted very soon by Bill Patton from Region 4 of the EPA to initiate the FPA development process. As the development phase is limited to six months, please be prepared to begin discussions as soon as possible and to sustain a high level of involvement. We are pleased to be working with you in a process that holds such promise for the future of environmental protection.

Sincerely,

David Gardiner
Assistant Administrator

Enclosure

Berry Corporation

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