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State of Tennessee



Mr. David Harbin

State of Tennessee
Department of Environment and Conservation
401 Church Street
Nashville, Tennessee 37243-1548

Dear Mr. Harbin:

Thank you for submitting a Project XL proposal on behalf of the Tennessee Department of Environment and Conservation and the Tennessee Environmental Council. We applaud your efforts to improve the efficiency and accuracy of the federal spill reporting system. The Tennessee proposal for a one-stop spill reporting system was carefully reviewed by EPA. While the proposal has merit based on our evaluation, it does not provide the superior environmental benefits needed for participation in Project XL.

This project, as proposed, appears only to provide minimal environmental improvement. Under the current spill notification process for most spills, facilities are required to make a maximum of 2 to 3 phone calls (local agency, state agency, and the National Response Center). Under the Tennessee proposal, the number of calls made by a facility would be reduced to a maximum of two (state agency and local agency). While possibly improving facilities' willingness to report spills by reducing the reporting burden, the project would not address the volume or frequency of the spills themselves.

As you may know, EPA, the NRC, and other federal agencies have formed the National Response Team which is working to improve the current spill reporting process. The current objectives of EPA and the National Response Team is to promote a one-stop spill reporting process that uses the NRC as the primary contact for facilities. This reporting process would reduce the burden on industry and improve efficiency while providing a central location for spill information throughout the country. Discussions with states on implementation have begun. We re hopeful that Tennessee will choose to participate as one of these pilot projects.

Although the Tennessee proposal is not an appropriate fit for Project XL, EPA would like to continue working with you to craft a one-stop spill notification project that meets our mutual goals. Dana Stalcup, in the Office of Solid Waste and Emergency Response, will contact you within the next two weeks to continue discussions on development of an innovative spill notification system. In the meantime, if you have any questions please contact Dana at (703) 603-8735. Thank you again for your interest in Project XL.


David Gardiner
Assistant Administrator

cc: John Hankinson
Justin Wilson
Milton Hamilton
Bill Patton

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