DuPont Petrochemicals

Letter from Eileen McGovern to F. Farnsworth of DuPont

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460

Office of
Policy, Planning and Evaluation

April 25, 1996

Mr. F.W. Farnsworth
DuPont Petrochemicals
P.O. Box 2626
Victoria, Texas 77902

Dear Mr. Farnsworth:

We have reviewed the XL proposal submitted by DuPont for implementation at its Victoria, Texas facility. We would like to request some additional details to assist us in evaluating your submission. Pending receipt of information that addresses the following concerns, we will consider this proposal to be incomplete.

Project XL is intended to provide regulatory flexibility that is unavailable through existing means in exchange for an enforceable commitment to achieve better environmental results than would be attained through full compliance with regulations. It is unclear what regulatory flexibility DuPont seeks in this proposal. A request for a delisting can now be processed through the Regional Office in a more timely and efficient manner than previously. If you choose to pursue this proposal as an XL project, please describe in more detail the flexibility you anticipate will need to be granted in order to successfully implement this project.

Additionally, we seek clarification of the superior environmental results DuPont expects to attain through this project. As written, the proposal does not explain why treating the small amount of listed hazardous waste with a major waste water system at the Victoria facility is preferable and superior to continuing underground injection. It would also be useful to know the identities of the constituents in the F039 waste and their levels in the waste to be treated. Finally, because the proposal would result in some exposure to three media (air, surface water, solid waste) via the water treatment process, we are interested in both a discussion of risk and how DuPont concluded that there are no Environmental Justice issues related to this project.

While it is true that many of the specific details of an XL proposal are negotiated during development of the FPA, the framework for those negotiations are approved in the review process. When the requested information is received, DuPont's proposal will re-enter the initial triage phase before moving through the Project XL review and selection processes. If you have any questions or require clarification concerning this request, please feel free to contact me at (202) 260-5352.

Sincerely,

Eileen McGovern
Staff Advisor
Project XL

cc:	Rob Lawrence, EPA Region 6

DuPont Petrochemicals

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