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Exxon Fairmont Coke Works

Letter from Thomas C. Voltaggio/EPA to Don Esch/Exxon

841 Chestnut Building
Philadelphia, Pennsylvania 19107-4431


May 4, 1998

Don Esch
Exxon Company, U.S.A.
P.O. Box 728
Linden, NJ 07036

RE: Project XL Proposal
Sharon Steel Corporation - Fairmont Coke Works Site

Dear Don:

The Environmental Protection Agency ("EPA") is in receipt of your proposal dated April 17, 1998 regarding implementation of Project XL at the Sharon Steel - Fairmont Coke Works Site in Fairmont, West Virginia. While EPA Region III, EPA Headquarters, and the West Virginia Department of Environmental Protection ("WVDEP" or "the State") continue to review the proposal, I would like to take this opportunity to provide you with some initial feedback. It is the Region's position that before this proposal can be considered complete, Exxon Company, U.S.A. ("Exxon") should recognize that all XL criteria (8) need to be addressed. EPA is willing to work with Exxon toward developing this proposal into a satisfactory XL project. Our specific concerns are outlined below.

It appears as if Exxon has not made sufficient progress in its efforts to include WVDEP in the process during the development of this proposal. Specifically, it does not appear that Exxon has contacted senior level management at WVDEP, as suggested by EPA previously. Please keep in mind that in order for an XL Project to be successful, the State, as well as EPA, must approve it. Every day that goes by without senior level WVDEP involvement jeopardizes the chances for a successful XL project.

EPA needs to gain a better understanding of the Superior Environmental Performance ("SEP") contemplated under this proposal. EPA is interested in working with Exxon to clarify the SEP concepts.

At previous meetings we agreed that the Remedial Investigation would proceed in accordance with the Administrative Order on Consent ( Docket No. III-97-103-DC) and would recognize that some typical portions of the RI/FS work plan could be deferred pending the determination of the approvability of an XL proposal. EPA and WVDEP are currently reviewing the Remedial Investigation Work Plans submitted by Exxon. Recognizing that there are portions of the Work Plan which are absent because they could appropriately be deferred pending XL approval, EPA still believes that there are a number of fundamental shortcomings to the remaining portions of the work plan which were submitted. Additionally, EPA has concerns regarding some aspects of the submitted Project XL proposal as well. In order to minimize the time needed to address these issues, we feel we should meet to discuss these concerns as soon as possible.

Ms. Melissa Whittington will be contacting you shortly to make arrangements for this meeting. Please contact me should you have further questions.


Thomas C. Voltaggio, Acting
Deputy Regional Administrator
EPA Region III

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