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Illinois Environmental Protection Agency (EPA) and Safety-Kleen

Letter from David Gardiner to Mary Gade, Henry Habicht

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



Mr. F. Henry Habicht
Senior Vice-President
Corporate Development and Environment
Safety-Kleen Corporation
1000 N. Randall Road
Elgin, Illinois 60123-7857

Dear Hank:

The Project XL selection committee has completed the review of the Illinois Environmental Protection Agency (IEPA)/Safety-Kleen Corporation (Safety-Kleen) proposal and has decided to defer making a decision at this time. As you know, the U.S. Environmental Protection Agency (EPA) identified selection criteria to be considered in choosing projects for further development. A project may be deferred if it appears to have the potential to meet the criteria, but contains insufficient information to make an informed judgment. The IEPA/Safety-Kleen proposal falls in this category, particularly regarding information related to anticipated environmental benefits.

The IEPA/Safety-Kleen proposal, with its potential to identify alternative methods of recycling management, warrants further discussion in which clarification and amplification of the proposal's concept can be explored. The IEPA/Safety-Kleen proposal is unique among the Project XL proposals received thus far with regard to the ability to predict environmental benefits at the proposal stage. Unlike most XL proposals, the level of environmental benefits hoped to be derived is not entirely within the control of IEPA or Safety-Kleen: the response of the market of potential recyclers cannot be fully anticipated prior to the actual implementation of the project.

EPA invites you to engage in a creative dialogue with the Region 5 Project XL team to develop options that may provide assurance of overall environmental benefits from this project. For instance:

development of a marketing plan that describes: the universe of generators and others that Safety- Kleen is considering as potential participants, the method to be used to increase the number of recyclers and volume of waste recycled, and the basis for evaluating the success of recruiting new recyclers;

elaboration of your intended evaluation of environmental benefits and a commitment to reassess the project at early stages;

proposals to reinvest anticipated cost savings from the project into other beneficial environmental activities in the event that the more direct environmental benefits are not being achieved as anticipated.

In addition, EPA offers the following comments to establish the basis for a dialogue that can be productive for all parties:

1) IEPA might also elaborate on the environment benefits that they hope to realize from the proposal.

2) It would be helpful if Safety-Kleen would identify the specific federal and Illinois regulations and statutes which you believe are barriers to implementing your proposed system.

3) The current hazardous waste manifest system includes the waste minimization certification. It would be helpful if Safety-Kleen/IEPA could clarify how they may handle this certification under the proposed new system.

4) It is important that stakeholder involvement be established very early in the process, so that stakeholders can be included in development of the project. The proposal should include a list of possible stakeholders such as the Department of Transportation, State police, cities, environmental and other non-governmental organizations, and others.

A discussion of the IEPA/Safety-Kleen proposal and EPA's comments will further the Agency's understanding of this proposal for a potentially instructive project. If this dialogue results in a modified proposal, the XL selection committee would be pleased to revisit the IEPA/Safety-Kleen proposal.

Thank you for your interest in Project XL. As a follow up to this letter, you should expect a call from Dave Ullrich, Deputy Regional Administrator of our Region V office, in the next few days. In addition, Marilou Martin, Region V Project XL Coordinator, will call shortly to arrange a meeting with your staff. If you have any questions, please contact Ms. Martin (312-353-9660), or Lisa Hunter at EPA Headquarters (202-260-4744).

Sincerely,



David Gardiner
Assistant Administrator

cc: Dave Ullrich, Deputy Regional Administrator, Region V

Identical Letter Sent To: Ms. Mary A. Gade, Illinois Environmental Protection Agency


UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


Ms. Mary A. Gade
Director
Illinois Environmental Protection Agency
2200 Churchill Road
Springfield, Illinois 62794-9276

Mr. F. Henry Habicht
Senior Vice-President
Corporate Development and Environment
Safety-Kleen Corporation
1000 N. Randall Road
Elgin, IL 60123-7857

Dear Ms. Gade and Mr. habicht:

The Project XL selection committee has completed the review of the Illinois Environmental Protection Agency (IEPA)/Safety-Kleen Corporation (Safety-Kleen) proposal and has decided to defer making a decision at this time. As you know, the U.S. Environmental Protection Agency (EPA) identified selection criteria to be considered in choosing projects for further development. A project may be deferred if it appears to have the potential to meet the criteria, but contains insufficient information to make an informed judgment. The IEPA/Safety-Kleen proposal falls in htis category, particularly regarding information related to anticipated environmental benefits.

The IEPA/Safety-Kleen proposal, with its potential to identify alternative methods of recycling management, warrants further discussion in which clarification and amplification of the proposal's concept can be explored. The IEPA/Safety-Kleen proposal is unique among the Project XL proposals received thus far with regard to the ability to predict environmental benefits at the proposal stage. Unlike most XL proposals, the level of environmental benefits hoped to be derived is not entirely within the control of IEPA or Safety-Kleen: the response of the market of potential recyclers cannot be fully anticipated prior to the actual implementation of the project.

EPA invites you to engage in a creative dialogue with the Region 5 Project XL team to develop options that may provide greater assurance of overall environmental benefits from this project. For instance:

development of a marketing plan that describes: the universe of generators and others that Safety- Kleen is considering as potential participants, the method to be used to increase the number of recyclers and volume of waste recycled, and the basis for evaluating the success of recruiting new recyclers;

elaboration of your intended evaluation of environmental benefits and a commitment to reassess the project at early stages;

proposals to reinvest anticipated cost savings from the project into other beneficial environmental activities in the event that the more direct environmental benefits are not being achieved as anticipated.

In addition, EPA offers the following comments to establish the basis for a dialogue that can be productive for all parties:

1. IEPA might also elaborate on the environmental benefits that they hope to realize from the proposal.

2. It would be helpful if Safety-Kleen/IEPA would identify the federal and Illinois statutes on which this proposal is based.

3. The current hazardous waste manifest system includes the waste minimization certification. It would be helpful if Safety-Kleen/IEPA could clarify how they handle this certification under the proposed new system.

4. It is important that stakeholder involvement be established very early in the process, so that stakeholders can be included in development of the project. The proposal should include a list of possible stakeholders such as the Department of Transportation, State police, cities, environmental and other non-governmental organizations, and others.

A discussion of the IEPA/Safety-Kleen proposal and EPA's comments will further the Agency's understanding of this proposal for a potentially instructive project. If this dialogue results in a modified proposal, the XL selection committee would be pleased to revisit the IEPA/Safety-Kleen proposal.

Thank you for your interest in Project XL. Marilou Martin, Region 5 Project XL Coordinator, will call within the next few days to arrange a meeting. If you have any questions, please contact Ms. Martin (312-353-9660), or Lisa Hunter at EPA Headquarters (202-260-4744).

Sincerely,



David Gardiner
Assistant Administrator


cc: Dave Ullrich, Deputy Regional Administrator, Region V


UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Washington D.C. 20460



Ms. Mary A. Gade
Director
Illinois Environmental Protection Agency
2200 Churchill Road
Springfield, Illinois 62794-9276

Dear Ms. Gade:

The Project XL selection committee has completed the review of the Illinois Environmental Protection Agency (IEPA)/Safety-Kleen Corporation (Safety-Kleen) proposal and has decided to defer making a decision at this time. As you know, the U.S. Environmental Protection Agency (EPA) identified selection criteria to be considered in choosing projects for further development. A project may be deferred if it appears to have the potential to meet the criteria, but contains insufficient information to make an informed judgment. The IEPA/Safety-Kleen proposal falls in htis category, particularly regarding information related to anticipated environmental benefits.

The IEPA/Safety-Kleen proposal, with its potential to identify alternative methods of recycling management, warrants further discussion in which clarification and amplification of the proposal's concept can be explored. The IEPA/Safety-Kleen proposal is unique among the Project XL proposals received thus far with regard to the ability to predict environmental benefits at the proposal stage. Unlike most XL proposals, the level of environmental benefits hoped to be derived is not entirely within the control of IEPA or Safety-Kleen: the response of the market of potential recyclers cannot be fully anticipated prior to the actual implementation of the project.

EPA invites you to engage in a creative dialogue with the Region 5 Project XL team to develop options that may provide greater assurance of overall environmental benefits from this project. For instance:

development of a marketing plan that describes: the universe of generators and others that Safety- Kleen is considering as potential participants, the method to be used to increase the number of recyclers and volume of waste recycled, and the basis for evaluating the success of recruiting new recyclers;

elaboration of your intended evaluation of environmental benefits and a commitment to reassess the project at early stages;

proposals to reinvest anticipated cost savings from the project into other beneficial environmental activities in the event that the more direct environmental benefits are not being achieved as anticipated.


In addition, EPA offers the following comments to establish the basis for a dialogue that can be productive for all parties:


1. IEPA might also elaborate on the environmental benefits that they hope to realize from the proposal.

2. It would be helpful if Safety-Kleen/IEPA would identify the federal and Illinois statutes on which this proposal is based.

3. The current hazardous waste manifest system includes the waste minimization certification. It would be helpful if Safety-Kleen/IEPA could clarify how they may handle this certification under the proposed new system.

4. It is important that stakeholder involvement be established very early in the process, so that stakeholders can be included in development of the project. The proposal should include a list of possible stakeholders such as the Department of Transportation, State police, cities, environmental and other non-governmental organizations, and others.

A discussion of the IEPA/Safety-Kleen proposal and EPA's comments will further the Agency's understanding of this proposal for a potentially instructive project. If this dialogue results in a modified proposal, the XL selection committee would be pleased to revisit the IEPA/Safety-Kleen proposal.

Thank you for your interest in Project XL. As a follow up to this letter, you shouold expect a call from Dave Ullrich, Deputy Regional Adminstrator of our Region V office, in the next few days. In additon, Marilou Martin, Region 5 Project XL Coordinator, will call shortly to arrange a meeting with your staff. If you have any questions, please contact Ms. Martin (312-353-9660), or Lisa Hunter at EPA Headquarters (202-260-4744).

Sincerely,



David Gardiner
Assistant Administrator


cc: Dave Ullrich, Deputy Regional Administrator, Region V

Identical Letter Sent To: Mr. F. Henry Habicht, Safety-Kleen Corporation


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