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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