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Union Carbide

Letter from J.R. Dement to Chris Knopes

Union Carbide Corporation

Health, Safety & Environment
39 Old Ridgebury Road. Danbury, CT 06817-0001

Memorandum

From:
J.R. Dement
Assistant Director, Environment
Tel: (203) 794-5506
Fax: (203) 794-5275

TO: Chris Knopes, USEPA
CC: David Bond - EPA Region VI
John Glen - LaDEQ
Lisa Hunter - EPA Washington
Union Carbide Project XL Stakeholders

DATE: June 4, 1996

SUBJECT: Request For Extension - Union Carbide Project XL Final Project Agreement

Dear Mr. Knopes,

The undersigned applicant and prospective signatories to the Union Carbide Taft Project XL Final Project Agreement (FPA) respectfully request an extension of the deadline for submitting a completed FPA to no later than September 30, 1996. This extension is needed because of initial delays in project startup caused in part by the government shutdown and ensuing logistical difficulties.

Since that time, the stakeholder workgroup has made significant progress in defining demonstration projects for inclusion in the FPA, as well as measures of performance. Following is a list of critical action items that will lead us to final submission of the FPA for Agency approval:

By 6/12/96: UCC to incorporate comments from 5/30, 31 meetings into a revised FPA draft.

By 6/30/96: EPA Region VI, LaDEQ and UCC review FPA for legal alignment.

By 6/30/96: Draft circulated for iniital UCC, EPA, LaDEQ input and identification of key issues.

By 6/30/96: Briefing/communication to broader list of stakeholders.

By 7/15/96: EPA/LaDEQ begin work on any necessary rulemaking for demonstration projects.

By 7/22/96: UCC to incorporate new comments into "final draft" FPA, and review by stakeholder workgroup.

By 8/19/96: "Final draft" FPA circulated for management review and stakeholder endorsement.

By 8/23/96: Incorporate additional comments from management review into the "final draft" FPA.

By 8/31/96: EPA Region VI to issue public notice of intent to approve FPA.

By 9/15/96: EPA to address comments received.

By 9/30/96: FPA signed off by EPA, LaDEQ and UCC; with stakeholder endorsement.

This request has been discussed with the members of the stakeholder workgroup at its meeting on May 31. A majority of the group being present, this request was supported.

Please let me know if there are questions or if additional information is needed.


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