Anheuser-Busch Companies

Letter from Larry Keith to Bill Patton

ANHEUSER-BUSCH COMPANIES

June 17, 1996

Via Fax 404/347-5207

William J. (Bill) Patton
Special Assistant
Region IV, USEPA
345 Courtland Street, Room 312
Atlanta, GA 30365
Re: EPA XL Meeting - 6/20/96

Dear Bill:

As you requested, the following is a list of questions for Region IV and the State of Florida:

1) Do the attached bar chart and tables showing proposed enforceable and voluntary limits satisfy the EPA "Environment Results" criteria for Project XL?

2) Our accepted XL proposal included an "expanded buble" to make industry more accountable (XL requirement) for total impact of their operations in the community. Is this concept still acceptable?

3) Is going from pond monitoring to stream monitoring for compliance at our land application still acceptable?

4) Is the list of regulatory relief items reasonable and workable under Project XL? 5) Is the concept of splitting enforceable limits (multi-media permit) and voluntary targets (agreement) acceptable?

6) Can we improve the process for FPA development by arranging a small committee of key individuals for decision-making?

We looked at the 3M draft Final Project Agreement for 3M Hutchinson and feel it is very good. It is somewhat understandable that they are further along than A-B since they have been working with the state of Minnestota on alternative compliance mechanisms since 1991, and 3M was already with MPCA "on another experiment similar to the Project XL high priority action item described in Reinventing Environmental Regulation." Several other XL participants who were working on initiatives such as "CSI" prior to Project XL are also further along than A-B in areas such as stakeholder development. In many regards, our project is similar to 3M's. The following is a side-by-side comparison of A-B's proposed XL project with 3M's:

3M A-B

Proposing mass air-caps above today's actual emissions but below those allowed under current permit and reasonably anticipated future regulations. Same as 3M except we are going further and proposing an "expanded buble." It is felt this makes industry more accountable for total community impact.

3M A-B

Committed to establishing environmental improvement goals Same

Requesting regulatory flexibility from certain state and federal air quality permitting requirements plus relief in several other areas. Similar - A-B also proposing stream monitoring for compliance determination at land application sites.

Established stakeholder group(s) in place and active. Completed stakeholder communication plan in place and ready to implement.

Committed to develop an EMS. State-of-the-art EMS (electronic on Lotus Notes for keeping "evergreen.") already developed and in use.

Reduced air emission reporting requirements based on emissions from previous year. Proposing quarterly electronic reporting of emissions vs. established baseline plus results of "self-assessment" of overall facility environmental compliance. Self-assessment tool, developed as part of the EMS, to be modified with agency input to simulate agency inspection. This quarterly self reporting gives agency, stakeholders, and A-B on-going determination of facility environmental status not available in the past.

Fewer air permit amendments, combined reporting and record keeping, etc. included under cost savings and paperwork reduction. A-B, mainly through the proposed electronic reporting, is projecting 20,000 page reduction in paperwork, and refocusing of 4,000 saved manhours to more "value-added" work during the initial 5-year life of the FPA. Similar savings would be projected for environmental agencies.

XL permit is flexible, performance based and therefore allows flexibility to accomplish multi-media pollution prevention. Same plus the "expanded buble" encourage refuction through pollution prevention and resource conservation (energy efficient motors, reduced process loss, etc., all provide real reduction in emissions in the expanded bubble.

Transferrable to other programs or industries With 45% of U.S. beer market and 11 other breweries in the U.S., the XL project is transferable, not only to other A-B facilities but to other industry groups.

The meeting in Washington, DC this Thursday is critical. Unless we (Region IV EPA, State of Florida DEP, City of Jacksonville RESD, and A-B) are united behind this project on Thursday, it is not likely it will go forward. A-B is strongly committed to the concept being proposed in our Project XL. It is felt that from the standpoint of satisfying all 8 EPA Project XL criteria, our project compares favorably with any other XL proposal to date.

Attached is a very rough draft of the presentation planned for Thursday in Washington DC.

Bill, it may be appropriate to have a conference call among all parties prior to Thursday's meeting. I am available up through noon on Wednesday. Please let me know if you think this is necessary.

I am interested in everyone's comments (mark-ups) on the attached presentation. To the extent possible, I will try and incorporate those comments received by close of business Tuesday.

Bill, I would also like yours and the team's responses to the questions above by the close of business Tuesday.

ANHEUSER-BUSCH COMPANIES, INC.

L.W. Keith
Director, Environmental Engineering and Development
Corporate Environmental Affairs
LWK-lb

cc: John Kessler - USEPA
Mike Phillips - FLDEP
Ernie Frey - FLDEP
James Manning - City of Jacksonville RESD

3M	A-B
Proposing mass air-caps above today's actual emissions but below those allowed under current permit and reasonably anticipated future regulations.	Same as 3M except we are going further and proposing an "expanded buble." It is felt this makes industry more accountable for total community impact.
3M	A-B
Committed to establishing environmental improvement goals	Same
Requesting regulatory flexibility from certain state and federal air quality permitting requirements plus relief in several other areas.	Similar - A-B also proposing stream monitoring for compliance determination at land application sites.
Established stakeholder group(s) in place and active.	Completed stakeholder communication plan in place and ready to implement.
Committed to develop an EMS.	State-of-the-art EMS (electronic on Lotus Notes for keeping "evergreen.") already developed and in use.
Reduced air emission reporting requirements based on emissions from previous year.	Proposing quarterly electronic reporting of emissions vs. established baseline plus results of "self-assessment" of overall facility environmental compliance. Self-assessment tool, developed as part of the EMS, to be modified with agency input to simulate agency inspection. This quarterly self reporting gives agency, stakeholders, and A-B on-going determination of facility environmental status not available in the past.
Fewer air permit amendments, combined reporting and record keeping, etc. included under cost savings and paperwork reduction.	A-B, mainly through the proposed electronic reporting, is projecting 20,000 page reduction in paperwork, and refocusing of 4,000 saved manhours to more "value-added" work during the initial 5-year life of the FPA. Similar savings would be projected for environmental agencies.
XL permit is flexible, performance based and therefore allows flexibility to accomplish multi-media pollution prevention.	Same plus the "expanded buble" encourage refuction through pollution prevention and resource conservation (energy efficient motors, reduced process loss, etc., all provide real reduction in emissions in the expanded bubble.
Transferrable to other programs or industries	With 45% of U.S. beer market and 11 other breweries in the U.S., the XL project is transferable, not only to other A-B facilities but to other industry groups.

Anheuser-Busch Companies

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