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Uniroyal Chemical Co.

Letter from Jerry Clifford, U.S. EPA, to Vincent Stadolnik, Uniroyal, declining project proposal

1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733

Mr. Vincent J. Stadolnik
Factory Manager
Uniroyal Chemical Company, Inc.
P.O. Box 397
Geismar, LA 70734

Dear Mr. Stadolnik:

Thank you for the Uniroyal Chemical Corporation (Uniroyal), Geismar, Louisiana, proposal to participate in the Environmental Protection Agency's Project XL initiative. We appreciate your efforts in preparing and clarifying this proposal. However, we regret to inform you that it is EPA's decision not to enter into negotiations with Uniroyal to develop the proposed XL project.

Project XL is a pilot program to test alternative approaches to environmental protection where project sponsors are granted flexibility in return for superior environmental performance and ongoing stakeholder involvement. Ultimately, the pilots may, if successful, be incorporated into our current system of environmental regulation, resulting in a system that is more flexible, efficient and cost effective even while achieving greater environmental progress.

Our review of Uniroyal's proposal against the Project XL criteria raised concerns as to whether the proposal could meet the criterion for superior environmental performance required in order to move forward into development of a Final Project Agreement. The Uniroyal proposal, instead of outlining an alternative approach to achieve or exceed compliance with the Total Suspended Solids (TSS) standards, requests authorization to not meet the standard. While other benefits were suggested in lieu of meeting the standard, it was not a clear beneficial trade-off. EPA acknowledges that it is difficult to measure the benefits of allowing continued discharges of one pollutant against the reductions of other pollutants in a different media, but in the Federal Register of April 23, 1997, it was suggested that when such trades were proposed, the project sponsor present a methodology to evaluate the trade that was acceptable to all stakeholders and was a clear win-win for all parties. This was not done in this instance.

EPA's decisions to accept or decline Project XL proposals are based, at least in part, on the criteria and guidance laid out in the May 23,1995, Federal Register notice, as further clarified by the April 23, 1997, Federal Register notice. These documents are all available on EPA's Project XL Home Page on the Internet.

While it is our decision not to pursue this particular project, EPA would welcome the opportunity to work with Uniroyal on a different proposal that meets the Project XL criteria and guidance. If you have any questions, please feel free to contact Nancy Birnbaum at (202) 260-2601 or Adele D. Cardenas of my staff at (214) 665-7210. Once again, we thank you for your interest in Project XL and your continued support of environmental protection.

Sincerely yours,

Jerry Clifford
Acting Regional Administrator

cc: Jay S. Patel, Uniroyal Chemical Corp.

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