Uniroyal Chemical Co.
Letter from Jerry Clifford, U.S. EPA, to Vincent Stadolnik, Uniroyal, declining project proposal
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6
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.