The Pacific Marine and Supply Company
Letter from David Gardiner to Fred Gehrman
OFFICE OF
POLICY, PLANNING AND EVALUATION
Fred Gehrman
Unitek Environmental Companies
930 Mapunapuna Street
Suite 200
Honolulu, Hawaii 96819
Dear Mr. Gehrman:
Thank you for Pacific Marine and Supply
Company's proposal to EPA's Project XL. Although your proposal was extremely
thorough, I am sorry to inform you of our decision not to pursue it
as an XL project.
XL proposals are reviewed carefully by a team from across all EPA regions
and headquarters offices, and by representatives of state and tribal
environmental agencies. EPA indicated it would consider proposals using
eight criteria outlined in the 23 May, 1995, Federal Register
notice launching Project XL. One consideration is environmental
results -- the eXcellence part of XL. Based upon our review of the information
you submitted, your proposal would not deliver the superior environmental
results which the XL program was designed to foster. Although I agree
that the Terra-Vit technology holds promise for the treatment of hazardous
waste, it has been determined that Project XL would not be the best
vehicle for this demonstration project.
Project XL is just one of many regulatory reinvention initiatives at
EPA. For regulatory reinvention to be a success, some innovative ideas
need to be embraced within the agency's existing programs. Pacific Marine's
demonstration project provides an excellent opportunity to look for
currently available mechanisms that permit innovation. Region nine staff
has spoken frequently with Beth Ginsberg of Bogle & Gates to discuss
alternatives to Project XL for Pacific Marine to conduct this demonstration
project. A Research, Development and Demonstration Permit has been mutually
agreed on by Ms. Ginsberg and EPA to be the most appropriate mechanism
for this project Ray Sarasino and Joanne Asami of Region 9 will continue
to work closely with Pacific Marine to provide technical assistance
and to expedite the administrative process for this permit.
I want to stress that EPA's decisions on whether to accept or decline
XL proposals are, by definition, judgment calls. Project XL has produced
tremendous interest, and so competition for participation in the program
is significant. Good arguments were made on both sides of the issues
raised in your proposal. I hope that you will appreciate EPA's efforts
to fully, fairly, and thoroughly consider your proposal.
If you have any questions or need further assistance, please contact
Ray Sarasino at (415) 744-2040. Once again, thank you for your interest
in Project XL, and your continued support of environmental protection.
David Gardiner
Assistant Administrator