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Dow Chemical Company, Freeport Texas

Letter from Sandy Henderson to Walter Walsh

The Dow Chemical Company
2301 N. Brazosport Blvd.
Freeport, Texas 77541-3257

April 11, 1996

U.S. Environmental Protection Agency
401 M Street SW - Mail Code 4101

Attention: Walter Walsh

Regulatory Reinvention Pilot Projects
FRI 510749, Water Docket
Washington, DC 20460

RE: THE DOW CHEMICAL COMPANY'S PROJECT XL APPLICATION, TEXAS BIF COMPONENT

Dear Walter,

Thank you for reviewing our XL proposal and identifying areas for clarification. We appreciate this opportunity to respond to your questions so that this proposal can move forward. This letter responds to your questions from March 22, 1996.

1. EPA has requested specific information on the volume of waste incinerated both before and after implementation of the XL project in order to evaluate how this proposed reduction meets the selection criteria of providing superior environmental results. Dow has already stated that we will be committing to a 25% reduction in the unit ratio of liquid halogenated wastes burned per pound of associated product. We believe that this ratio is indicative of superior environmental performance since pollution prevention, source reduction and recycling are integral and necessary to accomplishing the ratio reduction goal. The ratio is superior to a specific volume reduction since this incorporates the philosophy of sustainable development which is critical to future viability. Dow estimates that we will avoid increasing the overall amount of waste burned at the Freeport site by approximately 150 million pounds per year by the year 2005.

We have not yet finalized our model of predicted 2005 volumes but would be willing to discuss this with you when completed. Dow would like to point out that volumes will fluctuate for several years as pollution prevention and source reduction projects are implemented and new production processes are constructed.

2. EPA requested clarification of the commitment related to dioxins and furans (D/F) and how it relates to historical accomplishments and corporate goals. First of all, there is some misunderstanding concerning to the specific Project XL commitments for D/F. The Project XL proposal will commit to a D/F sampling and analysis program and establishment of a baseline with subsequent D/F reduction commitments to be made in 1997 when sampling is complete. The XL commitment will consist of a percentage reduction in D/F emissions to the atmosphere specifically from the BIF units located at Texas Operations. The Project XL commitment will be based on sampling done over a two year period. The Dow Chemical Company does have other D/F reduction effort on-going that include the following:

3. Dow plans to achieve a 20% reduction in BIF units by implementing pollution prevention, source reduction, and recycling projects that will reduce the amount of waste material that would otherwise be incinerated. Dow will also be replacing older units with newer, more efficient BIFs. In some cases, alternative technologies are being investigated.

A number of BIF units will be closed under interim status prior to the need to conduct a trial burn or submit a Part B permit application. Those units are shown on the attached able. The schedule for conducting trial burns will list them last so that they would be closed prior to having to conduct the test. This would save time, money, and resources both for Dow and the agencies. For a number of units, the date of closure is known. For several, others, the closure date will depend on implementation of source reduction and recycling projects. It is expected that these would close sometime after the year 2000.

4. Dow has been given an indication that TNRCC will not call in the BIF Part B applications until after the BIF technical standards have been finalized sometime in 1998 or 1999. Dow would like to negotiate a schedule of trial burns that would extend 4-6 years from that time frame. We believe that TNRCC will be an active stakeholder in the Project XL process and will participate in negotiations related to the trial burn schedules. It is not clear to us whether EPA or TNRCC would take the lead on negotiations. We do not believe that TNRCC has established any guidance for the length of time allowed for trial burns after a Part B call-in.

We believe that all of Dow's BIF Part Bs may be called in simultaneously. Staging the trial burns in a manner that allows for complete and accurate sampling will be very difficult to do without some sort of extended schedule. Each trial burn itself could take up to four months to complete. One month could easily be needed for preliminary testing and preparation on the unit to be tested. At least one week will be needed for the actual trial burn. Laboratory results of this scope generally take 6 to 8 weeks and then another month to write the report. An extended schedule will also allow TNRCC to ensure that the trial burn is conducted properly.

5. There are several reductions in paperwork that Dow is seeking and are discussed below:

ˇ Dow would like to eliminate the requirement to log Automatic Waste Feed Cutoff (AWFCO) actuation in a handwritten log and recommends instead maintenance of a computer record of the AWFCO activation. The requirement to log all waste feed cutoffs in a separate handwritten log is a duplication of an identical record kept by the computer operating system.
ˇ Dow would like to eliminate the used to keep all records for the life of the facility and instead recommends a retention time of five years. Keeping records for the life of the facility is extremely burdensome and unnecessary and in many cases technically unreasonable. Dow would propose that records be kept for five years from the date that they are generated rather than the life of the facility.
ˇ Dow would like to eliminate the need to keep both one minute averages and hourly rolling averages of carbon monoxide, oxygen, temperature, and other triggers for AWFCO. Currently both these averages must be kept on the computer and ultimately for the life of the facility. These two averages are really documenting the same thing and do not add to overall compliance. Maintenance of records of the hourly rolling averages should be sufficient for compliance with the BIF rules.
6. Dow would like to negotiate flexibility in the need to recertify BIF units every 3 years. Performance tests for process vents required under numerous regulations in the Clean Air Act (NESHAPS, NSPS, NSR, RACT) are generally conducted once by the compliance date and again only when operating conditions change. A recertification is essentially the same as a performance test. As long as operating conditions do not change and BIF operating conditions remain within specified operating parameters, then a recertification should not be required. Dow would also like the ability to consolidate performance tests required for compliance with NSPS, NESHAPS, and RCRA into one performance test.

7. The request to specify that a risk assessment is not necessary if BIF technical standards are met, or, alternatively, BIF technical standards can be waived if the unit passes a risk assessment is based on the current EPA Combustion Strategy that appears to require a risk assessment in addition to compliance with the standards. If this requirement is not included in the technical standards nor is required by the Combustion Strategy, then Dow does not need to pursue this point. However, we would like the option to negotiate this point as appropriate.

I hope this response answers your questions related to our Project XL proposal. If you would like to discuss any of these answers in more detail, please feel free to call me at 400-238-4132.

Sincerely,

Sandy Henderson

Senior Environmental Associate

Environmental Services

FOR MORE INFORMATION CONTACT:

Scot Wheeler

The Dow Chemical Company

2020 Dow Center

(517) 536-2205

February 8, 1995


DOW TO REDUCE DIOXIN EMISSIONS

FROM MANUFACTURING FACILITIES

MIDLAND, Mich. - The Dow Chemical Company announced today that it will reduce overall dioxin emissions by greater than 80 percent from its manufacturing facilities over the next decade with some facilities having a 1990 baseline. To meet this target, Dow expects to invest approximately $250 million in a variety of projects which are expected to yield significant recycling and incineration improvements while greatly increasing its manufacturing efficiency.

"Dow has invested nearly three years of extensive research into incinerator technology at our Stade, Germany site to make significant dioxin reductions possible," said Jerry B. Martin, Vice President of Environmental Affairs for Operations. "These reductions are also possible through Dow's investment in recycling and pollution prevention technologies aimed at reducing the amount of organic water being incinerated."

The results Dow expects to gain through this initiative are closely aligned with the chemical industry commitment to characterize the sources of dioxins and to reduce public exposure to emissions. Dow plans to achieve its new goals in a voluntary manner while continuing its use of leading edge combustion technology as an important tool in responsible waste management.

According to the U.S. Environmental Protection Agency, hazardous waste incineration accounts for less than 1 percent of known dioxin emissions nationally. EPA is currently formulating programs to characterize and reduce emissions from other industrial and non-industrial sources.

Dow's announcement today follows on the heels of a company report in August that it is well within reach of its global goal to eliminate priority compound emissions by 50 percent to air, water and land by the end of 1995. Dow reported that the emissions of these priority compounds have been cut by more than 40 percent between 1988 and 1993.

"This initiative is consistent with the guiding principles of Responsible CareŽ and represents a major step forward in our effort to continuously improve our environmental performance," said Martin. "Toward that end, we have invested nearly $1 billion over the past six years which is approximately 10 percent of our total capital expenditures each year."

Dow, based in Midland, Michigan, is a manufacturer and supplier of more than 2,000 product families including chemicals and performance products, plastics, hydrocarbons and energy, agricultural products, pharmaceuticals and consumer products. Dow has annual sales of more than $20 billion, operates 183 manufacturing sites in 33 countries and employs about 55,000 people around the world.


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Table 1

Plant/Process
Interim status in 1995 for burning RC1 liquids?
Operational in 2005 for burning RCI liquids?

Mag (B-824)
Yes
Yes

Mag (B-821)

Mag (B-822)

Mag (B839)
Yes

Yes

Yes
No (June 1995)

No (June 1995)

No (June 1995)

Mag (A-607A)

Mag (A-607B)
Yes

Yes
No (1997)

No (1997)

Mag (A-619C)

Mag (A-619D)

Mag (A-619E)
Yes

Yes

Yes
No (1996)

No (1996)

No (1996)

Allyl Chloride (F-2A)

Allyl Chloride (F-2B)
Yes

Yes
No

No

Allyl Chloride (FTD-603)
Yes
Yes

TDI (F-820A)

TDI (F-820B)
Yes

Yes
No (~2000)

Evaluating

Glycerine I (F-11)
Yes
No

Glycerin I (FTB-210)
Yes
Yes

EDC/VCMI (R-30)
Yes
Evaluating

EDC/VCM I (FTB-400)
Yes
Evaluating

EDC/VCM V (FTB-401)
Yes
Yes

EDC/VCM-V (FTB-402)
Yes
Yes

Phenol (B-901)
Yes
Yes

Phenol (B-902)
Yes
Yes

Phenol (B-903)
Yes
Yes

Mag (R-100) - replaces A-619 C, D and E
No
Yes

Mag (R-200) - replaces A-619 C, D and E
No
Yes

Mag (R-300) - replaces A-607 A and B
No
Yes

TDI (F-2820) - replaces F-820 A and B
No
Yes
NOTE: This table is subject to change and is based on Dow's best estimate of burner needs through the year 2005.

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