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Crompton Corporation (Formerly Witco Corporation)

Letter from David Gardiner to Janet Fout

Ms. Janet Fout
Project Coordinator
Ohio Valley Environmental Coalition
1101 Sixth Avenue, Suite 222
Huntington, WV 25701

Dear Ms. Fout:

Thank you for your comments on the OSi XL project. In your letter, you state that OVEC is advocating a zero discharge of certain toxic chemicals. We recognize that zero discharge is a laudable goal; however, it is not always feasible, and we therefore support projects that move toward that goal. We believe that the OSi project is one of these projects.

The OSi project originally involved the replacement of its current methyl capper unit with a new unit. However, the project has been modified so that OSi will now install emission control equipment on its existing unit. It is my understanding that you have received information from OSi on the changes to the project. The information contained in this letter uses the new emission reduction figures for the proposal.

We understand your concern regarding OSi's toluene releases. In 1995 OSi had SARA 313 releases (including offsite transfers) of toluene totaling 1,728,008 pounds. Their media releases excluding offsite transfers totaled 165,326 pounds. Since toluene can have negative effects on the human nervous system, we share your interest in reducing human exposure. Therefore, we have set a limit for drinking water of 1 ppm toluene. In addition, we require that substantial spills or accidental releases of toluene be reported. Similarly, OSHA has set a limit of 200 ppm toluene for workplaces. No part of OSi's project will allow the company to exceed these limits. In addition, over the last two years OSi has reduced their toluene releases by 32 percent excluding offsite releases and 62 percent when offsite releases are included. However, as a result of your comments we have clarified with OSi that the feasibility studies conducted as part of its XL project will include possibilities for reducing toluene releases.

In your letter, you expressed concern about the carcinogenic effects of exposure to toluene. However, according to studies by the National Toxicology Program toluene does not cause cancer in humans. Similarly, the Department of Health and Human Services and the International Agency for Research on Cancer have not classified toluene as a carcinogen, nor does the Environmental Protection Agency regulate it as a carcinogen.

In addition to the toluene feasibility studies mentioned above, OSi's XL project will provide significant environmental benefits. The project will result in substantial decreases in the facility's air emissions and methanol and sludge discharges. It will also include waste minimization studies for the entire facility. Therefore, despite the fact that OSi's XL project would not necessarily reduce the facility's toluene releases, the project should result in the environment being significantly better off than it would have been otherwise. For example, the project will eliminate over 1 million pounds of air emissions over the life of the project and will reduce sludge generation by 500,000 pounds per year. It will also result in the recycling and reuse of about 500,000 pounds of methanol.

You note in your letter that OVEC's limited time and resources prevent it from thoroughly reviewing materials on the project and that OVEC is unable to Asign off@ on OSi's XL project. We would appreciate whatever time your organization has available to consider OSi's XL proposal and any comments that OVEC can provide. We will gladly do everything in our power to provide further information to you regarding the project. In addition, while, at times, stakeholders may sign the final project agreement or provide letters of support for an XL project, this is by no means a requirement for participation in the stakeholder process. We would be glad to hear any comments that you might have on the proposal and can assure you that we would not take your comments as implicit approval or rejection of OSi's XL project. We believe that the OSi XL project can only benefit from any comments that your organization is able to provide. We therefore request that you reconsider OVEC's involvement in commenting on the project.

If you have any further questions about OSi's XL project, please contact Nancy Birnbaum at 202/260-2601. Once again, thank you for your interest in Project XL.


David Gardiner
Assistant Administrator

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