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Crompton Corporation (Formerly Witco Corporation)
July 1, 1998 Meeting Minutes
I. Meeting Participants
Dennis Heintzman Witco-OSi
Okey Tucker Witco-OSi
Tony Vandenberg Witco-OSi
Brenda Gotanda Witco-Manko, Gold & Katcher
Beth Termini EPA Region III
Tad Radzinski EPA Region III
Brian Grant EPA Headquarters
Nick Franco EPA Headquarters
Nancy Birnbaum EPA Headquarters
Sherri Stevens Walker EPA Headquarters
Britt Ludwig WV DEP
Lucy Pontiveros WV DEP
II. Project Implementation Status
A. Beth Termini and Brenda Gotanda opened the discussion noting that this call had been convened to address issues raised by EPA yesterday afternoon regarding the status of OSi's implementation of its XL Project. EPA had expressed concerns about the recent delay in completion of the initial performance test of OSi's new thermal oxidizer. OSi advised EPA that the delay was the result of unanticipated problems with the operation of the new control equipment. The purpose of this call was to bring the agency up to date on the status of project implementation and to explain the causes of the delay.B. Dennis Heintzman explained that the new thermal oxidizer installed at the facility under the XL project had experienced several mechanical difficulties after start-up. Dennis advised EPA that it appears that the problems with the new equipment have now been resolved, however, he noted his frustration and disappointment that such problems were encountered at all since OSi had performed a diligent inquiry concerning the experience and reputation of the vendor, including checking references, prior to purchase in a concerted effort to avoid potential equipment problems. Dennis added that because OSi felt confident with the recommendations it had received concerning this vendor, it had agreed during FPA negotiations to a reduced period of time for start-up and shakedown of the new equipment. He noted that typically facilities are provided with a 180-day period to adjust new control equipment to its proper efficiency, but that in the spirit of XL and pursuant to OSi's commitment to providing superior environmental performance, OSi had agreed to a shorter period of 60 days. Unfortunately as a result of the unanticipated mechanical difficulties encountered with the equipment after start-up, OSi was unable to complete its performance test prior to the deadline set forth in the FPA. Nevertheless, Dennis noted, OSi has not operated the capper unit without simultaneous operation of the thermal oxidizer since startup of the oxidizer (April 1, 1998) except as provided by the startup shutdown malfunction provisions of the Reg. 13 permit and the FPA. When mechanical difficulties were encountered with the thermal oxidizer, the production unit was held down and was not operated. Further, when the production unit was operating, the thermal oxidizer was run at least at its minimum required temperature of 1600 degrees Fahrenheit. OSi, therefore, has continued to meet its FPA commitments to reducing emissions as there have been no uncontrolled emissions from the capper unit since start-up of the thermal oxidizer. C. Tony Vandenberg, who has been handling the XL project implementation for OSi on a day-to-day basis, provided an overview of OSi's implementation activities since start-up on April 1, 1998. He noted that OSi initially encountered problems in maintaining the proper temperature for curing of the refractory. It was subsequently discovered that the control equipment had been fitted with an improperly sized burner, which prevented the equipment from heating properly. OSi has since replaced the burner. In addition, OSi encountered problems associated with water leaks from the quench. To remedy this problem, it was necessary for OSi to send a portion of the equipment off-site to be re-lined with a different type of refractory. Tony noted that the identification and resolution of these problems required considerable time and attention by OSi, its contractor, and their subcontractors and vendors. Tony estimated that OSi invested over 200 hours of unplanned maintenance and craftsperson time to deal with these implementation issues plus over 500 hours of time spent by environmental and engineering professionals at the plant in efforts to resolve the problems. In addition, OSi has expended additional sums of money for new materials. Tony added that OSi has been very serious about its commitment to EPA and WVDEP under Project XL. Any delay in Project implementation has been beyond the control of, and despite the best efforts of, OSi. D. Tony explained that when OSi realized that it would not be able to complete the performance test by the original deadline, he contacted the agencies immediately and requested an extension of time. Pursuant to the terms of the FPA, OSi was to have completed the initial performance test by May 30, which was 60 days after startup. Tony noted that on May 21 it was determined that, as a result of problems with the new thermal oxidizer, OSi could not complete the performance test by the original deadline. Accordingly, Tony contacted Jon McClung (WVDEP) and Beth Termini (EPA) on that day to explain the situation and to verbally request a 60-day extension of the performance test deadline. WVDEP responded to OSi on May 26, verbally approving the extension and requesting that OSi prepare draft language to amend the WVDEP Consent Order and Reg. 13 permit. By May 29, the WVDEP documents extending the deadline were executed and finalized, granting OSi the 60-day extension. Tony sent an e-mail to Beth Termini and Michele Aston to advise them that WVDEP had granted the extension. In the interim, Tony had spoken with Beth concerning how to extend the EPA deadline in the site-specific rule, since the rule had not yet been finalized. On June 4, Tony received a call from EPA expressing its concern about the delay and suggesting a course of action for extension of the deadline. EPA stated that it would provide OSi with only a 30-day extension, but that such extension could be followed by two additional 15-day extensions, if necessary. EPA noted that it would add these extensions into the draft site-specific rule. During the June 4 call, EPA requested that OSi submit a letter summarizing the problems. This letter was provided to Tad by Okey via e-mail, fax, and U.S. mail on June 10, 1998.