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Uniroyal Chemical Co.

Initial Proposal

UNIROYAL CHEMICAL COMPANY, INC.
P.O. Box 397
Geismar, Louisiana 70734
504-673-8871
504-387-5112


May 30, 1997
Receipt Certified #P279 031 426


Regulation Reinvention Pilot Project
FRL-5197-9, Water Docket
Mail Code 4101
U.S. Environmental Protection Agency
401 M Street, SW
Washington, D.C. 20460

Re: Project XL - Uniroyal Chemical Company, Inc., Geismar, Louisiana Facility


Dear Sir:

Uniroyal Chemical Company, Inc. hereby submits a proposal to achieve superior environmental performance through Project XL for the Geismar facility. Uniroyal Chemical has been working with the U.S. EPA Region VI and Louisiana Department of Environmental Quality (LaDEQ) to implement polution prevention projects that will reduce the generation of hazardous wastes and pollutant by 1.5 million pounds every year. This is a summary of the proposal. We have developed a detailed description of this proposal which, at their request, has been submitted to LaDEQ and U.S. EPA Region VI for their review. The detailed supplement to this proposal will be submitted as soon as their review is complete.

Uniroyal Chemical proposes to achieve the superior environmental performance by applying resources to implement pollution prevention projects that would otherwise be required to construct an on-site waste water treatment plant. The waste water treatment plan twould decrease the aluminum hydroxide solids discharged by the facililty by approximately 4,000 pounds per day, while creating 19 million pound sper year of wastewater treatment sludge. This sludge would be transported through local communities and disposed of in local landfills.

The facility's current NPDES discharge permit issued in 1995 includes a schedule whereby Uniroyal Chemical must begin construction of a waste water treatment plant in June 1997 and have it operating in April 1998. This waste water treatment plant would be removing Total Suspended Solids (TSS), primarily aluminum hydroxide, from the facility's wastewater. The facility has been discharging TSS containing aluminum hydroxide since 1964 with no known adverse impact to the environment. The facility has passed bioassay toxicity tests on its effluent every year since 1988.

The facility's discharge is regulated under the Clean Water Act by the effluent guidelines set for th in 40 C.F.R. 428.32 (Rubber Manufacturing Point Source Category -- Subpart C, Solution Crumb Rubber Subcategory). These effluent guidelines were promulgated in 1974. And the NPDES permits were issued to the facility in 1983, 1988, and 1991, these regulations were interpreted by U.S. EPA Region VI in such a manner as not to require the construction of an on-site waste water treatment plant.

Beginning in 1993, U.S. EPA Region VI changes its interpretation on how and where the pH limitations of the guidelines should be monitored, resulting in the facility's inability to comply with the applicable TSS requirements in the effluent guidelines. The facility's 1995 LPDES permit contains a compliance schedule for constructing and operating the necessary waste water treatment plant.

The construction of the waste water treatment plant will not eliminate or reduce any polluatnts; it will simply transform approximately 4,000 pounds per day of TSS into 19 million pounds per year fo waste water treatment sludge. The 19 million pounds of solid waste will have to be transported through local communities and disposed of in local landfills annually. The increased risk associated with this activity, including transportation hazards, vehicle air emissions and risks associated with land disposal are precisely the types of increased hazards to local communities that the President and U.S. EPA seek to avoid through the implementation of Executive Order 12898 on Environmental Justice.

In the past 33 years of the facility's operation, there is no evidence that its TSS discharge has caused any water quality problems in the Mississippi River where the facility's waste water is discharged. Indeed, the facility has conducted bioassay toxicity tests on its effluent every year since 1988 and passed each of those tests. Therefore, constructing an doperating the waste water treatmen tplant to remove TSS will not improve water quality -- rather it will simply move solids from one medium (water) to another (land disposal). This is contrary to the Agency's policy against cross-media transfers that create no environmental benefit.

Uniroyal Chemical is proposing to allocate several million dollars for the pollution prevention projects that will reduce the generation of hazardous wastes and pollutant by approximately 1.5 million pounds per year. Not only will this result in a significant reduction in the generation and off-site disposal of hazardous waste, it will also avoid the transportation of 19 million pounds per year of waste water treatment sludge.

Uniroyal Chemical has prepared a comprehensive description of this Project XL proposal that sets forth in detail the superior environmental performance, the regulatory flexibility sought, and how the proposal meets all of the Project XL criteria. Uniroyal Chemical has submitted a draft of the detailed proposal to U.S. EPA Region VI and LaDEQ for their review, at their request to insure conformity to U.S. EPA's Project XL's guidelines and to obtain early input from these key stakeholders. We will submit the comprehensive description supplementing this proposal as soon as their review is complete. Uniroyal Chemical has received an order from LaDEQ which grants the stay of permit schedule for constructing the waste water treatment plant for a specified time during the pendency of our Project XL proposal approval and the negotiations of the Project XL Final Project Agreement. If the proposal does not result in a successful resolution, the permit schedule for the waste water treatment plant will be reactivated by the LaDEQ.

We are very confident that our proposal will meet and exceed U.S. EPA's Project XL criteria, and look forward to working with U.S. EPA, LaDEQ and other stakeholders on this project. If you have any questions, please do not hesitate to call me at (504) 387-5112.

Yours truly,



Jay S. Patel
Environmental Manager

JSP1.00g/mlg/File: 8.4.3.4

cc: Adele Cardenas (6EN-XP)
Environmental Engineer
U.S. EPA Region VI
1445 Ross Avenue
Dallas, Texas 75202-2733
(Receipt for Certified Mail #P279 031 428)

John Glenn,
Special Projects Manager
Office of the Secretary
Louisiana Department of Environmental Quality
P.O. Box 82263
Baton Rouge, Louisiana 70884-2263
(Receipt for Certified Mail #P279 031 429)

Gary Aydell,
Administrator
Office of Water Quality
Louisiana Department of Environmental Quality
P.O. Box 82215
Baton Rouge, Louisiana 70884-2215
(Receipt for Certified Mail #P279 031 430)

Linda Korn Levy
Assistant Secretary
Office of Water Resources
Louisiana Department of Environmental Quality
P.O. Box 82215
Baton Rouge, Louisiana 70884-2215
(Receipt for Certified Mail 3P279 031 431)


UNIROYAL CHEMICAL COMPANY, INC.
P.O. Box 397
Geismar, Louisiana 70734
504-673-8871
504-387-5112


August 7, 1997

Certified Receipt #P279 033 143


Regulatory Reinvention Pilot Projects
FRL-5197-9
Water Docket, Mail Code 4101
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460

Re: Uniroyal Chemical, Inc.
Project XL Proposal

To Whom It May Concern:

Enclosed for U.S. EPA's consideration is Uniroyal Chemical Inc.'s proposal to participate in EPA's Project XL. This proposal responds to and meets each of the criteria set forth in EPA' solicitation, 60 Fed. Reg. 27282 (May 23, 1995); 62 Fed. Reg. 19872 (April 23, 1997). This proposal reflects comments from U.S. EPA Region VI and the Louisiana Department of Environmental Quality (LaDEQ) on an earlier draft that we provided them.

This proposal offers EPA, the Louisiana Department of Environmental Quality, Uniroyal Chemical and our stakeholders to work together to implement innovative approaches to environmental protection that will significantly decrease the volume of hazardous and solid waste generated by Uniroyal Chemical's Geismar, Louisiana facility.

We urge you to accept this innovative proposal. If you have any questions, please do not hesitate to call Jay Patel at (504) 387-5112, ext. 783, or me at (504) 387-5112, ext. 737. We look forward to working with you.

Yours truly,



V.J. Stadolnik
Factory Manager

JSP/xlpro2/mlg
Attachments
File #8.4.3.4.

cc: William B. Hathaway
Director Water Quality Protection Division
U.S. EPA Region VI
6WQ
1445 Ross Avenue
Dallas, Texas 75202-2733
(Certified Receipt #P279 031 416)

Adele D. Cardenas, P.E.
Environmental Engineer - Project XL
U.S. EPA Region VI
6EN-XP
1445 Ross Avenue
Dallas, Texas 75202-2733
(Certified Receipt #P279 033 144)

J. Dale Givens,
Secretary
Louisiana Department of Environmental Quality
P.O. Box 82135
Baton Rouge, LA 70884-2263
(Certified Receipt #279 033 151)

Linda Korn Levy
Assistant Secretary
Office of Water Resources
Louisiana Department of Environmental Quality
P.O. Box 82215
Baton Rouge, Louisiana 70884-2215
(Certified Receipt #P279 033 147)

John C. Glenn,
Special Projects Manager - Project XL
Office of the Secretary
Louisiana Department of Environmental Quality
P.O. Box 82263
Baton Rouge, Louisiana 70884-2263
(Certified Receipt #P279 033 145)

Gary Aydell,
Administrator
Office of Water Quality
Luoisiana Department of Environmental Quality
P.O. Box 82215
Baton Rouge, Louisiana 70884-2215
(Certified Receipt #P279 033 146)


UNIROYAL CHEMICAL COMPANY, INC.
GEISMAR, LOUSIANA FACILITY

PROJECT XL PROPOSAL

August 7, 1997


SUMMARY OF PROJECT
Uniroyal Chemical Company, Inc.'s Geismar, Louisiana facility seeks to implement pollution prevention projects that will reduce the generation of hazardous wastes and pollutants by 1.5 million pounds every year. This superior environmental performance will be achieved by applying to these pollution prevention projects some of the resources that would otherwise be required to construct an on-site waste water treatment facility that would generate over 12.5 million pounds of waste water treatment sludge per year.

The applicable Clean Water Act effluent guidelines appear to require Uniroyal Chemical, at a cost of several million dollars, to construct and operate a new waste water treatment plant. This new plant, which would supplement the existing treatment system that removes rubber-related mateirals from the waste water, would decrease the relatively small amount of non-toxic solids contained in the facility's waste water that are discharged to the Mississippi River. However, this new waste water treatment plant would also generate over 12.5 million pounds per year of waste water treatment sludge that would have to be trucked through local communities to local disposal facilities.

The current discharge of solids, which has been permitted for 20 years, does not pose any actual or potential risks to human health or the environment. Further, the generation, transport and disposal of tons of sludge generated by the required waste water treatmentplant will actually increase risks to public health, safety and the environment. The application of the effluent guidelines will simply transfer environmental loadings from one medium (water) to another (land) at great cost while at the same time increasing, not decreasing, risks to human health and the environment. The effort associated with building and operating the waste water treatment plant would be better allocated to projects that significantly improve environmental performance without any "downside" risks or cross-media transfers.

Uniroyal Chemical proposes to implement pollution prevention project sthat will produce real and permanent reduction of hazardous wastes generated by the facility. The facility intends to eliminate the generation of 1.5 million pounds per year of hazardous wastes and pollutants through four specific projects.

1. Improve Toluene Recovery: This will result in a reduction of the off-site hazardous waste disposal of toluene wastes (F005//D001) from 698,000 pounds per year to 398,000 pounds per year, a 300,000 pound/year reduction (or 43%). 2. Recvery and Recycle Solvents (primarily toluene) from High Boiling Tars: This will result in the reduction of the off-site hazardous waste disposal of these solvent wastes (F005/D001) from 4,000,000 pounds per year to 3,200,000 pound sper year, a 800,000 pound/year reduction (or 20%). 3. Ketone Reccovery: This will result in the reduction of off-site hazardous waste disposal of ketone wastes (F003) from 650,000 pounds per year to 350,000 pounds per year, a reductino of 300,000 pounds per year (or 46%). 4. Ketone Secondary Separation: This will result in the reduction of a water soluble ketone in the water effluent disposed via underground injection well from 150,000 pounds per year to 50,000 pounds per year, a reduction of 100,000 pounds per year (or 67^).

The facility is also investigating additional water conservation opportunities to enhance its existing water conservation program. Since the facility has successfully implemented a number of water conservation program over the past several years, it is currently not clear what, if any, additional water conservation opportunities exist.

It is important to note that these are all pollution prevention projects that will not only decrease the volume of hazardous waste generated; they will also decrease the volume of chemicals that the facility must use. These projects are a much more efficient and environmenatlly protective use of Uniroyal Chemical's resources than constructing a treatment plant that will actually increase the amount of waste generated by the facility.

Uniroyal Chemical seeks, through its NPDES permit or some other appropriate legal mechanism, the flexibility to continue to discharge its waste water in a manner consistent with its earlier permits so that it will not have to construct and operate the new waste water treatment plant. This will allow Uniroyal Chemical to implement the pollution prevention projects that will result in truly superior environmental performance.

This proposal meets the criteria set forth by U.S. EPA for Project XL initiatives (set forth in 60 Fed. Reg. 27282 (May 23, 1995) and 62 Fed. Reg. 19872 (April 23, 1997).

Superior Environmental Performance: This project will result in the elimination of 1.5 million pounds per year of hazardous wastes and pollutant, decrease the volume of chemicals that the facility must transport to the facility as raw materials, and will avoid generating and transporting over 12.5 million pounds per year of waste water treatment sludge through local communities to local landfills. This superior environmental performance is summarized in the following table.
ENVIRONMENTAL LOADING
WITHOUT PROJECT XL
WITH
PROJECT XL
DIFFERENCE WITH PROJECT XL
Off-site Hazardous Waste Disposal
9,269,379
pounds per year
7,869,379
pounds per year
1,400,000
pounds per year reduction
On-site Deep Well Injection
1,817,820
pounds per year
1,717,820
pounds per year
100,000
pounds per year reduction
TSS Discharged to River @ pH7
48,180
pounds per year
1,500,515
pounds per year
(current level)
1,452,335
pounds per year
(maintain current level)
Waste Water Treatment Plant Sludge to Landfill
12,699,567
pounds per year
0
pounds per year
12,699,567
pounds per year reduction
Truckloads of Hazardous Waste
276
trucks per year
241
trucks per year
35
trucks per year reduction
Truckloads of Solid Waste
1,102
trucks per year
725
trucks per year
377
trucks per year reduction
Raw Materials Savings
0 pounds
1,290,060
pounds per year reduction
1,290,060
pounds per year reduction

This project will clearly result in superior environmental performance.

Stakeholder Support: This project is supported by the Louisiana Department of Environmental Quality (LaDEQ) and U.S. EPA Region VI, and will be discussed with the facility's local community environmental group. The facility has, in conjunction with LaDEQ, developed a plan for stakeholder participation in this project. This plan has the following features:

- Working with U.S. EPA, LaDEQ and local stakeholders to identify potential "direct participants" and "commentors" in this project. This procedure includes makes direct contacts with stakeholders and, if this proposal is accepted, publishing a notice in the local media inviting participation. - Forming early in the project development process a Stakeholders Advisory Committee consisting of "direct participants" that Uniroyal Chemical will work with during the project development and Final Project Agreement negotiation phases. This Stakeholders Advisory Committee is intended to be a balanced and representative group whose makeup and ground rules will be agreed upon in a cooperative manner with all participants. The Stakeholders Advisory Committee will meet on a regularly schedules and open basis. - Those who wish to be "commentors" will be placed on a mailing list, kept up-to-date on project developments and activities of the Stakeholder Advisory Committee and be given notice and opportunities to comment on draft documents.

This plan is described in more detail beginning on page 13 of this proposal.

Regulatory Flexibility: Without regulatory flexibility, the facility will be forced to construct and operate a waste water treatment plant that will increase, not decrease, risks to human health and the environment. This project seeks a more flexible approach to Clean Water Act permitting and the application of the effluent guideline regulations to the facility, allowing the facility to better allocate its resources to achieve superior environmental performance.

Cost Savings: This project will re-direct certain of the resources that would be required by the construction and operation of the waste water treatment plant, resulting in several million dollars dedicated to four pollution prevention projects. These projects will produce superior environmental performance with less cost than if the current regulatory requirements were inflexibly applied. These projects will create additional cost savings by decreasing the volume of wastes that are transported and disposed of off-site and by reducing the volume of new chemicals that must be brought to the site as raw materials.

Innovative/Multi-Media Pollution Prevention: This project approaches pollution prevention from a multi-media perspective by avoiding spending scarce resources on simply transferring solids from one medium (water) to another (land), and instead focusing the facility's efforts on permanent reductions in the generation of hazardous wastes and pollutants. By improving the facility's capability to recycle and reuse solvents, this project will also reduce the amount of new chemicals that the facility must use as raw materials.

Shifting of Risk Burden: This project will reduce risks to our community and is consistent with Executive Order 12898 on Environmental Justice. Indeed, this project will:

- avoid the generation of millions of pounds of sludge that would have to be transported through local communities and disposed of in local landfills; - eliminate the generation of 1.5 million pounds/year of hazardous waste that is currently transported through local communities for land disposal; and - decrease the volume of chemical raw materials that must be transported to the facility through local communities.

Transferability: This project will produce transferable experiences for U.S. EPA and LaDEQ by suggesting creative and more environmentally protective solutions to multimedia challenges. Further, Uniroyal Chemical is prepared to share information about its pollution prevention processes, with the caveat that confidential business information cannot be disclosed.

We are confident that this project meets U.S. EPA's Project XL criteria and will produce superior environmental performance in a manner that meets the expectations of Uniroyal Chemical, U.S. EPA, LaDEQ, and the community.

DESCRIPTION OF THE PROJECT
THE CURRENT SITUATION

UNIROYAL CHEMICAL COMPANY, INC. - GEISMAR, LOUISIANA FACILITY

Uniroyal Chemical Company, Inc., a subsidiary of Crompton & Knowles Corporation, has been operating this facility in Geismar, Louisiana since 1963. The site employs more than 500 people and produces over 290 million pounds of products per year. The site is a major world-wide producer of synthetic rubber products primarily used in automobiles, rubber hoses, roofing, and wire and cable. The site also produces a variety of specialty chemicals used as processing aids and antioxidants for the rubber and plastic processing industry. These specialty chemicals protect and extend the life of products affected by exposure to the sun and other weather conditions.

The facility has a long record of superior environmental performance. Among the facility's accomplishments are:

1. The facility has maintained an excellent compliance record, including passing a recent U.S. EPA Region VI multi-media inspection.

2. By 1995, the facility decreased its Toxics Release Inventory reportable releases by 11.4 million pounds, a 79% reduction from its 1990 reportable releases.

3. Exceeded applicable Clean Air Act MACT standard for hexane several years ahead of schedule.

4. Received a National Performance Review Certificate from Vice President Al Gore for outstanding achievements in U.S. EPA's 33/50 program.

5. Recognized as an LaDEQ Environmental Leadership Facility.

6. Received the 1997 Louisiana Governor's Award for outstanding achievements in pollution prevention.

7. Received U.S. EPA Region VI 1996 Regional Administrator's Environmental Excellence Award for Underground Injection Control Class I Non-hazardous Injection Well Category.

8. Recognized as a "Facility of the Year' in 1997 by the Environmental Protection Magazine.

Attachments 1-8 provide additional information on these points.

The facility has had a long and positive relationship with the local community through several programs. The facility participates in the local Community Advisory Panel (CAP) and Community Awareness and Emergency Response (CAER) committee. Both the CAP and CAER routinely inform the loal community regarding Uniroyal Chemical's environmental performance, including releases to the environment and the facility's various pollution prevention projects. The facility has also "adopted" two local schools, providing educational support through employee participation, and has also established local university scholarship fund for environmental engineering education.

Overall, the facility is very proud of its "beyond compliance" environmental performance record, and looks forward to enhancing that superior environmental performance through this project.


THE CLEAN WATER ACT REGULATIONS AND THEIR IMPACT ON UNIROYAL CHEMICAL'S OPERATION

Uniroyal Chemical discharges 800,000 gallons per day of waste water from the synthetic rubber manufacturing plant. The facility's discharge is regulated under the Clean Water Act by the effluent guidelines set forth in 40 C.F.R. 428.32 (Rubber Manufacturing Point Source Category - Subpart C, Solution Crumb Rubber Subcategory). These effluent guidelines were promulgated in 1974. The effluent guidelines establish parameters for COD, BOT, Total Suspended Solids (TSS), Oil and Grease and pH. The pH parameter is set at 6-9. What is at issue in this proposal is where the pH is measured and how the facility's TSS discharges will be regulated. The process wastewater is first created at the facility by rubber "crumb removal" in five "crumb pits." Crumb removal involves the physical removal (skimming) of floating solids from the wastewater. All crumbs are transported off-site for disposal. The significant remaining materials in the effluent are catalyst residues. These catalyst residues remain in solution at low pH and only precipitate as inert and non-toxic aluminum (~ 90%) and vanadium hydroxides (~ 10%) ("hydroxides") when neutralized. These catalyst solids cannot be removed through simple gravity separation like the rubber crumb solids.

The permitted outfall for the effluent is located at the facility and is not the point where effluent is discharged to the Mississippi River. The discharge is sent to a treatment facility operated by Monochem, Inc., where the facility's effluent is adjusted for pH prior to discharge through a common effluent pipe to the Mississippi River. Monochem is an independent utility company that is jointly owned by Uniroyal Chemical and Borden Chemical & Plastics. This arrangement has been in place since 1963.

The NPDES permits issued by U.S. EPA Region VI for the facility in 1974, 1983, 1988, and 1991 allowed the facility to discharge its effluent without pH adjustment prior to it being piped to the Monochem treatment plant. The effluent has been neutralized by Monochem to the required pH of 6-9 prior to discharge to the Mississippi River since 1963. The pH of the effluent at the facility before it is piped to Monochem ranges from 3 to 4. At that pH level, the catalyst residues do not precipitate out of the effluent as solids. After pH adjustment at Monochem, approximately 4,000 pounds/day of hydroxide solids precipitate out of the Uniroyal Chemical facility's effluent. The approach taken by the 1974-1991 NPDES permits allowed the facility to meet its TSS limit at the discharge point from the facility.

For the 1993 NPDES permit, U.S. EPA Region VI changed the approach of the previous permits. Rather than allowing the pH limit to be controlled at the outfall to the Mississippi River at Monochem, the Agency required that the pH limit be controlled at the facility prior to the effluent discharge to Monochem. Controlling the effluent to the 6-9 pH level at the facility ahs a significant effect on Uniroyal Chemical's ability to meet the TSS requirements of the effluent guidelines. At a higher pH, the catalyst residues have a greater tendency to precipitate out of the waste water as hydroxides and therefore increase the TSS concentrations at the monitoring point.

If Uniroyal Chemical's effluent is neutralized prior to the transfer to Monochem, the facility will not be able to meet the TSS limits set by the applicable effluent guidelines without constructing and operating a new on-site waste water treatment plant. The treatment plant would reduce the facility's TSS discharge from approximately 4,000 pounds per day to less than 130 pounds per day, thereby meeting the appliable effluent guidelines.

The facility has already conducted preliminary engineering studies on the design and operation of the treatment plant. The treatment plant would adjust the pH of the effluent through the addition of lime slurry. The hydroxides that precipitate from the effluent would be separated by a series of steps that would first result in the creation of a sludge with a 2% solids content. This sludge would be piped to a dewatering unit with a precoated (with diatomaceous earth) rotary vacuum filter. The dewatering unit would generate filter cake with a solids content of approximately 15%.

It is estimated that the treatment plant would generate over 12.5 million pounds of sludge per year. This figure is derived from calculations taking into account the quantity of solids that will precipitate out of the effluent, the solids that would be added to the sludge during the treatment process (primarily the diatomaceous earth during dewatering) and the water content of the sludge. This sludge would have to be land disposed at local solid waste landfills. It would take almost 400 truck trips per year to transport this sludge to offsite disposal locations. This outcome has several serious implications, including its impact on landfill capacity, the environmental impact of transportation, and the safety issues associated with the increased truck traffic through local communities.

The facility's current permit was issued on November 1, 1995, with an expiration date of October 31, 2000. The permit was initially issued by U.S. EPA Region VI as an NPDES permit, but since administration of the federal NPDES program was delegated to the state in August 1996, the NPDES permit was transformed into a state LPDES permit. The LPDES permit contains a compliance schedule for Uniroyal Chemical to construct a waste water treatment plant, with construction to begin in June 1997 and start-up scheduled for April 1, 1998. Uniroyal Chemical has received an order from LaDEQ which grants the stay of permit schedule for constructing the waste water treatment plant for a specified time during the pendency of our Project XL proposal approval and the negotiations of the Project XL Final Project Agreement. If the proposal does not result in a successful resolution, the permit schedule for the waste water treatment plant will be reactivated by the LaDEQ.

THE ENVIRONMENTAL IMPACT OF FOLLOWING THE APPLICABLE CLEAN WATER ACT REGULATIONS AT UNIROYAL CHEMICAL'S FACILITY

Forcing Uniroyal Chemical to meet pH and TSS limits within the facility boundary does not make environmental or economic sense for the following reasons:

1. It would not result in the elimination of any waste. Rather, it would simply transfer the TSS discharge from the river to a local landfill in the form of waste water treatment sludge with vastly increased weight and volume.

2. It would result in an increase in the amount of water generated by the facility. In an effort to eliminate approximately 4,000 pounds per day of TSS, the waste water treatment facility would generate over 12.5 million pounds per year of sludge. As discussed above, the high volume of sludge is due to its water content and the addition of solids from the filter medium during the dewatering process.

3. The TSS in the facility's discharge does not pose a threat to the environment. The TSS in the facility's discharge is primarily aluminum hydroxide, with low levels of vanadium oxide. The TSS contains extremely low concentrations (below those set by the effluent guidelines) of synthetic rubber crumbs, which was the primary constituent of concern when the U.S. EPA originally promulgated the effluent guidelines in 1974. The facility has conducted bioassay/toxicity testing on its effluent at a point prior to its transfer to Monochem every year since 1988, and has passed every test. Further, there is no evidence that the TSS in the facility's discharge has or could create any solids-related water quality problems in the Mississippi River. The facility has been discharging TSS to the river through Monochem since 1963, and there have been no problems detected over the past 34 years that would support mandating a dramatic reduction in TSS now.

4. Managing and disposing of over 12.5 million pounds per year of waste water treatment sludge would increase the environmental, health, safety and transportation risks associated with the facility's operations. The volume of sludge represents almost 400 truck loads per year that will have to be transported through local communities. This volume of truck traffic creates accident and spill risks, vehicle air emissions, increased energy use and potential concerns such as noise. Further, this volume of sludge will place a significant burden on local solid waste landfills.

The strict interpretation of the effluent guidelines applicable to Uniroyal Chemical would be contrary to a number of core U.S. EPA policies.

1. It is inconsistent with the well-accepted pollution prevention hierarchy, which stresses that environmental protection should initially focus on materials substitution and reuse rather than treatment and disposal. In this situation, not only are Uniroyal Chemical's resources being diverted from substitution and reuse to treatment, but the waste water treatment plant will actually generate more waste.

2. It is inconsistent with U.S. EPA's policy to avoid addressing environmental issues by transferring pollution from one medium to another. Requiring the transfer of non-toxic solids from the river to land disposal will actually increase environmental, health and safety risks.

3. It is inconsistent with the President's and the U.S. EPA's policy to avoid disproportionate impacts on local communities. Shifting the management of non-toxic solids from the discharge to the river, where there are no demonstrated ill effects after 33 years of discharge, to transporting hundreds of truck loads a year of sludge through local communities and to local landfills will increase the environmental, health and safety risks to the public.

For these reasons, the application of the effluent guidelines at the facility boundary does not make environmental or economic sense and regulatory flexibility is warranted and will result in significant benefit to the environment.

UNIROYAL CHEMICAL'S PROPOSAL
A. POLLUTION PREVENTION PROJECTS

In lieu of constructing the waste water treatment plant, Uniroyal Chemical proposes to undertake four pollution prevention projects that will result in the elimination of 1.5 million pounds per year of hazardous wastes and pollutant. Of the total, 1.4 million pounds per year will be hazardous wastes, and 100,000 pounds per year will be reductions in a non-hazardous pollutant disposed via deep well injection. The pollution prevention projects are based on raw materials recovery and recycle processes.

The baseline for these calculations is 1995 performance derived from data reported pursuant to the Toxics Release Inventory provisions of the Emergency Planning and Community Right to Know Act. The projected improvements in environmental performance related to each project are based on engineering calculations that rely on the facility's knowledge of the processes involved and professional expertise. More technical details associated with the projects can be discussed during the Final Project Agreement ("FPA") negotiation process.

1. Improve Toluene Recovery: This will result in a reduction of the off-site hazardous waste disposal of toluene wastes (F005/D001) from 698,000 pounds per year to 398,000 pounds per year, a 300,000 pound/year reduction (or 43%).

- The current toluene recovery process uses a vacuum technology. The efficiency of the recovery process would be enhanced to achieve the projected reductions by shifting to an atmospheric recovery system, which would entail the use of high pressure steam and heat exchangers. The performance of this project will be tracked through the TRI data collection and reporting process.

1. Recover and Recycle Solvents from High Boiling Tars: This will result in the reduction of the off-site hazardous waste disposal of these solvent wastes (F005/D001) from 4,000,000 pounds per year to 3,200,000 pounds per year, a 800,000 pound/year reduction (or 20%).

- These performance enhancements will be achieved by installing a secondary separation unit and associated storage units in order to recover intermediate reaction products and recycle material back to the manufacturing process. The performance of this project will be tracked through the TRI data collection and reporting process.

1. Ketone Recovery: This will result in the reduction of off-site hazardous waste disposal of ketone wastes (F003) from 650,000 pounds per year to 350,000 pounds per year, a reduction of 300,000 pounds per year (or 46%).

- This project will involve making improvements to the separation column to enhance the recovery of alcohol which will then be converted to usable ketone. The performance of this project will be tracked through the TRI data collection and reporting process.

1. Ketone Secondary Separation: This will result in the reduction of a water soluble ketone in the water effluent disposed via underground injection well from 150,000 pounds per year to 50,000 pounds per year, a reduction of 100,000 pounds per year (or 67%).

- A secondary ketone separation process will be added which will vaporize the aqueous phase from the existing decanting process and recover ketone which will then be returned to the manufacturing process. The performance of this project will be tracked by measuring the concentration of MIBK in the waste water.

Once initiated, two of the projects should be complete and operating in 2-3 years, while two other projects that require more extensive engineering and testing may take 4-5 years to become operational.

It is important to note that an additional benefit of these projects will be reductions in the quantities of chemicals the facility must use as raw materials.


A. REGULATORY FLEXIBILITY

The regulatory flexibility sought by Uniroyal Chemical is a variance (or some other appropriate mechanism) from the requirement that it meet the pH limit at the point where its effluent is transferred to Monochem. If the proposal is approved and a Final Project Agreement is signed, Uniroyal Chemical's LPDES permit would be revised to incorporate the permit conditions and limitations set forth in such agreement. However, if the facility is unable to obtain approval of the proposal within a defined period of time, the facility would be obligated to construct and operate the on-site waste water treatment system within a reasonable period of time thereafter.

Pending full consideration of Uniroyal Chemical's proposal and any resulting modification of Uniroyal Chemical's LPDES permit, the pH in Uniroyal Chemical's waste water discharges will be subject to an order issued by LaDEQ in June 1997.


B. MEASURING THE PROJECT XL CRITERIA

1. SUPERIOR ENVIRONMENTAL PERFORMANCE

This proposal clearly meets U.S. EPA's recently issued guidance on "superior environmental performance." 62 Fed. Reg. 19872 at 19873-19876 (April 23, 1997).

a. Tier One: The Tier One assessment establishes a benchmark which is a reasonable estimate of what has happened to the environment absent Project XL. The facility's projected performance under Project XL cannot be less than this benchmark. While the benchmarks are loadings set for each medium, U.S. EPA will allow "trade offs" among loadings where the overall level of environmental performance is superior. Therefore, it may be acceptable for projected performance to exceed loadings to a particular medium.

The relevant Tier One loadings for this proposal, i.e., those that would occur in the absence of Project XL, along with the facility's projected performance if Project XL is implemented, are as follows:
ENVIRONMENTAL LOADING
WITHOUT PROJECT XL
WITH
PROJECT XL
DIFFERENCE WITH PROJECT XL
Off-site Hazardous Waste Disposal
9,269,379
pounds per year
7,869,379
pounds per year
1,400,000
pounds per year reduction
On-site Deep Well Injection
1,817,820
pounds per year
1,717,820
pounds per year
100,000
pounds per year reduction
TSS Discharged to River @ pH 7
48,180
pounds per year
1,500,515
pounds per year
(current level)
1,452,335
pounds per year
(maintain current level)
Waste Water Treatment Plant Sludge to Landfill
12,699,567
pounds per year
0
pounds per year
12,699,567
pounds per year reduction
Truckloads of Hazardous Waste
276
trucks per year
241
trucks per year
35
trucks per year reduction
Truckloads of Solid Waste
1,102
trucks per year
725
trucks per year
377
trucks per year reduction
Quantity of Raw Materials Saved
0
1,290,060
pounds per year
1,290,060
pounds per year reduction


These figures speak for themselves; implementing this project will certain exceed the Tier One benchmark of the facility's projected environmental performance absent Project XL. The proposed pollution prevention projects are beyond any regulatory requirements and also economically unfeasible.

The only potential cause for concern is that the TSS loadings will be greate rwith Project XL than without. However, it is important to note that this is not an increase in TSS levels; it is maintaining the TSS levels that have been permitted for decades. There is no evidence that this discharge of TSS has ever caused a water quality problem over the past 34 years, and the fadcility has passed every bioassay/toxicity test of its effluent conducted over the past decade. Further, with the significant reduction in toxic waste generation and the avoidance of generating massive amounts of solid waste, there can be little doubt that Uniroyal Chemical's project is "equivalent" as discussed by U.S. EPA.

a. Tier Two: Assuming that the proposed project is at least "equivalent" as discussed above, the Agency applies a number of other criteria to evaluate whether the proposed project will produce "truly superior environmental performance." Uniroyal Chemical's project meets or exceeds these criteria.

(1) Increment by which the project exceeds the Tier One benchmark. The chart on the previous page vividly illustrates the degree to which this project will exceed the Tier One benchmark. 1.5 million pounds of hazardous wastes and pollutant per year will be eliminated and the generation of approximately 12.5 million pounds per year of waste water treatment sludge will be avoided. In addition, the facility will decrease its use of new chemicals as raw materials.

(2) Pollution prevention through source reduction instead of treatment or disposal. This project is premised on reducing pollution by process changes, reuse and recycling rather than treatment or off-site disposal. The existing regulatory regime would have the opposite effect: on-site treatment combined with significant levels of off-site land disposal. These projects will reduce the volume of new chemicals the facility must use as raw materials by over 1 million pounds per year. (3) The extent to which the project produces clear reduction of risk. This project will significantly reduce environmental risks by achieving major reductions in the generation and off-site disposal of hazardous wastes and avoiding the generation of even larger volumes of waste water treatment sludge. (4) Improvement in environmental conditions that are of interest to stakeholders. Among the benefits of this project will be reduced traffic associated with chemical deliveries and hazardous and solid waste transportation. This project will also reduce the loadings on local disposal sites. (5) Historic demonstration of environmental leadership. Uniroyal Chemical is a well-recognized environmental leader in the area of pollution prevention, having received awards from U.S. EPA Region VI, LaDEQ, the White House and professional groups.

Uniroyal Chemical's proposal meets U.S. EPA's Project XL criteria for superior environmental performance.

1. COST SAVINGS

This project will allow the facility to achieve a higher level of environmental performance at a reduced cost. It will re-direct a significant percentage of the funds associated with constructing the waste water treatment plant to the more effective pollution prevention projects. On an ongoing basis, it will decrease Uniroyal Chemical's cost of hazardous and solid waste disposal by reducing the amount of hazardous waste generated and avoiding the generation of over 12.5 million pounds per year of waste water treatment sludge.

2. STAKEHOLDER PARTICIPATION

At the initial phase of this project, Uniroyal Chemical has shared drafts of this proposal with U.S. EPA Region VI and LaDEQ in order to determine their interest in the proposal. Both agencies agree that the proposal would offer superior environmental performance and is worthy of consideration for Project XL.

Uniroyal Cheimcal has asked LaDEQ and EPA Region 6 to recommend potential "direct" and "commentor" stakeholders as described in 62 Fed. Reg. 19872 (April 23, 1997). We have specifically asked LaDEQ's Environmental Justice Coordinator, Janice Dickerson, for her recommendations for an environmental justice representative. We are also requesting recommendations from the Ascension Parish Council, the Louisiana Environmental Action Network, Save Our Selves, Ascension Parish Residents Against Toxic Pollutants (environmental justice) as well as the Citizens Advisory Panel ("CAP").

If accepted into Project XL, Uniroyal Chemical will publish a notice in the Gonzales Weekly and the Ascension Parish Citizen inviting additional citizen participation for both direct participants and commentors. In addition, we will notify local chapters of national environmental groups that have shown in interest in Project XL.

a. Stakeholder Advisory Committee Formation If accepted into Project XL, Uniroyal Chemical will host an initial meeting of the Stakeholders Advisory Committee. A major agenda item at the initial meeting will be to discuss the makeup and responsibilities of the advisory committee. Among the issues that must be addressed are which stakeholders will choose to be "direct participants" in the project and which will choose to be "commentors," as those terms have been defined by U.S. EPA. The number of "direct participants" should be large enough to be representative while small enough to be able to work effectively together. Uniroyal Chemical anticipates that there will be between 10 and fifteen "direct participants." If there appear to be too many potential direct participants, a process will be worked out amongst the various interests (Uniroyal Chemical, U.S. EPA, LaDEQ and other stakeholders) to create a balanced committee of a reasonable size. In such a situation, preference will be given to CAP members and those local stakeholders who could potentially be directly affected by the project.

The goal will be to create a balanced group of direct participants that represent local stakeholders and those interested in the broader implementation of the concepts being tested. Should a vacancy occur or should there be a decision to seek input from additional viewpoints, Uniroyal Chemical will work with LaDEQ, U.S. EPA and the existing direct participants to seek such input.

b. Commentors and the General Public All persons that request to be "commentors" on the project will be put on a mailing list. Commentors will be kept informed of the progress of the project, including minutes of Stakeholder Committee meetings. Commentors will be provided an opportunity to comment on draft documents (e.g., drafts of the FPA).

The general public will be kept informed through periodic news releases to the Gonzales Weekly and the Ascension Parish Citizen.

The FPA will be subject to general notice and comment via publication in the Federal Register.

c. Other Process Issues

The Stakeholder Advisory Committee will play a significant role in defining the project and providing stakeholder input on the project. Uniroyal Chemical has a history of excellent environmental performance and good relations with the community, and takes the views and concerns of the community very seriously.

The Stakeholder Advisory Committee will be advisory in nature: final authority to approve the project lies with U.S. EPA and LaDEQ. Uniroyal Chemical recommends that the Stakeholder Advisory Committee operate on a general consensus basis (rather than on a 100% unanimity basis). The Stakeholder Advisory Committee will meet on a regular basis, with the schedule to be worked out among the participants. The goal will be to meet on a schedule that enhances stakeholders' ability to participate on a regular basis.

If this proposal is accepted, the initial meeting of the Stakeholder Advisory Committee will, as discussed above, address issues such as the makeup of the committee and the procedures whereby it will operate. This initial meeting will also include an overview of the Project XL program (perhaps provided by either U.S. EPA or LaDEQ) and a presentation by Uniroyal Chemical outlining its proposal. The local press will be invited to this meeting.

If the project is approved, Uniroyal Chemical expects that the Stakeholder Committee will have an ongoing role in following the progress of the project. This role will be more clearly defined in the FPA.

1. MULTI-MEDIA POLLUTION PREVENTION

Without Project XL, the facility would be spending several million dollars simply to convert solids from its waste water to sludge destined for off-site land disposal. Uniroyal Chemical's proposed project would instead follow the well-accepted pollution prevention hierarchy and U.S. EPA policy by applying its resources to reducing or eliminating the generation of hazardous wastes and pollutants. The four projects to recover solvents will also result in reductions in the volume of new chemicals the facility must use as raw materials.

2. TRANSFERABILITY

This project should produce transferable experiences at both the conceptual and technical levels.

- On the technical side, to the extent permitted within the constraints of not disclosing confidential business information, Uniroyal Chemical will share technical information about the pollution prevention projects that will be implemented. While there are no many facilities that produce similar products in the U.S., some of the technologies employed by Uniroyal Chemical to reduce the generation of solvent wastes may be useful to other facilities in the chemical industry. In addition, the experience in the practical application of these technologies may also generate some useful "lessons learned" for other facilities.

1. FEASIBILITY

The pollution prevention projects proposed by Uniroyal Chemical are technically feasible. Uniroyal Chemical has already satisfied itself through engineering studies that the pollution prevention projects are feasible and is in the process of developing detailed plans on how to implement them. This work has included developing plans for conducting pilot studies. Top management has already committed the necessary resources should this proposal be accepted. The regulatory flexibility element of the project is also administratively and legally feasible, using the facility's LPDES permit as the legal vehicle.

2. MONITORING, REPORTING AND EVALUATION

This project is suited to clear tracking and reporting. The four proposed pollution prevention projects are capable of being monitored since they involve reductions in the generation of regulated waste. At this time, the primary tracking vehicle for the pollution prevention projects is anticipated to by TRI reporting. The objectives of the projects are well defined, as is the anticipated duration of the projects. These characteristics of the project will make reporting progress to regulators and other stakeholders relatively easy.

3. SHIFTING OF RISK BURDEN

This proposed project is consistent with Executive Order 12898 on Environmental Justice, is protective of worker safety, and does not subject anyone to unjust or disproportionate environmental impacts. Indeed, the project will do precisely the opposite by:

- significantly decreasing the quantity of hazardous wastes and pollutants generated by the facility; - avoiding the generation of much larger quantities of sludge that would have to be transported off-site through local communities and disposed of in local landfills; and

- reducing the volume of new chemicals that the facility must transport through local communities for use as raw materials.

CONCLUSION
Uniroyal Chemical is very proud of its past environmental performance and strongly believes that this proposal meets or exceeds all of U.S. EPA's requirements for Project XL. This project will produce demonstrable superior environmental performance in a defined period of time. The proposed pollution prevention projects, if approved, will provide measurable superior environmental performance. In the absence of the project, a waste water treatment plant may have to be built to meet the water effluent guidelines which will generate over 12.5 million pounds per year of solid waste and added environmental risks to the community.


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