Crompton Corporation (Formerly Witco Corporation)

Minutes for Meetings Used to Develop the Final Project Agreement

OSi Specialties - Project XL
August 27, 1996 Conference Call Minutes

I. Conference Call Participants

Jesse Barnhart Witco-OSi

Dennis Heintzman Witco-OSi

Okey Tucker Witco-OSi
Tony Vandenberg Witco-OSi
Brenda Gotanda Witco-Manko, Gold & Katcher
Tim Malloy Witco-Manko, Gold & Katcher
Cheryl Atkinson EPA Region III
Beth Termini EPA Region III
Michele Aston EPA Headquarters
Julie Frieder EPA Headquarters
Amey Marrella EPA Headquarters
Jonathan McClung WV DEP (OAQ)

II. Minutes Approved

The August 13 meeting minutes were approved by the Workgroup pending review and approval by Amy and Beth, both of whom had not yet had an opportunity to review them. Upon their concurrence, copies will be sent to everyone on the distribution list.

III. Project XL Criteria

A. The Workgroup reviewed and revised the draft Analysis of Project XL Criteria. Minor language changes are not incorporated in these minutes but will be reflected in the revised analysis, a redlined copy of which is appended hereto as Attachment 1.

B. Environmental Results

1. Cheryl suggested that the first paragraph under Environmental Results should break out the emissions reductions to indicate the level of reductions to be achieved for each period in which a distinct regulation will impact the Project, e.g., RCRA Subpart CC and CAA Subpart YYY. For example, indicate the level of reduction for the 1998 to 2000 time period (RCRA Subpart CC in effect) and then indicate the combined reductions to be achieved thereafter (CAA Subpart YYY in effect). Indicate for each, the level of reductions without Project XL and with Project XL.

2. In addition, Cheryl would like the analysis to identify, at some point, all the compounds, in addition to methyl chloride, which will be present in the emissions. When discussing the compounds collectively, they should be referred to as facility air emissions or organic compounds or volatile organic constituents, but not as volatile organic compounds or "VOCs" which Michele views as terms of art under the CAA.

3. Cheryl also requested the addition of a paragraph which describes in simple terms the methanol recovery condensing unit. She suggested that it may be helpful to describe it as a refrigerated condenser. OSi suggested that it may be more appropriate to include such description in the Project Description section of the Final Project Agreement ("FPA") where other equipment will be described. Cheryl agreed that including the description in that section of the FPA would be appropriate.

4. Okey noted that the XL criteria analysis reflects that there will be decreased sludge generation which would not be achieved in the absence of the Project.

5. Discussion of the paragraph describing the implications of the Miscellaneous Organic NESHAP ("MON") was deferred. It will be addressed in conjunction with the project termination issues at the next meeting of the Workgroup.

C. Performance Criteria

1. The performance criteria have yet to be developed.

2. EPA offered to provide assistance to OSi in drafting the criteria. EPA will discuss possible criteria internally and will provide Okey with some specific suggestions regarding what EPA would like to see included in the performance criteria.

D. Stakeholder Support

1. Okey informed the Workgroup that despite public announcements on the radio and in the newspapers, no one responded to OSi's invitation to attend the August 22 public meeting scheduled to educate interested parties on the basis for OSi's XL Project. Okey noted, however, that one plant employee, who is the union representative for employee safety and health, expressed an interest in learning how the Project may impact the issues for which he is responsible. OSi's XL team will meet with him individually to address his particular issues.

Cheryl suggested that perhaps OSi should open up this meeting to all interested employees at the plant. Okey noted that all employees of the plant were invited to the public meeting and none, other than this individual, indicated any interest in attending. This individual would simply like to know how the Project will impact him personally in his capacity as union representative for employee health and safety. Jesse Barnhart, who is also a union representative at OSi, noted that the Project is on the agenda for the plantwide manager update and so all the employees will hear about the Project again at that time and will have another chance to ask questions if they desire. In addition, Project XL has been discussed during regularly scheduled issues forum meetings at the plant. Jesse added that there is a tremendous level of ongoing communication at the plant about the Project and that the employees feel well-informed about the nature of the Project.

Cheryl replied that these extensive ongoing communication efforts should be detailed in the Public Involvement Plan and that the plan should be referenced in this section of the criteria. She explained that several national environmental groups have been particularly concerned with what they perceive is lack of attention to worker health issues in the XL Projects and, accordingly, EPA wants to make sure that these issues are fully addressed in all projects and are appropriately documented. Okey responded that the employee with whom they will be meeting is the union point person for employee health and safety and that they will ask him whether he believes that OSi should hold another meeting with the employees on these issues.

2. EPA noted that it appears that local community is being kept well-informed about OSi's XL Project and that they have not expressed concerns about the Project.

3. OSi has contacted Janet Fout of the Ohio Valley Environmental Coalition to inform her of the development of OSi's XL Project and invite her participation in the process. She indicated an interest in learning more about the Project and Okey has sent her materials from the administrative record file as well as the video from the kick-off meeting. She stated that she would contact Okey to advise him of her desired level of involvement, if any, in the Project development.

E. Monitoring, Reporting, Evaluation

1. This section of the analysis has yet to be developed.

2. Cheryl questioned whether it is possible to monitor emissions from the surface impoundments. Okey replied that it would not be feasible to do so, which is why EPA's Water 8 modeling software is used to estimate the emissions.

3. Cheryl suggested that the section on monitoring should provide for monitoring of the Project's overall impact, not just the control unit.

F. Cost Savings and Paperwork Reduction

1. EPA suggested that if there are cost savings associated with the reduction of sludges from the wastewater treatment unit under this Project, that those savings should be noted in this section.

2. There were some questions concerning the level of detail that should be included in this section. The Workgroup consensus was that this section, and all the other sections, should be kept fairly short and concise. Appendices with more detailed supporting information can be appended, if necessary, to the Final Project Agreement ("FPA"). The Workgroup agreed that this section should simply indicate the dollar savings associated with this Project and that the details, if any are necessary, should be set forth in an appendix.

G. Innovation/Multi-Media Pollution Prevention

1. EPA requested a number of changes to this section, which are reflected in Attachment 1.

2. OSi clarified its intent to shut down the old capper unit when the new capper unit is brought on-line.

3. As part of this Project, OSi will set up a methanol recovery operation. EPA will verify that methanol generated from this unit would not be considered "produced" for purposes of the NSPS.

4. The group discussed the innovative nature of the Project and clarified that it is the approach to pollution prevention and emissions reduction which makes this Project innovative, rather than the technology being employed.

5. Cheryl would like this section to be expanded to describe exactly what OSi will physically be doing in the Project.

H. Shifting of Risk Burden

1. Michele will provide a third paragraph for this section which speaks to the issue of risk.

IV. No Action Assurance

A. Beth advised the Workgroup that EPA Region III is in the process of drafting a no action assurance. She stated that she and Cheryl will be working on it and they anticipate that a draft will be available for internal circulation by the end of next week. They hope to get a draft to OSi the following week.

B. WV DEP indicated that they prefer to wait until EPA has prepared its no action assurance before the state takes action in this regard. WV DEP would prefer to follow EPA's lead.

V. Update on Deliverables

A. OSi advised that they will have the draft emissions estimates, with an executive summary, completed and out for circulation by August 29 or 30.

B. The draft regulatory analysis will be ready by the end of next week.

C. EPA advised that they currently favor the issuance of a site-specific rule to address the RCRA Subpart CC portion of the Project but have not yet made a decision on how they will handle CAA Subpart YYY.

D. To date, WV DEP has not made any decisions concerning appropriate legal implementation mechanisms. Tim and Brenda will contact Britt to follow up on this issue.

E. Tim inquired whether there are any other procedural requirements, not previously identified, which must be met under the program. Cheryl did not believe so but suggested that Tim speak directly with Beth (who had left the call).

VI. Next Meeting

The next meeting of the XL Workgroup will be held in Philadelphia at EPA Region III headquarters. The meeting will begin at 1:30 p.m. on Thursday September 5 and will take place during the afternoon of September 5 and the morning of September 6.
Attachment 1

Crompton Corporation (Formerly Witco Corporation)

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