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Crompton Corporation (Formerly Witco Corporation)

Minutes for Meetings Used to Develop the Final Project Agreement

OSi Specialties - Project XL October 11, 1996 Conference Call Minutes

I. Conference Call Participants

Okey Tucker Witco-OSi
Dale Koontz Witco-OSi
Tim Malloy Witco-Manko, Gold & Katcher
Brenda Gotanda Witco-Manko, Gold & Katcher
Beth Termini EPA Region III
Cheryl Atkinson EPA Region III
Julie Frieder EPA Headquarters
Jonathan McClung WV DEP

II. Performance Standards

A. The group agreed that as a result of recent regulatory changes, Tank T-872 is now exempt from RCRA Subpart CC. Therefore, it falls out of OSi's XL Project and references to the tank should be deleted from the FPA.
B. Beth stated that Michele would like OSi to look to the MACT standards, not just NSPS, in designing the Project XL performance standards because she believes that the capper unit may ultimately be subject to the MACT standards. Beth added that Jim Cashel had compared the two regulations found them to be quite similar, yet noted a few differences. Tim replied that OSi had reviewed the NSPS, the HON and RCRA Subpart CC. He also noted that the MACT standard, unlike the NSPS, was only designed to measure HAPs. Okey stated that OSi would review any differences and get back to EPA.
C. Beth will have Jim Cashel send his comments on the performance standards to OSi on Thursday. Tim requested that Beth ask Jim to walk through the Part 63 standards and note any significant differences between those standards and the proposed performance standards. In addition, OSi would like EPA to review the definitional differences, if any, for TOC in the process vent performance standards contained in section B.1.a. and those contained in Part 63.
D. Beth noted that the performance standards section of the FPA should reflect that the performance standards, as set forth in the FPA, are not enforceable, but that the standards agreed to will only become enforceable upon their incorporation into an enforceable legal mechanism. Therefore, terms such as "shall" and "will" should be avoided. The "shall" which appears at B.3.b.(1) will be removed.
E. The group agreed to delete the bracketed text in section A.1. as it was only included in the draft performance standards for explanatory purposes.
F. Beth requested that section B.3.a. be revised to include a subsection (2) which states that parameter boundaries will be established as a result of the performance test referenced in subsection (1).
G. Beth asked if Okey had prepared additional language regarding the condenser unit referred to in section C.1. Okey stated that the facility description section of the FPA has been revised to include a description of the design and operation of the methanol recovery operation.
H. Beth and Cheryl expressed some concerns with measuring methanol recovery on an annual basis and asked if the measurement could be made more frequently. Okey stated that there should not be great variations in recovery over different time periods because the system is designed to achieve a minimum recovery rate of 90 percent and the capper unit will not run unless the methanol recovery unit is in operation. The recovery rate of 90 percent was determined by OSi's Engineering Department. Okey added that, regardless of the efficiency of the operation of the methanol recovery system, no sludge or wastewater emissions will result because any methanol which is not condensed will go directly to the vent incinerator, not to the process sewer. Tim added that the technology OSi is implementing will be designed to provide a constant 90 percent methanol recovery rate; it is only the measurement of recovery that will be performed annually.
I. Cheryl inquired about the monitoring provisions and noted that they reflected the taking of various measurements. She suggested a change in the title of the section to reflect that measurements are taken.
J. Beth asked why temperature is being monitored. Okey replied that the regulations typically require measuring of temperature because it is the only way to perform a continuous monitoring of the operation of a unit. Beth also inquired what it is that will be monitored for temperature. Okey replied that the Engineering Department will inform us, once the design is completed, whether it would be more appropriate to measure the temperature of the cooling media (the brine) or the methanol which is condensed.
K. Cheryl asked where the collected methanol would be stored. Okey replied that it is expected that two tanks will be used to store the methanol until it is transferred to trucks or rail cars for shipment. Okey estimated that the tanks will probably need to be emptied weekly to accommodate the quantity of methanol which is expected to be recovered. A description of the storage tanks will be included in the FPA section describing the facility.
L. Beth explained that EPA would like to see as much methanol recovered and reused as possible. Okey stated that OSi will probably recover more than 90 percent of the methanol, but cannot make an enforceable commitment to recover more at this time because the technology is new to OSi's operation and, therefore, its capabilities have not yet been tested. Further, OSi will commit to reusing 70 percent of the methanal recovered. OSi has calculated 70 percent as its break-even point in that if OSi cannot reuse or sell the methanol and must pay for off-site disposal, then OSi will begin losing money on this Project if it must pay for off-site disposal of more than 70 percent of the methanol. Nevertheless, it is OSi's intention to reuse or sell for reuse as much methanol as possible. EPA encouraged OSi to include this goal in the FPA. Tim stated that because it is only a goal, and not an enforceable commitment, it should not be included in the performance standards section of the FPA. Julie agreed that it should be located elsewhere in the FPA so as not to confuse the public.
M. Beth asked whether the reuse of the methanol would occur on-site. Okey explained that OSi has identified a contractor who is willing to purchase the methanol for reuse as biomass nutrient in a wastewater treatment system. Without this methanol, the contractor would need to purchase virgin methanol to sustain its biomass. The methanol is used as a nutrient source for denitrification. Okey noted, however, that OSi may also be able to reuse it on-site for carbon loading in its own sewer system. He explained that just today OSi had to go out and purchase dogfood to feed the biomass in its system because the carbon was very low as a result of a shutdown for electrical maintenance.
N. Cheryl asked if putting methanol into the wastewater system was a form of waste treatment. Okey explained that it was not treatment of a waste because the recovered methanol put into the system would be a substitute for virgin methanol. There is an identifiable point at which carbon must be added to the system to sustain the biomass. Beth asked if there is a way to measure how much carbon needs to be added to the system at a particular point in time. Okey replied that a certain minimum carbon loading must be maintained. He will attempt to determine the necessary level and generate a number to reflect it.
O. Cheryl suggested including in the methanol recovery provisions section of the performance standards a preference for reuse and recycling over treatment or disposal. She suggested that this would take the form of a hierarchy of alternatives for the disposition of the recovered methanol. Cheryl asked about the significance attributed to downstream introduction of methanol which is contained in the definition of bio-treatment. Okey explained that by introducing downstream, there would be no affect on air emissions coming from the wastewater treatment system. The recovered methanol would be introduced directly into the inground tanks containing the biomass.
P. EPA suggested that the performance standards should include a requirement that records be kept on-site at the facility.
Q. Tim added that OSi will be including a section to the FPA which contains the reporting requirements.
R. Beth requested that OSi check in with Chris van Löben Sels for his comments on the performance standards.
S. Several non-substantive language changes were made to the performance standards and those will be reflected in the next draft of the FPA.

III. Schedule
A. Face-to-Face Meeting
A face-to-face meeting will be held in Charleston on October 16 and 17. The meeting is scheduled to begin at 1:00 p.m. on October 16 and to resume on October 17 at 8:30 a.m.

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