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Crompton Corporation (Formerly Witco Corporation)
December 16, 1996 Letter
P283 708 752
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
December 16, 1996
Ms. Nancy Birnbaum
U.S. Environmental Protection Agency
401 M Street, S.W. (2129)
Washington, D.C. 20460
OSi Specialties Toluene Pollution Prevention
Dear Ms. Birnbaum,
You indicated that you would like to have some information from OSi Specialties regarding our
emissions of toluene, to aid your response to the concerns raised by Janet Fout of the Ohio Valley Environmental Coalition. Attached is the narrative OSi has submitted to the National Institute for Chemical Studies for their annual West Virginia Scorecard© . The narrative addresses our toluene pollution prevention efforts. We believe that this demonstrates our commitment to reducing toluene emissions.
In the table below, I've added our toluene usage to the release data included in our narrative.
Combined Media Releases Excluding Offsite Transfers Total SARA 313 Releases Including Offsite Transfers Total Toluene Usage
If you feel that you need further information, please contact me.
Sincerely,
Okey G. Tucker
Environmental Protection Manager
(304) 652-8131
cc: D. R. Heintzman
A. J. Vandenberg
T. Malloy
File
OSi SPECIALTIES, INCORPORATED
Sistersville, WV
Contact: Okey G. Tucker (304) 652-8131
Facility Description
OSi Specialties, Inc., a subsidiary of Witco Incorporated, Greenwich, Connecticut, is a worldwide manufacturer of specialty silicone chemicals. OSi became a Witco subsidiary in October 1995. Manufacturing facilities are located in the US, Italy, Belgium, Brazil, Mexico and the Far East. Research and development is carried out primarily in facilities in South Charleston, WV; Sistersville, WV, Tarrytown, NY; and Meyrin, Switzerland. The flagship of the OSi Group of Witco is the Sistersville Plant, which is located approximately six miles south of Sistersville, WV on WV State Route 2. The plant is in a rural setting, on approximately 1300 acres. The operating facilities occupy about 50 acres. Approximately six hundred employees work at the plant, which opened in 1955.
The Sistersville plant produces a family of man-made organo-silicon chemicals which are used in industry and homes throughout the world. Sistersville's organo-silicons have applications in electronic equipment; aircraft, missile, and space technology; appliance, automotive and metal working production; textile, paper, plastics, and glass fabrication; rubber products; paint, polish, cosmetics, and specialties; food processing and preparation; building and highway construction and maintenance; and chemical reactions and processes. Production in 1995 increased by about 10% over 1994.
OSi Specialties places the utmost priority on delivering high quality products to its customers. As evidence of this, the Sistersville plant is ISO 9002 accredited, giving it international recognition in the area of quality.
Point Source Emissions
1995 point source air emissions from the facility are 54% below our 1987 baseline, but 12% higher than 1994. This is primarily due to re-calculated emissions from a major source by using a mass balance approach, resulting in an increase of chloromethane emissions by 18 tons, accounting for 9.2% of the 12% increase over last year. The remaining increase in point source emissions was due to increased production and operating time.
Hydrogen chloride point source emissions decreased by 15 tons from 1994 due to a shift in some product manufacturing from older, less efficient process equipment to a new system which is more efficient, with better air pollution controls. Methanol point source emissions increased by 14 tons from 1994. This increase was due to increased production, as well as re-calculated emissions using a mass balance approach.
Fugitive EmissionsFugitive emissions are calculated using EPA approved methods, based on the number of components (valves, flanges, etc.) and the materials flowing through them. These methods give very conservative (high) estimates of the emissions.
TRI fugitive emissions increased by 14% (52,000 pounds) from 1994 to 1995. Almost half of this increase was due to increased production, using methanol as a reactant. Toluene fugitive emissions have decreased by about 18 % (29,000 pounds) from last year. Chloromethane fugitive emissions from the waste water treatment unit also decreased by nearly 58% (15,000 pounds) from 1994. This is due to more efficient reactions in the process units.
Beginning in 1990, the Sistersville plant began a leak detection and repair (LDAR) program to monitor the actual emissions acrylonitrile and allyl chloride. This program has continually confirmed low emission levels for both pollutants (less than 2000 lbs each). In implementing an LDAR program it is estimated that a facility may incur up to a 70% reduction in emissions because the monitoring results are used to calculate the emissions. Given this fact, OSi Specialties, Inc. plans to proceed with a voluntary LDAR program for other production units in the plant.
Water Discharges and Secondary Emissions
Waste water discharges are primarily based on influent and effluent sampling and analysis, particularly for methanol, toluene, chloroethane and chloromethane. Based on the results of such sampling, 1995 TRI waste water discharges decreased by 32% (12,000 pounds). Chloromethane discharges decreased by 50% (1,100 pounds) due to more efficient reactions in production units. Toluene decreased by about 76% (over 8,000 pounds) due in part to replacement of toluene with a more environmental friendly cleanup solvent in some production units. Chloroethane discharges increased by about 63% (1,200 pounds) from 1994 to 1995; this increase is attributed to increased production.
The secondary emissions from the waste water treatment unit are accounted for as fugitive emissions in Section 5.1. Secondary emissions factors were determined by inputting the resulting chemical concentrations of analyzed waste water samples into EPA's WATER 8 model, along with other parameters.
Chloroethane secondaries were determined to have increased by about 46% due to higher concentrations in the waste water influent in 1995 than in 1994. Chloromethane secondary emissions were determined to have decreased by about 90% (over 13,000 pounds) due to more efficient operations, as chloromethane is a by-product of a few process units. Toluene discharges decreased tremendously (46%, or about 21,000 pounds) due in part to replacement of toluene with other cleanup solvents.
Total Environmental Releases
To summarize the above information on environmental releases, 1995 emissions relate to 1994 emissions as follows: total air emissions increased by about 8% (or 69,000 pounds); water discharges decreased by 32% (or 12,000 pounds); land releases (landfilling) remained the same. Therefore, our total releases to the environment increased by 7% (or 57,000 pounds) from 1994 to 1995, in the way of point source and fugitive emissions, but are still down 54% (or 1,021,000 pounds) from our 1987 baseline.
Offsite Transfers
Offsite transfers include those wastes containing SARA 313 materials that were shipped off-site for either energy recovery (fuels blending) or thermal treatment through incineration. Therefore, off-site transfers are not releases to the environment, as the materials are completely destroyed. From 1994 to 1995, our facility's off-site transfers of SARA 313 materials have decreased by 7% (or 245,000 pounds). Much of the reduction is due to reduced offsite shipments of toluene as well as the increased thermal treatment of SARA reportable chemicals on-site. Of the amount of TRI off-site transfers of SARA 313 materials, about 68% went for off-site thermal treatment, and the remainder for energy recovery.
Toluene Releases
Reduction in toluene released to the environment has been one of the Sistersville plant's primary waste minimization objectives in recent years. The chart below shows our successes in this area.
Toluene Releases in lbs
Combined Media Releases Excluding Offsite Transfers Total SARA 313 Releases Including Offsite Transfers
Several ongoing efforts have brought about significant reductions in toluene use and waste generation. These reductions have been achieved through revision of many of our processes to use no solvents, to use water in place of toluene for cleaning, or to use solvents which are environmentally friendlier than toluene. This work, combined with work currently being conducted by our research and development personnel on solvent recycling, will allow us to further reduce both our solvent raw material usage and any potential environmental impact.Pollution Prevention
Since becoming a subsidiary of Witco Corporation, OSi Specialties, Inc. participates in CMA's Responsible Care® program (the company had previously participated in SOCMA's program). Under the Pollution Prevention Code of the Responsible Care® program, OSi Specialties, Inc. will conduct the self evaluation annually, and set reasonable goals to achieve in each coming year.
In 1995, OSi implemented several pollution prevention projects, of which we mention a few. The first was the commissioning of a new production unit which more efficiently reacted alcohols with other raw materials to make product. It is estimated that this project has reduced alcohol usage by about 730,000 pounds per year. The technology of the same production unit also accounted for less generation of chloroethane and chloromethane in side reactions during product manufacture, than if the product were made in the usual kettle systems.
We have begun reducing the amount of methanol used for cleanups by using the final cleanup solvent in a campaign as the first cleanup on the next product campaign in the same systems in some areas of the plant.
Used isopropyl alcohol is being segregated and sent off-site for recovery. The recovered IPA is returned for use by OSi Specialties, Inc.
Future Pollution Prevention
The following have been identified as potential waste minimization/pollution prevention projects. These projects will be further evaluated to determine their viability.
· Replace an ozone depleting substance used as heat transfer medium in two heat transfer systems associated with our production units
· Further waste reduction through off-site recycling of useful by-products
· Continue research on how to reduce alkyl halides (chloroethane and chloromethane) that will be introduced into the waste water treatment unit from future production operations
· Continue research, selection and use of more environmentally friendlier solvents for equipment cleanupsFuture Goals
The OSi Specialties Environmental, Health and Safety, Inc. Policy includes the following goals:
· placing a high priority on minimizing harmful process emissions and wastes in our development of technology, and in the design, operation, and maintenance of our facilities;
· treating process wastes to reduce their volume and toxicity to the maximum degree practicable prior to disposal;
· maximizing the efficiency of our use of raw materials and energy with a focus on waste minimization, recycle, and reuse in order to reduce our impact on the environment; and
· properly training and/or informing our employees to promote proper environmental awareness and foster individual responsibility for meeting our vision.
OSi SPECIALTIES - PROJECT XLSchedule as Developed at Pittsburgh Meeting January 21-22, 1997
B. Project Development
Jan. 31 - Waste Minimization Language (EPA to OSi)
Comments on Draft FPA #5 (EPA to OSi)
Feb. 4 - Comments on Allowable Exclusion (EPA to OSi)
Feb. 18 - Draft FPA #6 (OSi to EPA)
Feb. 28 - Draft Final FPA (OSi to EPA)
Mar. 14 - Draft Final FPA [Workgroup closure draft]
Mar. 28 - Final EPA Comments on FPA
Apr. 11 - Send Notice of Availability to Federal Register
Apr. 25 - Notice appears in Federal Register
Apr. 28 - OSi holds public meeting
[Need date] - State RCRA CC Consent Order
[Need date] - EPA site specific rule
[Need date] - AA level briefings within EPA
OSi XL Project Summary
OSi Sistersville Project XL Scope Revision
Existing Capper Reliability Upgrade with XL controls (vent controls only)
No additional methanol controls will be placed on the unit. Existing condensers will be maintained
1995 w/XL Reductions (lb/yr) (lb/yr) Air Emissions Constituent Capper Methyl Chloride Methanol Dimethyl Ether trace Subtotal Capper WWTU Methyl Chloride - Methanol - Dimethyl Ether * Ethyl Chloride - Toluene - Other VOC's - Subtotal WWTU - Total Air Emissions - Capper Discharges to WWTU (lb/yr) - Methyl Chloride - Methanol (from scrubber) - Methanol (from condenser) - Dimethyl Ether * Acetic Acid - Total Organic - MMethanol Collected (lb/yr) Methanol - Sludge Generation
* - The source of this component is being evaluated to determine if it can be routed to the
vent incinerator also.