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Crompton Corporation (Formerly Witco Corporation)
Minutes for Meetings Used to Develop the Final Project Agreement
OSi Specialties - Project XL December 17, 1996 Conference Call Minutes
I. Conference Call Participants
Dennis Heintzman Witco-OSi
Okey Tucker Witco-OSi
Tony Vandenberg Witco-OSi
Dale Koontz Witco-OSi
Jim Nortz Witco-Headquarters
Tim Malloy Witco-Manko, Gold & Katcher
Brenda Gotanda Witco-Manko, Gold & Katcher
Beth Termini EPA Region III
Cheryl Atkinson EPA Region III
Michele Aston EPA OAQPS
Nancy Birnbaum EPA Headquarters
Jim Michaels EPA Headquarters
Sherri Stevens EPA Headquarters
Britt Ludwig WV DEP
Lucy Pontiveros WV DEP
Jonathan McClung WV DEP
II. Discussion of Updated Project Proposal
A. Clean Air Act Subpart YYY Applicability
1. The participants discussed whether Clean Air Act ("CAA") Subpart YYY would apply to the upgrade of the existing capper unit. OSi explained that the work to be done would not constitute a modification nor a reconstruction triggering CAA Subpart YYY.
B. Emissions Estimates For Modified Project
1. EPA asked why the updated emissions summary reflected a change in the capper wastewater treatment unit emissions. OSi explained that the new capper unit would have been more efficient than the existing unit and, therefore, would have produced less methyl chloride. However, the new unit would have generated more dimethyl ether as part of its wastewater. The changed emissions, thus, are attributable to changes in production volume as well as production efficiencies.
C. Capper Flow Diagram
1. In advance of the Workgroup conference call, OSi circulated a flow diagram showing the processes associated with the existing capper, as well as the expected upgrades. (See Attachment A.) Okey noted that the anticipated in-kind replacement of parts on the existing capper unit would not cause any increase in emissions.
2. EPA inquired about the disposition of the methanol that is currently condensed. Okey explained that once the methanol is condensed, it is collected and stored in a non-RCRA tank. The majority of the collected methanol is then sent to the wastewater treatment unit. Under the revised Project, however, it will be diverted and recovered. Okey added that methanol from the scrubbers would continue to be discharged to the sewer, as it could not be routed to the condenser.
3. EPA asked whether the vendor, who had been identified for methanol reuse under the prior Project, would still be interested in purchasing the reduced volume of methanol under the current Project. Okey stated the vendor appeared to be willing to sign the contract for the methanol even after he was advised that the volume would be lower than originally anticipated.
4. EPA asked what percentage of the methanol would be sent to reuse or recovery under the revised Project. Dennis stated that OSi believed that it would be able to send all of the methanol to reuse or recovery, so long as OSi retained the ability to reuse methanol on-site as a nutrient source for the wastewater treatment plant.
5. Okey noted that the dashed boxes on the flow diagram indicate the processes which will have their vent streams routed to the vent incinerator. He added that the vent stream of such processes consists mainly of methyl chloride and dimethyl ether. He noted that some other streams will also be sent to the vent incinerator. The OSi XL team is currently working with their engineering group to finalize the numbers and to confirm that the incinerator can handle all of the expected incoming vent streams. OSi will have more details on this issue some time in January.
D. Implementation Mechanisms
1. The Workgroup discussed the timetable for the site-specific RCRA Subpart CC rule. Britt questioned whether the existing timetable is still achievable. Michele noted that although the baseline for the current unit has not, and will not, change, the Project modifications will have to be verified by EPA. Okey noted that the only delta will be dimethyl ether removal. He agreed to check what he had previously sent to EPA, and to follow-up with Michele on this issue. In addition, he will run the Water 8 model again, removing the dimethyl ether.
2. The Workgroup discussed what could be done at the state level to establish an implementation mechanism. The participants agreed that the concept of the state consent order is still the most viable approach. Although it may still be possible to attempt to obtain some changes to Reg 25 at the state level, this approach is not currently feasible because for federal changes to be incorporated by reference into the Reg, those changes must be in place at the time of consideration by the State.
E. Final Project Agreement
1. OSi expects to circulate a revised draft FPA #5 during the first full week of January.
2. Dennis noted that he will be sending a letter out to all stakeholders informing them of the proposed change in the Project.
3. OSi will try to circulate a written draft of the de minimis proposal by January 10.
F. Beth asked whether the restructuring of Witco Corporation reported in the Wall Street Journal would have any effect on the Sistersville facility. Dennis responded that the Witco restructuring would have no impact on the Project, although Sistersville is expected to reduce its employees by 5% over the next three years.
G. De Minimis Provision
1. Beth noted that it is unclear whether EPA management will be able to accept a CAA Subpart YYY de minimis provision which is based on an automatic approval of de minimis increases. She asked what would happen to the Project if the parties were unable to agree on the de minimis issue. Dennis responded that he is confident that we will be able to resolve this issue. He noted that it is an important issue for OSi because the entire economic benefit of the Project could be lost if, as a result of a very small emissions increase from the wastewater treatment plant in the future, OSi were required to install all of the controls which are being deferred under this Project.
H. Schedule
The next Workgroup conference call is scheduled for January 16 at 1:30 p.m.. The Workgroup participants tentatively set aside the dates of January 21 and 22 for a face-to-face meeting in Pittsburgh.
Attachment A
67970 2/19/97 DRAFT - 12/16/96
OSi Specialties Project XL Proposed Changes
December 1996
OSi Specialties is proposing a change in its XL project due to a business decision which will result in the continued operation of the existing methyl capper unit at Sistersville and not building a new methyl capper unit at Sistersville. The existing (February 1996) proposal called for addition of process vent controls on the new unit to control methyl chloride, dimethyl ether and methanol emissions. In addition, tankage would have been installed to allow for recovery of methanol from the process.
Rather than build a new production unit, a reliability upgrade will be completed on the existing production process. OSi Specialties is now proposing to install emission controls on the existing process unit to control methyl chloride, dimethyl ether and methanol emissions. This is the proposal that was initially submitted to the EPA in September 1995. The emission controls cost is estimated to be $500,000.
In addition, OSi Specialties will continue the current operation of collecting methanol from the production process but plans to direct this methanol to recovery/reuse rather than disposal. There will be no upgrades or additional equipment necessary for this current practice of methanol collection.
Differences in the project with new production unit versus existing unit are summarized in the following table:
Project with addition of voluntary emission controls to existing unit and methanol recovery/reuse (New XL) Project with voluntary emission controls included on new methyl capper unit, and methanol recovery/reuse (Old XL) Air emission reductions from production unit 270,695 lb/yr 120,980 lb/yr Air emission reductions from WWTU 38,290 lb/yr 174,980 lb/yr Total air emissions reduction 308,985 lb/yr 295,960 lb/yr Methanol Collected 500,000 lb/yr 3,820,000 lb/yr Sludge Avoided 800,000 lb/yr 6,292,900 lb/yr
As the table indicates, the air emission reductions under the New XL proposal are greater and the methanol and sludge reductions are less than under the Old XL proposal. Note that the primary reason for the lower methanol collected and sludge avoided is the higher production capacity of the new unit which had been proposed.
DRAFT - 12/16/96
The performance standards developed for the vent incinerator will be the same as those for the previous proposal. Performance standards for the existing methanol recovery system will need to be revised as the existing condensing equipment is not the same as was proposed with the new production unit. Performance standards for percent methanol recovery and reuse percentages will also be revised to reflect the capabilities of the existing equipment and a commitment by OSi Specialties to recycle/reuse a higher percentage of the collected methanol than was previously proposed.
Existing Methyl Capper Upgrade
The existing methyl capper unit at Sistersville will be upgraded to improve its reliability in order to meet current and expected demand. This upgrade will require approximately $1,000,000 in capital funds (not including the cost of emissions control). The upgrade is expected to consist of replacement of the evaporators, the pre-filtration tank and the vacuum system (refer to attached sketch of existing unit).
These upgrades will not increase emissions from the existing unit. None of these changes will increase the production rate of equipment but there could be an increase in annual production volumes due to an increase in operating hours (decreased downtime of the equipment).
Because the upgrade involves only replacement of existing equipment with more reliable equipment, or replacement of obsolete components with more efficient components, and because the upgrade is consistent with the design of the unit, OSi Specialties feels the changes are not a modification, construction or reconstruction under NSPS, PSD or WV OAQ Regulation 13. As such, the upgrades can be performed without triggering any permitting or NSPS requirements (particularly 40 CFR subparts NNN, RRR and the proposed YYY). Installation of the vent incinerator will require a WV OAQ Regulation 13 construction permit, due to the requirements of WV OAQ Regulation 6 (Combustion of Refuse).
Witco OSi Specialties Methyl Capper Unit Reliability Upgrade & Project XL Controls Process Flow Diagram
To obtain a copy of this diagram, contact OSi Specialties.
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 - 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 Methanol Collected for Reuse (lb/yr) Methanol Sludge Generation