Dow Chemical Company, Midland Michigan
Letter from Walter Walsh to Richard Olson
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
March 22, 1996
Mr. Richard A. Olson
Senior Environmental Associate
Environmental & Health Regulatory Affairs
The Dow Chemical Company
2030 Dow Center
Midland, MI 48674
Dear Mr. Olson:
Dow's proposal for an XL Project is currently undergoing
review. We have determined that, due to the distinct nature of each
of the components of the proposal, it may simplify and perhaps expedite
the review and selection process if each component--Midland, Michigan;
Freeport, Texas; and Plaquemine, Louisiana--is handled as a separate,
individual proposal. Additionally, in the event that one or more of
the components is selected as a XL Project, it will ease development
of the Final Project Agreement(s) and related logistics, local stakeholder
issues, etc. Please advise us if you are agreeable to this separation.
We also would like to request some additional details to assist us in
evaluating Dow's XL proposal for the Freeport, Texas, facility. At the
present time, this component of the proposal is on hold in the Technical
Review stage pending receipt of information that addresses the following
concerns:
1. The proposal references "a 25% reduction in the unit ratio of liquid
halogenated wastes burned per pound of associated product." The specific
ratio and base year are to be formalized in the Final Project Agreement
(FPA). To evaluate how this proposed reduction meets the selected criteria
that the project achieve superior environmental results, we will need
to know the volume of waste incinerated both before and after implementation
of the XL project.
2. Also, the proposal states that Dow seeks to reduce the emissions
of dioxins and furans (D&F) by 90% by the year 2005. What is the base
year? Dow states that since 1990, it has reduced dioxin release by 90%
through its NPDES outfalls. Does this mean that Dow intends an additional
90% reduction in D&F emissions for a total reduction of 99% compared
with 1990?
The proposal states that after completion of a sampling and analysis
plan for D&F and establishment of a baseline by year-end 1996, Dow will
commit to a specific reduction in D&F emissions. How does this relate
to the 90% reduction described above?
Also, the proposal notes that Dow has recently formalized a global goal
of reducing D&F emissions to air and water by 90% by the year 2005.
With whom has this goal been formalized? If Dow has already committed
to these reductions, please explain how and why you see this as a point
of negotiation in the context of Project XL.
3. Please provide specific details to explain how Dow plans to achieve
a 20% reduction in BIF units in liquid service. Will the waste streams
be reduced or will they be shifted to other BIFs or alternative treatment
units?
The proposal discusses elimination of the need for trial burns and Part
B call-ins for BIF units that will not be operated in liquid service
in the long term. Please provide additional details to identify those
units; to explain how this would be accomplished; and to describe the
period of time the units would be operated.
4. Dow asks for an approval of a schedule of trial burns that would
extend four to six years beyond the initial TNRCC Part B call-ins. Does
Dow have to negotiate with TNRCC directly for this request? How long
are facilities typically given to conduct a trial burn after a Part
B call-in? Would all of Dow's BIF's Part Bs be called in simultaneously?
5. What specific reductions does Dow seek regarding the frequency and
scope of its BIF record keeping?
6. Please clarify the specific modification Dow is requesting for the
3-year BIF rectification.
7. The proposal asks for a waiver from requirements to perform risk
assessments if the BIF technical standards are met, or alternatively
to waive the BIF technical standards for units passing risk assessments.
Are these references to upcoming MACT technical standards for BIFs?
If so, this request in problematic as those standards will not be promulgated
in the foreseeable future. At this point, the Agency cannot determine
what the final standards are likely to be. How would Dow propose to
address this issue?
While it is true that many of the specific details of an XL proposal
are negotiated during development of the FPA, the framework for those
negotiations are approved in the Technical Review process. Your assistance
in providing the additional information requested will enable us to
complete this review. We believe that there is enormous potential to
make significant environmental gains at the Freeport facility in the
context of Project XL. We look forward to resolving these technical
issues as soon as possible so that this component of Dow's XL proposal
can continue to move through the Project XL selection process. If you
have any questions or require clarification concerning this request,
please feel free to contact me at (202) 260-2770.
Sincerely,
Walter Walsh
Staff Advisor
Project XL