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Crompton Corporation (Formerly Witco Corporation)

Progress Reports

WITCO

Z 458 747 030, Z 458 747 031, Z 458 747 032
Witco Corporation
OrganoSilicones Group
Sisters-ville Plant
3500 South State Route 2

CERTIFIED MAIL Friendly, WV 26146
RECEIPT REQUESTED (304) 652-8OOO

April 9, 1998

Report Recipients Under the Federal Rule

Mr. Tad Radzinski (3WCI 1)
U,S. EPA, Region III
841 Chestnut Street
Philadelphia PA 19107


Ms. L. Nancy Birnbaum
Mail Code 2129
U.S. EPA 401 M Street S.W.
Washington DC 20460

Mr. John H. Johnston
WV Division of Environmental Protection
Office of Air Quality 1558 Washington Street East
Charleston @ 25311-2599


Advisory Committee

Ms. Pam Lyons
WV Division of Environmental Protection
303 Methodist Building
Wheeling WW 26003


Mr. Tad Radzinski (3WCI 1)
(Address above)
Mr. James McKnight
Route 39, Box 109
St. Marys, @ 26170


Mr. Jesse Barnhart
Witco Corporation, OrganoSilicones Group
Sistersville Plant
3500 South State Route 2
Friendly, WV 26146 - 9720



Mr. Ray Neupert
Industrial Extension Agent
West Virginia University at Parkersburg
300 Campus Drive
Parkersburg WV 26101

Mr. Fred Dailey
Plant Manager
Witco Corporation, Sistersville Plant
Mr. Dennis Heintzman
Director of EH&S
Witco Corporation, Sistersville Plant



WASTE MINIMIZATION/POLLUTION PREVENTION STUDY
SECOND PROGRESS REPORT



Attached is our WM/PP Study Progress Report describing our activities over the second 90-day period since the signing of our Project XL Final Project Agreement. Per that Agreement, this report is due on April 15, 1998.

Sincerely,


F. E. Dailey
Plant Manager
p:\environmental\ pollutn_p\wmpp_st\wmprog2.doc
WASTE MINIMIZATION/POLLUTION PREVENTION STUDY SECOND PROGRESS REPORT ADril 9,1998 2

Copy to: Okey Tucker
Tim Malloy / Brenda Gotanda, Manko, Gold & Katcher

WM/PP Study Team:
Bob Kayser, Witco
Tony Vandenberg, Witco
Dale Koontz, Witco
Jim Guterl, STV
Bob Briggs, STV
Roger Price, CTC
Doug Meyers, WRATT

Federal Correspondence
State Correspondence

XL Agreements, Notices, and Reports File



SISTERSVILLE PLANT 3500 South State Route 2 Witco OrganoSilicones Group Friendly, West Virginia Environmental Protection
Department Phone (304) 652-8000 Fax (304) 652-8738
April 9, 1998

PROJECT XL WASTE MINIMIZATION / POLLUTION PREVENTION STUDY


SECOND PROGRESS REPORT

For the Period January 16, 1998 to April 15, 1998

SUMMARY

The Waste Minimization / Pollution Prevention Study has progressed a great deal in the last 90 days. The T-F Foundation has completed their five-day Pollution Prevention site assessment, and have issued their draft report to Witco. Witco and its consultants have developed the assessment process for the study. A wide cross-section of plant employees participated in the first Brainstorming Session and developed initial lists of-. criteria for evaluating and prioritizing Pollution Prevention opportunities; and elements that should be considered when determining the total cost of wastes. The Advisory Committee has met twice to review progress to date, and has found that they like the approach that Witco is taking.

INTRODUCTION

On October 17, 1997, the U.S. Environmental Protection Agency, the West Virginia Division of Environmental Protection and OSi Specialties, Inc., a wholly owned subsidiary of Witco Corporation, signed a Final Project Agreement ("FPA") to carry out a pilot project as part of EPA's Project XL program to test innovative approaches to environmental protection. The parties to this agreement recognize that pollution prevention is an integral part of modem environmental management. While enormous strides in environmental protection have been made through the use of "end of pipe controls," pollution prevention strategies can often achieve farther, substantial environmental performance in a more cost-effective manner. In the past, Witco has implemented a number of pollution reduction opportunities at the Sistersville, WV Plant, and is committed to implementing source reduction where possible and cost-effective. In an effort to formalize its continuing source reduction efforts, Witco will, as part of the Project, implement a comprehensive waste minimization/pollution prevention study.

The P Study will examine plant operations in an effort to identify existing and future pollution prevention and waste minimization opportunities. Witco will retain an outside consultant to work with plant and corporate personnel to conduct this study. Witco expects to implement those waste minimization and/or pollution prevention opportunities which are technically and economically feasible. Through the use of an Advisory Committee, Witco will involve EPA, W-VDEP, and appropriate stakeholder representatives in the study and implementation phases of the WM/PP Project.

Under the Final Project Agreement, ninety days after signing of the FPA by all parties and every ninety days thereafter until submission of the final WM/PP Study Report, the Study Team will submit a progress report to the Advisory Committee detailing its efforts during the prior ninety day period,



STUDY TEAM ACTIVITY

The 5-Day Site Pollution Prevention Assessment

The Waste Reduction and Technology Transfer (WRATT) Foundation was on-site February 16-20 to conduct a 5-day long initial survey of the plant to help identify WM/PP opportunities. WRAT-R is a nonprofit organization located in Alabama employing retired engineers as consultants for the sole purpose of providing WM/PP assessments to industry. The three WRATT assessors met with over 45 Witco employees interviews and tours of our facilities, each lasting one-half hour to several hours.

WRATT has completed a draft of their assessment report. Witco is currently reviewing and commenting on that report for factual accuracy and Confidential Business Information concerns. In their draft, WRATT noted that the Sistersville Plant is well managed and efficiently operated. They commended management for its positive attitude toward waste reduction and pollution prevention. WRATT has made several suggestions and

recommendations to reduce waste. These ideas are now being fed into the assessment process described below.

Once the WRATT report has been issued in its final form, Witco will send copies to the WM/PP Advisory Committee members. Witco will then include these recommendations among those to be evaluated in the remainder of the WN"P Study as discussed below.


The WM[PP Study Pollution Prevention Assessment Process

We have begun the P2 ("Pollution Prevention") Assessment Process as depicted in the attached diagram. Key to the process is a series of brainstorming sessions. Each session is designed for 20-30 people, from a cross section of the plant's technical and operating staffs. Employees can attend any number of sessions, just one to all four. Involving more people in only one or two sessions will, we hope, increase the richness of ideas and buy-in to the process. Folks attending more than one adds continuity to the discussions.

Roger Price of Concurrent Technologies Corporation is leading the Brainstorming Sessions. At the beginning of the first two sessions, he is presenting a two-hour Pollution Prevention training course, to help develop the P2 mind-set. Each session will build upon the results of the previous one. At the end of session four, we will have completed the following tasks, specifically for the Sistersville Plant:


Brainstorming Session #1 was held on March 24, and was very successful, as judged by the participants' reactions and the session's results. Participants developed initial lists of. criteria for evaluating and prioritizing Pollution Prevention opportunities; and elements that should be considered when determining the total cost of wastes. The next session will refine these lists and proceed with brainstorming ideas for P2 projects and P2 programs.




ADVISORY COMMITTEE ACTIVITY

First Advisory Committee Meeting
The Advisory Committee met for the first time on January 29th. The Study Team presented its work to that point, and laid out the plans for the work described above.



SECOND ADVISORY COMMITTEE MEETING

The Advisory Committee met for the second time on April 6th. The meeting included a plant tour and reviewing the information that is the basis for this report. We discussed and gathered ideas regarding: cost accounting, incentive programs for P2 ideas, how to fund opportunities, how to technically and economically evaluate opportunities, and how to publicize the study's successes. The Committee liked the Study's approach to date.



KEY FUTURE DATES

Brainstorming Sessions:
#2 April 29
#3 June 3
#4 July 22
Advisory Committee next meeting
July 8
Witco issues to Advisory Committee the Draft WM/PP Report
October 17 -- (I -year from signing XL Final Project Agreement)
Advisory Committee submits comments on draft by November 16
Witco issues Final Report by December 16


NEXT PROGRESS REPORT

The next progress report is due July 14, 1998.



WITCO - Second Progress Report
Waste Minimization/Pollution Prevention Study First Progress Report - January 14th, 1998

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