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Crompton Corporation (Formerly Witco Corporation)

Minutes for Meetings Used to Develop the Final Project Agreement

OSi Specialties - Project XL

April 15, 1997 Conference Call Minutes

I. Conference Call Participants

II. Minutes and Miscellaneous Items

A. Brenda stated that she is waiting for Workgroup comments/approval on the draft minutes for February and March. Workgroup members who have not yet reviewed these minutes should do so as soon as possible.

B. Beth reminded OSi that EPA needs OSi's proposal for interim milestones for installation of the incinerator.

C. Britt asked Beth whether WVDEP needs to provide public notice of its consent agreement implementing the terms of the Project. She noted that WVDEP does not usually seek public comment on its consent orders but asked whether such procedure needs to be followed under Project XL. Beth noted that EPA's site-specific rule will incorporate by reference the terms of the State consent order and, therefore, when the EPA rule goes out for public comment, EPA will also make available for review the State's consent order. Thus, WVDEP does not need to provide any independent public notice.

D. OSi noted that Nancy has requested copies of all the draft FPAs for inclusion on EPA's web page. OSi inquired whether it is appropriate to include draft documents on the web page once the FPA is finalized. Beth stated that she will discuss this issue with Nancy and they will report back to OSi.

III. EPA's PBT List

A. Okey reported that OSi has received from Sherri the cross-match list of chemicals culled from EPA's larger "PBT list." This cross match list (the "FPA chemical list") contains those chemicals from EPA's PBT list which are associated with these listings for OSi's waste streams and which EPA would like OSi to evaluate during the Waste Minimization/Pollution Prevention ("WMPP") portion of the Project.

B. Okey noted that most of the substances on the FPA chemical list appear to be low risk and he inquired whether chemicals must be categorized by EPA as persistent, bioaccumulative and toxic to make it onto EPA's PBT list or whether they can get on the list if they simply exhibit one of those characteristics.

C. Cheryl explained to the Workgroup how EPA's PBT list was developed. She stated that a score was assigned to each chemical to reflect EPA's assessment of its risk. In assigning the scores, EPA made two assessments, one of the chemical's risk to humans and one of its ecological risk. For each of these types of risk, each chemical was assessed a score between 1 (low risk) and 3 (high risk) for each PBT characteristic (persistence, bioaccumulation, and toxicity). Therefore, each chemical was given a total of six scores, three scores each for two types of risk, and all six scores were added together to determine the final scoring which is reflected on the PBT list. In EPA's opinion, there are no "risk-free" chemicals, therefore no chemical could score less than 1 on any of the initial rankings. Accordingly, a total score of 6 was the lowest total score possible for any chemical and the highest total score was 18.

D. Okey stated that OSi would review the list to assess whether it agrees with EPA that the chemicals contained on the FPA chemical list correspond to chemicals likely to be found in OSi's major waste streams. He added that, based upon his cursory review of the list thus far, it appears that there are several chemicals on this list that OSi would like to address in its pollution prevention/waste minimization efforts. However, there are also many chemicals on the list which would not be found in OSi's waste streams. Sherri responded that EPA recognizes that not all chemicals on the FPA chemical list will be found at OSi's facility, however, if they are identified during the WMPP Study, EPA would like OSi to try to develop opportunities for reducing these pollutants.

E. EPA noted that reductions of the chemicals on the FPA chemical list will further EPA's National Goal of reducing chemicals it classifies as PBTs. While EPA has established for itself a target percentage reduction of these chemicals to be achieved nationally, OSi cannot commit to a similar percentage reduction at the facility level since no study has yet been performed to determine what levels of chemicals are present or by what level they could be reduced.

IV. Incinerator Installation Schedule

A. Okey stated that OSi will have the incinerator installed and operational by April 1, 1998. He added that OSi is willing to establish an interim milestone on the installation schedule. He explained that OSi would propose as a milestone the date by which OSi will place its order for the incinerator. OSi feels strongly, however, that there should not be any stipulated penalties associated with any interim milestones similar to those contained in the OSi-EPA consent order and agreement regarding RCRA Subpart CC compliance.

B. Beth asked what activities need to occur between the purchase and the installation of the vent incinerator. OSi stated that it has decided to hire an outside engineering firm to perform the work. This contractor should be able to provide a response to this question.

V. Allowable Exclusion/Allowable Increase

A. OSi will circulate the draft Allowable Exclusion/Allowable Increase provisions to the Workgroup tomorrow.

B. Okey advised EPA that OSi has shortened the original list of substances under the Allowable Increase provision so as to include only those with the highest potential for possible recovery operations. These include: acetic acid, chloroethane, dimethyl ether, ethanol, methanol, methyl chloride, isopropanol, and toluene. Okey noted that several of these substances are associated with solvent usage and, therefore, have a greater potential for recovery than some of the other chemicals previously included in the list.

C. There was discussion concerning the appropriate criteria to be applied by EPA in deciding when to grant an Allowable Increase. Beth stated that the criteria will be developed at a later time but that it should include an assessment of whether the impact of the increase would be adverse to human health and the environment. Okey and Brenda stated that it is very important that we include the criteria in the FPA so that everyone understands up front how the Allowable Exclusion and Allowable Increase provisions will work.

VI. Status of Deliverables

A. FPA Draft #6 will be circulated for final review by April 28 and will include the Regulatory Analysis.

B. Britt will begin drafting the WVDEP consent order, however, she will need to obtain from OSi the identification of the vent streams that will be routed to the incinerator.

C. Lucy stated that the WVDEP hazardous waste group will review the Reg. 13 permit for the vent incinerator and will consult, as appropriate, with the air group. Beth asked how long it usually takes to obtain a Reg. 13 permit. WVDEP responded that it usually takes about 180 days to issue a permit.

D. Jonathan noted that Bev has comments on the draft performance standards pertaining to testing and monitoring. He suggested that these comments be added to the agenda for the next conference call. The Workgroup tentatively scheduled a call for 2 pm tomorrow (April 16) to discuss these issues with Bev.

VII. Schedule

A. A conference call will be held on Wednesday, April 16 at 2 pm to discuss WVDEP's comments on the performance standards for the vent incinerator.

B. The next Workgroup conference call will be held on Tuesday April 22 at 10:00 am.

C. A face-to-face meeting is scheduled for Friday April 25, 1997 at WVDEP in Charleston, West Virginia. The Workgroup will reevaluate the need for this meeting during the April 22 conference call.

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