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Crompton Corporation (Formerly Witco Corporation)

Minutes for Meetings Used to Develop the Final Project Agreement

OSi Specialties - Project XL

April 22, 1997 Conference Call Minutes

I. Conference Call Participants

II. Performance Standards

A. The Workgroup discussed the draft incinerator performance standards which were circulated by fax on April 3. OSi explained that most of the provisions were based upon those contained in 40 C.F.R. Part 63.

B. Bev noted that the draft standards establish a combustion temperature range for operation of the incinerator. She stated that West Virginia usually establishes a minimum temperature of 1600 degrees Fahrenheit, rather than a range of acceptable temperatures, for vent stream incinerators. She suggested that the performance standards be revised to be consistent with West Virginia's standard requirement. Michele explained that for the NESHAPs, EPA usually establishes a percentage efficiency for the unit (here, it is 98%) and then leaves it up to the facility to determine the temperature necessary to achieve the required efficiency. Bev stated that, in West Virginia, a minimum temperature of 1600 degrees is initially included in all preconstruction permits, with possible adjustment later based upon performance testing. If a lower temperature can achieve the required removal efficiency, the permit is modified and the temperature established by the facility replaces the minimum default temperature.

C. Bev inquired about the flow indicator requirement contained in the draft performance standards and asked whether a flow meter requirement would be preferable. She stated that in West Virginia they generally require a meter, not just an indicator. Michele explained that requiring a flow indicator would be sufficient here because the requirement is designed simply to indicate when a bypass occurs. There was some discussion concerning the meaning of the existing draft provision and whether the provision was necessary or appropriate.

D. Bev suggested that the Workgroup include a provision in the FPA which would require operation of the incinerator at all times when the capper is in operation. OSi stated that it intends to run the incinerator at all times when the capper is operating, however, there need to be exceptions incorporated into the performance standards for periods of maintenance and malfunction. Bev stated that West Virginia's regulations include an exception for malfunction, but not for maintenance, and allow a facility to apply for a variance when a malfunction occurs. OSi and EPA noted that federal requirements generally provide a period of time for both maintenance and malfunction. There was further discussion among the Workgroup concerning the appropriate requirements for addressing maintenance and malfunction of this unit under Project XL.

E. Bev requested that the performance standards make clear that the stack test will be performed at or above the minimum temperature, rather than using an average temperature for the test. Based upon this initial stack test, the facility may establish that a lower temperature achieves the targeted efficiency. Bev stated that WVDEP would like the FPA performance standards to be modified to include these requirements so that the performance standards will be consistent with West Virginia's requirements for preconstruction permitting.

F. WVDEP requested that the reference to "total organic carbon" in the leak detection monitoring requirements be changed to refer, instead, to "volatile organic carbon" so that it will be consistent with West Virginia's regulatory provisions which follow 40 C.F.R. Part 264, Subpart BB. Michele explained that the reference currently used in the performance standards is the same as that contained in 40 C.F.R. Part 63. OSi stated that it would review both provisions and report back to the Workgroup on which provisions were more appropriate.

G. There was additional discussion concerning miscellaneous provisions contained in the draft performance standards.

III. RCRA Subpart CC Applicability Issue

OSi had previously noted that recent changes to RCRA Subpart CC could render those provisions inapplicable to the Sistersville plant. OSi had requested that EPA review this issue since it could impact this Project. At Michele's request, OSi had submitted additional information to EPA about the facility which was relevant to this issue. After having reviewed the information, Michele reported that RCRA Subpart CC would still apply to OSi's facility. The Workgroup agreed to discuss the basis for EPA's determination at the next face-to-face meeting.

IV. Schedule

A. The next face-to-face meeting is scheduled for Friday, April 25. The meeting location is tentatively set for Charleston, West Virginia but it may be changed to Pittsburgh, Pennsylvania to accommodate schedules and travel budgets. The agencies will meet in the morning and OSi will join them in the afternoon.

B. The agenda for the face-to-face meeting will include the performance standards, the Allowable Increase/Allowable Exclusion provisions, and the issue of RCRA Subpart CC applicability.

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