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Crompton Corporation (Formerly Witco Corporation)

Minutes for Meetings Used to Develop the Final Project Agreement

Witco OSi Specialties Group
Project XL
Kickoff Meeting
July 9, 1996

About Project XL USEPA published FR article on 5/23/95
Part of "Regulatory Reinvention"
Invited industry to submit alternative regulatory compliance proposals where greater environmental benefits could be obtained through strategies to replace or modify regulatory requirements.
Project XL Criteria
Greater Environmental Results
Cost Savings and Paperwork Reduction
Stakeholder Support
Innovative/Multimedia Pollution Prevention
Monitoring, Reporting and Evaluation
No Shifting of Risk Burden
RCRA Subpart CC Regulations
New regulation under the Resource Conservation and Recover Act (RCRA)
Effective October 1996 with compliance deadline of December 1997
Requires controls on air emissions from certain hazardous waste tanks, containers and surface impoundments
OSi's only practical means of compliance for surface impoundments is replacement with open top tanks
Compliance cost ~ $2,500,000 to install tanks and close impoundments
CAA Subpart YYY
Proposed rule under the Clean Air Act (CAA)
Expected final date for rule - Late 1996
Requires air emissions controls on wastewater systems (includuing sumps, trenches, manholes, etc.) dealing with the same types of emissions as RCRA Subpart CC
Cost to cover sewer system and install control device(s) estimated in excess of $2,500,000
Capper Production Unit
Manufactures intermediates for surfactant production
Uses methyl chloride as a reactant
Existing unit - Inefficient
High maintenance
At capacity
New unit will provide better efficiencies, reliability and additional capacity
Project XL Proposal
Proposal submitted to EPA in September 1995
OSi proposes to place voluntary controls on new production unit to reduce air emissions and wastewater treatment unit loading
Seeking consideration in place of controls required by Subparts CC and YYY and other future wastewater emission control requirements
Additional equipment cost on new unit ~ $1,000,000
Project selected by EPA on May 22, 1996
Environmental Benefits
Reduced air emissions
Wastewater treatment unit loading reduction
Sludge reduction

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