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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
· Transferability
· Feasibility
· 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
Summary