Jump to main content.

Project XL Logo

Crompton Corporation (Formerly Witco Corporation)

Minutes for Meetings Used to Develop the Final Project Agreement

OSi Specialties - Project XL September 30, 1996 Conference Call Minutes

I. Conference Call Participants

Dennis Heintzman Witco-OSi
Okey Tucker Witco-OSi
Tony Vandenberg Witco-OSi
Dale Koontz Witco-OSi
Jesse Barnhart Witco-OSi
Tim Malloy Witco-Manko, Gold & Katcher
Brenda Gotanda Witco-Manko, Gold & Katcher
Cheryl Atkinson EPA Region III
Jim Cashel EPA Region III
Michele Aston EPA OAQPS
Julie Freider EPA Headquarters

II. Discussion of Performance Standards

A. Start-Up Date

1. The Workgroup discussed what would be an appropriate start-up date for the thermal incinerator on the new capper unit. EPA suggested that May 8, 1998 would be an appropriate date as that was six months after the effective date of the RCRA Subpart CC rules. OSi noted that it was important that the Project not drive the business decision concerning when to put the new capper unit on-line.

2. OSi inquired as to whether May 8, 1998 was suggested as a date for the initial start-up of the equipment or as a date by which shakedown of the equipment must be complete and the whole system must be fully operational and in compliance. EPA suggested that OSi discuss the issue internally to determine what is reasonable. EPA also suggested that OSi consider including interim milestones in addition to establishing final dates for performance.

3. Dennis pointed out that this Project will be the first engineering project involving both Witco Corporation and OSi and that EPA should be aware that it will be difficult to predict the amount of time necessary to coordinate efforts to complete such a project. In addition, OSi is currently intending to use a pre-commissioned unit. This is a new approach for OSi and, therefore, could also cause some unanticipated delays.

B. Performance Standards for the Vent Incinerator

1. Okey noted that the incinerator will need a State Reg 13 permit and therefore suggested that we simply use the Reg 13 permit standards as the performance standards for the incinerator. In addition, a stack test should be performed at start-up to provide indicator parameters (e.g., temperature, etc.) which would then be monitored on an ongoing basis.

2. EPA replied that monitoring and testing requirements under the federal air regulations generally require more than just a stack test and an emissions limit. Michele suggested that it would be useful to look at the process vent rules and testing requirements specific to process vents. She suggested including something similar to the Part 264 Subpart AA rules or other Clean Air Act rules in the performance standards.

3. Tim stated that we should first focus on what the control device is supposed to do and then flush out from that what the performance standards ought to be. For example, if the Project were to require the reduction of pollutants by a certain amount, and if the Reg 13 permit emissions limits are designed to do the same thing, then the Reg 13 standards would probably be appropriate. Michele responded that the goal here is a 98% efficiency in reduction of process vent emissions and added that in addition to performance, EPA may also need leak detection monitoring and other items.

4. OSi agreed to obtain an example of the Reg 13 permit requirements and forward it to Michele for her to review. Michele will also look at the requirements set forth in the hazardous organic NESHAPs ("HON").

C. Performance Standards for Methanol Recovery Operations

1. Cheryl expressed interest in seeing performance standards drafted for methanol recovery which focus on pounds recovered per a certain time period (e.g., month, day or year). In addition, she stated that EPA was uncomfortable with tying the reuse of methanol to only those approaches that are deemed "economically feasible." Cheryl also expressed some concern about the concept of methanol being sent to the wastewater treatment system, as that would result in generation of sludge which, she stated, is not acceptable.

2. Okey noted that some amount of flexibility to send methanol to the wastewater treatment system is necessary because OSi must maintain a minimum level of organic loading in the system. He noted that OSi's first commitment is to collect as much of the methanol as possible. Then, OSi will turn to the question of what should be done with the collected methanol.

3. Beth inquired whether the market for methanol is volatile or whether there is some fixed standard that can be used to obtain a commitment that the methanol will be reused in some form. In response to a concern expressed by OSi about fixing a particular poundage for the amount of the methanol that is reused, Beth pointed out that the recovery and reuse of the methanol is part of what made this Project superior. She added that we must have a reuse goal, but can also build in some flexibility to refine the goal if OSi encounters unanticipated market forces.

4. Tim stated that establishing a fixed poundage is not the only way to establish a performance standard. He explained that in many circumstances, performance is measured by the way equipment is operated. Jim Cashel added that, indeed, there were assumptions made with respect to the operation of the equipment in determining the amount of methanol that would be recovered and we need to equate recovery rates with how the equipment is operated. Jim stated that there needs to be a method for tying the amount of methanol recovery to production levels and sludge generation. Okey stated that OSi used assumptions based on a best case scenario and he is not sure whether it is possible to lock-in actual numbers with respect to the methanol recovery. Okey also noted that the air emission pounds of reduction would not change, even if the methanol made its way to the wastewater treatment system. Dennis stated that there is quite a bit of methanol that gets into the sewer system in the current system. Under the new Project, all methanol would be collected and would bypass the sewer. Any methanol needed for organic loading would be added downstream of any open sewers.

5. The Workgroup discussed whether the performance standards for methanol collection need to be expressed in pounds of methanol recovered or whether there was another way to draft performance standards. They also discussed the possibility of reusing the collected methanol at the facility. OSi explained that traces of water and polyether in the recovered methanol, which currently are not removable, prevent the facility from reusing the methanol in its processes. Nevertheless, OSi is looking into possibilities for some future uses. OSi will propose some performance standards which address the concerns raised in the discussion.

D. Baseline
1. The Workgroup discussed what should be the appropriate baseline for the Project, either the new capper without controls or the existing capper without controls.

2. Michele noted that while the existing capper without controls may be helpful for comparison on a chart, it is not really the baseline and it may confuse the public to incorporate it into the FPA. Thus, she recommended that it be omitted from the FPA.

E. Reporting Requirements

1. The Workgroup next discussed what should be the reporting requirements under the FPA. Okey noted that OSi had suggested annual reporting to quantify the results of the Project. Michele added that there should also be technical reporting associated with the control devices. Julie stated that she would like OSi to prepare a report on the administrative aspects of the Project which describes how the Project is working out. Julie felt that this information is important given that this is a pilot Project and such information would be helpful to evaluate the program on a semiannual basis. Julie anticipates that the report would identify problems associated with the new approach to regulation and would explain how the parties addressed the problems they encountered.

2. Cheryl noted that she would like to see reporting on more than an annual basis because of the Agency's desire to have a sense of how things are progressing on an ongoing basis. Michele added that when you look at control device requirements under the HON, there are periodic reporting requirements for regular operations and special reporting requirements for exceedances. She suggested that reporting under this Project should be similar to those requirements of the HON. Cheryl added that reporting serves an important function in that it lets EPA know if something is not working during the course of the Project.

3. Cheryl also noted that there ought to be some performance standards for emissions from the surface impoundments to make sure that emissions associated with the wastewater treatment system are not dramatically altered during the Project. Dennis responded that he thought OSi would probably propose some type of annual report based on the Water 8 modeling. Okey suggested that perhaps OSi could update the existing spreadsheet on an annual basis. Michele thought this was a workable idea.

4. Julie thought that perhaps an annual meeting with signatories and stakeholders would be useful.

III. Action Items

1. OSi to obtain some examples of Reg 13 permit language.

2. Michele will look at the HON process vent and incinerator control standards for site-specific rulemaking.

3. OSi will review comments they received on the methanol recovery operation standards.

4. OSi will review monitoring, recordkeeping, and reporting requirements, and the possibility of more frequent reporting.

Local Navigation

Jump to main content.