![[logo] US EPA](../gif/logo_epaseal.gif){kind=logo}
Crompton Corporation (Formerly Witco Corporation)
Minutes for Meetings Used to Develop the Final Project Agreement
OSi Specialties - Project XL October 8, 1996 Conference Call Minutes
I. Conference Call Participants
Jesse Barnhart Witco-OSi
Dennis Heintzman Witco-OSi
Dale Koontz Witco-OSi
Okey Tucker Witco-OSi
Tony Vandenberg Witco-OSi
Brenda Gotanda Witco-Manko, Gold & Katcher
Tim Malloy Witco-Manko, Gold & Katcher
Cheryl Atkinson EPA Region III
Beth Termini EPA Region III
Maria Parisi Vickers EPA Region III (for portion of call)
Michele Aston EPA Headquarters
Julie Frieder EPA Headquarters
Amey Marrella EPA Headquarters
Jonathan McClung WVDEP
II. Meeting Minutes
Comments on the draft minutes from the September 17 and 24 conference calls remain outstanding. Beth said that Cheryl and Jim had some comments which Beth would pass along to Tim and Brenda. Everyone agreed to have their comments on the minutes to Brenda by Friday, October 11. Michele will have her comments in on Monday, October 14.
III. Order Regarding RCRA Subpart CC Compliance
A. Beth stated that she had received comments this morning from Headquarters on the RCRA Subpart CC compliance package which consists of a complaint, consent agreement, and consent order. She will incorporate those comments and then send a draft to Tim for review.
B. Dennis inquired as to the time frame anticipated in finishing this up. Beth explained that the package will need to go through management and to be signed by the regional judicial officer; therefore, she could not provide an exact date for completion. She said that she would send the draft to Tim and to WVDEP within the next day or two.
C. Beth stated that she still needs to speak with Britt to determine what WVDEP wants to do with respect to the order and agreement. The draft currently contains bracketed references to state authorities.
IV. Performance Standards
The Workgroup reviewed and discussed the draft performance standards prepared by OSi. A copy of those standards are appended hereto as Attachment 1. Below is a brief summary of the items discussed.
A. Start-Up and Shakedown
1. Cheryl inquired about the meaning of the phrase "initial start-up." Tim and Okey explained that the phrase "initial start-up" is intended to have the same meaning as it has in the context of the NSPS. Dennis added that when new equipment is put on-line, there is typically an initial start-up followed by a period of time in which adjustments may be made to the equipment as necessary to achieve the maximum production rate. This is referred to as the shakedown period. During the shakedown period, the equipment may need to be shut down for short periods to make necessary adjustments. Equipment shut downs may be a few hours or up to a couple of days at the maximum.2. Dennis reassured EPA that the vent incinerator and condenser will run whenever the capper unit is running, even during the shakedown after initial start-up, other than for periods when maintenance is needed and or that is not anticipated to be for lengthy periods of time.
3. Tim referred EPA to the NSPS provisions which require initial start-up by a certain date and then allow a 180-day period to work out all the kinks in the system and to demonstrate compliance with applicable requirements. Dennis added that OSi's intent is to conduct the performance test when the unit is operating at peak efficiency, and that the equipment often needs to run for some time before the maximum rate of product production is achieved.
4. EPA had questions about the use of an initial start-up date and a shakedown period but agreed to review the NSPS requirements and get back to OSi on the issue.
B. Monitoring, Recordkeeping and Reporting
1. Michele suggested that the performance standards should include a requirement for continuous monitoring and recordkeeping from the time of initial start-up. This way, EPA would be able to measure the environmental benefit achieved during the shakedown period.
2. Michele also suggested adding some additional reporting requirements, such as reporting exceedances, malfunctions, and maintenance shut downs to the Regional Administrator. Tim indicated that OSi is still working on the reporting section of the document. Michele suggested that Tim should review the HON, RCRA Subpart CC, and the Subpart AA amendments which were promulgated last Friday. She will fax a copy of the relevant sections of the Subpart AA amendments to Tim.
3. Okey noted that the facility's Regulation 13 permit will address start-up, shut down, malfunction, and maintenance. He suggested that we make the performance standards consistent with those requirements. Tim added that the performance standards were drafted to dovetail concepts in the HON with those of Reg. 13 and expressed the expectation that the permit development process would be the proper route for incorporating these provisions into an enforceable document. Beth stated that it should not make a difference which vehicle is used as long as everything is consistent. After some discussion concerning whether the rulemaking or permit process would likely occur first and which should contain the relevant provisions, the Workgroup decided to defer further consideration of the issue until we get a better sense for the timing of the implementation mechanisms.
4. Julie noted that the Weyerhauser FPA is going out for public comment tomorrow.
C. Operation of Capper Unit
1. Cheryl inquired as to why the measurement of TOC on the process vent incinerator is designated as "less methane and ethane." Tim explained that this language is drawn directly from the regulatory requirements (see e.g., 40 CFR Subparts NNN, RRR, III, and the HON).
2. Cheryl also inquired about the level of detail concerning the condenser and the incinerator. Dennis stated that additional detail will be added to the facility description on this issue.
3. Beth inquired about the disposition of the old capper unit once the new unit is put on-line. Dennis stated that the old unit will be taken off-line, but will not necessarily be completely dismantled. While there are no plans for that unit at this time, OSi may, in the future, decide to use it, or a portion of it, to manufacture other products. Appropriate permitting would be conducted for such activities.
4. EPA raised some additional questions about various performance standard requirements. Tim explained that the provisions were drawn directly from EPA regulations in the hope that the Workgroup would not get bogged down in the detail of each of the requirements. EPA requested that Tim provide them with citations to the provisions from which the performance standards were drawn. Tim will provide these to EPA tomorrow. The Workgroup agreed to defer further discussions on these issues until EPA has had a chance to review the regulatory requirements.
D. Methanol Recovery Operation
1. Okey explained the nature of the performance standards relating to methanol recovery operations which are set forth in section IV.C of Attachment 1. Briefly, OSi will recover a minimum of 90% of the methanol from the capper unit on an annual basis. Further, OSi will commit to utilizing, on an annual basis, at least 70% of the methanol collected for reuse, recovery, or thermal recovery/treatment as defined in the performance standards. No more than 30% will be biologically treated.
2. After some questions concerning the translation of the standards to environmental benefit, EPA agreed that these standards will provide the environmental benefit set forth in OSi's Project XL proposal.
3. In addition to the performance standards, which are the enforceable commitments, the Workgroup considered including other information of an educational nature about the FPA. OSi will take a look at the information available and evaluate the alternatives.
4. Cheryl expressed some concerns about the frequency of reporting. The Workgroup discussed the burdens and benefits of more frequent reporting, including the associated increase in paperwork. Dennis suggested adding a provision for semi-annual reporting. The Workgroup agreed that this would be appropriate and concluded that so long as requirements for continuous monitoring and recordkeeping are in place, more frequent formal reporting of routine operations may not be necessary, provided that the information is available to EPA or stakeholders upon request.
5. Cheryl inquired about the certainty of recovering 90% of the methanol. Okey and Dennis noted that, based upon the technology associated with the condenser, they are able to reach a 90% recovery rate. They added that the condenser will run at all times that the capper unit is running. Thus, over the year the recovery rate will be at least 90%.
V. Schedule
A. Conference Call
The next conference call will be held on Friday, October 11 at 1:00 p.m.
B. Face-to-Face Meeting
1. The face-to-face meeting in Charleston is scheduled to begin at 1:30 p.m. on October 16. The meeting will run through the afternoon of October 16, will resume on October 17 at 8:30 a.m. and will continue into early afternoon. EPA is planning to meet separately with WVDEP for some time on Thursday afternoon.
2. Dennis noted that Eric Peters from the stakeholders group plans to attend the Charleston meeting.
Attachment 1
INSERT TO FPA
IV. Performance Standards
C. Installation of Capper Unit Control Device and Methanol Recovery Operation
1. Installation and initial start-up of a thermal incinerator on new capper unit's process vent and commencement of the methanol recovery operation will be completed by June 8, 1998 [6 months after RCRA Subpart CC compliance date].
2. Notification of the actual date of initial start-up and commencement will be provided to EPA and WVDEP within 15 days after such events.
D. Operation of the Capper Unit Process Vent Incinerator
1. Performance Standards
a. Except as provided under IV.B.5, the process vent thermal incinerator will reduce emissions of total organic compounds ("TOC") (less methane and ethane) from the process vent by 98 weight-percent. For these purposes, TOC has the meaning set forth at 40 C.F.R. § 60.661 (1995).
b. During the shakedown period for the new capper unit, OSi will not operate the existing capper unit at any time during which the new capper unit is in operation. Following the shakedown period for the new capper unit, the existing capper unit will be taken out of service for capped methyl polyether production.
2. Compliance Date: OSi will comply with the performance standard set forth in Section IV.B.1.a on and after the date on which the initial performance test referenced in Section IV.B.3.a. is completed, but no later than 180 days after the initial start-up date.
3. Monitoring
a. Initial Performance Test: Within 60 days after achieving the maximum production rate at which the capper unit will be operated, but no later than 180 days after its initial start-up, OSi will conduct a performance test to determine compliance with the emission reduction requirement specified in Section IV.B.1.
(1) The initial performance test will be conducted consistent with 40 C.F.R. §§ 60.8 and 60.664(b) or such equivalent methods and procedures as may be approved by WVDEP.
b. Subsequent Monitoring: OSi will install, calibrate, maintain and operate according to manufacturer's specifications the following equipment:
(1) A temperature monitoring device equipped with a continuous recorder. The temperature monitoring device shall be installed in the firebox or in the duct work immediately downstream of the firebox in a position before any substantial heat exchange is encountered.
(2) A flow indicator that provides a record of vent stream flow to the incinerator at least once every fifteen minutes. The flow indicator will be installed in the vent stream from the process vent at a point closest to the inlet of the incinerator.
(3) For purposes of this section, the term "flow indicator" means a device which indicates whether gas flow is present in the vent stream.
(4) For purposes of this section, the term "continuous recorder" means a data recording device recording an instantaneous data value at least once every fifteen minutes.
4. Recordkeeping: OSi will keep an up-to-date, readily accessible record of the following:
a. Data measured during the initial performance test regarding the average firebox temperature of the incinerator and the percent reduction of TOC achieved by the incinerator, and/or such other information required in addition to or in lieu of that information by the WVDEP in its approval of equivalent test methods and procedures.
b. Continuous records of the equipment operating procedures specified to be monitored under Section IV.B.3.b., as well as records of periods of operation during which the parameter boundaries established during the initial performance test are exceeded. For these purposes, the periods of operation during which the parameter boundaries are exceeded are defined as any consecutive three hour period of operation during which the average combustion temperature was more than 28° C (50° F) below the average combustion temperature during the initial performance test.
c. Records of all periods when the vent stream has no flow rate to the extent that the capper unit is being operated during such period.
5. Start-up/Shutdown/Maintenance and Malfunction: During periods of start-up, shutdown, maintenance and malfunction, OSi will operate the process vent thermal incinerator in accordance with the requirements in procedures to be set forth in the operating permit issued under 45 W. Va. Code Series 13, to the extent consistent with applicable federal and state law.
E. Operation of the Methanol Recovery Operation
1. Performance Standard
a. The condenser associated with the methanol recovery operation will, on an annual basis, recover 90% by weight of the methanol contained in the influent gas stream to the condenser.
b. The condenser associated with the methanol recovery operation will be in operation at all times during which the capper unit is being operated to manufacture product.
2. Monitoring
a. OSi will perform measurements necessary to determine the following information needed to demonstrate compliance with the standards set forth in IV.C.1., above:
(1) the annual amount of methanol recovered by the condenser associated with the methanol recovery operation, and
(2) such other information as is necessary to permit the stoichiometric calculation of the annual amount of methanol contained in the influent to the condenser associated with the methanol recovery operation.
b. OSi will install, calibrate, maintain and operate according to manufacturer specifications a temperature monitoring device with a continuous recorder for the condenser associated with the methanol recovery operation.
c. OSi will record the dates and times during which the capper unit and/or the condenser are not operating.
3. Recordkeeping: OSi will keep up-to-date, readily-accessible records of the parameters specified to be monitored under Section IV.C.2., above.
F. Disposition of Methanol Collected by the Methanol Recovery Operation
1. Performance Standard: On an annual basis, a minimum of 70% by weight of the methanol collected by the methanol recovery operation will be utilized for reuse, recovery, or thermal recovery/treatment as defined below. No more than 30% of the methanol collected by the methanol recovery operation will be subject to bio-treatment on an annual basis.
a. "Reuse" includes the substitution of collected methanol (without reclamation of the methanol subsequent to its collection) for virgin methanol as an ingredient (including uses as an intermediate) or as an effective substitute for a commercial product.
b. "Recovery" includes the substitution of collected methanol for virgin methanol as an ingredient (including uses as an intermediate) or as an effective substitute for a commercial product following reclamation of the methanol.
c. "Thermal recovery/treatment" includes the use of collected methanol in fuels blending or as a feed to any combustion device to the extent permitted by federal or state law.
d. "Bio-treatment" includes the introduction of the collected methanol into a biological treatment system, including the treatment of the collected methanol as a waste stream in an onsite or off-site wastewater treatment system. Introduction of the collected methanol to the onsite wastewater treatment system will be limited to points downstream of the surface impoundments, and will be consistent with the requirements of federal and state law.
2. Monitoring: OSi will perform measurements necessary to determine the pounds of collected methanol directed to reuse, recovery, thermal recovery/treatment and bio-treatment on an annual basis.
3. Recordkeeping: OSi shall keep up-to-date, readily-accessible records of the amounts of collected methanol directed to reuse, recovery, thermal recovery/treatment and bio-treatment necessary for the measurements required under IV.D.2., above.
G. Emissions From Tank T-872
1. Performance Standard: Total organic emissions from Tank T-872 shall be limited to 200 lbs. per year.
2. Monitoring: OSi will perform measurements necessary to perform emissions calculations for Tank 872 using AP-42 on an annual basis.
3. Recordkeeping: OSi will keep up-to-date, readily-accessible records of the calculations referenced in Section IV.E.2, above, as well as measurements required to be made under that section.
F. Record Retention: Each record that will be kept under this section will be retained by OSi for at least two years from the date such record is generated.
G. Reporting: To Be Inserted