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Crompton Corporation (Formerly Witco Corporation)

Minutes for Meetings Used to Develop the Final Project Agreement

OSi Specialties -
Project XL
November 14, 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 Hustis Gotanda Witco-Manko, Gold & Katcher
Beth Termini EPA Region III
Jim Cashel EPA Region III
Nancy Birnbaum EPA Headquarters
Julie Frieder EPA Headquarters
Amey Marrella EPA Headquarters
Britt Ludwig WV DEP

II. Summary of Discussions

      A. OSi informed the Workgroup that in a meeting held yesterday afternoon the company decided not to install a new capper unit at the Sistersville plant as the economic outlook no longer justified the increased capacity associated with the new production unit. Instead, the company plans to upgrade the existing capper unit at the facility. Nevertheless, the company would like to continue with its XL Project, modifying the Project to provide for installation of the proposed vent incinerator on the existing capper unit. In addition, methanol recovery operations and the waste minimization study would also be included, although the amount of methanol recovered and sludge generation avoided would be less.
      B. OSi reminded the group that the company's initial proposal to EPA for participation in Project XL contemplated installation of emission controls either on a new capper unit or on the existing unit. Recent negotiations, however, have focussed on the installation of controls on a new unit, rather than on the existing unit. Now that the business decision not to install a new unit has been made, the company would like to refocus attention on the voluntary installation of controls on the existing capper unit.
      C. Because the business decision was made late yesterday, OSi has not yet had an opportunity to verify the environmental performance calculations associated with the change to the Project. OSi, however, anticipates that it will cost approximately a half million dollars to install a vent incinerator on the existing capper unit. OSi expects that with the installation of the vent incinerator, it will achieve similar, and perhaps even greater, emissions reduction than it expected to achieve through the control of emissions from the new capper unit.
      D. OSi explained that it plans to perform a reliability upgrade on the existing capper, but will not increase the productive capacity of the unit. Had the new capper been installed, there would have been increased production and, concomitantly, a great increase in amount of methanol and sludge generated by the capper process. Accordingly, under the Project, OSi planned to recover significant quantities of methanol and to thereby make a significant reduction in sludge generation. Now, however, there will be no increase in production and, therefore, the volume of methanol recovery will likely remain at present levels. The existing capper already has a methanol collection system which collects approximately 500,000 pounds of methanol per year. That methanol is presently discharged to the sewer. However, if EPA is amenable to continuing the Project, OSi will commit to reuse, recover, etc. the methanol it collects as it had planned to do with the methanol expected to be recovered from the new capper, thereby reducing the amount of sludge that is currently generated.
      E. To assist EPA and the rest of the Workgroup in understanding the impact of this change to the Project, OSi will draft revised estimates for the existing unit. Okey will fax this information to Workgroup members for their review this afternoon. (The information is attached hereto as Appendix A.)
      F. EPA asked whether CAA Subpart YYY would still apply to the Project as a result of the upgrade of the existing unit. Tim stated that OSi is still analyzing this issue, but it is likely that it will not apply.

      G. EPA stated that it will have to consult internally to decide whether to continue with the XL Project in light of this change. Tim referenced Maryann Froelich's memo concerning how to handle XL Projects which change during the development stage and asked EPA to review this memo in making its decision. He explained that the memo distinguishes between minor changes to projects and significant deviations. He added that the memo provides that even where EPA determines a project change to be significant, it is not necessary in all cases to go through a complete reevaluation of the Project.
      H. OSi noted that it still believes that significant environmental benefit can be achieved by proceeding with the XL Project, but modifying the terms to provide for installation of control equipment on the existing, rather than a new, capper unit. The rest of the Project would remain essentially the same. OSi would still commit to collecting and reusing or recovering the methanol and would still undertake the waste minimization opportunity assessment. OSi also offered to bring the company business people to the table to talk with EPA if EPA felt that such discussion would be beneficial.
      I. Beth asked OSi what is the likelihood that production of capped methyl polyethers at the facility would cease absent Project XL. Dennis replied that production at the facility will not cease in the foreseeable future. He noted that the existing capper unit is still fully loaded and operating at capacity, which is why the company needs to perform a reliability upgrade on the unit.

III. Schedule
      A. The face-to-face meeting planned for November 19 in Pittsburgh may need to be rescheduled in light of the Project developments raised today. Further, Britt noted that no WVDEP representative is available to attend that meeting. The Workgroup will reassess the appropriateness of that meeting next week.

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