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Crompton Corporation (Formerly Witco Corporation)

Minutes for Meetings Used to Develop the Final Project Agreement

OSi Specialties -
Project XL
December 6, 1996 Conference Call Minutes

I. Conference Call Participants

Dennis Heintzman Witco-OSi
Okey Tucker Witco-OSi
Tony Vandenberg Witco-OSi
Dale Koontz Witco-OSi
Tim Malloy Witco-Manko, Gold & Katcher
Brenda Gotanda Witco-Manko, Gold & Katcher
Beth Termini EPA Region III
Cheryl Atkinson EPA Region III
Michele Aston EPA OAQPS
Nancy Birnbaum EPA Headquarters
Sherri Stevens EPA Headquarters
Lucy Pontiveros WV DEP
Jonathan McClung WV DEP
Chris van Löben Sels No comments on draft minutes were received from these individuals. NRDC

II. Minutes

      The Workgroup agreed to provide all comments on outstanding minutes to Brenda by Wednesday, December 11. Dennis will send out copies of the finalized minutes to everyone on the distribution list on Monday December 16. To date, comments on the draft minutes taken on the following dates remain outstanding: October 1, 8, 11, 16-17, 22, 29 and November 14. Draft minutes from the September 30 conference call will be circulated shortly.

III. Status of Project
      A. On December 5, EPA sent a letter to David Verner, Vice-President of Witco/OSi, addressing OSi's recent decision not to install a new methyl capper unit with air emission controls at its Sistersville plant and OSi's proposal to, instead, install emission controls on the existing capper unit and implement methanol collection and reuse. Beth explained that, as set forth in the letter, EPA is disappointed with this recent development, but nevertheless expects to be able to move forward with OSi's XL Project if appropriate modifications are incorporated into the Project. Beth further explained that EPA was disappointed because it believed that authorization had already been granted for installation of the new unit. Dennis responded that the decision not to install the new unit was made only recently and was based upon information not previously known to OSi.
      B. Beth explained that in order to move forward with a modified Project, OSi will need to submit a letter to EPA which explains, to the extent appropriate and without disclosing any confidential business information, OSi's decision to change the scope of its XL Project. Dennis agreed to provide such a letter to EPA.
      C. In addition, Beth stated, OSi will need to submit to EPA a written proposal for modifying its Project which specifically describes the components of the modified Project, including what changes will be made to the existing capper unit (e.g., the reliability upgrade), the regulatory effects of these changes, and their effect on the Project. This should also include a detailed explanation of the changes to the emissions estimates. Further, OSi should set forth the nature of the regulatory relief which it expects to need as part of the Project. Dennis stated that OSi can put together a 2 to 3 page summary which addresses all these issues.
      D. Dennis noted that the existing capper unit is currently operating at capacity and that OSi will be performing a reliability upgrade on the unit to prevent potential interruptions in production. He added that certain pieces of the unit are quite old and, therefore, it is difficult to find replacement parts for them. Accordingly, OSi plans to replace these pieces with new pieces for which off-the-shelf parts are readily available. Beth inquired as to how much time this upgrade would take. Dennis stated that OSi will try to complete the upgrade by December 1997. He added that the detailed engineering is not yet started, but that the engineering for this work will be much more abbreviated than that which would have been necessary for installation of a new unit.
      E. In addition to the reliability upgrade, Dennis stated that OSi will install a vent incinerator on the existing capper unit. This incinerator will pick up the process gas emissions (including methyl chloride and methanol) and OSi is also investigating whether it is possible to capture some of the dimethyl ether. OSi estimates that the vent incinerator will result in reduction of approximately 270,000 to 300,000 pounds of air emissions, as compared to 295,600 pounds of reductions under the "old" Project.
      F. Dennis explained that, currently, OSi recovers methanol from the existing capper unit. This recovered methanol is either incinerated or fed into the wastewater system at a downstream location. Dennis stated that OSi believes that it has found a market to reuse this material, just as it had proposed to do in its Project prior to the modification. In 1995, the capper unit generated 880,000 pounds of methanol. OSi believes it can reuse or sell for reuse approximately 500,000 pounds which is condensed.
      G. Beth asked whether any new substances will be released as air emissions which would not have been present if the new capper unit with controls had been installed. Dennis stated that there would not be any emission of new substances under the modified Project.
      H. Beth asked, in light of the fact that the upgrade will take until December 1997, whether it will be possible to have controls for the existing unit in place by the middle of next year. Dennis replied that he has asked the engineering department for a timing estimate. While he has not yet received a response from engineering, he anticipates that the controls can be in place and operating by June 1998. He added that while it is unlikely that controls would be operational by June 1997, they could be up and running by as early as December 1997. He is hoping to receive the estimates from engineering in January 1997. Tony noted that the timing estimates are not only dependent upon OSi, but also upon the schedules and availability of the vendors. Okey noted, as well, that part of the equipment from which emissions will be collected, will be installed as part of the reliability upgrade and, therefore, installation of some control equipment is tied directly to the reliability upgrade. Beth stated that EPA wants to set a solid time frame for implementation as soon as possible and requested that OSi advise EPA as soon as the estimates come back from engineering.
      I. Nancy Birnbaum stated that EPA has received a letter from OVEC requesting that OSi look at possibilities for the reduction of toluene emissions at its plant. Nancy asked whether, as part of the waste minimization assessment, OSi could find ways to reduce toluene emissions. Okey stated that OSi has done a lot of work with respect to toluene reduction, both in actual reduction and in assessing the potential for further reductions. He added that OSi participated in EPA's 33/50 program and obtained reductions at that time. He noted, however, that toluene reductions can certainly be addressed further in the assessment to be undertaken as part of this Project. Nancy requested that OSi send her the information concerning OSi's participation in the 33/50 program. Okey will send her the information by the end of next week.
      J. Cheryl asked for additional explanation concerning the present status of methanol collection from the capper unit. Okey explained that currently 500,000 pounds of methanol is collected. Of that amount, 350,000 pounds was sent to the wastewater treatment system and 150,000 pounds was sent for incineration/fuels blending in 1995. He added that the volume of methanol collected will remain pretty much the same under the Project, but that OSi will attempt to direct all 500,000 pounds to reuse.
      K. Chris asked what the market is for reuse of the methanol and Okey replied that it is used for denitrification. Beth asked if the potential buyer will be interested in receiving a lesser amount than was originally proposed under the Project. Dennis replied that he believes that the buyer is still interested.
      L. Beth inquired as to what type of regulatory relief OSi will need under the modified Project. Dennis replied that OSi still desires relief under RCRA Subpart CC and CAA Subpart YYY. Dennis explained that although this upgrade to the capper unit will not in itself trigger CAA Subpart YYY, it is quite possible that future alterations to other production processes may trigger it. OSi is having trouble justifying the expense of emission reductions undertaken as part of this Project because of the very real potential that some future change in operations could trigger CAA Subpart YYY or some other regulation which may require OSi to control emissions from the wastewater collection and treatment system and to seal up its sewers. Then all the savings anticipated as a result of this Project would disappear because the delayed costs would be incurred earlier than anticipated. Therefore, OSi is still interested in the de minimis concept discussed previously.
      M. Beth cautioned that the notion of allowing a de minimis level of emissions under Project XL is not something that EPA personnel have adopted as yet and there could potentially be objections to the concept. Michele added that EPA would more likely favor a reopener provision than a strict de minimis provision. Beth suggested that OSi prepare a proposal for EPA review. Dennis stated that OSi could have such a proposal prepared by December 17.
      N. Beth requested that OSi revise the draft FPA to reflect the recent changes to the Project. She noted that the Project Description will need to be revised as well as the section on CAA Subpart YYY. Cheryl added that EPA also expects to see some revisions to the waste minimization provisions but that we can discuss that at our next meeting or conference call.
      O. Chris related that NRDC spent some time working with Dow Chemical on a waste minimization assessment and addressed some tough issues and conflicting interests. He suggested that the Workgroup should discuss and agree, prior to the assessment, how the company will select and implement the best projects identified during the assessment.
      P. Beth stated that OSi should include in its letter to EPA a proposal for some sort of commitment with respect to implementation of waste minimization opportunities identified in the assessment. Beth added that EPA is very interested in pursuing waste minimization to increase the environmental benefit of the Project.

IV. Schedule
      The next Workgroup conference call is scheduled for Tuesday December 17, 1996 at 9:30 a.m.

V. Action Items:

A. OSi will be preparing the following items:

1. OSi Letter to EPA explaining decision to modify Project
      2. Modification Proposal
              (incl. explanation of modification and work required, regulatory effects of modification, regulatory relief requested, waste min proposal)
          3. Revise FPA
          4. Revise Emissions Estimates
          5. De Minimis Proposal

B. OSi will also send to Nancy Birnbaum information regarding toluene reductions at the Facility


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