United States
                       Environmental Protection
                           Office of the
                           [Mail Code 1101]
October 1997
Project XL:
OSi Specialities,  Inc.
Project XL is a national pilot program that tests innovative ways of
achieving better and more cost-effective public health and
environmental protection.  Through site-specific agreements with project
sponsors, EPA is gathering data and project experience that will help
the Agency redesign current approaches to public health and
environmental protection.  Under Project XL, sponsors, private facilities,
industry sectors, Federal facilities, and communities can implement
innovative strategies that produce  superior environmental performance,
replace specific regulatory requirements, and promote greater
accountability to stakeholders. For more information on Project XL, see
EPA's fact sheet entitled, "What Is Project XL? Excellence and
Leadership in Environmental Protection" (EPA231-F-97-001), April
1997, available on the Internet at http://www.epa.gov/ProjectXL or via
Project XL's fax-on-demand line at 202-260-8590.

OSi Specialties, Inc. (a subsidiary  of Witco Corporation) is a specialty
chemical manufacturer. OSi, EPA, and the West Virginia Department of
Environmental Protection (WVDEP) have signed an agreement for
OSi's Sistersville, WV plant that will achieve superior environmental
benefits while providing OSi with significant cost savings. To achieve
the environmental benefits, OSi has agreed to (1) install air pollution
controls on a production unit well ahead of when the controls are
anticipated to  be required by EPA regulations (the Miscellaneous
Organic NESHAPS, or"MON"), (2) reuse/recycle methanol, reducing
generation of sludge at the facility, and (3) study the feasibility of
reducing its waste streams. As an incentive for the environmental
benefits of the Project, EPA and WVDEP have agreed to propose a
deferral of new organic air emission regulations (RCRA Subpart CC)
applicable to OSi's two hazardous waste surface impoundments, as
described in the Regulatory Flexibility section below. In addition, if
necessary, EPA and WVDEP will also propose a deferral of certain
regulations (CAA Subpart YYY) that may be triggered if OSi implements
waste reduction projects, as described in the Regulatory Flexibility
section below.  CAA Subpart YYY would be deferred on a case-by-case
basis and only if these waste reduction projects meet strict
environmental protection requirements.

Without the project, OSi would be  required to comply with RCRA
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                    Subpart CC and may be required to comply with CAA Subpart YYY
                    under certain circumstances, but would not implement any of the
                    environmentally beneficial components of the project. As a result, the
                    facility's air emissions and waste generation without the project are
                    estimated to be substantially greater than with the project.

REGULATORY      Under the project, OSi will install an incinerator and route the process
FLEXIBILITY        vents from a production unit to the incinerator. The incinerator will
                    destroy 98 percent (by weight) of the organic compounds in the vent
                    stream, or about 309,000 pounds per year. In addition,  OSi will recover
                    and reuse an estimated 500,000 pounds per year of methanol that
                    would otherwise be treated in its wastewater system. This will result in
                    a reduction in sludge from the facility's wastewater treatment system of
                    about 815,000 pounds per year. OSi will also conduct a waste
                    minimization/pollution prevention study which should lead to additional
                    reductions in the volume and toxicity of the waste generated by the
                    facility and provide useful information on waste reduction to EPA and
                    other facilities.

                    EPA and VWDEP have agreed to propose and promulgate (subject to
                    review of public comment) a deferral of RCRA Subpart CC organic air
                    emission standards applicable to OSi's two surface impoundments. If
                    not deferred, these new standards would require OSi to install air
                    emission controls on its surface impoundments.

                    If OSi begins recovering certain substances listed in proposed CAA
                    Subpart YYY as a result of its waste minimization efforts, EPA and
                    VWDEP will consider  issuing  a limited scope deferral of the regulations
                    on a case by case basis. If such a deferral is granted, EPA and VWDEP
                    will propose and promulgate (subject to review of public comment)
                    regulations implementing the  deferral. This XL project includes this
                    provision because CAA Subpart YYY, if applicable, would require
                    additional air emission controls. These air emission controls could
                    make certain waste minimization projects economically infeasible for

                    EPA and WVDEP would propose any regulatory deferrals such that
                    they are effective until the required compliance date of the MON.  This
                    future Clean Air Act standard  is expected to require installation of
                    controls similar to the  incinerator to be installed under the project.  The
                    compliance date of the future air standard is currently anticipated to be
                    in 2002. At that time, the Project will end unless additional
                    environmental benefits warrant the continuation of the regulatory

                    OSi is working to ensure that stakeholders have an opportunity to
                    participate fully in the Project.  Efforts so far include:
                    $ A series of public information meetings held at the OSi facility

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$ A presentation to the West Virginia Conference on the Environment
$ Interviews with radio and newspaper media
$ Publication of meeting notices in local newspapers
$ A public file on the Project located at the local Sistersville library and
  EPA Region III in Philadelphia
$ Meeting minutes and other information sent to interested parties

In the future, periodic reports featuring information on the site's
environmental programs and progress will be distributed to

  Can providing the flexibility to control pollution in a more cost-
  effective manner produce benefits for both industry and the
  Is it environmentally beneficial to defer regulations as an incentive for
  encouraging waste minimization/pollution prevention activities?
  What results can be obtained through a waste minimization/pollution
  prevention study?

Regional Contact:  Cheryl Atkinson, 215-566-3392
EPA/XL HQ:      Nancy Birnbaum, 202-260-2601
State Contact:     Lucy Pontiveros, 304-558-1220
Company Contact: Okey Tucker, 304-652-8131

More information about Project XL is available on the Internet at
http://www.epa.gov/ProjectXL, via Project XL's fax-on-demand line at
202-260-8590, or via Project XL's Information Line at 703-934-3239.
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