Project XL  Progress  Report
         CK Witco Corporation
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         On March 16,1995, the Clinton Administration announced a portfolio of reinvention initia-
         tives to be implemented by the U.S. Environmental Protection Agency (EPA) as a part of its
         efforts to achieve greater public health and environmental protection at a more reasonable
         cost. Through Project XL, which stands for excellence and Leadership, EPA enters into
         specific proj ect agreements with public or private sector sponsors to test regulatory, policy,
         and procedural alternatives that will produce data and experiences to help the Agency make
         improvements in the current system of environmental protection. The goal of Proj ect XL is to
         implement 50 proj ects that will test ways of producing superior environmental performance
         with improved economic efficiencies, while increasing public participation through active
         stakeholder processes. As of October 1999,15 XL projects are in the implementation
         phase and 3 5 XL proj ects are under development. EPA Proj ect XL Progress Reports
         provide overviews of the status of XL proj ects that are implementing Final Proj ect Agree-
         ments (FPAs). The progress reports are available on the Internet via EPAs Proj ect XL web
         site at http://www.epa.gov/Project XL. Or, hard copies may be obtained by contacting the
         Office of Reinvention's Project XL general information number at 202-260-7434. Additional
         information on Proj ect XL is available on the web site or by contacting the general informa-
         tion number.

         Background

         CK Witco Corporation (CK Witco) is
         a specialty chemical manufacturer. This
         XL proj ect focuses on CK Witco's
         chemical manufacturing plant located 6
         miles south of Sistersville, West Vir-
         ginia, where CK Witco produces a
         broad range of silicone and silane
         products including surfactants, emul-
         sions, antifoams, and oils. The facility is
         located along the east side of the Ohio
         River in a rural setting near the border
         of Tyler and Pleasants Counties. The
         operating units are situated centrally within the
         facility and encompass approximately 50 acres.
Major Milestones
• 	 7 	
September 29, 1995
CK Witco XL Proposal
Submitted
/
October 17, 1997
Final Project
Agreement Signed
7
December 11, 1998
Waste Minimization/
Pollution Prevention
Study Report Completed
/
July 30, 1999
First Annual
Report Submitted
	 7 	 •
2002 Project
Reevaluation

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 CK Witco Corporation XL Project                                                       12-31-99
The CK Witco XL proj ect strives to reduce air emissions through a combination of flexible air pollution control
and waste minimization/pollution prevention (WMPP) activities. The polyether methyl capper unit is the focus
of emission control efforts. The capper unit is the site of a two-step reaction that results in one of CK Witco's
products, methyl-capped polyether. This proj ect also involves the facility's generation of solid waste and two
lined one-million-gallon surface impoundments that contain process wastewater.

In return for a deferral of certain air emissions standards, CK Witco has achieved superior environmental
performance at this facility by
• installing a process vent incinerator that is destroying 98% by weight of organic compound emissions in the
  facility's process vent stream, resulting in a reduction of over 200,000 pounds of emissions per year;
• recovering and reusing over 400,000 pounds of methanol per year, resulting in the reduction of over
  500,000 pounds of sludge per year;
• reducing methanol air emissions from the wastewater treatment unit by more than 20,000 pounds per year;
  and
• conducting a WM/PP Study to identify opportunities for additional reductions in waste generated by the facility.
The Experiment
The CK Witco proj ect tests whether regulatory flexibility will lead to reductions in air emissions and hazardous
waste from the two hazardous waste surface impoundments located onsite. The project strives to reduce
pollution through a combination of flexible air pollution control, waste minimization, and pollution prevention
activities.

The Flexibility

As an incentive to achieve superior environmental performance at CK Witco's facility, EPA and the West
Virginia Division of Environmental Protection (WVDEP) have offered CK Witco regulatory flexibility in the
areas of pollution control technology and air emissions.
The statutory programs, and the EPA offices administering those programs, that affect the CK Witco XL
Proj ect are
• Clean Air Act (CAA) programs administered by EPA's Office of Air Quality Planning and Standards;
• Resource Conservation and Recovery Act (RCRA) programs administered by EPA's Office of Solid Waste; and
• Pollution Prevention Act (PPA) programs administered by EPA's Office of Prevention, Pesticides, and Toxic
  Substances.
EPA's Region 3 office is also active in the development and implementation of the CK Witco XL project as a
member of the WM/PP study advisory committee, which participated in the design of the WM/PP Study and
reviewed and commented on progress reports from the study.
EPA and WVDEP agreed to a deferral of the RCRA Subpart CC organic air emission standards through a
site-specific rule and consent order, respectively, applicable to CK Witco's two surface impoundments. These
surface impoundments are one-million-gallon reservoirs that hold process wastewater from the facility's pollu-
tion control equipment and other sources. If not deferred, the Subpart CC standards would have required CK
Witco to install air emission controls on these surface impoundments. Alternatively, CK Witco could have
replaced the existing reservoirs with open-top tanks that are not regulated under RCRA Subpart CC regula-

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 CK Witco Corporation XL Project                                                        12-31-99
tion, and air emissions would not have been reduced. However, with the deferral, CK Witco has implemented
both the emissions control measures on the capper unit and the WMPP activities mentioned above.

In 2000, EPA plans to promulgate National Emission Standards for Hazardous Air Pollutants (NESHAPs) that
would be applicable to miscellaneous organic processes; this standard is called "the MON." Production activities
at the Sistersville facility will likely be classified as one type of these "miscellaneous organic processes." The
MON is anticipated to require process vent controls similar to the vent incinerator installed by CK Witco under
the XL proj ect. Therefore, the XL proj ect will provide superior environmental performance only until the MON
isin effect. The FPA provides for re-evaluation of the proj ect foil owing proposal of the new standards. CK
Witco will prepare a proj ect re-evaluation report within 90 days following the close of the comment period for
the new standards. If EPA, WVDEP, and other stakeholders agree to continue the proj ect, the FPA will be
amended to include new approaches to providing superior environmental performance.

EPA and WVDEP consider the WMPP initiatives important to the superior environmental performance
offered by the CK Witco XL project. Some of the WMPP initiatives could be undermined, however, if the
requirements proposed in CAA Subpart YYY are approved. As proposed, CAA Subpart YYY would apply
to certain WMPP initiatives if CK Witco begins recovering substances, such as acetic acid, listed in proposed
CAA Subpart YYY. If CK Witco starts recovering these substances, EPA and WVDEP will consider issuing
a limited-scope "allowable exclusion/allowable increase" deferral of the regulations on a case-by-case basis,
provided that EPA and WVDEP determine that this deferral will not cause an increase in actual emissions of
volatile organic compounds (VOCs) or cause a net adverse environmental impact, and that CK Witco will
remain in compliance with the FPAs provisions. If such a deferral is granted, EPA and WVDEP will propose
regulations implementing the deferral.

Promoting Innovation and System Change

Proj ect XL provides EPA opportunities to test and implement approaches that protect the environment and
advance collaboration with stakeholders. EPA is continually identifying specific ways in which XL proj ects are
helping to promote innovation and system change. The innovations and system changes emerging from the CK
Witco XL project are described below;
National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Organic
Processes. Flexibility in the control of air pollutants by CK Witco's Sistersville plant shows the adaptability
that is possible in complying with air regulatory requirements. These adaptations may be applicable to other
plants that are facing similar emission requirements and should be investigated relative to existing and future air
emissions issues. As EPA works to promulgate by the year 2000 NESHAPs applicable to miscellaneous
organic processes; the Agency will gather data on, and assess the performance of, the technology used at the
Sistersville plant. The new technology standard may require process vent controls similar to the controls
installed by CK Witco.
Waste Minimization and Pollution Prevention (WMPP). CK Witco committed to conducting a Waste
Minimization/Pollution Prevention (WM/PP) Study to identify opportunities for additional reductions in waste
generated by the facility. Normally, WMPP assessments are conducted as single events and outside of the
routine business operations of companies. However, the CK Witco study was an employee-driven effort that
sought to integrate the pollution prevention process into the company's standard business practices, facilitate
employee involvement, and implement a site-specific process tailored to the particular needs at the facility.
CK Witco used a multiphased process to conduct the WM/PP study: (1) identifying and characterizing
plantwide wastes and emissions; (2) screening and prioritizing these wastes and emissions; (3) identifying
pollution prevention options; (4) screening and prioritizing pollution prevention options; (5) examining the

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 CK Witco Corporation XL Project
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technical and economic feasibility of these options; and (6) developing an implementation plan. CK Witco's
proj ect approach toward pollution prevention and recycling may offer an innovative model for other chemical
intermediate-product manufacturers.
Innovative Technology. The CK Witco XL project provides a pilot for testing the benefits of allowing
regulatory flexibility in the technology used to control air emissions under RCRA regulations, in order to
provide superior and less expensive environmental protection. In return for a deferral of air emission standards
for its surface impoundments, CK Witco agreed to install a thermal oxidizer and route the process vents from
its poly ether methyl capper unit to that oxidizer for control of organic air emissions. Since the process vent
incinerator was installed on CK Witco's capper unit in April, 1998, air emissions have been reduced by more
than twice the amount that would have otherwise been achieved without proj ect XL. OnJuly 15,1998,a
performance test demonstrated that the thermal oxidizer is reducing total organics in the vent stream by
99.99%, versus the 98% minimum required by the EPA.  CK Witco estimates cost savings from emission
reductions and methanol recycling at approximately $ 16,000 for calendar year 1998. When combined with
other Pollution Prevention ("P2") opportunities identified by the Pollution Prevention Council, total potential
cost savings to the facility are estimated at $640,000 per year.

Project Commitment Summary

This table and the environmental performance section that follows summarize progress in meeting commitments
described in the FPA for CK Witco's Sistersville facility in West Virginia.
Commitment Status
Regulatory Implementation
EPA to propose a site-specific rule to defer surface
impoundment requirements under RCRA Subpart
CC by December 7, 1997.
WVDEP to execute a Consent Order to defer
surface impoundment requirements under RCRA
Subpart CC by December 7, 1997.
EPA to propose a site-specific rule to defer applica-
tion of the proposed C AA Subpart YYY to waste-
water collection and treatment systems, within 120
days of verifying need for deferral.
WVDEP to execute a Consent Order to defer
application of the proposed CAA Subpart YYY to
wastewater collection and treatment systems, within
45 days of verifying need for deferral.
Deferral final rule published in the Federal
Register September 15, 1998.
Consent Order executed.
Not yet necessary.
Not yet necessary.
Equipment Installation, Operation, and Monitoring
Complete installation and initial startup of thermal
incinerator by April 1, 1998.
Conduct a performance test of thermal incinerator to
determine the minimum temperature at which compli-
ance is achieved.
Installation and startup completed April 1, 1998.
Performance test completed July 15, 1998.

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 Commitment
   Status
                       Equipment Installation, Operation, and Monitoring
Monitor incinerator operating temperature and
closed vent stream flow.
Ongoing.
Monitor methanol recovery by condenser unit.
Ongoing.
Develop incinerator startup, shutdown, and
malfunction plan.
Complete.
                                   Methanol Recovery
Begin collection of methanol from condenser unit
within 10 days of FPA signing.
Begun October 8, 1997.
Reuse, recycle, or incinerate 95% of methanol
(remaining 5% to go to wastewater biotreatment
unit).
100% of methanol collected has been reused from
April 1, 1998 to December 31, 1998.
Monitor amount of methanol reused, recovered,
incinerated, and treated biologically in the waste-
water treatment unit.
Monitoring in progress.
                   Waste Minimization/Pollution Prevention (WM/PP) Study
Create study team within 45 days of FPA signing
to perform WM/PP Study.
Study team formed December 16,1997. It is made up
of representatives of CK Witco Corporation; a CK
Witco contractor, STV; Concurrent Technologies
Corporation; and the Waste Reduction and Technology
Transfer (WRATT) Foundation.
Identify and prioritize waste streams to be evalu-
ated in WM/PP Study.
Presented in final WM/PP Proj ect Report delivered
December 11,1998.
Establish advisory committee within 30 days of
FPA signing to oversee WM/PP Study.
Advisory committee established December 30,1997 to
review and comment on the study team's activities and
periodically review the effectiveness of WMPP oppor-
tunities implemented. Advisory committee made up of
representatives from WVDEP, EPA Region 3, local
residents, CK Witco Corporation, The International
Chemical Workers Union Council, and West Virginia
University atParkersburg.
Submit WM/PP Progress Reports every 90 days
after signing of FPA.
Three progress reports submitted on schedule. A
WMPP assessment of the facility identified numerous
ways to reduce waste, which are included in the WM7
PP Study final report issued December 11,1998. CK
Witco also sponsored brainstorming sessions from a
cross-section of the plant's technical and operating
staffs to screen, prioritize, and analyze the feasibility of
WMPP opportunities and prepare WM/PP Project
implementation plans.

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   CK Witco Corporation XL Project
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Commitment Status
Waste Minimization/Pollution Prevention
Prepare draft WM/PP Study Report one year after
FPA signing.
Implement WMPP opportunities.
Draft report issued for Advisory Committee com-
ment on October 16, 1998. Final report completed
December 11, 1998.
The Annual Report issued on July 30, 1999 lists 59
WMPP opportunities in various stages of imple-
mentation, 25 of which are implemented.
Reporting
Prepare semiannual progress reports
beginning January 31,1 999.
Prepare annual reports beginning July 31, 1999.
Prepare final proj ect report within 1 80 days after
termination of project.
Prepare proj ect re-evaluation report within 90 days
following the close of the comment period for MON
standards.
First semiannual progress report issued January 29,
1999.
First annual report issued July 30, 1999.
Not yet necessary.
Not yet necessary.
Environmental Performance
This section summarizes progress in meeting the environmental performance described in the FPA for CK Witco.
                                                              Air Emissions from Capper Unit
                                                     1998 Actual
                                                    1995 Baseline
                                                Estimated without XL
                                                                     59.9
Reduce Air Emissions from Capper Unit: Methyl
chloride, dimethyl ether, and methanol emissions
generated in the capper unit during production of the
methyl-capped poly ether are being collected and
routed to a new process vent incinerator installed on
the capper unit. CK Witco estimated the incinerator
would destroy at least 98% of the organic
compounds (by weight) in the vent stream, or about
271,000 pounds of these by-products per year.
Progress: The Annual Report issued July 30,1999,
provided data on the level of air emissions for 1998.
In 1998 the capper unit emitted a total of 59,898
pounds of organic compounds. This data includes
emissions from the capper prior to the oxidizer startup on April 1,1998. Since the vent incinerator was installed
and put into operation,  air emissions of total organics have been reduced by over 217,000 pounds per year as
compared with 1995 baseline levels. Performance tests indicate that the oxidizer is reducing total organics in the
vent stream by 99.99%, versus the 98% minimum required by the agreement.
                                                                  50   100   150   200   250
                                                                     Thousands of Pounds perYear
                                                                                            300

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CK Witco Corporation XL Project
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                                                                 Collected Methanol Reuse
                                                   Performance Goal
                                                     1995 Baseline
                                                                                           95%
                                                                                          100
Reduce Organic Capper Unit Discharges to Wastewater Treatment System: Production of methyl-
capped poly ether generating excess methanol in the
capper unit. Formerly, a portion of this methanol was
condensed, collected, and either disposed of in the
facility's wastewater treatment unit or incinerated.
Under thi s XL proj ect, CK Witco agrees to direct a
minimum of 95% of the collected methanol towards
reuse and recycling, or subj ect it to thermal recovery
or treatment, thus minimizing biotreatment of the
methanol in wastewater treatment units. CK Witco
estimated that approximately 550,000 pounds of
methanol that otherwise would be biotreated in the
wastewater system would be transferred to tank trucks
or rail cars for reuse or recycling each year.  There-
fore, the 940,000 pounds of discharges that would
have occurred without the XL Proj ect was estimated
to be reduced to 3 89,000 pounds per year.
Progress: The July 30,1999, Annual Report included data on the rate of methanol discharges for 1998. In
1998, the capper unit discharged to the wastewater treatment system, resulting in a reduction of nearly
519,000 pounds per year of menthol as compared to 1995 baseline figures. 424,254 pounds, or 100% of
recovered methanol by weight, were reused, recycled, or thermally recovered or treated in 1998, exceeding
the 95% performance standard established in the agreement.
Reduce Wastewater Treatment Sludge Generated from Capper Unit Methanol: As a result of CK
Witco's methanol recovery and reuse efforts, the amount
of sludge generated by the wastewater treatment system
from capper operations, and disposed of in an onsite
hazardous waste landfill was expected to decrease by an
estimated 815,000 pounds per year, from an estimated
1,425,000 pounds per year to an estimated 610,000
pounds per year.
                                                                                            100%
                                                                    20    40    60     80
                                                                    Percent of Collected Methanol Reuse
                                                                Wastewater Treatment Sludge
                                                             Generated from Capper Unit Methanoi
                                                      1995 Baseline
                                                   Estimated without XL
                                                               0  200  400 600  800 1000 1200 1400 1600
                                                                      Thousands of Pounds per Year
Progress: The July 30,1999, Annual Report included
data on the reduction of sludge generation for 1998.  In
1998,420,053 pounds of sludge were generated by the
wastewater treatment system from capper operations
representing a 757,247 pound reduction per year as
compared with 1995 baseline figures. Superior
environmental performance is evident in that 542,783
fewer pounds of sludge were generated in 1998 than would otherwise have been if the XL proj ect were not
implemented.
Reduce Air Emissions from Wastewater Treatment Unit: Reducing the amount of methanol that is sent to
the wastewater treatment system leads to a reduction in air emissions from the wastewater treatment system
that could occur during the treatment of that methanol. CK Witco estimated that as a result of its recovery and
reuse of methanol, air emissions from the wastewater treatment system would be reduced by 38,000 pounds
per year, from 140,300 pounds peryear to 102,000 pounds per year.

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CK Witco Corporation XL Project
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                                                                     Air Emissions from
                                                                Wastewater Treatment System
                                                       1998 Actual
                                                     1995 Baseline
                                                 Estimated without XL
                                                                                  88.9
                                                                                            140
                                                                                            140
                                                               0   20
                                                                       40  60  80  100  120  140  160
                                                                       Thousands of Pounds per Year
Progress: The Annual Report issued July 30,1998,
included data on reduced air emissions for 1998. In
1998, 88,932 pounds of air emissions were released
by the wastewater treatment unit representing a
reduction of 51,368 pounds per year as compared to
1995 baseline figures.
Implement a Comprehensive Waste Minimiza-
tion/Pollution Prevention Project: The WMPP
Project included a study of plant operations that
identified existing and future WMPP opportunities and
developed a plan to implement those that are techni-
cally and economically feasible. Through the use of an
advisory committee, CK Witco has involved EPA,
WVDEP, The International Chemical Workers Union Council, and other stakeholders in the study and imple-
mentation phases of the WM/PP Project.
Progress: CK Witco delivered the final WM/PP Study Report on December 11,1998. Highlights of the study
are described below.
A WM/PP Study Team (made up of CK Witco Corporation management and employees and an independent
contractor, STV Incorporated) was established to guide and conduct the daily activities of the WM/PP Study.
An advisory committee (made up of representatives of the community, regulatory agencies, and the plant) was
established to offer comments and suggestions throughout the process.
Four employee brainstorming sessions were a key component of the process. These sessions included repre-
sentatives from a cross-section of the plant's technical and operating staffs. The goals of the brainstorming
sessions were to develop criteria and methods to screen, prioritize, and analyze the feasibility of WMPP
opportunities; to increase awareness of pollution prevention; to evaluate and prioritize opportunities based on
technical and economic feasibility; to prepare implementation plans; and to determine how to measure
progress. In addition, a week-long survey conducted by the Waste Reduction And Technology Transfer
Foundation (WRATT) helped the facility identify waste and emission sources, and suggested ways to reduce
the quantity or toxicity of plant wastes.
A number of the study's pollution prevention options were determined to be technically and economically fea-
sible; these options are currently being implemented. The WM/PP Study Report is available from CK Witco.
The Annual Report issued on July 30,1999, lists 59 WM/PP opportunities in various stages of implementation
(scoping, planning, implementing, etc.). Of these, 25 proj ects have been implemented and are in place.

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 CK Witco Corporation XL Project
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                                  CK Witco WM/PP Study Results*
CK Witco Waste Minimization/Pollution Prevention
Study
One-time pollution prevention options — completed
in 1998.
Expected
recurring/
ongoing savings
XL proj ect air emissions
reduction and methanol recycle
(excludes capital savings).
Other pollution prevention
options.
Total savings
Potential Cost Savings
$42,000
$16,000 per year
$620,000 per year
$636,000 per year
Potential Waste/Emission
Reductions
26,000 pounds
1,1 00, 000 pounds per year
730,000 pounds per year
1,830,000 pounds per year
         *CK Witco has not yet assigned the expense of implementing these projects, and when it does the net
         cost savings will be less.

Stakeholder Participation

Stakeholder involvement during the proj ect development stage was encouraged in several ways. The methods
included communicating through the media (newspaper and radio announcements), directly contacting inter-
ested parties, and offering an educational program on the regulatory programs impacted by the XL proj ect.
Stakeholders have been kept informed via mailing lists, newspaper articles, public meetings and the establish-
ment of public files at the Sistersville Public Library and the EPA Region 3 office.

A local environmental group, the Ohio Valley Environmental Coalition, was contacted but stated that it did not
have time to participate actively in the development of the XL proj ect. However, a representative from the
Natural Resources Defense Council, a national environmental interest group, participated in conference call
meetings with the XL proj ect team and provided comments during the FPA s development. There are few homes
located near the facility, and therefore, few local stakeholders other than the employees of the facility expressed
interest in actively participating in the development of the proj ect. The Sistersville Plant provided stakeholders
with regular project development updates by circulating meeting and conference call minutes.

As this XL project's continues implementation, the stakeholder involvement program will shift its focus to
ensuring that stakeholders are apprised of the proj ect's status, and have access to information sufficient to
judge the success of this Project XL initiative. Facilitating stakeholder involvement during the term of the
proj ect likely will include holding general public meetings to present periodic status reports and making avail-
able data and other information as it is generated. CK Witco has appointed a Sistersville Plant Proj ect XL
contact at the facility to serve as a resource for the community. In addition, the plant is required to make copies
of semiannual and annual project reports available to all interested parties.

Six-Month Outlook

Key focus areas for successful implementation of the FPA over the next six months include the second semian-
nual proj ect report due January 31,2000, the second annual proj ect report due July 31,2000, and the ongo-
ing implementation of options identified in the WM/PP.

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         CK Witco Corporation XL Project                                                       12-31-99
         Contacts

         • Okey Tucker, CK Witco OSi Group (CK Witco), (304)652-8131.
         • Nancy Birnbaum, EPA Headquarters, (202) 260-2601.
         • Tad Radzinski, EPA Region 3, (215) 814-2394.
         • Lucy Pontiveros, DEP, (304) 558-1220.
         • Jonathan McClung, DEP, (304) 558-1220.

         Information Sources

         The information sources used to develop this progress report include (1) discussions during a teleconference
         among representatives of the U. S. EPA, CK Witco, and WV DEP; (2) the FPA Final Proj ect Agreement for
         the CK Witco XL project; (3) the final Report from the WM/PP Study undertaken by CK Witco as part of
         this XL project; and (4) the First Annual CK Witco XL Proj ect Report, issued July 30,1999. The information
         sources are current through July, 1999.

         Glossary

         Air Emissions: Pollution discharged into the atmosphere from smokestacks, other vents, and surface areas of
         commercial or industrial facilities; from residential chimneys; and from motor vehicle, locomotive, or aircraft
         exhausts.

         Air Emission Standard: The maximum amount of air-polluting discharge legally allowed from a single source,
         either mobile or stationary.

         Allowable Exclusion/Allowable Increase: Where CK Witco implements a Qualifying Change to a process unit
         at the Facility, EPA and WVDEP expect to defer applicability of C AA Subpart YYY for the Qualifying
         Change.

         Baseline: The measure by which future environmental performance can be compared.

         Biotreatment: A process that uses bacteria to consume organic waste.

         Capper Unit: The poly ether methyl capper unit is the point in CK Witco's production process where a two-
         step reaction occurs that results in the intended end product, methyl-capped poly ether.

         Clean Air Act (CAA):  The Clean Air Act is the Federal law that regulates air emissions from area, stationary,
         and mobile sources. This law authorizes the U.S. Environmental Protection Agency to establish National
         Ambient Air Quality Standards (NAAQS) to protect public health and the environment.

         CAA Subpart YYY (New Source Performance Standards): Proposed regulations to control VOC emissions
         from wastewater generated by certain process units. As proposed, these standards would generally apply to
         new or modified process units that generate a wastewater stream with VOC concentrations above a specified
         amount and that produce any of a specific list of substances ("Subpart YYY Substances"), such as acetic acid
         as a product or by-product.

         Consent Order: An agreement between two parties that does not involve any judicial action.

         Deferral: A legally sanctioned delay in compliance with regulations.

         Dimethyl Ether: A colorless flammable gas. Used in refrigeration, as a solvent, and in chemical production.
         Harmful if inhaled; irritating to eyes.
10

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Discharges: Flow of liquid or chemical emissions from a facility into water or air.

Final Proj ect Agreement (FPA): The FPA outlines the details of the XL proj ect and each party's commitments.
The proj ect's sponsors, EPA, State agencies, Tribal governments, other regulators, and direct participant
stakeholders negotiate the FPA.

Hazardous Waste: By-products of society that can pose a substantial or potential hazard to human health or
the environment when improperly managed. These wastes possess at least one of four characteristics—
ignitability, corrosivity, reactivity, or toxicity—or appear on special EPA lists.

Impoundment:  A body of water or sludge confined by a dam, dike,  floodgate, or other barrier.

Incineration: A treatment technology involving destruction of waste by controlled burning at high temperatures.

Incinerator: A furnace for burning waste under controlled conditions.

Media: Specific environments-air, water, soil-which are the subject of regulatory concern and activities.

Methanol: An alcohol that can be used as an alternative fuel or as a gasoline additive. Poisonous if ingested.

Methyl Chloride: A colorless flammable gas. Used in the production of chemicals, as a solvent and refrigerant,
and as a food additive. Mildly toxic if inhaled.

Multi-media: Several environmental media, such as air, water, and land.

"The MON": The National Emission Standard for Hazardous Air Pollutants (NESHAP) for the source
category "Miscellaneous Organic Chemical Production and Processes." Some examples of these processes
are: explosives production, photographic chemicals production, polyester resins production, and the produc-
tion of paints, coatings and adhesives.

National Ambient Air Quality Standards (NAAQS): Standards established by EPA applicable to outdoor air
throughout the country.

National Emissions Standards for Hazardous Air Pollutants (NESHAPs):  Emissions standards set by EPA for
air pollutants not covered by National Ambient Air Quality Standards (NAAQS), that may cause an increase
in fatalities or in serious, irreversible, or incapacitating illness. Primary standards are designed to protect human
health, and secondary standards are designed to protect public welfare (e.g., building facades, visibility, crops,
and domestic animals).

Organic Compounds: Naturally occurring (animal or plant-produced) or synthetic substances containing
mainly carbon, hydrogen, nitrogen, and oxygen.

Pollution Prevention (P2): Identifying, altering, or eliminating areas, processes, and activities that create
excessive waste products or pollutants. Such activities, consistent with the Pollution Prevention Act (PPA) of
1990, are conducted across all EPA programs.

Process Vent: A gas stream discharged to the atmosphere (with or without passing through a control device or
recovery device) from chemical processing equipment.

Resource Conservation and Recovery Act (RCRA): RCRA gives EPA the authority to control hazardous
waste from the "cradle to grave." This includes the generation, transportation, treatment, storage, and disposal
of hazardous waste. RCRA also sets forth a framework for the management of nonhazardous wastes. RCRA
enables EPA to address environmental problems that could result from underground tanks storing petroleum
and other hazardous substances. RCRA focuses only on active and future facilities and does not address
abandoned sites.
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        RCRA Subpart CC: Requirements for the control of air emissions from hazardous waste tanks, surface
        impoundments, and containers. The name comes from the fact that they are found in the regulations in Subpart
        CC of 40 CFR Parts 264 and 265.

        Sludge: A semisolid residue from air or water treatment processes; it can be a hazardous waste.

        Thermal Oxidizer: An enclosed device that destroys organic compounds by thermal oxidation, i.e. reacting at
        elevated temperatures with oxygen.

        Thermal Recovery or Treatment: In the CK Witco XL project, refers to the use of collected methanol in fuels
        blending or as a feed to any combustion device.

        Waste Minimization: Measures or techniques that reduce the amount of wastes generated during industrial
        production processes; term is also applied to recycling and other efforts to reduce the amount of waste going
        into the waste stream.

        Wastewater:  The spent or used water from a home, community, farm, or industry that contains dissolved or
        suspended matter.
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