Project XL Progress Report
Crompton Corporation
Sistersville Facility
In 1995, the U.S. Environmental Protection Agency (EPA) embarked on a series of innova-
tive initiatives in an effort to test new ways to achieve greater public health and environmental
protection at a more reasonable cost. Through Proj ect XL, which stands for excellence and
Leadership, EPA enters into specific proj ect agreements with public or private sector spon-
sors to test regulatory, policy, and procedural alternatives that will produce data and experi-
ences to help the Agency make improvements in the current system of environmental protec-
tion. The goal of Project XL is to implement 50 projects that will test ways of producing
superior environmental performance with improved economic efficiencies, while increasing
public participation through active stakeholder processes. As of January 2001, EPA has
reached its goal of 5 0 proj ects in the implementation phase. EPA Proj ect XL Progress
Reports provide overviews of the status of XL projects that are implementing Final Project
Agreements (FPAs). The progress reports are available on the Internet via EPAs Proj ect XL
web site at http://www.epa.gov/Project XL. Hard copies may be obtained by contacting the
Office of Policy, Economics and Innovation's (formerly Office of Reinvention) Proj ect XL
general information number at 202-260-5754. Additional information on Proj ect XL is
available on the web site or by contacting the general information number. The information
and data presented in the January 2001 Progress Report is current as of December 2000.
Background
Crompton Corporation (formerly Witco Corporation) is a specialty chemical manufacturer.
This XL proj ect focuses on Crompton's chemical manufacturing plant located six miles south
of Sistersville, West Virginia. Five other
towns are located in the vicinity of the
plant, including Ben's Run, Friendly,
Middlebourne, Paden City, and St.
Mary's. The population of these com-
munities totals approximately 1,500
people. The Crompton facility is
located along the east side of the Ohio
River in a rural setting near the border
of Tyler and Pleasants Counties. Both
Tyler County (the county where the
Crompton
Corporation
XL Project
Sistersville,
West Virginia
Major Milestones
• 7
September 29, 1995
Crompton 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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Crompton Corporation XL Project 1-31-01
plant is located) and Pleasants County (the down-river county) are predominantly rural, with populations totaling
10,000 and 7,500 respectively. Since the arrival of Union Carbide in the 1950's, these communities have relied
on the manufacturing industry, including Crompton, for employment. Six hundred residents of Tyler and
Pleasants County are employed by Crompton at the Sistersville plant.
Crompton produces a broad range of silicone and silane products including surfactants, emulsions, antifoams,
and oils. The operating units are situated centrally within the facility and encompass approximately 50 acres.
The Crompton XL project strives to reduce air emissions through a combination of flexible air pollution control
and waste minimization/pollution prevention (WM/PP) activities. The poly ether 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 Crompton's
products, methyl-capped polyether. This project 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, Crompton has achieved superior environmental
performance at this facility by:
• installing a process vent incinerator that is destroying 98 percent 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
Crompton estimates annual cost savings from emission reductions and methanol recycling at approximately
$ 16,000. When combined with other Pollution Prevention ("P2") opportunities identified by the Pollution
Prevention Council, annual, recurring cost savings are $240,000 for those implemented in 1997, $25,000 for
those implemented in 1998, $650,000 for those implemented in 1999, and $381,000 for those implemented
during the first half of 2000. These total $1,010,000. (These savings, however, do not include the expenses of
implementing the P2 measures. The actual, net savings will be less.)
The Experiment
The Crompton proj ect tests whether regulatory flexibility will lead to reductions in air emissions and hazardous
waste greater than what would be achieved by otherwise required emissions controls for the two hazardous
waste surface impoundments located onsite. The proj ect 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 Crompton's facility, EPA and the West
Virginia Division of Environmental Protection (WVDEP) have offered Crompton 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 Crompton XL project
are:
• Clean Air Act (CAA) programs administered by EPA's Office of Air Quality Planning and Standards;
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Crompton Corporation XL Project 1-31-01
• 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 Crompton 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.
RCRA Subpart CC contains requirements for the control of air emissions from hazardous waste tanks, surface
impoundments, and containers. 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 Crompton's two
surface impoundments. These surface impoundments are one-million-gallon reservoirs that hold process waste-
water from the facility's pollution control equipment and other sources. If not deferred, the Subpart CC stan-
dards would have required Crompton to install air emission controls on these surface impoundments. Alterna-
tively, Crompton could have replaced the existing reservoirs with open-top tanks that are not regulated under
RCRA Subpart CC regulation, and air emissions would not have been reduced. However, with the deferral,
Crompton has implemented both the emissions control measures on the capper unit and the WM/PP activities
mentioned above.
In the first quarter of 2001, EPA plans to propose National Emission Standards for Hazardous Air Pollutants
(NESHAPs) under Section 112 of the CAA that would be applicable to miscellaneous organic processes; this
standard is called "the MON." The MON is anticipated to apply to a broad spectrum of chemical processes
not regulated under other NESHAP rules. The MON is expected to include controls for process vents, and
wastewater collection and treatment systems. It is anticipated that the MON will apply to the capper unit at the
Crompton facility, and that controls on both the production unit and wastewater treatment system will be
required. EPA believes that the MON will include process vent control requirements similar to those already
implemented under the proj ect. Accordingly, EPA expects to receive superior environmental benefits from the
proj ect only until such time as compliance with the technical requirements of the MON is required (the "MON
compliance date"). At the expected end of the proj ect (assumed to be late in 2004, the year in which it is
expected that the MON may require control of capper unit emissions, hence approximately six years after the
installation of the emissions controls), any required emission controls will be placed on the capper unit and the
waste water treatment unit and voluntary methanol collection could continue. The FPA provides for re-evalua-
tion of the proj ect following proposal of the new standards. Crompton will prepare a proj ect re-evaluation
report within 90 days following the close of the comment period for the proposed new standards. If EPA,
WVDEP, and other stakeholders agree to continue the project, the FPA will be amended to include new
approaches to providing superior environmental performance.
EPA and WVDEP consider the WM/PP initiatives important to the superior environmental performance offered
by the Crompton XL proj ect. Some of the WM/PP initiatives could be undermined, however, if the require-
ments proposed in CAA Subpart YYY are approved. CAA Subpart YYY (New Source Performance Stan-
dards) contains 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. As proposed, CAA Subpart YYY would apply to certain WM/PP initiatives if Crompton begins
recovering substances, such as acetic acid, listed in proposed CAA Subpart YYY. If Crompton starts recover-
ing 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
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Crompton Corporation XL Project 1-31-01
adverse environmental impact, and that Crompton will remain in compliance with the FPA's 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
Crompton XL proj ect are described below.
National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Organic Pro-
cesses. Flexibility in the control of air pollutants by Crompton'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 noted previously, it is likely that the MON will apply in the future to require some level of control of
emissions from the capper unit and the wastewater collection and treatment system. That event would not
diminish the superior environmental performance obtained prior to the compliance date of the MON under this
proj ect. The total emission reductions and pollution prevention achieved as a result of implementation of the
proj ect during the minimum proj ect term will be significant. As EPA works to promulgate NESHAPs applicable
to miscellaneous organic processes; the Agency will gather data on, and assess the performance of, the technol-
ogy used at the Sistersville plant. The partners in this proj ect realize that a dynamic, rather than static, FPA
encourages the parties to identify additional opportunities for superior environmental benefits during the course
of thi s proj ect. Proj ect reevaluation provides the parties with a fluid process, during the course of the proj ect, to
identify proj ect enhancements to achieve superior environmental results at the facility. Accordingly, the parties
may determine during reevaluation that implementation of those enhancements supports continuation of the
expanded proj ect past the compliance date of the MON.
Waste Minimization and Pollution Prevention (WM/PPj. Crompton committed to conducting a Waste
Minimization/Pollution Prevention (WM/PP) study to identify opportunities for additional reductions in waste
generated by the facility. Normally, WM/PP assessments are conducted as single events and outside of the
routine business operations of companies. However, the Crompton 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. A
Pollution Prevention Council, consisting of employees from throughout the plant was established at the beginning
of 1999 to help foster and communicate "P2" ideas and monitor progress. Crompton 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 technical and economic feasibility of these op-
tions; and (6) developing an implementation plan. As of July 2000,370 WM/PP options have been identified, of
which 26 are at some stage of study and 67 have been implemented. The 67 WM/PP initiatives that have been
implemented at the Sistersville plant, have resulted in atotal annual, recurring cost savings of $1,010,000 and
the prevention of 2,900,000 pounds of wastes. (These savings, however, do not include the expenses of
implementing the P2 measures. The actual, net savings will be less.) Crompton, also identified potential future
cost savings of over $1,000,000 per year. As a result of theRCRA deferral, alone, Crompton expects future
savings of about $700,000 over the life of the project. Crompton's project approach toward pollution preven-
tion and recycling may offer an innovative model for other chemical intermediate-product manufacturers.
Innovative Technology. The Crompton XL project provides a pilot for testing the benefits of allowing regula-
tory flexibility in the technology used to control air emissions under RCRA regulations, in order to provide
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Crompton Corporation XL Project
1-31-01
superior and less expensive environmental protection. In return for a deferral of air emission standards for its
surface impoundments, Crompton 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 incin-
erator was installed on Crompton'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. On July 15,1998, a perfor-
mance test demonstrated that the thermal oxidizer is reducing total organics in the vent stream by 99.99 percent,
versus the 98 percent minimum required by the EPA.
Project Commitment Summary
This table and the environmental performance section that follows summarize progress in meeting commitments
described in the FPA for Crompton'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 CAA 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 ^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.
Monitor incinerator operating temperature and
closed vent stream flow.
Monitor methanol recovery by condenser unit.
Develop incinerator startup, shutdown, and malfunc-
tion plan.
Installation and startup completed April 1, 1998.
Performance test completed July 15, 1998.
Ongoing.
Ongoing.
Complete.
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Crompton Corporation XL Project
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Commitment
Status
Methanol Recovery
Begin collection of methanol from condenser unit
within ten days of FPA signing.
Begun October 8, 1997.
Reuse, recycle, or incinerate 95 percent of
methanol (remaining five percent to go to waste-
water biotreatment unit).
100 percent of methanol collected has been reused
from April 1,1998 to June 30,2000
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 was made
up of representatives of Crompton Corporation; a
Crompton 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 WM/PP oppor-
tunities implemented. Advisory committee made up of
representatives from WVDEP, EPA Region 3, local
residents, Crompton 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 WM7
PP assessment of the facility identified numerous ways
to reduce waste, which are included in the WM/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
WM/PP opportunities and prepare WM/PP Proj ect
implementation plans.
Prepare draft WM/PP Study Report one year
after FPA signing.
Draft report issued for Advisory Committee comment
on October 16,1998. Final report completed Decem-
ber 11, 1998.
Implement WM/PP opportunities.
The Annual Report issued on July 31,2000 states that
370 WM/PP opportunities have been identified. 26 of
these are being studied and 67 have been implemented.
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Crompton Corporation XL Project
1-31-01
Commitment Status
Reporting
Prepare semiannual progress reports
beginning January 3 1, 1999.
Prepare annual reports beginning July 31, 1999.
Prepare final proj ect report within 180 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. Second semiannual report issued January 14,
2000.
First annual report issued July 30, 1 999. Second
annual report issued July 3 1 , 2000.
Not yet necessary.
Not yet necessary.
Environmental Performance
This section summarizes progress in meeting the environmental performance described in the FPA for
Crompton.
Air Emissions from Capper Unit
1999 Actual - 0.341
1998 Actual
1995 Baseline
Estimated without XL
59.9
1
3 50
i i i i
277
277
i
100 150 200 250 300
Thousands of Pounds per Year
Reduce Air Emissions from Capper Unit: Methyl
chloride, dimethyl ether, and methanol emissions gener-
ated in the capper unit during production of the methyl-
capped polyether are being collected and routed to a
new process vent incinerator installed on the capper unit.
Crompton estimated the incinerator would destroy at
least 98 percent of the organic compounds (by weight) in
the vent stream, or about 271,000 pounds of these by-
products per year.
Progress: In 1998, the capper unit emitted a total of
59,898 pounds of organic compounds. This data in-
cludes emissions from the capper prior to the incinerator
startup on April 1,1998. In 1999, the capper unit emitted a total of 341 pounds of organic compounds.
Crompton estimates that 199,445 pounds would have been emitted in 1999 if the XL proj ect had not been
implemented; a reduction of 199,104 pounds. Performance tests indicate that the oxidizer is reducing total
organics in the vent stream by 99.99 percent, versus the 98 percent minimum required by the agreement.
Reduce Organic Capper Unit Discharges to Wastewater Treatment System: Production of methyl-
capped polyether generates 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 this
XL project, Crompton agrees to direct a minimum of 95 percent of the collected methanol towards reuse and
recycling, or subj ect it to thermal recovery or treatment, thus minimizing biotreatment of the methanol in waste-
water treatment units. Crompton 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.
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Crompton Corporation XL Project
1-31-01
1/1/99-6/30/00 Actual
4/1/98-12/31/98 Actual
Performance Goal
1995 Baseline
100%
100%
95%
- 0%
20 40 60 80
Percent of Collected Methanol Reuse
100
Progress: In 1998, the capper unit discharged Collected Methanol Reuse
271,000 pounds of methanol to the wastewater
treatment system, resulting in a reduction of nearly
519,000 pounds per year of methanol as compared
to 1995 baseline figures. All the 424,254 pounds, or
100 percent of recovered methanol by weight, were
reused, recycled, or thermally recovered or treated
in 1998, exceeding the 95 percent performance
standard established in the agreement.
In 1999, the capper unit generated a total of
572,000 pounds of methanol and the methanol
recovery operation collected 428,000 pounds of
methanol. As discussed in the FPA, a portion of the
methanol generated in the capper unit cannot be economically collected, but rather goes to the onsite waste
water treatment unit via a steam ej ector, or to the thermal oxidizer. This accounts for the 144,000 pounds of
methanol that were generated by the capper unit but not recovered. One Performance Standard of the FPA
requires that "on an annual basis, the Sistersville Plant shall ensure that a minimum of 95 percent by weight of the
methanol collected by the methanol recovery operation is utilized for reuse, recovery, or thermal recovery/
treatment." In 1999,100 percent of the 428,000 pounds collected was reused. This exceeds the performance
standard by five percent.
Reduce Wastewater Treatment Sludge Generated from Capper Unit Methanol: As a result of
Crompton'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 peryear, from an estimated 1,425,000 pounds peryearto an estimated
610,000 pounds per year.
Wastewater Treatment Sludge
Generated from Capper Unit Methanol
1999 Actual
1998 Actual
1995 Baseline
Estimated without XL
254.8
420
1177
Progress: 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. In 1999,254,851 pounds of sludge were
generated by the wastewater treatment system from
capper operations. Crompton estimates that 931,782
pounds would have been generated in 1999 if the XL
project had not been implemented; a reduction of
676,930 pounds.
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.
Crompton 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 peryear, from 140,300 pounds peryearto 102,000
pounds per year.
1425
200 400 600 800 1000 1200 1400 1600
Thousands of Pounds per Year
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Crompton Corporation XL Project
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Air Emissions from
Wastewater Treatment System
1999 Actual
1998 Actual
Performance Goal
1995 Baseline
Estimated without XL
105.6
102*
140
140
20
40 60 80 100 120 140 160
Thousands of Pounds per Year
*This goal is not specified in the FPA; it is a voluntary performance goal
estimated by Crompton.
Progress: In 1998, 88,932 pounds of air emissions
were released by the wastewater treatment unit; a
reduction of 51,368 pounds from the 1995 baseline
total of 140,300 pounds. In 1999,105,646 pounds of
air emissions were released by the wastewater treat-
ment unit. Crompton estimates that 111,892 pounds
would have been released in 1999 if the XL proj ect
had not been implemented; a reduction of 6,246
pounds.
Implement a Comprehensive Waste Minimization/
Pollution Prevention Project: The WM/PP Project
included a study of plant operations that identified
existing and future WM/PP opportunities and devel-
oped a plan to implement those that are technically and
economically feasible. Through the use of an advisory
committee, Crompton has involved EPA, WVDEP, The
International Chemical Workers Union Council, and
other stakeholders in the study and implementation
phases of the WM/PP Project.
Progress: Crompton 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 Crompton 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 WM/PP
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
feasible; these options are currently being implemented. The WM/PP Study Report is available on the EPA
website and also from Crompton. The Annual Report issued on July 31,2000 states that 370 WM/PP oppor-
tunities have been identified, of which 26 are at some stage of study and 67 have been implemented.
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Crompton Corporation XL Project
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Crompton Corporation Sistersville Facility [formerly Witco)
Capper Operations*
Year Opportunity was
Implemented
Air Emissions and Sludge Reduction
plus Methanol Recycle (Excludes
capital savings from XL project)
Actual for Calendar Year 1 999
Number of New P2
Opportunities
Implemented
Recurring Wastes
Prevented,
Latest Estimates,
Ibs/yr
1,310,921
Recurring Cost
^ . Savings*,
Latest Estimates,
' %r; ' •
$16,000
Data presented are based upon information found in Crompton Sistersville Plant Project XL Annual Report, July 2000.
*Note that these savings do not consider the expense of implementing them. Hence net savings will be less. It is often
difficult to assign that expense. For example, a totally new process unit may cost millions of dollars to construct. If that
new process produces less waste, how much of the design and construction expense ought to be assigned to the P2
benefits? In the case of a process change being done explicitly for P2 reasons, the expense is more easily determined.
Crompton Corporation Sistersville Facility [formerly Witco)
WM/PP Study Results
Year Opportunity was
Implemented
1997
1998
1999
2000 Jan. -June
Total
Number of New P2
Opportunities
Implemented
10
11
32
14
67
Recurring Wastes
Prevented,
Latest Estimates,
Ibs/yr
376,000
111,000
930,000
216,000
2,943,921
Recurring Cost
. Savings*,
Latest Estimates,
.. • $/yr
$228,000
$25,000
$650,000
$381,000
$1,010,000
Data presented are based upon information found in Crompton Sistersville Plant Project XL Annual Report, July 2000.
*Note that these savings do not consider the expense of implementing them. Hence net savings will be less. It is often
difficult to assign that expense. For example, a totally new process unit may cost millions of dollars to construct. If that
new process produces less waste, how much of the design and construction expense ought to be assigned to the P2
benefits? In the case of a process change being done explicitly for P2 reasons, the expense is more easily determined.
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 project.
Stakeholders have been kept informed via mailing lists, newspaper articles, public meetings and the establish-
ment of public files at the Sistersville JAiblic Library and the EPA Region 3 office.
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Crompton Corporation XL Project 1-31-01
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 proj ect development updates by circulating meeting and conference call minutes.
As this XL proj ect'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 Proj ect 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 available data and
other information as it is generated. Crompton 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 proj ect reports available to all interested parties.
As of April 2000, participating stakeholders reported that they were satisfied with the stakeholder involvement
process, but felt that the process was too long (two years between submittal of the first proposal and the signing
of the FPA). The community representatives felt that the EPA was too stringent in their requirements, and that
improvements in EPAs efficiency would save time and money for everyone involved. The community represen-
tatives stated that the rapport between the community and Crompton has always been good, but that EPA had
more difficulty working within the industrial culture of the community. Representatives of the community,
Crompton, EPA, and WVDEP were all disappointed by the low level of community involvement. The commu-
nity representatives were not sure if this was a sign of apathy or an indication that the community trusts
Crompton and is satisfied with the information that has been made available to them. The EPA and WVDEP
were impressed with Crompton's initiative and respect in the community. Company representatives felt that the
proj ect was a good way for both EPA and Crompton to learn how to work together.
Six-Month Outlook
Key focus areas for successful implementation of the FPA over the next six months include the third semiannual
proj ect report due January 31,2001, the third annual proj ect report due July 31,2001, and the ongoing imple-
mentation of options identified in the WM/PP EPA is expected to propose new MON standards in the first
quarter of the year 2001. As per the FPA, Crompton 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.
Contacts
• Tony Vandenberg, Crompton Corporation OSi Group, (304) 652-8812.
• Kristina Heinemann, EPA Headquarters, (202) 260-53 55.
• TadRadzinski, EPARegion 3, (215) 814-2394.
• Lucy Pontiveros, DEP, (304) 926-3638.
• Jonathan McClung, DEP, (304) 926-3638.
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Information Sources
The information sources used to develop this progress report include (1) focus group discussions in December
1998 with representatives of the Federal and state regulatory agencies, Crompton, and public stakeholders
involved in the proj ect; (2) the FPA Final Proj ect Agreement for the Crompton XL proj ect; (3 ) the December
1998 final Report from the WM/PP Study undertaken by Crompton (4) the March 1999 XL Proj ect Progress
Report—OSi Specialties; (5) the First Annual Crompton XL Proj ect Report, issued July 30,1999; (5) the
Project XL Progress Report, Crompton Corporation, December 1999; (6) the Project XL Semi-Annual
report, January 14,2000; (7) the Proj ect XL Stakeholder Involvement Evaluation Draft Final report, April 15,
2000; (8) the Proj ect XL Stakeholder Involvement Evaluation - Final Draft Report, May 2000; and (9) the
Proj ect XL Second Annual Report, July 31,2000. The information sources are current through July 2000.
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 Crompton implements a Qualifying Change to a process unit at
the Facility, EPA and WVDEP expect to defer applicability of CAA 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 Crompton'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 Ambi-
ent 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.
Discharges: Flow of liquid or chemical emissions from a facility into water or air.
Final Project Agreement (FPA): The FPA outlines the details of the XL project and each party's commitments.
The project's sponsors, EPA, state agencies, tribal governments, other regulators, and direct participant stake-
holders negotiate the FPA.
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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: explo-
sives production, photographic chemicals production, polyester resins production, and the production 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 exces-
sive 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.
RCRA Subpart CC: Requirements for the control of air emissions from hazardous waste tanks, surface im-
poundments, 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.
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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 Crompton 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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