SUMMARY OF JULY 16, 2002 ROCHE CAP MEETING

The Roche Vitamins Community Advisory Panel convened at 7:00 P.M. on July 16, 2002. CAP members present at the meeting were Bud Allen, Kathy Belby, Jane Bullis, Peter Grogan, Michael Grossmann, Lisa Jacob, Gary Meddaugh, Betty Merring, Claude Mitchell, Stan Wilkins, and Dr. Beecher Zollinger. Present from RVI was Jim Brandl. Kelly Henry of Holt & Ross facilitated the meeting.

1. APPROVAL OF JUNE 2002 MEETING SUMMARY

The CAP unanimously approved the May 2002 meeting summary.

However, Jane Bullis suggested the CAP revisit Steve Ross’s idea of sponsoring an exhibit at the County Fair. After discussion, Jane agreed to find out the costs and requirements involved in exhibiting at the fair, including determining if full-time staffing of the exhibit is required. Jim Brandl committed Roche to pay the cost of the exhibitor fees if the group decided to move forward with the event.

The suggestion that Roche identify alternate facilities for future CAP meetings was revisited and the majority of CAP members agreed they want to continue holding the CAP meetings at the facility and not off Roche property.

The CAP also revisited Betty Merring’s suggestion to invite a high school student to participate in CAP meetings. Jane Bullis recalled that Pam Geisinger, a Belvidere High School science teacher who attended the June Open House, asked if there were any potential projects that could involve students.

Given the interest by the High School and the fact that one of the SEP 1 air monitoring stations will be located there, the CAP agreed to reach out to the science teacher. Jane Bullis will make the contact.

2. STATUS OF BUDGETS AND SCHEDULES FOR SEPs 1 AND 3

Jim Brandl, Gary Wassel, Gary Meddaugh, and Bryan Burke met at the Warren County Office of Emergency Management to review the cost savings that potentially could be realized by using the county’s DCC system, developed by Diologic Communications Corporation, in place of the Merrill Creek Reservoir’s CAN system to meet the notification needs of SEP 3. The group determined that the use of the DCC system could save the budget about $85,000 over the course of the project, assuming that the number of households requiring notification ranged between 300 and 500. Roche would also agree to pay the system’s annual maintenance fee of $3,000. The group decided that this would be the best way to meet the objectives and budget needs of both SEPs. However, if the number of households to be notified is significantly higher than 500, the decision to use the DCC should be revisited.

Jim Brandl reported that RVI met with the NJDEP on July 12, 2002 regarding the status of SEPs 1 and 3. Roche presented the SEP 1 budget shortfall to the NJDEP, along with the proposed solution to transfer $85,000 from SEP 3 to SEP 1 as well as use monies from any additional Roche fines as the means to address any shortfalls in funding SEP 1. The Department tentatively consented to the proposal, pending receipt of a formal written request from RVI, which was mailed to the Department on Monday, July 15.

Bud Allen reported that he sent an email to Tom Eppehimer, Plant Manager for PPL’s Martins Creek Plant, requesting the company’s support in funding the shortfall. Tom responded to both Bud Allen and Jim Brandl that PPL would consider providing some support, pending the outcome of NJDEP’s response to Roche’s aforementioned proposal.

The location of the proposed Belvidere High School air monitoring station was also discussed at the June 12 NJDEP meeting. The Department agreed to placement of the station on the ground based on EnviroPlan’s concerns that rooftop placement of the station would create logistical and scheduling delays.

Several CAP members were concerned that the proposed new location was in the middle of the field hockey field. Jim Brandl did not believe that to be the case but indicated that Mr. Spagnoli approved the new location on behalf of the High School. The air monitoring equipment will be housed inside an 8’ x 10’ trailer box and there will be a 30’ high meteorological tower, enclosed by a fenced 15’ by 20’ area. All the equipment is temporary and will be removed at the end of the 3-year period.

RVI will provide copies of the photographs presented to the NJDEP and a photograph of the air monitoring equipment at the next CAP meeting.

The Department strongly emphasized its desire to have a September 1 launch date for SEP 1. RVI and EnviroPlan are making every effort to meet the timetable, but there is a monumental amount of work to be done. EnviroPlan plans to send the protocols to NJDEP by July 31 and anticipates having all the equipment ordered by July 25. Some equipment is already in. The greatest potential causes for scheduling delays will be in obtaining the necessary permits from the Belvidere and White Township zoning and/or planning departments as well as finalizing the land lease agreements with the individual property owners. If delays do occur, these are two areas where the CAP members may be helpful in reaching out to local officials and/or property owners to ask for their consideration and support.

The definition of a “bad air day” remains unclear. While alerts about ozone and particulates are fairly straightforward, and already being done statewide by NJDEP, sulfur dioxide is more problematic, as measurements will be taken every five minutes and levels can change dramatically from reading to reading, with exceedances of air quality standards often limited to very short durations.

3. IMPACT OF RVI SHUTDOWN ON SEPs 1 AND 2

Jim Brandl inquired if all the CAP members had seen the June 25 editorial in the Express-Times on the planned 3-month shutdown of the Vitamin C operation beginning in October. Roche wanted to address the article’s implication that the shutdown would impact the validity of the results from SEPs 1 and 2. The decision to temporarily shut down the Vitamin C operations was based solely on business considerations and maximizing the facility’s output relative to product-specific demand at current market prices. Roche does not believe the shutdown will have a significant impact on SEP 1 because the primary purpose of the project is to monitor emissions that affect asthma, specifically sulfur dioxide and particulates. Roche’s operations produce minor sulfur dioxide emissions relative to PPL’s operations. The majority of Roche’s emissions are VOCs, which SEP 1 will also be monitoring every 6th day in keeping with standard NJDEP-approved protocol for such emissions. In response to real or perceived community concern that the shutdown will impact SEP 1’s findings, Roche has instructed EnviroPlan to begin VOC sampling on August 1. Roche has initiated this testing voluntarily and will pay for the costs directly. It will not be covered by the SEP 1 budget. The results will serve as a basis for providing background data against which post-shutdown data can be compared. Additionally, Roche’s ability to meet the NJDEP’s new Maximum Achievable Control Technology (MACT) standards can be more effectively and efficiently achieved during a shutdown. In order to comply with NJDEP’s new MACT requirements, changes will need to be made to the Vitamin C plant that will further reduce the plant’s VOC emissions. Only a small reduction will be needed however, because the plant is already close to meeting the new requirement. The addition of the thermal oxidizer will simply provide the insurance needed to guarantee compliance with the new regulations. As such, it is unlikely that the changes will be reflected in a before and after comparison of the air sampling results.

4. REPORT ON AIRSHED CAP MEETING AND STATUS

Bud Allen reported that the Airshed CAP meeting focused on establishing the group’s procedures and protocols, much of which are the same as those used by the RVI CAP. The decision to elect a CAP chair was not discussed. Mike Grossmann, Tom Eppehimer, Nancy Mason and Bud Allen volunteered to serve as the PR committee and review CAP press releases. The Belvidere News ran an article on the first press release. The next meeting will be the 4th Tuesday in July at Roche. Future meetings will be rotated between member company locations.

5. STATUS OF SEP 2 ASTHMA STUDY

Dr. Weisel reported that the website is under development and should be completed by late August. The website is the vehicle through which study participants will respond to daily survey questions. The developer will be on vacation the last two weeks of August and Dr. Weisel feels it would be wise to delay the launch of the pilot study until after the developer returns to enable prompt response to any start-up glitches or questions. The pilot study will therefore begin in September, pending receipt of the necessary approvals from the Institutional Review Board and the Harmony, White Township and Belvidere school boards and recruitment of the necessary study participants. Only 2 participants are enlisted to date, but Dr. Weisel has received full support from the three school nurses and does not anticipate difficulties filling the pilot study once the needed approvals are in and he can actively solicit participants. Nonetheless, he welcomed the recommendations and recruitment support of CAP members in identifying both pilot- and full-study participants.

Several members had questions regarding how the pilot study will be conducted. Dr. Weisel agreed to send a 1-page description of the study to Jane Bullis for distribution to the group. He indicated that the study primarily consisted of participants responding daily to set survey questions regarding their asthma symptoms and conditions and the medications they used and/or other actions they took to alleviate those symptoms and conditions. Each participant will be provided with a peak/flow meter before the study commences and instructed on how to use it. During the survey, participants will be asked to report daily their peak/flow results.

The full study will begin in late fall. Dr. Weisel indicated that November through March is the best time to sample the impacts of sulfur dioxide.

Dr. Weisel reported he is responding to an RFP from the Agency for Toxic Substances Disease Registry (ATSDR), which is offering grant money to asthma studies being conducted near chemical plants. The purpose of Dr. Weisel’s proposed study is to determine the impact, if any, that residing upwind or downwind of a chemical plant has on school absenteeism. The study will look at other companies, in addition to Roche, and would involve a more comprehensive air monitoring system than that of SEP 1. Dr. Weisel asked if the CAP would pen a letter of support, which he would submit as part of his application.

The CAP agreed and Jane Bullis agreed to draft the letter using recommended language provided by Dr. Weisel.

6. STATUS OF FOLLOWUP TO WHITE TWP. HEALTH SURVEY

Claude Mitchell had an intern working at the County Health Department review the White Township Health Survey data to provide additional analysis. Although still under review, Claude presented some initial results to the CAP. Data from survey participants who lived in White Township for 2 years or less was eliminated from the analysis. This reduced the number of respondents to 1633 from 2019. Of the 1633 respondents, 19% in the 0-18 age bracket, 13% in the 19-65 age bracket and 10.5% in the 65 and over age bracket reported having asthma. It was agreed by the CAP that this analysis is premature and did not take into account many variables. The County is continuing its review of the data.

7. ROCHE STATUS REPORT ON ENVIRONMENTAL COMPLIANCE

Jim Brandl reported that on June 4 the facility experienced a release of 21 lbs/hour of ethanol due to a faulty connection of a flexible connection tube. The error was quickly caught and repaired, and the release reported to the NJDEP. Because it was the result of operator error, Roche did not request affirmative defense and anticipates that the facility will be fined an amount between $5,000 and $10,000. Roche has requested the monies be applied to the SEP 1 budget.

An environmental compliance violation that occurred in 1997-98 and resulted in an EPA fine was recently announced through an EPA-issued press release. Although factually accurate, several omissions of facts in the press release and resulting news article made it appear that this was a recent event. Jim Brandl clarified that the fine, which totaled $219,000, was levied for procedural violations only. Specifically, the violations were:
(1) Failure to notify the EPA at the startup of the cogeneration system. The NJDEP was notified.
(2) Failure to request an exemption for daily reporting of nitrogen content once the natural gas cogeneration system was in place.
(3) Poor record-keeping in the recycling and reuse of Freon refrigerants.

Jim Brandl personally contacted the mayors of Belvidere and White Township to clarify both the nature and timing of the violations and also contacted Jane Bullis as CAP chair.

8. NEXT CAP MEETING

The group discussed and agreed to include a tour of the Vitamin C operations as part of the next CAP meeting, so that they can see the operations before the shutdown. The tour will take place promptly at 6:30 p.m. and dinner will be provided afterward.