Summary of April 2003 Meeting of Roche Vitamins Community Advisory Panel

The Community Advisory Panel working with Roche Vitamins met on April 15, 2003. The meeting convened at 7:05 p.m. and was attended by Advisory Panel members and alternates Bud Allen, Kathy Belby, Jane Bullis, Judy Chamberlain, Peter Grogan, Gary Meddaugh, Doug Smyth, Joe Venesky, Stan Wilkins and Dr. Beecher Zollinger. Mike Adams, Jim Brandl and Jeff Wanko attended for Roche Vitamins. The meeting was facilitated by Steve Ross.

Chairman's Report

Gary Meddaugh reported that he has received Warren County Air Monitoring Program (WCAMP) raw data reports for January and February 2003. Doug Smyth asked for a hard copy of the reports so he could provide the information to Belvidere High School science students, who have been assigned a study project related to the WCAMP. Steve Ross suggested the students be invited to report on their project at the May CAP meeting.

Chairman Meddaugh also reported that he and Bud Allen had spoken with a member of the public, Marie Volk, about the WCAMP and that Steve Ross had compiled all of the raw data reports submitted to date and sent them to Mrs. Volk.

Chairman's Update

Approval of March 2003 Meeting Summary

The Panel approved the March 2003 meeting summary.

Status Report on DSM Purchase of Roche Vitamins

Mike Adams reported that the sale of RVI to DSM was now expected to be completed during the second quarter of 2003, following the reviews of regulators at the Federal Trade Commission in the U.S. and the European Union. In the meantime, environmental assessments of RVI's sites are underway, including the ISRA study of the Belvidere site for the New Jersey Department of Environmental Protection, which has been discussed at previous CAP meetings.

Stan Wilkins asked whether there would be any change in the products made in Belvidere as a result of the sale. Mike replied that it was too soon to tell. However, Mike didn't expect there to be any changes at the site's management or at the management level to which he reports in Europe.

Overview of RVI's Title V Permit Application

Jim Brandl explained that the Clean Air Act of 1990 included a provision under Title V requiring that major industrial facilities obtain a comprehensive operating permit for their air emissions. New Jersey subsequently established its own Facility Wide Permit process and Roche Vitamins was one of 18 industrial facilities that volunteered to participate in that process, the first of its kind in the U.S. The McGreevey Administration has now abandoned the FWP process and required all major facilities to get Title V permits. Since Roche has already done all of the work required for a Title V permit through their FWP effort, the company is seeking the agreement of NJDEP and EPA that it has met the requirements of Title V. NJDEP expects to conduct a public comment period on RVI's permit application early next year and issue a permit by mid-year 2004.

One component of this work was the conduct of a comprehensive, forward-looking assessment of the facility's health risk to the community over a resident's 70-year lifetime of exposure, based on the air emissions the facility is allowed to produce by its Title V permit. The risk assessment is based on permitted emissions level, which are higher than actual emissions, to assure that the projected health risk is overestimated. As reported at the March 2003 CAP meeting, this study concluded that the health risk to Belvidere residents is less than one in a million.

Jim noted that the new thermal oxidizer (TO) was installed to meet the new Pharma Maximum Achievable Control Technology (MACT) regulations that became effective in Oct 2002. RVI did not remove any of the existing pollution control devices but added the thermal oxidizer on the end. The thermal oxidizer collects emissions from about 68 vents in the Vitamin C complex and passes them through a high temperature burner, which destroys all organic solvents. For chlorinated solvents such as chloroform the organic portion is destroyed , leaving the chloride molecule, which can form hydrochloric acid (HCL). To prevent HCL formation a caustic scrubber has been installed to neutralize the exhaust gas from the thermal oxidizer units, so that the ultimate discharge is water vapor and products of combustion such as carbon monoxide. There is a backup thermal oxidizer in case the first unit fails or needs maintenance. The TO units burn natural gas.

The CAP agreed that it would like a tour of the thermal oxidizer in conjunction with an upcoming meeting.

Noting that Roche emitted 25 tons of chloroform in 1996, the year which served as the basis for the EPA's National Air Toxics Assessment, Jim also reported that he had asked EPA Region II to explain the basis for the 229 tons per year of chloroform that NATA projected for Warren County. EPA has replied that there appears to be an error in that NATA projection, which is much higher than it should be. Jim also noted that Roche's chloroform emissions have been greatly reduced, and are now about five tons per year.

Doug Smyth expressed concern about the VOCs that the WCAMP has measured in concentrations above the health benchmarks (chloromethane, 1,3-butadiene, chloroform, benzene and carbon tetrachloride) and asked that the NJDEP and EPA be invited to meet with the CAP and explain the health significance of these findings.

Reporting Format for Warren County Air Monitoring Results

Steve Ross reported that the AirQAP's Benchmarks Committee had met the day before and reached consensus on the summary report templates for the monthly air monitoring results. Bud Allen, who also serves on that Committee, said that EnviroPlan would be developing an Excel spreadsheet that would serve as the basis for converting the raw monitoring data into summary results for each of the pollutants being monitored. The NJDEP will also ask EnviroPlan to certify the data as part of the quality assurance/quality control requirements.

For VOCs, if less than 75% of the measured values are greater than the detection limit, the Non Detects will not be counted and no average will be calculated. While this will tend to skew the data by overestimating the concentrations of VOCs (since the Non Detects far outnumber the instances when concentrations are detected) this added margin of conservatism was seen by the Benchmarks Committee to be a plus.

Doug Smyth disagreed, suggesting that averaging and counting the NDs as zero would be more accurate, even though it might underestimate actual average concentrations somewhat over time. After some discussion, Steve Ross suggested that Doug attend the next meeting of the AirQAP and express his concerns directly so that direct communication could be established between the two advisory panels.

Bud Allen then reported that the Benchmarks Committee didn't feel that the summary reports should include the mercury monitoring results, since no standards or benchmarks for mercury existed and the value and meaningfulness of the data collected was uncertain. Doug Smyth and Jane Bullis strongly disagreed, arguing that mercury was a significant environmental contaminant in New Jersey and Warren County and, while scientific understanding of how mercury was deposited onto waterways and how it could be controlled was still in its infancy, the WCAMP monitoring was an important first step in helping to grapple with the issue through better understanding of the facts. Joe Venesky agreed that mercury was a problem and that there were fish advisories throughout the state because of it. However, he didn't see how the CAP could impact the mercury problem regardless of what the WCAMP monitoring data showed.

After some discussion, Jane asked that the CAP members present vote on the question of whether mercury should be included in the summary reports to see if there was a consensus. The members did vote by a margin of 6 to 4 in favor of retaining mercury as a parameter covered by the summary reports. Steve Ross noted that this was a slight majority of those present but was not indicative of a consensus on the issue. Steve suggested that Doug discuss the mercury issue with the AirQAP at their next meeting.

Jim Brandl suggested that perhaps the two panels should have a joint meeting, at which they could discuss (a) how to communicate and coordinate with each other better, (b) mercury and VOC monitoring issues, and (b) the planning and implementation of a public event to present the air monitoring results to date. The CAP agreed unanimously and Steve Ross said the AirQAP would be asked to participate in a joint meeting on their regularly scheduled May meeting date, May 27. The CAP agreed the Belvidere High School cafeteria would be an appropriate location for that meeting.

Status of SEP 2 Asthma Study

Kathy Belby reported that UMDNJ has recruited a total of 61 students who are participating in the study. Doug Smyth questioned why the study wasn't going to continue into the summer, when ozone problems were at their worst. Dr. Zollinger noted that the focus of the WCAMP was the lung irritant sulfur dioxide, which tends to be at peak concentrations in the winter, and ozone isn't being monitored as part of that program. Steve Ross explained that Dr. Weiss had surveyed the participants and concluded that it wouldn't be feasible to continue the study since most of the students would be away at one point or another during the summer, which would make consistent reporting on their conditions impractical.

The meeting was adjourned at 9:25 P.M.