Document 0Joa9jjZZoMBD8mvj3gY5YVyd

The Facility has also employed a voluntary process to strip chloroprenc from in-tank coagulant during maintenance of the five poly kettles. DPE has voluntarily decreased the site-wide leak detection and repair threshold from the regulatory standard of 500 ppm organic vapor concentration to 250 ppm. In conjunction with this new 250 ppm threshold hold, an additional voluntary process to screen certain components in the polymerization building located at the Facility and the 1236 waste organics storage tank area multiple times each week and to schedule repairs if leaking components are identified has been rolled out. DPE hired an LIAR technician with over 20 years of experience to lead these voluntary efforts which has included increased weekly screenings, new immediate repair procedures, and the purchase of state-of-the-art detection equipment. Furthermore, DPE has supplied operators in the polymers area with photoioniiation detectors (Pills) to perform LIAR screenings on any component at any time to detect leaks. Accordingly, prompt repairs are made when leaks are detected. DPE voluntarily implemented a process requiring transfers of chloroprene-containing wastes from the chloroprene heels tank to the waste organics tanks in the IIC1 recovery unit process area be performed only when the 123E tank system is connected to the MERP control system or other form of emissions control. DPE instituted new outdoor brine pit (OBI') management measures which require coagulant from the unstripped emulsion storage tanks and large poly kettles to be placed directly into plastic drums to be sent off-site for incineration. This new process change ensures that solid material is no longer placed in the OBP. 40. In addition, DPE is currently evaluating additional ERPs such as (i) a potential project to remove chloroprene from the poly kettle strainer waste by circulating water through the strainer and sparging the water in a closed vessel connected to the existing RIO, and (ii) the potential use of Forward Looking Infrared, or FUR, cameras to improve leak detection activities. 41. I have been involved in reviewing the Facility's Method 325B and Method .I.O-15 data which demonstrates that the voluntary ERPs discussed above have resulted in quantified reductions of chloroprene concentrations near the Facility. Moreover, the Facility has achieved the lowest average chloroprenc concentrations during my tenure following these voluntary changes. -17- Sierra Club FOIA 2025-EPA-04883 ED_018388_00000138- 00018 SC_EVERSPLIT0005853