Document 1QzKOnG01ddZxpZ04BxoKqkjj

INTER-OFFICE MEMO TENNECO CHEMICALS, INC gel. To From Distribution J. P. Sandstedt At At Pisca taway Subject EPA/VCM Compliance Projects Waiver Requests and Compliance Schedules December 9, 1976 Date Copy to Submissions have been made to EPA Region XI and Region VI represen tatives, requesting equivalencies and waivers of compliance with specific paragraphs of the Vinyl Chloride Standard, for Flemington/Burlington and Pasadena, respectively. The Standard required that each waiver request include a proposed schedule of compliance. The attached is a concise summary of the proposed schedules, as submitted to EPA, for easy reference. JPS :db Attachment Distribution: W. P. Anderson^ D. C. Coldiron C. E. Crain R. Fanter G. S. Flint W. F. Gabel R. T, Gottesman R. E. Harmond M. R. Haymon J. K. Jacob W. J. Klingebiel R. S. Miller J. W. Poarch P.M. Reed F. X. Ritter G. I. Rozand P. R. Scarito E. V. Schenke S. R. Sheeran J. T. Sweeney C. G. Thompson T. T. Zuhl 3< P. Sands ted t COLORITE 009072 1 of 2 EPA/VCM COMPLIANCE COMPLIANCE SCHEDULES PROPOSED TO EPA REGIONS AS PART OF EQUIVALEKCY/WAIVER REQUESTS SCHEDULE REQUIREMENTS 1. Issue Purchase Orders By 2. Start Construction By 3. Complete Construction By 4. Be In compliance By - Waiver or Eq uivalency Burlingt on 2_ 3_ 4_ Flemingto n 2_ 3_ 4_ Reactor Opening Homopolyne r Ccpolymer Dispersion 10/1/77 8/1/77 11/1/77 9/1/77 _ 4/30/78 11/30/77 10/19/76 6/1/78 12/15/77 S lurry S tripping Rorropo lyrr.er Copolymer Dispersion 7/1/77 12/1/77 _ _ 10/19/78 10/19/76 10/19/76 10/19/78 Monomer Rec'y -C/A 8/1/77 12/1/77 10/21/77 10/21/77 A' 1/15/77 4/l/7f " 7/31/77 ' --- 9/11/77 ' _ . - 8/1/77 - 12/1/77 -- 10/19/76 -- 10/21/77 10/21/77 Relief Valves 5/1/77 10/21/77 10/21/78 10/21/78 5/1/77 10/21/77' 10/21/78 10/21/78 Load/Unload Lines 5/1/77 7/1/77 10/1/77 10/1/77. 5/1/77" 7/1/77 10/1/77 10/1/77' Slip Gauges NA Leakage from Pump, Compressor & Agitator Seals 4/1/77 Opening of Equipment 8/1/77' 4/1/77 5/15/77 9/1/77 8/1/77 2/1/78 1/1/78 8/1/77 2/1/78 10/21/78 "** 5/1/77 S/1177' 7/1/77 9/1/77 8/1/78 1/1/78 8/1/78 10/21/78 In Process Waste water, Water Stripper 12/1/77 1/1/78 10/21/78 10/21/78'' 12/1/77 1/1/78 10/21/78 10/21/78 NA - Not Applicable Pasadena _1_ 2_ 3_ 4_ 4/15/77 10/15/77 8/1/78 -1 _ _ `' 10/1/78 3/15/77 . - 11/15/77 - - 8/1/78 - - 5/1/77 4/1/78 8/1/73 10/1/78 - 10/1/78 5/1/77 4/1/78 8/1/78 10/1/78 5/1/77 4/1/78 8/1/78 10/1/78 12/1/76 5/1/77 2/15/77 2/28/77 2/28/77 4/1/78 10/15/78 10/15/78 3/15/77 11/15/77 8/1/78 10/1/78 COLOR!TE 009073 Waiver or Equivalency Pilot Plant Facilities Analytical Procedures Burlington 1 1' 4/1/77 HA EPA/VCM COMPLIANCE (Cont.) AS PART OF EQUIVALENCY /WAIVER REQUESTS SCHEDULE REQUIREMENTS 1. Issue Purchase Orders By 2. Start Construction By 3. Complete Construction By 4. Be in Compliance By - 3T Flemington 12 3 4 Pasadena 12 NA NA 3/31/77' 6/30/77 l/l5/77 12/15/77 4/1/77 HA 11/15/77 12/15/77 4/1/77 HA NA - Not Applicable 2 of 2 34 11/15/77 12/15/77 Attnehi",cnt_A Proposed Amendments to the National Emission Standard lor Vinyl Chloride EPA's proposed amendments to the National Emission Standard for Vinyl Chloride, 40 C.F.R. Part 61 Subpart F, shall embody the following concepts: A. The ultimate goal of zero vinyl chloride emissions and EPA's intention to reduce emissions toward this limit will be expressed. B. The 10 ppm limitation under the existing standard will be proposed to be tightened to 5 ppm based on EPA's judgment that technology required by the existing standard can achieve the lower standard, with the following additional proposed features: 1. The 5 ppm standard will be applied to existing sources no later than three years from promul gation of the amendments; (a) Existing sources may institute a review procedure before EPA if the 5 ppm standard v-' cannot be met on the expected compliance date; (i) the review procedure may be initiated by the source notifying EPA in writing no later than one year from the expected, compliance date that compliance will not take place; the notification must contain written documentation why compliance is impossible, what interim steps the source will take to reach the 5 ppm standard, and a suggested compliance schedule for reaching the 5 ppm goal; (ii) within thirty days, EPA will confer with the source to consider any oral testimony: the public will be invited to testify or submit written documentation at the conference; COLOR!TE 009075 ? (iii) within sixtv days after the conference, EPA will (a) deny the source's request or (b) fashion a schedule for the source's compliance with the 5 ppm standard, accompanied by interim emission limitations if warranted; 2. New sources will be subject to the 5 ppm standard no later than six months from the promulgation of the amendments, but no procedure for relief from this deadline (such as that for existing sources) will be proposed. C. Emission limitations for the oxychlorination process and the stripping of dispersion resins, requiring more control of these procedures than the existing standard, will be proposed for new sources. D. It will be proposed that existing facilities will not be permitted to expand unless increased vinyl chloride emissions are offset by equivalent reduc tions in vinyl chloride emissions at the expanding facility. E. EPA will undertake a full-scale review of Subpart F of 40 C.F.R. Part 61 beginning three years from the promulgation of any amendments to determine what further changes might then be appropriate to move toward the goal of zero vinyl chloride emissions. In the study EPA will consider recent health, data and information concerning technological advances in the control of vinyl chloride emissions. COLORITE 009076 Attachment A Proposed Amendments to the National Emission standard for Vinyl Chloride EPA's proposed amendments to the National Emission Standard for Vinyl Chloride, 40 C.F.R. Part 61 Subpart F, shall embody the following concepts: A. The ultimate goal of zero vinyl chloride emissions and EPA's intention to reduce emissions toward this limit will be expressed. B. The 10 ppm limitation under the existing standard will be proposed to be tightened to 5 ppm based on EPA's judgment that technology required by the existing standard can achieve the lower standard, with the following additional proposed features: 1. The 5 ppm standard will be applied to existing sources no later than three years from promul gation of the amendments; (a) Existing sources may institute a review procedure before EPA if the 5 ppm standard w" cannot be met on the expected compliance date; (i) the review procedure may be initiated by the source notifying EPA in writing no later than one year from the expected compliance date that compliance will not take place; the notification must contain written documentation why compliance is impossible, what interim steps the source will take to reach the 5 ppm standard, and a suggested compliance schedule for reaching the 5 ppm goal; (ii) within thirty days, EPA will confer with the source to consider any oral testimony; the public will be invited to testify or submit written documentation at the conference; COLORITE 009077 (iii) within sixtv days after the conference, EPA will (a) deny the source's request or (b) fashion a schedule for the source's compliance with the 5 ppm standard, accompanied by interim emission limitations if warranted; 2, New sources will be subject to the 5 ppm standard no later than six months from the promulgation of the amendments, but no procedure for relief from, this deadline (such as that for existing sources) will be proposed. C. Emission limitations for the oxychlorination process and the stripping of dispersion resins, requiring more control of these procedures than the existing standard, will be proposed for new sources. D. It will be proposed that existing facilities will not be permitted to expand unless increased vinyl chloride emissions are offset by equivalent reduc tions in vinyl chloride emissions at the expanding facility. E. EPA will undertake a full-scale review of Subpart F of 40 C.F.R. Pai't 61 beginning three years from the promulgation of any amendments to determine what further changes might then be appropriate to move toward the goal of zero vinyl chloride emissions. In the study EPA will consider recent health data and information concerning technological advances in the control of vinyl chloride emissions. COLORITE 009078 Attachment A Proposed Amendments to the National Emission Standard ior Vinyl Chloride EPA's proposed amendments to the National Emission Standard for Vinyl Chloride, 40 C.F.R. Part 61 Subpart F, shall embody the following concepts: A. The ultimate goal of zero vinyl chloride emissions and EPA's intention to reduce emissions toward this limit will be expressed. B. The 10 ppm limitation under the existing standard will be proposed to be tightened to 5 ppm based on EPA's judgment that technology required by the existing standard can achieve the lower standard, with the following additional proposed features: 1. The 5 ppm standard will be applied to existing sources no later than three years from promul gation of the amendments; (a) Existing sources may institute a review procedure before EPA if the 5 ppm standard v" cannot be met on the expected compliance date; (i) the review procedure may be initiated by the source notifying EPA in writing no later than one year from the expected, compliance date that compliance will not take place; the notification must contain written documentation why compliance is impossible, what interim steps the source will take to reach the 5 ppm standard, and a suggested compliance schedule for reaching the 5 ppm goal; (ii) within thirty days, EPA will confer with the source to consider any oral testimony; the public will be invited to testify or submit written documentation at the conference; COLORITE 009079 _? (iii) within sixtv clays after the conference, EPA will (a-) deny the source's request or (b) fashion a schedule for the source's compliance with the 5 ppm standard, accompanied by interim emission limitations if wnrranted; 2. New sources will be subject to the 5 ppm standard no later than six months from the promulgation of the amendments, but no procedure for relief from this deadline (such as that for existing sources) will be proposed. C. Emission limitations for the oxychlorination process and the stripping of dispersion resins, requiring more control of these procedures than the existing standard, will be proposed for new sources. D. It will be proposed that existing facilities will not be permitted to expand unless Increased vinvl chloride emissions are offset by equivalent reduc tions in vinyl chloride emissions at the expanding facility. E. EPA will undertake a full-scale review of Subpart F of 40 C.F.R. Part 61 beginning three years from the promulgation of any amendments to determine what further changes might then be appropriate to move toward the goal of zero vinyl chloride emissions. In the study EPA will consider recent health data and information concerning technological advances in the control of vinyl chloride emissions. COLORITE 009080 Attachment A Proposed Amendments to the National Emission Standard for Vinyl Chloride EPA's proposed amendments to the National Emission Standard for Vinyl Chloride, 40 C.F.R. Part 61 Subpart F, shall embody the following concepts: A. The ultimate goal of zero vinyl chloride emissions and EPA's intention to reduce emissions toward this limit will be expressed, B. The 10 ppm limitation under the existing standard will be proposed to be tightened to 5 ppm based on EPA's judgment that technology required by the existing standard can achieve the lower standard, with the following additional proposed features: 1. The 5 ppm standard will be applied to existing sources no later than three years from promul gation of the amendments; (a) Existing sources may institute a review procedure before EPA if the 5 ppm standard v-"' cannot be met on the expected compliance date; 1 (i) the review procedure may be initiated by the source notifying EPA in writing no later than one year from the expected, compliance date that compliance will not take place; the notification must contain written documentation why compliance is impossible, what interim steps the source will take to reach the 5 ppm standard, and a suggested compliance schedule for reaching the 5 ppm goal; (ii) within thirty days, EPA will confer with the source to consider any oral testimony; the public will be invited to testify or submit written documentation at the conference; COLORITE 009081 (ixi) within sixtv clays after the conference, EPA will (a) deny the source's request or (b) fashion a schedule for the source's compliance with the 5 ppm standard, accompanied by interim emission limitations if warranted; 2. New sources will be subject to the 5 ppm standard no later than six months from the promulgation of the amendments, but no procedure for relief from this deadline (such as that for existing sources) will be proposed. C. Emission limitations for the oxychlorination process and the stripping of dispersion resins, requiring more control of these procedures than the existing standard, will be proposed for new sources. D. It will be proposed that existing facilities will not be permitted to expand unless increased vinyl chloride emissions are offset by equivalent reduc tions in vinyl chloride emissions at the expanding facility. E. EPA will undertake a full-scale review of Subpart F of 40 C.F.R. Part 61 beginning three years from the promulgation of any amendments to determine what further changes might then be appropriate to move toward the goal of zero vinyl chloride emissions. In the study EPA will consider recent health data and information concerning technological advances in the control of vinyl chloride emissions. COLOR!TE 009082 Attachment A Proposed Amendments to the National Emission Standard for Vinyl Chloride EPA's proposed amendments to the National Emission Standard for Viny7. Chloride, 40 C.E.R. Part 61 Subpart F, shall embody the following concepts: A. The ultimate goal of zero vinyl chloride emissions and EPA's intention to reduce emissions toward this limit will be expressed. B. The 10 ppm limitation under the existing standard will be proposed to be tightened to 5 ppm based on EPA's judgment that technology required by the existing standard can achieve the lower standard, with the following additional proposed features: 1. The 5 ppm standard will be applied to existing sources no later than three years from promul gation of the amendments; (a) Existing sources may institute a review' procedure before EPA if the 5 ppm standard w- cannot be met on the expected compliance date; (i) the review procedure may be initiated by the source notifying EPA in writing no later than one year from the expected compliance date that compliance will not take place; the notification must contain written documentation why compliance is impossible, what interim steps the source will take to reach the 5 ppm standard, and a suggested compliance schedule for reaching the 5 ppm goal; (ii) within thirty days, EPA will confer with the source to consider any7 oral testimony: the public will be invited to testify or submit written documentation at the conference; COLOR!TE 009083 _?_ (iii) within sixtv days after the conferenc EPA will (a) deny the source's reques or (b) fashion a schedule for the source's compliance with the 5 ppm standard, accompanied by interim emission limitations if warranted; Tt O 2. New sources will be subject to the 5 ppm standard no later than six months from the promulgation of the amendments , but no procedure for relief from this deadline (such as that for existing sources) will be proposed. C. Emission limitations for the oxychlorination process and the stripping of dispersion resins, requiring more control of these procedures than the existing standard, will be proposed for new sources. D. It will be proposed that existing facilities will not be permitted to expand unless increased vinvl chloride emissions are offset by equivalent reduc tions in vinyl chloride emissions at the expanding facility. E. EPA will undertake a full-scale review- of Subpart F of 40 C.F.R. Part 61 beginning three years from the promulgation of any amendments to determine what further changes might then be appropriate to move toward the goal of zero vinyl chloride emissions. In the study EPA will consider recent health data and information concerning technological advances in the control of vinyl chloride emissions. COLORITE 009084