Document 2RXarVQY7YDvy87V4K6ke75ZR

/ / ROY F. WESTON, INC ENVIRONMENTAL SCIENTISTS AND ENGINEERS 1 August 1973 \ RiWFt5wEEYSmiTsF 7w5'SrCK. C.WASFSJTFB |)|C * PENNSYLVANIA F930 2i5-632-3C30 TELEX NUMBER B3-SWB CABLE AUOFtESS RfV.INC Mr. R. J. Gamblin Conoco P.0. Box 605 Westlake, La. 70669 Dear Mr. Gamblin: During a recent telephone conversation on July 26, 1973. with Mr. Gerlach we briefly outlined the scope of a contract our firm has with the U.S. Environmental Protection Agency to aid in the development of effluent limitations and new source performance standards for the Organic Chemicals Industry. To develop the re quired effluent limitations and standards, it is necessary both to characterize the type and quantity of wastes which are generated and to identify the types of control and treatment technology which* are applicable. The data currently available from Phase I of the project relating to both these areas are not totally sufficient for the development of meaningful effluent limitations. To provide a realistic data base, Roy F. Weston, Inc. plans to visit selected plants to obtain information relating both to the manufacturing process raw waste loads and to the end-of-process treatment systems. Based on published information available in the open literature, and Refuse Act Permit Applications supplied by EPA, 80 facilities have been selected as candidates for visits. These facilities include plants with continuous and batch manufacturing operations, as well as those with end-of-process treatment systems. The Conoco plant located at Westlake, La. is included with those facilities we wish to survey. The Westlake facility was chosen on the basis of vinyl chloride manu facturing operation for which we wish to obtain data leading to the establishment of process raw waste load. I * CCR 000035076 fi -R---O---Y-------F-.-----W----E--S---T--O---N---.----I-N---C-------- FNViMONNiSNTAi. SCIENTISTS AND ENGINEERS The specific information we desire concern: 1. The water quality and type of treatment provided prior to utilization in manufacturing operations. 2. The raw waste loads generated by individual manufacturing pro cesses . 3. The end-of-process wastewater treatment systems which receive wastes from several manufacturing operations. Personnel from Roy F. Weston, Inc. and EPA representatives will conduct the actual plant visits. Information on manufacturing operations and thus the associated raw waste loads will be derived from: 1. Interviews with operating personnel. 2. Examination of plant design and operating data (process flow sheets, plot plans for sewer layout, and available analyses of process waste streams.) 3. Individual process wastewater sampling and analysis. To aid the project team in understanding your process or processes, a simplified process flow diagram should be prepared beforehand indicating major unit operations, any pollution control equipment, e.g. dust collectors, all process water and raw material additions to the system and all wastewater sources going to sewer or those that are recycled. Attached are sample flow diagrams which may be used for illustrative purposes. Information on the performance of wastewater treatment systems, if applicable, will be obtained through: 1. Interviews with pollution control personnel. 2. Examination of treatment plant design and operating data (flow rates and analyses of influent and effluent.) 3. Treatment plant influent and effluent sampling. Roy F. Weston, Inc. recognizes that most manufacturers consider the fol lowing types of information to be proprietary: process information re lative to actual production rates; catalyst types and usage; and the particular type and number of unit operations at a specific location. We are willing to sign secrecy agreements with industry to protect such process information. Furthermore, any data not utilized in the study will, be returned to the specific manufacturers involved. No data related to this study will be retained by Roy F. Weston, Inc. However, information which Is specifically utilized in the data base must be turned over to EPA upon completion of the contract. If this information Is considered to be a "trade secret", it should be marked as such. EPA CCR 000035077 fV-1} ROY F. WESTON. INC. gNVU^ONMENTAI. SCIENTIST ANO 6N5iNERQ has indicated that information so designated will be exempted from public disclosure pending the manufacturer's submittal of a brief providing affirmative evidence for such a classification. (Licensing agreements are one example of such evidence.) . Every attempt will be made to limit our discussions to soliciting only that information which we believe is necessary to fulfill our stated objectives. In this way* information released to EPA which is considered as a "trade secret" may be kept to a minimum. The analytical data in the final EPA report will be identified only by product name and there will be no mention of your company in the actual report. In the previous Phase I study, all analytical data was grouped in categories and generally not compared on a product for product basis. Therefore all data collected during this project will be useful in verifying previous categorizations and providing us with a broad data base upon which to make future recommendations. We plan to conduct our field data collection program from September 1 to October 30, 1973. Currently, we are planning to schedule visits to in dividual facilities daring this eight-week period. We will be calling you within the next few days to schedule a visit during this period. Any questions you may have should be directed to Dave Smallwood or Chuck Mangan. Very truly yours, 'A James H. Dougherty, P.E. Senior Project Manager JHD:js i \S; i CCR 000035078 oo mo90 Oez= -r>* mz n O O c I co O 73 -c m CO "O O n m, c/> cn ACETOPHENONE CCR 000035079 CCR 0 0 0 0 3 5 0 8 0 FIGURE/2 aSEMUCONTINUOUS and patch processes 1 WASTEHEAT RAW MATERIAL PROOUCT S/f/b* Jy, /yiML/fruu^n* - sfra*H&* t 4c/d*/ jtyu&ae/^ /*$, .j&oudrtd*^ .. Jb/t* 6) t/j^ <ss+*j/(A/&&4 jL^ta^OA* -4vi C#*du4* <a A$L+t^e<f AUrt&f s&KL OvxZX , yft*. /?fhS C*f^. s2&4*^4 ol^p^s u*4$/ St < fiz C&&$4#^* ~a^s*' T^fft/ /z^&t&a -S-^5Ju&16CL^ ^ d*ve_ ,^62+f 7^^ <*^ A, &ise t*st^_ ___ ______ sk<^^ K-CJjUfdfdL- <&24US>1 4 0-fA- S&-LZA -4^ffel(/fM-.^d*wh // /?sdiA4A$ *# J4HXS&* JLtrt&&4*ZL , %C -&U$ Uff 'totfJtjf' yvt^t^t^. jj00f ^ tb* C<Ut*Jt Z$C Z*_Uj& --Y/j Sbdb.'.. ........... OCR 000035081 CCR 000035082 John 0. Minott TO (conoco) Date COtUfa Ot~/ %tejj fa 3 fa S'cLu^a, ?fa*ujfa ***7^? jfaX^tuZ^^ crtrfaLp faw<b . CCR 000035083 jjb TO TIME .DATE `TVfale `tf.ou Ti/ene [out M. CJLsK_____ lrh<O^KjcC ^______ of Phone No. a jr- G *>2 3q-30 Telephoned Qrlease call back | | Called to see you Q Will call again lj- Left the following message:- j | Returned your call CCR 000035084V OFFICE OUTFITTERS LITHOGRAPHING PRINTING BOOKS GIFTS COUNTY RECORDS OFFICE PLANNING AND LAYOUT SERVICE 405 EAST GRAND PHONE (405) 765-4401 STATIONERY & BANK SUPPLY, Inc. PONCA CITY, OKLAHOMA 74601 (conoco) Date ZL