Document 2jg408xJq7qZ1B38xVn6VMwaa

INTER OFFICE MEMO TENNECO CHEMICALS, INC. To W.C. Champion at Burlington From F.W. Kanzler at Burlington Subject National Emission Standard fbr Vinyl Chloride date June 18, 1975 copy to R. A. Lojewski W. Miringoff ./File The preliminary copy of the subject standard gives rise to the following comments related to sampling and analyses of stack emission samples-as well as slurry and resin sampling and analyses; 1. Stack Sampling EPA proposes similar requirements for stack procedures as used for par ticulate emission determinations. This would require installation of permanent gas sampling tubes together with reverse ("S") type pitot tubes in all stacks used for venting of VCM from processing areas into the atmosphere. Sample tube locations, as proposed, would require the same considerations as needed for particulates, e.g., at'least two stack diam eters down-stream and one half diameter up-stream from any flow disturbance such as a bend, expansion or contraction. This type of requirement becomes very impractical fbr the majority of stacks installed in Burlington. Fur thermore, since only VCM is to be measured a uniformity of the exhaust gas should be given in any area, perhaps with the exception of areas near ex haust fans. The pitot tube could be used as indication of the consistency of the flow rates. If the above requirements will have to be met, inaccess ible sampling points would have to be fitted with permanent umbilical cords. While the proposed gas sample train is relatively simple and easy to oper ate (Figure 1), it would require explosion proofing of the vacuum pump and electrical supply at the sampling locations. As an alternative, umbilical cords could be used and the sample train located in a centralized safe area. 2. Stack VCM Analysis Analytical procedures used in the Burlington and Flemington Plants should be satisfactory to accomplish the analyses required. The standard, however, proposes the use of a different column packing - Chromosorb 102 - as cur rently used in Burlington and Flemington. In addition, accurate monitoring equipment for atmospheric pressure and temperatures are required. The frequency for sampling and analysis, as proposed, would be once/month since a monthly material balance report is required. 3. Slurry and Resin Sampling The proposed standard requires that each fifth batch of each resin type be analyzed with three samples each. While the sampling procedures established already are very similar, the standard requires an intensive sampling program. COLORITE 010106 Page 2 4. Slurry and Resin Analysis The analytical method suggests the use of a Perkin-Elmer F-40 headspace analyzer for residual VCM analyses of slurries and resins. This type of instrumentation is presently not available in Burlington or Flemington. Only equivalent methods seem to be acceptable, rendering solvent extraction techniques, currently used, invalid. Results, as proposed, must be reported once every ninety days. In addition, analyses are to be performed to determine the amount of VCM in reactors and effluent water. These methods are currently devel oped by EPA. Please advise which preparation should be made to be prepared for the additional test requirements. Attachment FWK/o'st F.W. Kanzler %* l COLORXTE 010107 Vent TTmHTT COLOR!TE 010X08