Document 3J24dEgGyyw93DZyBDoxpY760

February 25, 197 7 I. t. ' hi v * Conoco C-'ornicnn COntirr.t.l,i| 0<t f.Oil'fliVW F O rn* 9 1 , ''I' .v 25 Aln-rc.'c^^ Msvn* ppi J9~30 unictirt Scacay Eu vituuuuut.il 7voceccion Agency Suite 300 1421 Peachtree Street Atlanta. Ceoraia 30309 Attention: Mr. Thommie A. Gibbs. Chief, Air Engineering branch Dear Sir; We have received your letter of February 30, 1977 regarding our request for a waiver of compliance with the vinvi chloride standards at the 'rational Emission Standards for Hazardous Air Pollutants, '.'e have reviewed the changes as proposed by the EPA. Wo offer the following arguments and revisions regarding our compliance schedule: Items I. II, IV, VI. VIII, IX, XI, and XII concai Ho. 2. This system includes extensive revisions spec4* ercrences tc 3 d u 1 e illy required r.ir vinyl chloride emission control. TTilS""WVilM fafcffitjy wit l until w*~arm*6le to meat iPJC^Sn^ssTon Limitatlone^ 'JjrVsucjr.. * s?ectiLl compliance schedule la not applicable. we will not be operating out Of compliance at any time in this system* We will not be operating module No. 2 until about February 1, 1978, and will be in compliance upon initial operation. The exact date of initial operation is not within our control but is projected at about February 1, 197S, In-any event, module Mo. 2 will not, at any time, function euch that emissions in excess of the VCH stindirfc occurs. I, Reactor Exhaust Cases: We have no comment on the proposed EPA schedule except as noted above. II. Reactor Opening Loss: Me are now in compliance relative tc reactor opening.loss..Our ability to demonstrate that ve are in compliance is dependent upon the F.PA's acceptance of our proposed method of calculating this quantity. If the calculational method is not accepted as equivalent,then additional time will be needed to develop a technique of demonstrating compliance III, Emission from Mixing, Weighing^ and Holding Containers: Me have no comment on the schedule revision proposed 1-y the -PA. Me will work to meet the EPA's schecule. -1 SAL 000109207 21 'd 8 E : h i d 8_ 2 United States Environmental Protection Agency Mr. Thommic A. Oibbs February 25, 1977 Pape - 2 - IV. V. VI. VII. VIII. IX. X. XI, Sources Following, the Strippers: Regarding this item our schedule as proposed called For operation at 400 ppr. to be achieved by June 30, 1977. The EPA's proposed date of June 1, 1977 for achieving 400 ppm operation is acceptable. There is, however, no way we can complete any compliance performance tests by June 1, 1977, as we will not be able to routinely sample each reactor Knfi'h 'inrfi i;t? in Hay. Our ability to cample each reactor batch awaits delivery of analytical equipment. Until late in May we will be limited to about three or four reaccor samples per day. Loading and Unloading Lines*. After reviewing our project schedule for the various EPA compliance items, we do not think va can possibly make the construction completion date of January 1, 1978. This Drolect involves rather massive structural work which will be time consuming to build and engineer. The earliest we can visuaLize completing construction is February 15, 1978 with compliance being achieved on April 1, 1978. k'e ask the EPA to reconsider and accept our revised dates. Rotating Pump Seals; We have no comment on the EPA's proposed schedule and will attempt to meet the new dates. Reciprocating Compressor: As of now the machine vendors do not manufacture the required parts. Assuming such parts are available we certainly can order them by May 31, 1977. Our discussions with the compressor manufacturer indicates that parts will not be available until late summer. We ask the EPA to accept a "Purchase Order Issued" date of September 1, 1977. Agitator Seals: No comment. The EPA's proposed schedule is acceptable. Relief Valve Leakage: No comment. The EPA's proposed schedule is acceptable. Opening Of EqnipnentJ_ No comment. The EPA's proposed schedule is acceptable. Samples; No comment. The EPA's proposed schedule is acceptable. SAL 000109208 SI 'd 6 ; PI S8/A2-'20 i tusio N33aaiat) woad United Stales Environmental Protection Agency Mr. Thor.mic A. Gibbs February 25, 1977 Pane - 3 - XII. In Process Waste Water Stripping: /J XIII. Item XII is accepted as long as it refers only to the process waccr collection system, as was described in our compliance waiver request. Vent Gas Emission Recovery System We have again reviewed this schedule and find cite "Purchase Order Issued" date very difficult. The best we think, we can do is August 1, 1077. The remaining date under this item is acceptable. XIV Vent Gas Incineration: We have very significant problems Tilth Item XIV. We are now in the process of finalizing cur process design. This will be complete by April 1, 1977. We will then apply to the State of Mississippi for their "Approval for Construction". By law the State of Mississippi is allowed three months for review. Using this schedule, which is extremely optimistic, cur best date is August 15, 1977. The July 1, 1977 is not feasible. Please note chat we feel that some sort of pilot 'work Is desirable, We have no experience with incineration and we are relying on the EPA's judgment that incineration works. If this is not the EPA's position, (i.e. incineration is proper technology) then we should be allowed to conduct pilot work which would delay cur optimistic schedule by about three months. As I indicated on the phone to Mr. Beals, we are extremely anxious to resolve these problems, Please review the previous information carefully and let us know of your decisions. We remain willing to supply additional information or to go to Atlanta to discuss and resolve these problems. Sincerely, Chief Process Engineer DEM/jc SAL 00010920? p: ' d oC ^ l 0/ <LIE y"' 20 i Hsin N33aa38y woaj