Document 3V0nVwZVEZ1MQE6Zb7qDXEVa

UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS P. O. BOX 471, TEXAS CITV, TEXAS 77S90 June 22, 1977 Mr. Howard G. Bergman Director, Enforcement Division U. S. Environmental Protection Agency First International Bank Building 1201 Elm Street Dallas, TX 75270 Dear Mr. Bergman: Subject: Vinyl Chloride Regulation, Compliance With $ 61.64 (c) or (d), Suspension Vinyl Resins and Solvent Vinyl Resins, Termination of Waivers, Texas City Plant In the original application for waivers for these two processes were two vents on solvent tanks which at the time were believed might not be able to meet the 10 ppm maximum VCM concentrations prescribed by Art. 61.64 (c) or (d). Since that time, we have been periodically monitoring these two vents in their respective units to determine if possible whether they were within prescribed limits. Testing methods and data described below indi cates that both of these vents are in compliance with the regulation and that the waivers are no longer required. 1) Suspension Vinyl Process - Solvent (MEK) Wash Tank Vent i 61,64 (d). Compliance Schedule No. 7 This MEK wash tank vent was connected to point No. 7 of one of the two Suspension Vinyl Area VFA monitors on May 20, 1977. The vent was sampled every forty minutes until June 9, 1977 (20.3 days). There were no daily levels above 10 ppm, the average for the period was 4.6 ppm. (See attached tabulation taken from the computer print-out sheets.) The computer print-out sheets are a part of our permanent monitoring records. 2) Solvent Vinyl Process. Brine-Cooled Vent Condenser on Wash Acetone Storage Tanks, 61.64 (c). Compliance Schedule No. 5 The four tanks that receive the acetone wash solvent from the auto claves and other equipment in the process have a comnon vent header which leads to a brine-cooled vent condenser. Condensed organic vapors drain back to one tank and the condenser vent is fitted with a BS&B conservation control set at 6 oz/sq in pressure and 2 oz/sq in vacuum which conserves the nitrogen blanket normally introduced to the tanks at 3 oz/sq in pressure. This condenser vent was fitted with a dry gas flow meter to determine total emissions for the following periods: a) March 22-28, 1977: Six days, no flow detected, but nitrogen blanket had not been applied, so repeated test. ucc 052163 t Mr. Howard G. Bergman June 22, 1977 Page 2 b) April 18-29, 1977; 12 days, no flow detected by the dry gas meter which was fitted to total all flow from the vent. During both monitoring periods, the wash tanks were subjected to the most severe conditions under which we normally operate, but no flows were detected. We have therefore concluded that this condenser vent is in compliance and that the waiver may be terminated. The attached Compliance Schedules have been noted as terminated effective June 20, 1977 per the above disclosures. If there are any questions, please contact me. Very truly yours, f t: /.Wav / J. F. Erdmann^ Environmental Protection Coordinator (713) 945-7411, ext. 1126 JFE:ir Attachments cc: Mr. Cecil Bradford Texas Air Control Board 8520 Shoal Creek Boulevard Austin, TX 78758 bcc: Mr. H. P. Brady Mr. M. E. Eisenhour Mr. A. A. Peterson/Mr. R. L. Frantz Mr. W. T. Gray, Jr. Mr. S. M. Norwood/Mr. W. A. Mazzolini Mr. G. E. Peeler - 124 Mr. D. D. Robinson Mr. R. M. Guardiola Mr. J. B. Leverton/Mr. F. S. Provenzano Mr. R. N. Wheeler - 514 1 OCC SUSPENSION PVC PROCESS DAILY LEVELS OF MEK WASH TANK VENT Date May 20* May 21 May 22 May 23 May 24 May 25 May 26 May 27 May 28 May 29 May 30 May 31 June 1 June 2 June 3 June 4 June 5 June 6 June 7 June 8 June 9 Average * 8-Hours only. Level, PPM VC1 1.4 1.1 4.5 1.8 6.0 9.1 4.0 5.1 0.6 4.4 3.7 4.2 2.7 5.4 7.0 8.2 6.6 0.7 6.4 6.6 4.1 4.6 A. A. Peterson June 14, 1977 ucc 052165 Applicable Regulation 61.64(d) Emission Point Suspension PVC Plant _______________ Description Solvent (MEK) wash tank vent Compliance Schedule Number 7: 1. Date by which equipment will be ordered 2. Date of commencement of on site construction 3. Date of completion of on site construction 4. Date of final compliance and date on which this waiver terminates June 15, 1977 October 15, 1977 August 15, 1978 September 15, 1978 Item COMpP- LIA- NCE S- --CH*EDULEi. ACHIEV' --E*MENT* 'A*N*'D*' REPORTING RECORD Date of Compliance Rema rks 1-- 2 o r~ 3 ^ro O OJ 4" June 20, 1977 In compliance per letter of 6/22/77 to H. G. Bergman from J. F. Erdmann Applicable Regulation 161.64(c) Emission Point Solvent PVC Plant Description Brine cooled vent condenser on wash acetone storage tanks Compliance Schedule Number 5: 1. Date by which equipment will be ordered 2. Date of commencement of on site construction 3. Date of completion of on site construction 4. Date of final compliance and date on which this waiver terminates May 15, 1977 May 15, 1978 August 15, 1978 September 15, 1978 Item 1 4 I ucc 052167 COMPLIANCE SCHEDULE.------------ ~ -------- m Tz . . -i- ACHIEVEMENT AND- * ------------- 7. * **'*-' REPwOxvR*T-I-N' wG *R' ECORD Date of Compliance Remarks MaV15t 1977, Jhis item was_ortgina(ly suwnlttOd on the bail; OfTimiied data whicfrihdlcaKd control might be required. Extensive testing by UCC since then has shown that no controls are beaeTetea 'S curren^^ PrePann9 a report to submit to EPA requesting that this "source"3 -- --- June 20, 1977 In compliance per letter of June 22, 1977 to H. G. Bergman from J. F. Ertfenann