Document 44Lk7rrRGpkzvDddKjmMNx7Xx

INTERNAL CORRESPONDENCE CHEMICALS AND PLASTICS TO (name; rrr <7si COPY TO P.O. BOX 471. TEXAS CITY. TEXAS 77S90 IkULZ____ /974________________ SUBJECT RECEIVED HJN2Q 1379 J. F. L FROM f.fi. Sm.-fk %Uzc, 7t&L ^ 2- -------------- r --------- ~z:---------- - a---------------------------j . 6/20/79 faMt/-_______ Me*._____ T / rtW /t/J ~ a/ZCs /C _________________-/fit* 0^/' &**> '/b* *%/** j) /XJ JU/a/~~ ___________________Y ** ^ **</*/* ^ 4m S** r*JgJsCfcK4 4/ b* / - e/' ___//> W*S.Mf4/ faMtidot &U /ii 0Ay b ^ /fe >X/ j^*/^4i^i -ft /juuic* i/t -- cmS y /is-* 7 /r/MSiS sUfST&t* ir w 4^* 4* Sl*ttcu-* 4 r /&* //L J7 vj<* - &2 #4- &iM** ^ <9 ^ C/ /^y 4/r 4- )/#+/*/ , S3fc^p . fAtA+r/fc /v c^j/kA*,' a6*y/~~ -fi--- /Lk-------------(VlP.,M.___// cMlis ucc 051616 <} L jr*. (___ >>77/1/ INTERNAL CORRESPONDENCE uc n*- * CHEMICALS AND PLASTICS p. O. BOX 47*, TEXAS CI TV. TEXAS 77MO ' 'JV^NV r t os Mr. R. N. Wheeler S. CHARLESTON PLANT V/ OAT* January 10, 1977 T r MngKiinhflTf^s syejecT EPA VCM Regulation, Waiver L. J. Kunke/ . Request for Solvent Vinyl Resins, Mr. S. M. Norwood" Sources Following Strippers, Mr. W. T. Gray, Jr. Mr. J. B. Leverton/ Discussion with Dallas EPA Office Mr. R, E. O'Bryan/ E. P. Files Mr. R. A., Herrington/ Mr. H. P. Brady, Dear Nick: I received a phone call Friday from Mr. Martin Brittain of Dallas EPA office who was reviewing our waiver requests and. had a specific question about the solvent vinyl process, sources following strippers (page 22 of Waiver Request Package, Solvent Resins). He requested clarification about the stripped solvent stream containing about 1000 ppm VCM which is numerically added into the varnish stream calculation and thus exc eds the 400 ppm allowable level on the resin stream leaving the stripper area. He asked if it was incorporated as part of the resin varnish stream g ing to resin processing and recovery and I said no it was not a physical part of the resin-containing stream, but was directed back to other areas for further separation and eventual recycle to feed the autoclaves. He indi cated that die resin varnish stream was presently in compliance and since this stripped solvent! stream is not a part Of it that it should not be included. He therefore indicated they would take no action on this waiver request because there was no.violatioR of the 400 ppm level in the stripped resin stream. There were no questions about what happens to the VCM in these solvents that return to the No. 2 Tank Area and. B-114 for separation and recovery. I feel this is a~situation which will be pruPSflv settled in the future by the Modernization Project and will probably take care of itself. I'm sure th r may be differences of opinion on this, but Mr.Brittain felt this was the most understandable way to handle this particular waiver request. In any case, we asked for die waiver originally on the assumption that all the VCM contained in the two streams eventually was released to the air even though the two streams were not joined in any way. ucc 05161? / Mr. R. N. Wheeler January 10, 1977 Page 2 * If you feel this is inadequate, unsatisfactory or a possible pitfall, olease let me know and we can look into some other approach. Vi Very truly yours, JFE:ir 4' F* Erdmann ucc & 051618