Document 44jevBdKq0bXk8mzMOXqmEL6R

I{ INDUSTRIES PPG INDUSTRIES, INC. INDUSTRIAL CHEMICAL DIVISION P. 0. BOX 1000 LAKE CHARLES, LA. 7CC01 T. C. TAYl.Gn Ttchnteal Manager September 23, 1974 Mr. Gus VonDoclungen Louisiana Air Conirol Commission P. O. Box 60630 New Orleans, Louisiana 70160 Dear Gus: When you visited with us on 9/17/74, you requested that we provide you with a list of allernatives relative to the problem that we have with our incinerator stack gases. Following is 1 his list: 1, Continue what we are doing at the present and do everything possible to evnodire ihc m r.r.scnt and installation of r> s'-condarv weak caustic *' l ' I scrubber for the incineraror stack gases. Under this plan, v/e wlli.be discharging to the air approximately 6 lbs./hr. of ITCI and 17 lbs./hr. of a2. V'/e will be incinerating practically all of the liquid waste and will not vent to the atmosphere the chlorinated organics that are in the vent stream from our perchlor-trichlor reactors. 2. Continue to incinerate our liquid waste, the vent gases from the liquid phase EDC plant, and the vent gases from our ONC-tiDC plant. Take the perchlor-trichlor reactor vent out of the incineialors and scrub it with skater as we did prior to the s1a;t-up of the incineratoir.. This will drop the chlorine discharge from the incincraiois from 17 lbs./hr. to approximately 7 or 8 lbs./hr. It will result in the discharge to the atmosphere of approxi mately 'NO lbs,/hr. of chlorinated oiganics consisting of the following: Monochlorocthylcne 1, 1 Dichloroethylcne trans 1,2 Dichloroethylcne Cis 1,2 Dirhloroelhylene 1,1,2 Trichloroethylene 1, 1,2,2 Te!rachlorocthylcnc 41 Lbs./Hr, 100 Lbs ./Hr. 136 Lbs./Hr. 80 Lbs ./Hr. 75 Lbs./Hr. 10 Lbs./Hr. SL 078323 Mr. Gus VonBodungcn Poge No. 2 September 23, 1974 ( 3. Incinerate only the vent gases from the liquid phase EDC plant and the OHC-EDC plant. Scrub the perchlor-trichlor reactor vent as described in alternate No. 2. Haul all heavy liquid waste to our dump area and keep if co' nred with a layer of water to minimixe emissions resulting from sunii Jit decomposition. This v/ill bring us into compliance on Clp and HCI in the incinerator stack gases, but it v/ill still leave us discharging the 440 lbs./hr. of chlorinated organics described in aliernafe No. 2. 4. Incinerate the vent from the liquid phase EDC plant, the vent from the OHC-EDC plant, and 50 to 75% of the vent from the perchlor-trichlor reactors. Dump the liquid v/aste as described in alternate No. 3. Scrub 25 to 50% of the perchlor-trichlor reactor vent as described in altcmoN No. 2. This will bring us v/e!l into compliance on HCI in the incinerator stack coses end will reduce the chlorine level from 17 to approximately 4 to 6 ibs./hr. With 50' a> or less of the perchlor-irichlor reactor vent Pcnij fed ro the ardsiNg >',scrubbers, we should he able to keep the oigenic emissions from the perchlor-trichlor reactors down lo a satisfactory level. Alternate No. I and alternate No. 4 are acceptable to us. If ycudosire for us to gc with alternate No. 4, we will do excavation v/erk to provide a suitable adequafelysized waste dumping pit. When the dumping pit is no longer needed, the residue will be covered with dirt lo prevent emissions from sunlight decomposition. As you know, wo have been working on the design and procurement of a secondary incinerator stock gas scrubber. Wo placed a purchase order for this scrubber on Friday, September 9.0, Thu vendor bos promised us a delivery date in late March or early April 1975. If an early April delivery date is met, v/n will have this secondary scrubber in operation by ihe end of May. Wo explained jjsf how serious this situation is lo the scrubber vendor, and fhoir representative told us that they would do their best to meet tins delivery date. We are requesting that you grant us permission to operate as outlined in alternate No. 1 or alternate No. 4 until ilia end of KAay 1975. A) or before this lime we will have a secondary incinerator stack gas scrubber in service and will be in compliance with porm`1 No. 163. Delays in premised equipment delivery dales is the only thing that will picvenf us from achieving this compliance schedule. We will immediately notify you if equipment deliveries ere delnyod. Rcspoct fully. T. G. Taylor SL 078324 Mr. Gus VonBoclungen Page No. 3 September 23, 1974 Distribution A. T. Raetzsch D. L. Duncan R. E. Baker R. P. Lynch C. A. Burns i SL 078325