Document 5LZ1o3JD2Qx8q3vEvYzygYL1D

\ T R C F r : C E E m O TEfJiiECO CHEMICALS, INC. T,. p. R. Scarito AT Burlington d*'l April 13, 1977 F WOm J P. Sandstedt At Piscataway sliojclt epa Compliance - Reciprocating Compressors Copy to W. P. Anderson D. C. Coldiron W. F. Gabel N. J. Quist G. I. Rozand E. V. Schenke C. G. Thompson Mr. Quist ha s advised me that the third packing set required for modifying the reciprocating compressors is on order. Our compliance schedule requires completion of these changeovers concurrent with completion of installation of double mechanical seals on our rotating pumps. 1 do not believe the CAR prepared March 7, 1977 included monies to purchase and install the outstanding packing sets. If this work cannot/should not be handled as a maintenance expense, I recommend prompt preparation of the necessary CAR. In addition, the Plant should look into requirements to bring the unloading compressors into compliance. Also, it may be necessary to change the SIHI pumps (additive resin) if these cannot be adequately modified. Compliance with Paragraph 61.65 (b) 3 of the Standard is required by February 1, 1978. JPSrdb / J. P. Sandstedt COLOR!TE 018356 MANUFACTURING SPECIFICATIONS PASADENA HOMOPOLYMER EFFECTIVE 4/7/77 TES1': UNITS REIATIVE VISCOSITY (56-5-1) DRY BLEND TIME (56-5-6) COtnA'-mUTTCN COS (56-5-9) (56-5-5) Minutes, Max. Specks/100 g., KtT/100 In2 Max. Max. VOLATILES (56-3-1) Wt 7,, Max. VOUME RESISTIVITY (56-5-7) .. Chrp/an2 x 1012 Min, BULK DENSITY HEAT STABILITY (56-5-2) (56-5-8) Lbs/Ft3 X of Std.. Min. SCREWS (56-5-3) +P5 +)0 +105 -206 --emulative Weight, 7.------ VO-i CONl'lKi (56-6-3) PHi By Ut, K 0 1 i 195 1.91-1.97 8.5 20 13 0.4 - 32-37 90 30-60 0-5 10 200 2 .'00- 2.06 8.5 20 13 0.4 - 32-36 90 0-3 30-60 0-5 10 225* 2.25-2.31 8.0 20 13' 0.4 10 30-34 90 0-5 5-35 30-70 0-5 10 22520 2.19-2.25 250 2,35-2.41 14.0 7.0 30 20 25 0.4 13 0.4 10 30-34 29-33 90 90 0-5 30-80 0-5 vT< '"V-- 0-3 5-40 40-70- 0-5 10 10 250-1 2A7-2.53 7.0 20 13 0.4 10 30-34 90 0-3 >0-40'" '"40-7o' w 0-5 10 no oF ^Marketing to select 225 resin for fill grade customers with following additional requirements: Contamination Max. - 15, Average - 10 Magnetic Parcicles/Lb, Max - 6 R Cels, Max - 8/2, Average 5/2 Heat Stability - IlOf W Any resin showing unusual or indeslrarle properties or inusual contamination (e.g. short-stop) not listed above will be E Grade and held for disposition by Marketing. oo U) U1 Reason for Issue: Change 100 mesh screen size requirement on Type 200, -4 Supersedes specifications issued March 15, 1977 Pan 1 vT BppH Marmopr OnaHfv Aqflnrflnrp fcft (io; , 8'll .Hi i i! ,'3: , . 7: ! ; :-r: = ! :4. ; 'ii, <e3\ - tW. si a ?W 3N 1^6-.721 iZq I1 11 ?<*> 1i1 i 13 :3 ;*! ! i ill 1 3*4 ! 3?3i z%\ 2|* 7%1 \ 2*4| W 2f?^i I I I' /!'^6t!' $0(p iii M 22* 4 0* 2^ 2^* 3?v 1 Z\'D /O, 3 ! 2i7 I I X Zip (|1 ! 2^7 r <' Jt"Pf pq 1 // "P/z^r^T TCI POSITION ON PROPOSED CHANGES TO EPA REGULATIONS ON VINYL CHLORIDE epp The proposed settlement between EPA and A requires that EPA revise its exis ting standards to reduce the existing 10 ppm standard to 5 ppm. It further _ AM* proposS* to allow^3 years from promulgation of the revised regulation to meet the new standard (compliance date is expected to be about 12/31/80). It also provides for interim review procedures for existing sources if the 5 ppm stan dard cannot be reached by the compliance date. Such review must be instituted no later than one year from the expected compliance date (this should be about 1/1/80). It j e seems probable that settlement will be made but it is not in effect now. \>P It is difficult to rationalize the proposal to reduce the limits from 10 ppm to 5 ppm if one considers PVC plants only. The quantity of VCM involved is a very small fraction of the total plant emission so the net impact on the ambient air is insignificant. If the EDC-VC plants are also considered, the result is quite different. Those plants have large air streams subject to the +H 10 ppm limitj 4t seems probable that the EPF proposal was directed primarily at the EDC-VC operations rather than the PVC plants^'f'UJftH'OH / -b0 fo-th, Tenneco Chemicals has, tn ~i~ f irr~. based its EPA/VCM Compliance Program planning on meeting a 10 ppm limit by 10/19/78. Technology which Tenneco now plans to use, i.e., carbon adsorption at Pasadena and carbon adsorption or scrubbing at Burlington and Flemington cannot, at its present state of development, assure meeting a 5 ppm standard. A revision in the program at this point to change over to incineration, with the unknowns involved there will probably jeopardize meeting the 10 ppm limit by the legal deadline of 10/19/78. Failure to meet the deadline could result in severe penalties. COLORITE 018361 2- - Tenneco Chemicals requested waivers of the 90-day time period allowed by the regulation to reach complalnce and has received approval of these requests. As part of the submissions, Tenneco Chemicals proposed a time schedule for a series of intermediate steps. Approval of the waivers gamw the intermediate date legally enforceable deadlines unless changes are approved by EPA. The final compliance dates cannot be extended since they are fixed by the Federal Statute. The intermediate dates in most cases were determined by working backwards from the final date and constitute a very tight schedule at best. A delay in meeting these dates will jeopardize the final date also. We have several strategies open: I. We can continue our present effort to reach 10 ppm by 10/19/78 and plan on reaching 5 ppm by 1/1/81 by either optimization of the control system, or adding on second stage units between 10/19/78 and 12/31/80. II. We can scrap present plans and start over with a program to in stall incinerators to assure meeting an ultimate 5 ppm. III. We can take legal action now in an effort to present the pro posed change to the standard; or to revise it so it applies only to the EDC-VC plants. I recommend Option I for these reasons: 1. The 5 ppm standard will probably be promulgated, but it is not aa ( now and there is no reason for a crash program to -4- -Liu* //*. it jia**.<* 2. We have a considerable stake in carbon adsorption which can best be protected by using it to the limits 11^5 Capii bt * COLORITE 018362 -33. Scrapping present plans and starting over with incinerators oad- UJ/' the many questions open about them will make meeting the 10/19/78 target for the 10 ppm standard very doubtful with all the com plications that can cause. 4, From a tactical standpoint in dealing with EPA, I think it would be unwise to push too hard against the 5 ppm standard now. A hard line might result in reopening the entire standard and if so, I think we would see the 400 ppm limit on stripping reduced. After the 10 ppm standard is met, I think EPA might be more re ceptive to requests to waive the 5 ppm for PVC plants if it can be shown that the reduction from 10 ppm to 5 ppm will be very expensive and the reduction trivial. WPA:AS 4/21/77 A0 4 COLORITE 018363