Document 71N3DgRznrx23xL7Bq2kMrako

rtytjJ EC VENTS From our discussion on 8/22/89 I understand that the VCM and VDCM vents from loading these products at the VCM Loading Rack are incinerated. I also understand that the EC vents from loading EC at the rack are not incinerated. La. DEQ Regulation LAC33:III.2107 for Volatile Organic Compounds Loading states, ". . . any loading facility for volatile organic compounds servicing tanks, trucks, or trailers having a capacity in excess of 200 gallons and having 40,000 gallons or more throughput per day averaged over any 30-day period must be equipped with a vapor collection and disposal system. . . ". Records indicate that we exceeded 40,000 gallons/day at the Rack during numerous 30-day periods. As a result, the EC loading vents must be incinerated in order to bring the VCM^Loading Rack into " compliance with existing regulationsI also recommend that the EC~"vent from the EC/VDC truck loading"facility be incinerated as a part of this project. We also discussed proposed changes to the VOC loading regulations which could potentially affect VOC loading operations at the Solvents Loading Rack at the Shipping Building. I talked to DEQ officials on 8/23 to get clarification of the changes and learned the following: Assuming the changes are accepted (better than "good" chance they will be), they will go into effect on October 20, 1989. At that time, LAC33:III.2107 (above) will be changed to include all loading facilities at a single location or plant in "combination". This means that all of PPG's loading facilities including the VCM Loading Rack, EC/VDC Truck Loading Rack, Solvents Loading Rack, etc., but excluding barge and ship loading operations, will have a combined 30-day average throughput limit of 40,000 gallons/day. We obviously exceed that throughput, so, all VOC vents from the Solvents Loading Rack would then have to be incinerated as-~sdon-as-nossible. Remember, this__is still just ^proposed", but would go into effect on 10/20/89 i"T"Tt gets "through the rulemaking process. Therefore, some thought should be given to incineration of these vents in the very near future. I will let you know what happens on this issue. Please keep Esther Liggio and I informed on the progress of the incineration of EC vents project. If you have any questions, call me at 4814 or Esther at 4326. APP/vc SL 087846 cc: G. Jordan J. Lafleur W. J. Peard/J. R. Holliday`S E. Liggio C. Parnell File #107.2.16 . Wyche SL 087847