Document 7MdaDkY2o5zkN1qM6pG3y1Nge

L erf CJ2 GJUGj, PATRICIA L. NORTON SECRETARY OFFICE OF AIR QUALITY AND NUCLEAR ENERGY March 19, 1986 GREG J. GASPERECZ ASSISTANT SECRETARY CERTIFIED MAIL - RETURN RECEIPT REQUESTED P 669 936 928 Mr. R. A. Conrad Plant Manager Vista Chemical Company Lake Charles VCM Plant VCM Plant Road P. 0. Box 605 Westlake, Louisiana 70669 Dear Mr. Conrad: We have received your reply to my letter of February 20, 1986, supplying additional information concerning the February 3, 1986, incinerator bypass. We do especially note the previously omitted emissions from the railcar loading operation which now makes the four and one half hour incident accountable for 1,161 pounds of vented vinyl chloride. Under Louisiana R.S. 1089(1) we are to make a determination of the preventability and root causes of the incident. We feel that for these purposes some further information is required. Please answer the following: 1) The accumulated emulsion buildup in the Wet CrudeEDC Tank was attributed to "reworking byproducts too rapidly." What are these byproducts; what is their source and how much did the flows differ from normal operation (Give actual flow rates)? Supply a flow sheet if necessary. Why were the flows high? 2) Inyour original correspondence of February 12, 1986, it was specified that the Heavy Ends Column make was diverted to the EDC wash section to prevent water from getting into downstream EDC Purification. This step cannot be accounted for by the flowsheets supplied, please clarify. MR OI' AI.ITY FI! VISION PO ROY J4U*M BATON ROl'GE. I.OI'ISIANA 7H804 PHONE (5041*42-1 Mr. R. A. Conrad March 19, 1986 Page Two 3) What is the Full Load Amperage (FLA) of the Wet EDC Pump (P-103) that tripped? You have attributed the trip to increased flow to the wash section; does th-is mean that a wide open pump discharge will require an exceedairee~--of the FLA? If not, please explain the nature of the trip. -- Louisiana R.S. 1089(1) places the responsibility of proving that a discharge constitutes an emergency emission (and thereby a non-preventable situation) on the facility. Any more input into clarification of this point is welcome. We do ask that you respond promptly and submit your reply within fifteen days of receipt of this letter. For any questions, please call me at (504) 342-9046. Sincerely, CK: aa Files 12.40.2 Chris Kuttruff Environmental Program Specialist LESHAP Unit 000000317 CUH