Document 85dxE18V0BVyO1VE4o6aJwk8a

A SUBJECT: VCM Emission Regulations DATE: April 27* 1978 Attached are notes from the meeting with EPA in Dallas on April 26, 1978. Jim Jensen Is summarizing our legal position In a separate memo. Based on the EPA position discussed in the meeting notes, I recommend we try to achieve substantial compliance as quickly as possible by doing the following: 1. Eliminate to the extent possible, the venting of Incinerator feed gas in the PVC Area by improving the controls and reducing inert leakage into the process. 2. Review the causes of emergency vents in the PVC Area and implement programs to reduce the frequency. Alarms to be installed on Part 4 of B-2028 will help. 3. Burn the Hydrocarbon Area Light Ends and Dryer Vents In a VCM furnace if possible, and monitor the stack emission. 4. Eliminate routine venting of VCM tank cars to the flare. This program will cause many operating problems, but I feel that establishing substantial compliance prior to Oct. 21, 1978, will signifi cantly improve our negotiating position with EPA. I have requested that the Technical Service Group begin work on this program immediately. NEG:dlg Attachment H.. ^J.L--Beesorrv W. R. Cooke W. E. Foster G. C. Gaeke J. E. Gonce N. ET Garland J.......L........G.....r..i.f..f..i.n.............R...o..b...i.n.....M. orse J. H. Huguet C. W. Montgomery J. U. Jensen D. E. Park B. J. Lentz J. K. Presswood H. L. Loflin R. D. Sinner H. G. Smith R. G. Stirling W. C. Strader D. W. Sul 1ivan A. 0. Wikman FC 2630 Meeting with EPA Dallas, April 26, 1978 A meeting was held to discuss possible action as a result of EPA's April 4, 1978 denial of our waiver request regarding use of a flare as a control device. Representing EPA Martin Brittain - Engineering John Hepler - Engineering Bennett Stokes - Legal Kathleen Butler - Legal Representing Ethyl Neel Garland J. U. Jensen - Legal Robin Morse - Legal Baker Botts Initial discussion was limited to possible alternatives to the us of the flare as a control device in the event the incinerator is unable to burn the recovered monomer vent in the PVC Area. EPA stated no other company had applied for a waiver permitting use of a flare as a control device. They stated that their policy is to require monitoring of emissions from the control device 100% of the time. They also stated that it is not possible to monitor the emission from a flare. They did not indicate that in the case of an emergency release they would prefer burning In a flare to release to the atmosphere. EPA defines emergency releases as those caused by "acts of God" or "natural disasters". We indicated that it might be responsible to achieve substantial compliance in the PVC by process changes. These would include: 1. Improvements already made to the incinerator to Increase the service factor 2. Control modifications to eliminate vents during load changes 3. Reduction of amount of VCM vented by reducing inert leaks into the process We stated that no control system is 100% effective and the only way to achieve 100% compliance is by shutting the plant down when the controls are not working. EC 2^31 ! *- -r~*w P 2. K ''' Jk ;' ? ^ ' ' ' ;_ We also discussed installation of a second incinerator as a control device* but pointed out that this could not be done until many months after the Oct. 21, deadline. We indicated a 16 month schedule to have an incinera tor in operation. EPA asked if this schedule was based on paying a premium to expedite the schedule. We said we did not know. 4, , ` EPA asked if we were considering any other controls. We indicated we have investigated many alternatives. Mr. Brittain mentioned burning VCM vents In a boiler as a possible control. Finally, EPA brought up the point that other process vents contain ing VCM are being burned in the flare. EPA said that any settlement of the matter would have to be a complete plant-wide program to achieve compliance which would include burning the process vents in an incinerator. Ms. Butler also told Robin Morse in private that we were reporting too many atmospheric emergency vents and they were considering legal action on this point. ** We asked about the status of the five pending equivalency requests. EPA indicated they had completed the technical review and could perhaps complete the administrative review in a week. They did not choose to indicate the results although privately, Robin Morse got the impression from Ms. Butler that all would be denied except possibly the "0" ring seals on safety valves. EPA indicated there were two possible actions on their part at this time. 1. An administrative order under 111A3 outlining a a compliance schedule, possibly with fines. 2. A civil suit under. 113B with a fine and compliance schedule. EPA will consider their options and will contact Robin Morse in about a week. We believe that they will offer a litigated settlement under 2 above;wh;ich will require a comprehensive plant-wise compliance program plus payment of a fine. A t FC 2632