Document 8R8yJjyLJ3nyy3roJZVn783gy

(conoco) it Conoco ChomtctU Continental Oil Company P O Box 91. N*w Highway 25 Aberdeen. Miaaiaaippi 39730 October 2S, 1977 United States Environmental Protection Agency Suite 300 1421 Peachtree Street Atlanta, Georgia 30309 L< C SJ1/ J&t Attention: Mr. Thommie A. Gibbs, Chief Air Engineering Branch Dear Sir: This letter is written to update your office of the progress of our plant in our effort of achieving compliance with the National Emission Standards for Hazardous Air Pollutants, Standard for Vinyl Chloride (40 CFR, Chapter 1, Subchapter C, Part 61, pages 46560-46573). Region IV of the Environmental Protection Agency granted our plant a waiver on March 30, 1977 (Mr. Jack E. Ravan to Mr. G. G. Oraper, letter dated March 30, 1977). The letter granting the waiver listed specific dates by which the Plant was to achieve compliance with the various parts of the Emission Standard. Described below are each of the various areas as listed in Mr. Ravan's letter. * 61.64 (a) (1) - Reactor Exhaust Gases i) Purchase Order Issued ii) On Site Construction Started iii) On Site Installation Completed iv) Final Compliance Achieved Module No. 4/30/77 5/31/77 11/30/77 12/31/77 As stated in our submitted plan of December 20, 1976, Module No. 1 is in compliance in this area. Module No. 2 will not operate until a similar containment system is in place. The purcl^se orders (i) have been issued and on site constuction (ii) has started as required. We now project installation completion for January 20, 1978, This does not, however, imply any violation of emission standards or of our waiver as t 61.64 (a) (2) - Reactor Opening Loss Module No. 1 Module No. 2 i) Purchase Order Issued 3/31/77 4/30/77 ii) On Site Construction Started 4/30/77 5/31/^7 iii) On Site Installation Completed 7/31/77 iv) Final Compliance Achieved 8/31/77 11/30/77 12/31/77 SAL 000109225 PI 'd 63:tM 3/62/20 diSIO N 33Gd3 Odd Mr. Thommie A. Gibbs, Chief Air Engineering Branch October 25, 1977 Page 2 As indicated in our December 20, 1976 waiver request and compliance plan submittal, the achievement of compliance with reactor opening loss emissions is dependent upon the final temperature and pressure conditions within the reactor. Regarding Module No. 2, we do not intend to operate this section until compliance facilities exist. As indicated under Section 1, we expect to initiate Module No. 2 operation on about January 20, 1978. Engineering personnel are now monitoring operating conditions on Module No. 1. Accurate operating condition data is being obtained. This data is now being used to calculate reactor opening loss emissions. III. ^ 61.64 (e) - Emissions From Mixing, Weighing and Holding Containers i)Purchase Order Issued ii) On Site Construction Started iii) On Site Installation Completed iv) Final Compliance Achieved 6/1/77 10/1/77 12/1/77 2/1/78 Purchase orders (i) for the required equipment have been issued. Field construction (ii) was begun during July, well ahead of schedule. The completion of installation (iii) and the achievement of compliance (iv) remain on schedule as indicated by the above dates. IV. 61.64 (e) - Sources Following the Strippers Module No. 1 i) Purchase Order Issued Completed ii) On Site Consturction Started Completed iii) On Site Installation Completed Completed iv) Final Compliance Achieved 6/30/77 Module No. 2 5/30/77 11/30/77 12/31/77 1/31/78 Module No. 2 will not operate until the system for achieving compliance is in place. Projected initial operation for the Module No. 2 system is January 20, 1978. Regarding, Module No. 1, we are now stripping each reactor batch. Samples of each batch are being obtained and are being analyzed. 61.65 (b) (1) - Loading and Unloading Lines i) Purchase Order Issued U) On Site Construction Started iii) On Site Installation Completed iv) Final Compliance Achieved 6/1/77 11/1/77 2/28/78 4/1/78 SI d 0-Pl 98/60/30 SAL 000109226 i disin Nx3 3<maab woad Mr. Thommie A. Gibbs, Chief Air Engineering Branch October 25, 1977 Page 3 Purchase orders (i) for the required equipment have been issued. Field construction (ii) was begun October 1, 1977, ahead of schedule. Construction completion (iii) and the achievement of compliance (iv) remain on schedule. VI. i 61.65 (b) (3) (i) - Rotating Pump Seals i) Purchase Order Issued ii) On Site Construction Started iii) On Site Installation Completed iv) Final Compliance Achieved Module No. 1 Completed Completed Completed 10/31/77 Module No. 2 5/31/77 10/31/77 11/30/77 1/1/78 Module No. 2 will not operate until all rotating pumps in vinyl chloride service contain double mechanical seals. We do not project to operate any equipment in Module No. 2 until about January 20, 1978. All rotating pumps in vinyl chloride service in Module No. 1 have been equipped with double mechanical seals with one exception. We expect all pumps to be in compliance on October 31, 1977. VII. $ 61.65 (iv) - Reciprocating Compressors i) Purchase Order Issued ii) On Site Construction Started iii) On Site Installation CompLeted iv) Final Compliance Achieved 9/1/77 U/l/77 3/1/78 S/1/78 The purchase orders (i) for materials to install double mechanical seals on the plant's reciprocating compressors have been ordered. Construction (ii) was initiated on October 1, 1977, ahead of schedule. The remaining dates for installation completion (iii) and achievement of compliance (iv) are on schedule. VIII. f 61.65 (b) (3) (v) - Agitator Seals Module No. I Module No. 2 i) Purchase Order Issued ' Complete 4/30/77 ii) On Site Construction Started Complete 5/31/77 iii) On Site Installation Completed Complete 10/31/77 iv)'* Final Compliance Achieved Complete 11/30/77 The agitators on the Module No. 1 reactors contain double mechanical seals and are in compliance. The four reactors in Module No. 2 will remain inoperable until new agitators, equipped with double mechanical seals, are installed. gpiL 000109 Mr. Thommie A. Gibbs, Chief Air Engineering Branch October 25, 1977 Page 4 /G IX. 61.-65 (b) (4) - Relief Valve Leakage i) Purchase Order Issued ii) On Site Construction Started iii) On Site Installation Completed iv) Final Compliance Achieved A 6/30/77 8/31/77 10/31/77 11/30/77 B 4/31/77 5/31/77 11/30/77 12/31/77 A Unloading Area Equipment and Module No. 1. Equipment B Module No. 2 Equipment and Reactors The equipment in Module No. 2 (8) will not operate until the required compliance items are installed. Purchase orders (i) and the start of construction (ii) for the items under A were completed as per the required dates. The remaining work for the items in A are on schedule. X. / 61.65 (b) (6) - Opening of Equipment i) Purchase Order Issued ii) On Site Construction Started iti) On Site Installation Completed iv) Final Compliance Achieved 5/31/77 8/31/77 11/30/77 2/1/78 Purchase orders (i) have been issued and on site construction (ii) has been initiated. The completion of construction (iii) and the achievement of final compliance (iv) remain on schedule to meet the dates specified. . f 61.65 (b) (7) - Samples i) Purchase Order Issued U) On Site Construction Started iii) On Site Installation Completed iv) Final Compliance Achieved Module No. 1 Module Complete TJTTTT Complete 5/1/77 4/30/77 12/1/77 S/31/77 1/1/78 The plant will not take any samples and will thus avoid emissions in Module No. 2 until the required sampling system is installed. The sampling systems in Module No. 1 are installed and operable. XII. ^ 61.65 (b) (9) - In Process Waste Water Stripping Module No. 1 i) Purchase Order Issued Complete ii) On Site Construction Started Complete iii) On Site Installation Completed Complete iv) Final Compliance Achieved 5/1/77 Module No. 2 4/1/77 S/1/77 12/1/77 2/1/78 SAL U>9Z L I `d ie:pl S8/B2/20 i tfisin Naaaaaay woad J - Mr. Thommie A. Gibbs, Chief Air Engineering Branch October 25, 1977 Page 5 The various process water streams will be collected and batch strii the required 10 npm level.____________________________________ r, uiscusse^i^aection . . lule Wo. I is installed and is in operation. The Module No. 2 equipment is now being installed. The plant will not operate Module No. 2 until the required compliance equipment is operable. XIII. $ 61.65 (b) - Vent Gas Emission Recovery System i) Purchase Order Issued 8/1/77 ii) On Site Construction Started 10/1/77 iii} On Site Installation Completed 1/1/78 iv) Final Compliance Ahieved 2/1/78 Purchase orders (i) have been issued and on site construction (ii) has been started. Completion of installation (iii) and the achievement of compliance (iv) remain on schedule. XIV. f 61.64 and 61.65 - Vent Cas Incineration i) Purchase Order Tssued ii) On Site Construction Started iii) On Site Installation Completed iv) Final Comliance Achieved 9/1/77 4/1/78 S/15/78 8/1/78 The purchase order (i) for the incinerator was issued on June 14, 1977, far ahead of schedule. The incinerator vendor, Trane Thermal, Inc., has not yet finalized the delivery date to the Plant. We remain hopeful of meeting the other dates of the incinerator schedule. This is, however, somewhat dependent upon the equipment delivery date from Trane. We have tried to expedite delivery from Trane but we can not completely control their eventual delivery date. We hope the ahove information clarifies our current status on our compliance plan. If there are any questions concerning this information or if further clarifications are needed, please contact me at A.C. 601-369-8111, ext. 239. Doug! Chief Process Engineer Aberdeen PVC Plant tap SAL 000109229 8 1 ' d 2:fl 8/62/20 i yisio n 3 3 a a 3 s b woaa