Document 8VXV6g1pB2BEBepYaj8R68jLe

Lakft Charles VCM Plant September 22, 1980 ,,a.*K . A > H i: I Conoco Chemicals Company A Division of Conoco Inc P.0 Box 605 Westlake. Louisiana 70669 (318)491-5211 Mr. S. L. Bergh, Chemical Engineer Enviro Control, Inc. One Central Plaza 11300 Rockville Pike Rockville, MD 20852 Dear Mr. Bergh: The following is in response to your letter of September 8, 1980 related to information on 1,1-Dichloroethane for the Interagency Testing Committee. 1. I am unable to supply you with information related to total U. S. production of 1,1 DCE. The material is produced as a by product in our process for the production of 1,2 DCE (Ethylene Dichloride). 2. I am unable to forecast production trends of 1,1 DCE. For those industries producing it as a by-product, the normal trend is to reduce by-product production by process revisions. 3. 1,2 DCE (Ethylene Dichloride) is used in our process to produce Vinyl Chloride Monomer. 4. Our process is a continuous type with all vents controlled to meet existing EPA, State, and local air and water pollution standards. Control methods include thermal incineration and catalytic reaction. The by-product, 1,1 DCE leaves our plant contained in a light-ends stream which is sold to a CarbonTetrachloride processing plant for use as a raw material in that process. I do not have knowledge as to what wastes are produced or handling methods used in the Carbon-Tetrachloride processing facility. 5. I am unable to supply factual information related to environmental affects, biodegradability, or chemical reactions expected if 1,1 DCE is released to the environment. 6. In our process the by-product stream containing 1,1 DCE also contains Ethylene Dichloride, Ethyl Chloride, and Carbon Tetra chloride. 7. No health affect studies related to 1,1 DCE have been conducted by Conoco Chemicals Company. CCR 0000799M Mr. S. L. Bergh Page 2 September 22, 1980 We do not have technical bulletins or safety data sheets for 1,1 DCE. However, information on this material can be found in Industrial Hygiene and Toxicology, Volume II, Frank A. Patty, Editor, Page 1279-1280. Addi tional information is also available in Dangerous Properties of Industrial Materials, Fifth Edition, N. Irving Sax, Page 666-667. Sincerely J. A. DeBernardi CC: RDG-JJH CCR 0000799^2 ENVIRO CONTROL, INC. September 8, 1980 One Central Plaza 11300 Rockville Pike flockvilie, Maryland 20852 Telephone: 301-468-2500 Mr. Jim DeBernardi Conoco, Inc. Box 605 West Lake, LA 70669 Re: Information on 1,1-Dichloroethane (chemical abstract service registration number 75-34-3) for the Interagency Testing Committee (ITC), Dear Mr. DeBernardi: During our conversation on September 8, 1980, I indicated that the ITC was interested in the following information on 1,1-dichloroethane: %Us * 1. Total U.S. production of the chemical by all IS*.*/#*y. -y- i* 7 companies - this would include any produced as a byproduct. 3 2. Forecast production trends - if the annual production is 100,000 lbs. or less, the ITC is not interested in additional information unless the trend shows that production will exceed that figure in the near future. %s-/*4jr- 3. Key uses, by % - since you produce the che mical as a byproduct what are the uses of the main product? 4. Estimated release to environment at the plant site. Ifpossible indicate if process is batch orJencTosedj when and where chemical is released and how any wastes associated with gfA+Z**' Jr\ the chemical are processed. 5. If released would the chemical accumulate in the environment at the plant site? Is it %tr biodegradable? What reactions might the che mical undergo if released to the environment? Cc* oooo Letter to Mr. J. DeBernardi Conoco, Inc. September 8, 1980 Page 2 of 2 isXm- 6. Are any other substances present with the chemical^r'^^y'>)pfi^ which might be more harmful than the chemical itself? 7. Health effects - any work your company may have'4"T" CLuJ* done on this chemical would be helpful. f I would also like any available technical bulletins and ^ material safety data sheets on 1,1-dichloroethane that you have. The above information is to be submitted to the ITC by September 26, 1980. It is being compiled under contract No. 68-01-5789 with the ITC. As I mentioned the ITC functions under the authority of the Toxic Substances Con trol Act (TSCA). If you have any questions please call me at (301) 468-2500. Sincerely, ENVIR0 CONTROL, INC. Steven L. Bergh Chemical Engineer SLB/al CCR 000079945 Lake Charles VCM Plant CERTIFIED MAIL #315671 RETURN RECEIPT REQUESTED Conoco Chemicals Company A Division of Conoco Inc. P.O. Bo* 605 Westlake. Louisiana 70669 (318) 491-521 1 September 19, 1980 Mr. E, J. Struzeski and Mr. A. E. Franzen Environmental Protection Agency National Enforcement Investigations Center Denver Federal Center Box 25227, Building 53 Denver, Colorado 80225 Dear Mr. Struzeski and Mr. Franzen, Conoco Chemicals Company's VCM Plant in Westlake, Louisiana is submitting as requested the attached information pertaining to the EPA inspection of this facility in the fall of 1980. In best interests of both parties please give notice to the VCM Plantes turnaround, which is scheduled for the month of October, when scheduling your inspection of the plant for the fall of 1980. The plant will be shutdown for scheduled maintenance during the turnaround and will not be operating until late October. Items marked "CONFIDENTIAL" are to be treated as such pursuant to regulations appearing at 40 C.F.R, Part-2, subpart 8 (41 Fed. Reg. 369.08, September 1, 1976}.. Please direct any further questions concerning this inspection to Gary Foshee, Chief Process Engineer, who can be reached at (318) 491-5062. Sincerely yours, cc: Letter only - Diana Dutton, Director - EPA Dale Givens, Louisiana Department of Natural Resources bcc; Letter only - REL, CRH, HON, RLH, PLF, DLD, JWW, CWT Letter and manual - GLF, JCL, VAM CC 000079,46