Document 91NzwGj9rervnwKrKVYmoeQKp

inter-office memo TENNECO CHEMICALS, INC. To D, C. Coldiron from j# p. Sandstedt Subject EPA COMPLIANCE - WAIVERS ESR-1013 at Piscataway at Piscataway Date January 12, 1977 copy to W. W. F. R, P. F. G. P. J. P. Anderson F. Gabel Kanzler Lojewski Reed X. Ritter I. Rozand R. Scarito (2) X. Sweeney (2) Mr. Marcus Kantz of EPA called me on January 10 with an update on his review of our wiaver requests. In general, these were received very favorably, and we can expect approval as requested in most cases. Several areas were questioned, particularly. Reactor Opening (Burlington homopolymer) and Suspension Stripping (Burlington and Flemington). These are the areas in which we requested procedural equivalencies. Mr, Kantz indicated that while he recognizes that our procedures are effective, he will require additional data. We reviewed what might be needed as "proof positive." His response was unsatisfactory -- that the data should be "satisfactory to Tenneco." I will review current operations and available data with Manufacturing, and arrange for the necessary test programs to be implemented, A 3-4 month waiver period will be approved to gather the requested data, EPA has some questions on our analytical methods which must be answered before equivalencies will be approved. These will be resolved with Q.C. Finally, Mr. Kantz will probably be unable to review our Leak Detection Programs. A temporary waiver will be issued for such time that he requires to digest our submission, along with those of other PVC manufacturers. I shall keep you advised of further events. JPS:db r J.. P, Sandstedt COLOR!TE 018075 / : > 'zzl'iM " crv t Z/A /.y.y, ^y.j.yii- m u-**.'- ___ ./jL.y'p - ,1 , 0 v 'J__ - y* *v * __ v- y/au^.yl. c9 J 7 *}a+ k jguAjxjj/ssL. rfatzgt- ,.v a *3 T <^ITS /_________ y' ^ W ^ V~ O ^3/ -g Vtrfffi w t)? ,i/uf Jb%+kbb____________________________ ________________________________________Chpaafy ~ a&m&t&Q */L ---------------------- _----- ---------- ------------------ ttu/Xl`J^'uJt,U.C_________ __________ ; HJJ11 . y/ ^*>t ^ _____________ Z,o6Jj> toUt 9fjJtu>f UnJUxtlL__ w _____ /J rail uu fjaJuh* COLORITE 018076 L_______ u-jsL ` :a \ yt&JA. ^'1*4 . ~72< ^lq*4A ^j/eUxx^' **u.,u,A'b ~^L iJSL. \S<33x. 'fcs.cf L.< m COLORXTE 018077 pPPf/V/A/G 7Z>a/______ 5^/^ /3p?z,p?ASp: /t/pr^/S^f? <L . <t2/lfiJ9<?-/ ry _________ ______ _______ ___________ / /3o/<L JTS? ________________ ____________________________ ^ ^ _ . . .. ___ .. . _ _____ -3-fT, i3Q3 ______ -^-5} ^oo */mp ____________________ ____________ ~n=>-r;?j-_______ <^>oJ <oc&c> P&9X___ ^/?7y Cjd?'?d`} ______3S^_ &&a (** jpJP<Zi/j/? `/~7Sj'ts /X /s*= ^)s?yy? <5> C?Ct COLORXTE 018078 rr (C&cr-d-syv ___ _______ }Josi/V*z. /'/< <5V^ _. --3_________ 25c3, g> /g /?a'tfo-TXDJ _<5^/_/v^. 23j&j/ygL______ *poz-'^/< (x.S~` T2>^s} J-/r/X//W J ""__ ------ ___________________________ _ -^?* 3 ________ 3~m//a^/S'^e. 3 735/ P&sT/S. (a) -- -?* 3 75______ CO________ "_____ 3_ } /4Q1)'4 /^L &**/9 c2 3 5" /V^ o 3 . ///^ - _ 3^ __ &2/? Pcr,P /J&771X? Joa=U)_ fto/v/M/lt GaP/zc;, r-y {xx&oo yz>sJS^) _/_?_,, s?** ft?&&<-!!/*.# 3b/g g'P/?- C>m Q /*%* /37*//!&S- COLORXTE 018079 VESSEL OPENING PROCEDURE - FLEMINGTON 1. Water fill technique for recovery area. Water to be drained to Water Stripper prior to start-up. Compressors Condensers K. 0. Pots Vapor Containment Tank 2. Other vessels to be steamed for recovery. Subsequent water fill for safety purposes, if desired. This water fill can be drained to sewer. Charge Weigh Tank Master Mix Tanks (2) Recovered Monomer Tanks (3) Recovered VCM Day Tank Pure VCM Tank Strippers (2) 3. Bullets to utilize water fill technique. Recover off empty bullet via Unloading Compressor. Fill with well water while continuing recovery. Gradually run off water through new Water Stripper. (Maximum of 7 days) COLORITE 018080 T*d Trimbur Vou con build q plant for less in Georgia Get the details in this latest study of neiu plants Cost Data on Industrial Buildings in Georgia is the most complete study of construction costs in the state. The new fifteenth edition contains information on 26 recently con structed plants and warehouses, including a photograph of each building, specifications and de tailed cost breakdowns. Executives concerned with locating new plants will find it an interesting and useful reference. Write for your copy. No cost or obligation. EXAMPLE: This fine warehouse of 152,000 sq.ft was built for $5.77 per sq. ft., including rail siding and SI! grading and paving. J.W. TALLEY, JR., Vice President INDUSTRIAL DEVELOPMENT DEPARTMENT Georgia Power P.0 Box 4545W, Atlanta, Georgia 30302 58 L BUSINESS WEEK: January 17, 1977 POLl LJT10N CONTROL Vinyl chloride's great dilemma On Jan. 19, the day that the Environ mental Protection Agency's new air emission standards for vinyl chloride monomer (vcm) go into effect, the 74 U. S. plants that either make or use vcm will be in a classic "damned-if-you-do, damned-if-you-don't" situation. Those plants that have neither installed control equipment nor received a waiver from the EPA will face citation. And those that have taken steps to comply face a real danger that a pending law suit, in which environmentalists are asking the epa to review its new standard, may ultimately make their expenditures obsolete. The dilemma has created an uneasy alliance between the industry and the epa. "The standards already call for a 90% reduction in emissions, and we just want the epa to stand by this original action," says John R. Lawrence, tech nical director of the Society of the Plas tics Industry Inc., which has filed a motion to intervene in the suit on the agency's side. And although the epa has Should industry comply with air-quality standards that may change? asked the court not to grant full inter vention status to the industry group, it welcomes the Spi's limited involvement. "We got incredible cooperation from the industry, and now this llth-hour suit is muddying things up," says Ronald S. Naveen, an EPA staff attorney. Standing firmly against both groups is the Environmental Defense Fund, the controversial suit's sponsor. The Wash ington-based organization wants the EPA to take a closer look at fresh data emerging from Cesar Maltoni's ongoing experiments, which expose rats to vinyl chloride (BW--Apr. 21, 1975). The EDF also wants the government to differen tiate in its standards between new sources and old plants. "We want them to continuously review their standard and force new technology for future plants," explains Jacqueline M. Warren, staff attorney for the EDF, Compliance is blocked. The specter of the edf's suit has left the industry unsure of what standard to design for. "We are not canceling any equipment on order, but the suit certainly inhibits us in our plan ning," says Jackson B. Browning, cor porate director for health, safety, and Producing vinyl chloride: The EPA's standards are still being challenged. environmental affairs at Union Carbide Corp. "We are continuing to install and design vcm control equipment, but if the EDF petition is approved our ability to comply will depend on the new stan dards," echoes a spokesmen for B. F. Goodrich Co. Both the government and the SPI agree that the current standards would cost the industry about $200 million for control equipment, plus $70 million a year in operating costs. And EPA officials readily accept the industry's reluctance to spend that kind of money when the final requirements remain up in the air. "If the standards were tightened appre ciably, I question whether these facilities could continue operating," notes Roger Strelow, the EPA's assistant adminis trator for air and waste management He sees little merit in the environmen talists' suit. "If there were a good argu ment to be made along edf's lines, I'm sure our own scientists would have been banging on my door," he claims. Still, Strelow feels it is in the best interests of industry to comply with the standard and hope for the best. "A court would feel much freer to tighten up the standard if industry had not started to meet it," he notes. The SPi's Lawrence feels that the industry is taking a big chance. Most control technologies involve some form of incineration, activated carbon adsorp tion, or solvent absorption, he explains, and a concrete standard would let a plant decide which route to follow. "What if a plant orders a $2 million incinerator that will bring vcm emis sions from vents down below 10 parts per million, which the current standard calls for?" he asks. "If the standard goes down to 5 ppm, are they supposed to just scrap the incinerator?" POLLUTION CONTROL COLOR!TE 018081 /o _____ tt&srebr JEfA V/ &Me# a* GBfep or tsmrc gec&vco MAm. &? fiiKM Yt, mOCSW* ***,?*< ,,V****7/<M 7Tt*c*T T0 *ft*/*at sraafjsr. '/%ja*C#A *7#tS tencg.__ (O/U Jf*v *J &COA4*ttoJitAS/ v or co**tr eor*Pt*AAfar rr*ro* av/vk ^59. ____ rP'* COLORXTE 018082