Document 93Vjj2xXr99wMkg6Q0654YE4L

*> BFGoodrich The BFGoodrich Company Geon Vinyl Division 6100 Oak Tree Boulevard Cleveland, Ohio 44131 216-447-6000 December 11, 1986 Ms. Kelly Meloy Texas Water Commission Hazardous and Solid Waste Division Permit Section Post Office Eox 13087 Capital Station Austin, Texas 78711 Dear Ms. Meloy: Because State and Federal solid and hazardous waste regulations have changed somewhat in the last two years, BFGoodrich would like Texas Water Commission (TWC) review of our Catoxid process operations to assure that we continue to operate in full conformance with all currently applicable solid and hazardous waste regulations. You will recall that we reviewed our operations with you and other TWC personnel in 1984 and concluded that the then State and Federal solid and hazardous waste regulations were not applicable. Our operations today are as represented to you in 1984 except that we have not used EMPAC for feedstock supply. Our Catoxid process (see attached process schematic) is a BFGoodrich patented process which utilizes chlorinated hydrocarbon containing materials (feedstock) as an ingredient to make a new product (ethylene dichloride/vinyl chloride) without distinct components of the feedstock being recovered as an end product. Use of chlorinated hydrocarbon containing materials in this manner serves as a direct substitute for commercial chlorine. Every molecule of chlorine contained in the hydrocarbon containing feedstock displaces the purchase of a molecule of commercial chlorine. Notwithstanding, purchase of commercial chlorine is still necessary to satisfy the total chlorine feedstock requirements for our ethylene dichloride/vinyl chloride production. In addition to the chlorinated hydrocarbon feedstock produced in the BFGoodrich ethylene dichoride/vinyl chloride production processes, we utilize chlorinated hydrocarbon feedstock from non-BFGoodrich manufacturing operations (see attached feedstock specification). The chlorinated hydrocarbon containing materials used as feedstock ace not classified as solid or hazardous waste in accordance with 40 CFR Part 261.2 and 261.3 even though such feedstock may have previously been managed as solid or hazardous waste. The chlorinated hydrocarbon containing materials used as Catoxid feedstock are not solid wastes as CWN 000001357 2- - defined in 40 CFR Part 261.2 in that they are not discarded materials (abandoned, recycled or considered inherently waste-like) and are not being disposed o, used in a manner constituting disposal, burned, incinerated, reclaimed or accummulated speculatively, used to produce products that are applied to the land, used to produce a fuel or contained in fuels. Such feedstock materials are not required to be managed (including manifesting) as solid or hazardous wastes. Our Catoxid process is totally enclosed and environmentally sound. Records of chlorinated hydrocarbon feedstock receipt and usage are kept as well as are records of overall Catoxid process operations. The feedstock materials are handled in a manner (pipes, pumps, enclosed above grade diked tanks, concrete pads, etc.) which guard against loss. Wastewaters and vent gasses ace processed in TDWR, TACB and USEPA permitted facilities. Mr. David Hinson and I appreciate the time afforded us in your office on December 10th to review our Catoxid process operations. We would appreciate a letter from TWC confirming your position that our Catoxid operations do not constitute solid or hazardous waste storage, treatment or disposal and that Catoxid feedstock materials are not required by regulations to be manifested. Should you desire additional information, please contact me at 216/447-7925. Sincerely THE BFGOODRICH COMPANY Geon Vinyl Division WCH/dea 0041 j Attachments cc: V. Goode/J. Schonaects D. Hinson bcc S. Guidry/C. Orsborn J. Lewis/J. Fannin W. C. Holbrook Director, Safety, Health and Environment CUIH 000001358 o <u0 o hc o a Condenser *XOr2* (U0 OS o O aOj* QW > o as u Oo QO &3 <9 0 OS 0 cc s <z> -C jj O- Uo *XO-> 4fVlJj *9 0 U OS o a 9 OX J3 a 19 W 0 a0h O UO wO <<9D r4 *D V g^*- CO CO a u o os CL Q X o - U CUH 000001359 WCH/dea 8 9 l7 q CATOXID FEEDSTOCK SPECIFICATION A) Physical Properties 1) Should be a pumpable liquid at typical Houston temperatures. A maximum viscosity oC 5 cps is desired. 2) Heat Content - Should have sufficient heat of combustion to sustain a reactor temperature of 1000F. Approximately 4,300 BTU/lb is required. 3) Phase Composition - Should be homogenous liquid phase but can contain dissolved or finely divided suspended particles. No free water phase. 4) Acidity must be neutral or basic to prevent corrosion in carbon steel tanks and piping. B) Chemical Properties 1) Stability - Should be chemically stable at ambient conditions to prevent exothermic reactions and/or polymer formation. 2) The minimum H/Cl atom ratio required is 1.2, but the preferred ratio is greater than 1.4. 3) Elemental Composition - In general, any organic compound containing c, H, Cl, o, and N is acceptable (6ee following specification): Aromatic Content Olefinic Content Aliphatic Content less than 1% less than 10% greater than 89%; prefer chlorinated C2's, alcohols, ketones No dioxins or furans PCB' s less than 25 ppm Metals Sodium Copper Iron Molybdenum Chromium Potassium Sulfur Bromine Flourine Nickel less than 10 ppm less than 100 ppm less than 500 ppm total less than 100 ppm total less than 100 ppm total less than 100 ppm total less than 100 ppm total less than 100 ppm total less than 100 ppm total less than 100 ppm 0041j/dea CUH 000001360