Document DvQBg7eMqLXN4bjZY2GX33pgO

Dear Mr. Jewett: 1j y Thank you for your replies, dated January 7, 1977, and January 14, 1977; to our letter dated December 23, 1976, requesting information on hexachlorobenzene (HCB) at your plant in Ashtabula. On the basis of the additional facts you have supplied, we agree that the probability of any HC3 production at your facility is as you have stated virtually nil. Our inquiry to your firm resulted from an incorrect listing in the Directory of Chemical Producers, published by Stanford Research Institute. This reference included your Ashtabula plant among the manufacturers of toluene diIsocyanate which has a chlorinated hydrocarbon intermediate. You are hereby re Iieyed of any further obligation to respond to our Inquiry d3ted December 23, 1976, provided that the statements in your letters referred to above are true to the best of your knowledge. We regret any inconvenience caused by the misinformation with regard to your manufacturing processes. Should any additional information on this subject come to your attention, or should you have any specific questions, please contact Glenn Pratt or Jon Barney of my staff at the above address or by calling 312/353-2098. Very truly yours. James 0. McOonald, Director Enforcement Division cc: Ned Williams, Director Ohlo EPA, w/copy of responses Steve Gunsel, Ohio EPA, w/copy of responses ~n.,7 GENC 004300 R. Jackson G. Brumbaughy E. Senra H. Jewett January 21, 1977 Steam Purge on Reactor The Info you requested: 1) Vac 24" or less initially. 2) Vac falls off when steam injected to 24-16". 3) Steam pressure 20-40# is used. 4) 5 min. purge is used and vac re-established to 24" (About). 5) Residual MVC 200-1000 on experiments. These are general conditions and probably will need optimised for our reactors. H. E. Jewett HEJ/U& GENC 004301 January lU, 1977 / JU.E. Snvlronaant&l Protection Agency Snforcwaent DiYisiqnJ, Kegion V P30-0ogtB~~Dearbc>TpSt~?eet----------- Chicago, Illinois 6o6o4 Attention; Hr. Jon Barney Dear Sir: This nano la to conflm our phone conversations of January 12 andlfc, 1977 concerning HCB. General Tire doee not produce TDI (Toluene DUeocyanate) at Aahtehnla. The TDI facility la owned by Olin Corporation, and they solely --go the operation. We do supply then steaa and other alsor services. In rlew of the problen with certifled/reglstored nail dellrerlea, General Tire will send two --Hinge to each Individual, one regular all and one certified. We tract thla aeeta your approval* If you need any further infcxnatlou we will he glad to aaalat your office. Very truly yours, thi gshial im a mans combot HXJtsm Harlan X. Jewett Plant Hunger GENC 004302 January 7, 1977 U. 5... Environmental Protection Agency Enforcement Division, Region V 230 South Dearborn Street Chicago, Illinois 60604 Attention: Itr. David Kea, Acting Director Dear Sir: General Tire is in receipt of your letter stamped December 23, 1976, requesting information and data on 1'83 Qiexachlorobenzene). Your letter states "according to our information, the chloro-alkali or chlorinated hydrocarbons manufacturing processes employed at your facility at the above address have the potential for producing !:.C3 as a byproduct." General Tire would like to advise your office that this facility is not a chlor-alkali or chlorinated hydrocarbon manufacturing process. The General Tire plant ceased production of chlorinated hydrocarbon in 1967, at which time a process was used to produce vinyl chloride from hydrogen chloride and acetylene. This process, however, was not a chlorination process, and I!CB was not a byproduct of this process. The acetylene used was carbide acetylene and not hydrocarbon acetylene, so there were no aromatic heavy ends in the acetylene. Since 1967, the Ashtabula plant has received vinyl chloride monomer in tank cars, and the heavy ends past trichloroethylene are less than 1 ppm in the monomer. 95" of the monomer is polymerised each cycle, and the recovered monomer is recovered and returned to the process, so that the possibility of KCE in our effluent is nil. Based upon the above facts that this location is not a chloro--alkali or chlorinated hydrocarbon producing location, and that the existence of hC3 in our process is not possible. General Tire requests to be exempted from complying with your request under Section 303, 33 U.S.C. 1313 and Section 114. Tor your information, a complete description of the processes at this plant was furnished to the F..P.A. Standards and Engineering group in Durham, Ilorth Carolina in 1974, under authority of Section 114. GENC 004303 2- Cencral Tire would also like to infon your office that if this request is denied, we cannot conply with the 20-dav period on testing for MCE, and request a waiver to allow 60 days for testing and reporting- The undersigned certifies that, to the best of his knowledge and belief, the Ashtabula plant of General Tire has never used Kexachlorobenzene in its processes. Sincerely, THE GENERAL TIRE & RUBBER COMPANY Harlan E. Jewett riant Manager KZj/ikb GENC 004304 OvJ CD no CD RECEIPT FOR CERTIFIED MAIL--30c (plus postage) sent ro S--TREET pan..ud nnqv,. ?& v/ ----------- a' /3 s r'/V o.,p state and zip code JLti.".-- _ d- OPTIONAL SERVICES FOR ADDITIONAL ?Hs RETUflN RECEIPT SERVICES i. "Shows to whom inddiit* delivered-"' UWZi.tfki me__tjri.cj:to.d delivery 2. Shows to whom, tfoto ond whero OolirtfKI With restricted delivery ... fiESTSICTEOOELlvEPY SPE.i-L GEilYcST (extra foe required) ijT fv PS Form Aug. 1975 3800 HO INSURANCE COVERAGE PROVIDED-- NOT FOR INTERNATIONAL MAIL fSoe other >id*) CPC IW5--0-JJI-4K '*> V+- t 4 L 6ENC 00430