Document ExGaqOr4DQzn8vxQKjnMk8ZBb

Interoffice Communication To From Oate Subject Distribution Garrell Botto ns November 12 1981 Construction Permits - VCM Expansion i; W-' iiV The decision to stage the construction of the VCM Plant Expansion (ie, proceed with convers on of oxychlorination, delaying the remainder of the work for an indetermihate time period) requires that we assess our situation regarding permits issu d by the Louisiana Enviornmental Control Commission (LECC) and the Envi>rnrhental Protection Agency (EPA). Jim Hall, Joe Ledvina, Brad Raffle i nd Garrell Bottoms met on November 11 to develop the following status report and action plan. SUMMARY 1) Our LECC Pe rmit requires reduction of emissions from the oxy vent by May 31, 1983. We currently are scheduled to meet that commitment, subject to problems created by the current operating mode of the diant. 2) The EPA ruled that PSD review was not required for the project as originally submitted. There are specific requirements for construction timing which apparently we can meet, even with a three year delay in project completion. However, there is a possibility that the EPA cou Id rule that we have not complied with the intent as originally pro posed. To counter this risk, a program to develop our position and present our case to both the LECC and EPA has been initiated. If the Agenci 2S were to rule unfavorably, we would have to undergo PSD review fb r the expansion phase of the project. This could likely create a requ renrtent for additional fuel handling facilities. 3) To meet the equirements of the proposed New Source Performance Standard (NS I^S) for fugitive emissions of volatile organic compounds (VOC), we w ill proceed to modify the existing plant to offset increased fug .tive emissions from the oxy conversion. The cost for this work will be included in the oxy revamp project. It is proposed that a letter, setting forth our program and calculation methods, be f awarded to the EPA for their review and approval. vve 000013306 DISCUSSION LECC PERMIT A significant requirem nt of our agreement with the state is that we reduce hydrocarbon emissions from the oxy vent. We must be in compliance no later than May 31, 1983. Ou r current schedule forecasts completion of the project in April 1983. This scfjedule is based, however, on plant shutdowns slated for May 1982 and Februkry 1983. If the current operating mode requires significant departures from the norm, our planned approach to construction could be changed dram atically. We will continue to react to this situation as it occurs, with the inte nt to minimize cost impact while insuring we meet our commitment to the May 31, 1983 date. Joe Ledvina stated tha t if the plant was in a shutdown mode on that date for completion of the oxy conversion, this would fulfill our requirement. In this case our emissions wou Id be nil during the shutdown. On startup, we would be operating at our agreed upon emission rates. EPA PERMITS EPA determined that < PSD permit was not required for the expansion project as originally submitted on April 11, 1980. It is to our advantage to insure that this non-applicability cjecision is not affected by the delay to portions of the project. If the EPA de termined that our approach no longer met the original intent, we could be required to undergo PSD review for the expansion phase, A likely result would require we change from 1% to 0.7% sulfur fuel oil, necessitating the additi on of an appropriate handling system. The exemption from PS D review was contingent on the following: 1) Construction rlnust be commenced by February 7, 1982. This requirement has been satisfied. New foundation work, etc, was completed during the August 1981 plant shutdown 2) Construction must not be discontinued for a period of 18 months or more. As staled our current schedule calls for construction compiet on of the oxy revamp in April 1983. An 18 month hiatus v 'ould place construction start (major foundations in place) ir October 1984. If the expansion is delayed two years (process engineering completion in 1982, mechanical engineerng start January 1983) the October 1984 date will create no problem, however; if the project is delayed three years sp scial efforts must be made to achieve a construction start by that date. 3) Construction rpust be completed within a reasonable time. Brad Ra:fle stated there was no legal definition of this term. The interpretation is essentially in the hands of the Agency. VVC 000013307 On the surface it appe ars that we can prudently meet the above requirements, thereby maintaining o jr permit to build the plant without undergoing PSD review. However, Raff le stated that the EPA could take a position that (1) we had not started constr uction of the entire project, only a conversion of one segment of the plant, and (2) that our original argument that PSD review, if required, would signifilcantly delay the project no longer applies. To counter these possible objectio ns and maintain our relationship with the State and Federal agencies, the following program was agreed upon: 1) Meet with VC M plant personnel on November 23 to develop specific strategies anc arguments for presentation to LECC and the EPA. 2) Set meeting dates with both Agencies in the near future. It is proposed that plant personnel lead in these meetings, and that our current progrim be explained and justified. We feel this approach minimizes the risk of obtaining an unfavorable ruling on our desire to proceed vith the phased project under the current permit status. NSPS REGULATIONS -OR VOC FUGITIVE EMISSIONS This regulation, propo:.ed in January 1981, requires that the VCM plant be in compliance with the regulation upon promulgation. Our oxy conversion triggers the necessity to offset any fugitive emission increase by like fugitive emission decrease or :o initiate an extensive monitoring program. Since the law is not yet promu gated it is subject to delay, revision or cancellation, However, Joe Ledvina is confident that the regulation will be finalized and that it will probably c cjntinue to require any plant modified after January 1981 to be in compliance, There is a possibility that the Clean Air Act will be revised such that NS PS are only applicable upon promulgation, not when proposed. There again there is no assurance this will be the case. Plant personnel have calculated that we can offset the increased fugitive emissions from oxy < inversion by installation of rupture disks under relief valves discharging to atmosphere. A program to identify the exact valves and modification requirem mts is underway. The estimated cost for this work will be included in the defirh itive estimate. To insure the EPA agrees with our approach, especially the emission factors we are using in our calculations, it is proposed that Joe Ledvina prepare a letter to the EPA for DeBernardi's signature. This would spell out in detail our program and calculation methods, and request their agreement that we will be in compliance with the proposed regulation. This should be done shortly after we meet with the EPA on the PSD question. Garrell C. Bottoms Distribution: J.J. Hall J.C. Ledvina J.A. DeBernardi Ci.L. Foshee M.G. Hayes H.J. Neeld R. D. Gamblin D. 5. Huber G. J. Fryar B.I. Raffle oooo^303