Document G65pYxpye5xr3Z5nkOkLo1n4x

AL. .ED CHEMICAL CORPORATIC MEMORANDUM March 21, 1975 W. F.R. MAS 2 11975 TO: A. J. von Frank SUBJECT: Industrial Waste Control Review Baton Rouge North Works At-site review of air and water pollution control was conducted by the Division, plant, and Corporate Environ mental Services on March 19, 1975. The present plant program is satisfactory and is receiving strong support with progress appearing. Specific to the liquid waste area, although the plant has experienced 16 violations covering pH, chlorinated hydrocarbons, total suspended solids and ammonia, effluent per formance compared to the past is much improved. Lead discharges, which formerly were running about 150 ppd, averaged 13.7 ppd for the months of January and February. Chromium loadings are also being met. A program developed for the adjudicatory settlement conference (a technical meeting prior to the pre-hearing con ference) was reviewed and is satisfactory. In addition to settling the issues cited in the adjudicatory request, the meet ing scheduled for April 3 will be used to change the interim loadings to reduce violation frequency. The air program is proceeding with engineering support. A meeting has been scheduled to discuss the missed compliance milestones with the technical staff of the Louisiana Air Control Commission on April 10. The purpose will be to obtain State sup port on submission of the revised compliance program to the EPA. It is expected that an EPA enforcement order will be issued to insure that the revised compliance dates will be met. An attempt is being made to eliminate two emission sources associated with the soda ash process from the compliance program. The success of this step is open to serious question. It is probable that if the soda ash plant is to run until 1977, compliance will be re quired. Stack testing of ECD-VCM area vents is being initiated with particular emphasis on emissions from the heads condenser, lights condenser, and the oxychlor vents. These discharges are carrying in excess of 5,000 ppd of vinyl chloride. The EPA is ASI 00005953 2 -A. J. von Fran_ March 21, 1975 proposing that emissions be limited to no more than 10 ppm VCM. This will have a significant effect on the amount of capital re quired to control area emissions. The increase in capital re quirements has not been defined as yet. /jsp cc: J. M. DeVoe A. J. Levine G. Kanelis P. Cornell W. Reichenbach^ W. M. Reiter ASI 00005954