Document GDRNBQLpkywev3ZXLOykwDEq

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 Mr. K. S. Komoroski P. P. Industries Post Office Box 1000 Lake Charles, LA 70602 Dear Mr. Komoroski: This letter is to confirm our November 29th telephone conversation that a meeting has been scheduled for December 11th at 8:30 A.M. in Durham between representatives of the U.S. Environmental Protection Agency (EPA), Radian Corporation, and your company. As we discussed, the purpose of the meeting is to gather information that will improve our understanding of the need for adding a control device bypass provi sion to the vinyl chloride (VC) emission standard. A second purpose is to identify additional data required for any further Investigation of an appropriate bypass provision. Specifically, we are seeking information from your company about the following: 1. The general design and operating parameters of the control device(s) used at your EDC/VCM facilities to control exhaust gases sub ject to the VC standard. For incinerator controls, general design and operating parameters of interest include operating temperature range, design capacity, maximun capacity and turndown capabilities. Also of interest Is the usual state of the backup control device (cold, warm, or hot) and the time required to switch to the backup device. 2. The types of process upsets (or other conditions) that could lead to the bypass of incinerator systems and how such conditions might be avoided. 3. The types of incinerator malfunction that could lead to the bypass of the incinerator system and how such malfunctions might be avoided. 4. The method used to estimate the amount of VC in the bypassed exhaust gas streams. 5. Any method used to monitor the VC content of the incinerator discharge or bypass. SL 105054 2 6. For EX/VC facilities, the portion of exhaust gas that comes from the EX/VC purification vents and the oxjchlorination reactor vent and the Impact of the oxychlorinatlon vent fluctuation on control device bypass frequency and duration. 7. A brief description (reason and amount) of any VC emissions caused by plant start-up or shutdown. 8. An "Incineration Bypass History" similar to that presented at our October 30, 1984 meeting but with reasons for bypasses (if possible). If >ou have any questions about these discussion items, please call me at (919) 541-5671. We appreciate your continued cooperation in our review of the VC standard and look forward to meeting with you. Leslie B. Evans Chemicals Manufacturing Section Chemicals and Petroleum Branch SL 105055