Document JMqx6b0yyo7Gg6RrpN1qbMaB

$761,107 40CFiai <7-1-07 EdlH- I 781.1*7 Heporttf importer* and by per- mw fenermtimtt PCBa in excluded manufacturing prmcesse*. 761.193 Maintenance of men records by persons who import, faeture. process, distribute in In addition to meeting the basic re quirements of | 761,1(1) and the defini mere*, or use chemicals containing advertently generated PCBa. tion of excluded manufacturing proc (a) Persons who import, manuf- ess at 1701.3. PCB-generating manu ture, process, distribute in commr facturing procease* or importers ot or use chemicals containing r PCB-contalning products shall be con present as a result of Inadvertent sidered "excluded manufacturing proc esses" only when the following condi tions are met: (a) Data are reported to the EPA by the owner/operator or Importer con cerning the total quantity of PCBs in product from excluded manufacturing processes leaving any manufacturing site in any calendar year when such quantity exceeds 0.0025 percent of that site's rated capacity for such manufacturing processes as of October 1. 1904; or tne total quantity of PCBs Imported In any calendar year when such quantity exceeds 0.0025 percent of the average total quantity of such product containing PCBs imported by such Importer during the years 1978, eratlon or recycling who perform actual monitoring of PCB concen tlons must maintain records of such monitoring for a period of thryears alter a process ceases operatic or importing ceases, or for seven yean whichever Is shorter. (b) Monitoring records maintable pursuant to paragraph (a) of this tlon must contain: < U The method of analysis. (2) The results of the analysis. lr eluding data from the Quality Assui ance Plan. (3) Description of the sample matrb (4) The name of the analyst or am lysts. <5) The date and time of the anal? sis. 1979. 1960. 1901 and 1982. (6) Numbers for the lots from whlc] (b) Data are reported to the epa by the samples are taken. the owner/operator concerning the total quantity of Inadvertently gener ated PCBs released to the air from ex cluded manufacturing processes at any manufacturing site In any calendar year when such quantity exceeds 10 pounds. (Approved by the Office of Managemen and Budget under control number 2070 0008) (Sec. 0. Pub. U 94-409. 90 Stat. 2020 (li U.S.C. 2005) [49 FR 28193, July 10, 1984J (c) Data are reported to the EPA by the owner/operator concerning the total quantity of Inadvertently gener PART 702--FULIY HALOGENATED CHLOROFIUOROALKANES ated PCBs released to water from ex cluded manufacturing processes from any manufacturing site in any calen dar year when such quantity exceeds 10 pjun'is. Sec. 702.1 762.3 Subpart A--General frtvitlMi Scope. Definitions. rd/ Ti.tse report must be submitted io the U.S. Environmental Protection Subpnri B--[Kiarvtj` Agency. Document Processing Center. Swbpert C--frhlbHIn>, Exemption*, and P.O. Box 2070. Rockville, Maryland Certification acquirement* 20052. Attention: FCB Notification. 762.45 Manufacturing. (Sec. 0. Pub. L. 94-400. 90 Stat. 2020 <10 U.S.C. 2005) (Approved by the Office of Management and Budget under control number 2070- 762.50 Processing. 762.55 Distribution In commerce. 762.58 Sssentlal use exemptions. 763.59 Special exemptions. 0008) [49 FR 28192. July 10. 1904] Subpart 0--Record* and Report* 762.60 General reporting requirements. 246 VVV 0026773 To: From: inrarpmct Communication Date: Subject: Distribution P. Quinlan u f" January 19, 1990 Meeting Minutes--VCM By-products Project Team ACTION STEPS 1. Determine whether the Super Critical Water Oxidation process is applicable to chlorinated hydrocarbons.--WLS 2. Summarize cost, advantages, and disadvantages of the following processes for handling chlorinated hydrocarbon streams.-VEM a. ____ c. ____ W UOP Process BASF Process BFG Catoxid Process Incineration and HC1 recovery 3. Determine what methods are used by the other U.S. VCM producers.--PQ 4. Investigate the possibility of joint venturing a project to handle chlorinated hydrocarbons.-PQ 5. Define/investigate potential outlets for VCM Plant muriatic acid.-DRB All action steps are to be completed by the next team meeting on February 13. MEETING SUMMARY The mission for this team is to determine the best means, on a long-term basis, for handling the VCM Plant by-product streams (Light Ends, Heavy Ends, and Muriatic Acid). Currently, the Light Ends stream is sold to Vulcan, the Heavy Ends stream is shipped to PPG, and the Muriatic Acid stream is being neutralized (although customers for this stream are being pursued). Due to the effects of the Montreal Protocol and other concerns about chlorinated hydrocarbons, the long-term viability of Vista's current outlets is suspect. VCMBYP VVV 0026774 Distribution 2 January 19, 1990 The group developed the following brainstormed list of alternatives: 1. Install the UOP process. 2. Install the BFG Catoxid process. 3. Install the BASF process. 4. Employ an incineration and HC1 recovery process. 5. Commercially incinerate all by-products. 6. Establish alternate customers. 7. Eliminate production of these by-products. 8. Develop a joint venture project with another producer. 9. Employ the Super Critical Water Oxidation Process. 10. Work with some research entity to develop new technology. The following list of criteria was then developed to evaluate these alternatives: 1. If the alternative chosen requires technology not currently indigenous to Vista, then it must be proven technology. 2. There must be flexibility/reliability associated with the alternative chosen. 3. The alternative chosen should result in Vista becoming essentially self- sufficient in handling these by-products. 4. The alternative chosen must be practical. 5. The alternative chosen must be implementable within a 3-to 5-year period. Utilizing these criteria, alternatives 5, 6, 7, and 10 were eliminated from further consideration. The rest of the alternatives will be further investigated and summarized by the next team meeting. NEXT MEETING The next meeting of the team will be held on February 13. P. Quinlan Distribution: VEM-Houston RAC SAR GB DRB PJK JGC PLF WPB-LCVCM WLS--Austin cc: RJA JRB RDG RHG TGG JAH THH BEAL JCL WLM GDS-Houston MGH-LCCP JTF-Austin VCMBYP VVV 000026775 TO: Distribution ^ <<? ^ uA Interoffice Communication FROM: DATE: SUBJ: J. C. Ledvina January 31, 1990 F024, F025, AND NESHAP WATER STRIPPING VISTA We plan to meet at the VCM plant on Friday, February 16 from 10:00 is an agenda for the meeting. NESHAP Wastewater A. Regulation and background B. LCVCM current situation C. Other companies position D. LCVCM action plan II F024 , I/v is fA ",'V '- 11-12 a.m. A. Background B. VI meeting C. LCVCM position D. Future actions III. F025 12-1 p.m. A. Background B. Discussion of wastes covered by the rule C . Future actions ^'Ll~ MT' Ledvina -t*-- dlj .509 Distribution: W. L. McClain R. A. Conrad, D.R. Booth, P. L. Fetzer, P. Kober, S A. Rey-LCVCM *V\, OQ0 /.