Document JN0Db7ZkbQaa4M1Xk5okVYaqX

Interoffice Communication To B. I. Raffle - Houston From M. G. Hayes - Westlake Date -September 22, 1981 Subject VCM EXPANSION - PSD received St? B 3 BHl The VCM Expansion has been delayed for an indeterminate period. The conversion of the oxy process, however, will proceed. The basic question is how PSD permitting which has occurred will be affected. Attached are permitting determinations by EPA and the State. 1. The non-applicab ility determination states construction must commence within 18 months of August 7, 1980. Does conversion of the oxy process constitute conmencement of construction for expansion purposes? 2. What constitutes breaks in construction should oxy conversion be considered commencement for PSD, purposes? What time frame should be considered? 3. If not, is there a mechanism by which the non-applicability determination may be extended? If so, for how long? 4. In light of questions 1-3, please address how VCM expansion emissions should be considered when addressing contemporaneous emissions for permitting other projects. In preparing a response, please address any other areas you feel pertinent. If you have questions, please let me know. v'EV-26655 VVC 000013325