Document KRBpOJoo4rEX78L5EkLXJKOQo

ft.-* ~1 Conoco Chemicals Company Division of Conoco Inc. P.O. Box 91. New Highway 25 Aberdeen. MS 39730 v. I October 20, 1980 Ms. Rebecca Hanmer Regional Administrator Reg i on IV . United States Environmental Proteci 345 Courtland Street, N.E. Atlanta, GA 30308 ooo 7 Dear Ms. Hanmer: Conoco Chemicals Company, a divisi polyvinyl chloride plant located i operates pursuent to the National Emission Standards for Hazaroous mi Pollutants, 40 CFR, Part 61, Subpart F, National Emission Standard for vinyl chloride. In accordance with Section 61.05 of Subpart A of the Standard, the plant is submitting an application for approval of con struction of a spare inert vent gas incinerator system. Presently, to meet the emission requirements of 61.64 (a)(2), (b), (c), (d), and 61.65 (b)(i)(ii), (b)(5), (b)(6)(ii), (b)(9)(ii), the vents are collected, contained, and incinerated prior to their release to the atmosphere. The plant also has a contingency plan to collect and contain this vent stream in empty VCM storage tanks if the incinerator experiences operating problems. These storage tanks have sufficient volume to allow the plant to continue to operate for several days without the incinerator in service and to still meet the venting requirements of the Standard. The plant could continue to operate uiytij^ the storage tanks become pressurized and at that time would have to shut down until the inciner ator was back in service. The plant desires to install the spare incinerator system so it could be put in service if problems develop with the existing incinerator thus precluding a plant shutdown. The spare inert vent incinerator system will be the same type as the existing unit and will be capable of reducing the vent stream to less than 10 ppm VCM. Plans are to operate only one incinerator at a time, either the existing unit or the proposed spare unit, but not both at the same time. Therefore, the installation of the spare incinerator will not increase the VCM emissions from the plant. DTH 000114288