Document MMK9LwXkknGRoqrNbVr8xRbgV

CAM3X: 1} |j. EXHIBIT WRG-331 iuU456 TO: w. R. WRIGHT PROM: F. W. EATON CC: R. E. Schneider OATS: SUBJECT: November 26, 1969 Trenton Air Pollution On November 18, 1969, I aec with members of the State of New Jersey Air Pollution Control Program to discuss corrective action taken at our Trenton plant, and the results of stack emission tests conducted on October 8, 9, and 10. Very briefly, this meeting was not necessary from their standpoint, and the items in question could have been handled in the normal fashion, that is, a letter in the legal sense, stating noncompliance. Rather than doing this, I re ceived a phone call requesting chat we get together and work things out. Items discussed and actions to be taken are as follows: 1. Because we cannot meet allowable emissions from Che perlite oper ation, namely the vent stack over the furnace and the produce fines stack, I stated we plan to, a) replace the top of the perlite furnace, and b) install a bag house for the bagging cower fines and vent system. They went along with this approach, and will extend our Temporary Certi ficates To Operate to April 30, 1970, as requested in ay letter to the State of New Jersey of October 23. 2. They will accept cur emission level from the Model A furnace, but I must submit an alteration to the Application To Construct permit be cause the emissions were higher chan those originally submitted on the application and approved on the permit. (3 Vs. 1.5 lbs. per hour) Re sults will have to be certified by a Registered Professional Engineer in the state of New Jersey. 3. In spice of ay reasons and argisaents that we are within allowable emission limits on the D-16, the State does not agree. The phrase chat was constantly presented to me was that our equipment was not the latest "state-of-the-art". In ocher words, there is other equipment available (scrubbers and bag houses) chat would do a much better job controlling emissions. I feel chat with my honest and sincere attitude on the subject, we were able to arrive at a satisfactory approach to be taken in deter mining and maintaining allowable emissions. It was agreed chat we would conduct additional stack tests on the D-16; and this time I would set the furnace for normal operating conditions; and that the tests would be con ducted by a Registered Professional Engineer in the state of New Jersey. They calked about installing sophisticated controls to insure that we .003274 10U4S7 TO: 0. S. UrifKc FROM: ?. V. Eaten SUBJECT: Trenton Air Pollution DATS: November 24, 1969 Page 2 naintained allowable emission, but would accept an audit control program that 1 proposed. This audit control is basically an inspection check list of all points that would contribute to particulate or smoke emission. The audit would be made twice each shift by the Plant Superintendent or Shift Leader, and made a permanent record of the plant files. Any ab normal conditions would be noted and corrected. If ve can reduce the emissions down to approximately 3-10 lbs. per hour, they will approve it as meeting Che Code, although it is not the latest "state-of-the-art". The enforcement people had rather caustic comments to make about the plant's condition before chinges were made, and about emissions recently observed in passing. 1 stated chat the emissions'chat they had seen were from the perlite stack and not from the vermiculite stack. Mr. Harold Christlff, Senior Industrial Hygienist, (Enforcement Section), was asked by the Supervisor of Enforcement and Supervisor of Permits and Cer tificates to make an inspection of the plant and observe emissions. It was stated that his inspection report will be the major factor in deter mining whether we are granted a Permanent Certificate .To Operate with present installed control equipment. Based on what has been done, what has Co be done, and commit ments made, I am very concerned about the present condition and the apparent attitude in Trenton. There has been a general improvement in the plant; but very frankly, maintenance and proper operation of the equipment is the poor est I have ever seen. I am not going to itemize the conditions observed during my visits; but if these conditions and procedures are not changed, you do not have a ghost of a chance of getting air pollution control approv al, and in another six to twelve months, the equipment will be no better chan it was one year ago. I reviewed my meeting with Jerry Eeott and Lloyd Marshall and out lined to them what I thought must be done. Since some of these items con cern the plant's operation, I would like to list them. 1. Until certain modifications are made to the after burner, all masonry fill must be run after daylight hours. Shop order 029-13000-250 will cover this work and it should be completed by January 15, 1970. 2. Until Permanent Certificates To Operate are issued, an audit or inspec tion of equipment must be made twice a shift by the Shift Leader. Whether this program, or modification of it, are continued after Permanent Certi ficates are issued is up to you. 2 PLAINTIFF'S i EXHIBIT j; - * V TO: W.R.Wright iWWfc F.W.Eaton SUBJECT: Trencon Air Pollution DATE: November 24, 1969 Pag* 3 1011458 > 3. Known maintenance or operational problems will be corrected as soon as possible; but in general they should not resain on the to do list longer than one week. 4. When unloading perlite, the dust collector should be used. Cer tain changes are required, such as closing off daspers to chose vents not being used, and covering the furnace feed hopper. Personnel should keep the cyclone waste hopper empty to prevent any discharge of this material to the ataosphere. 5. Shop order 030-13000-250 has been written to enclose the veraleullte ore bins and once approved, work can start immediately. Closing off the or* bins will greatly improve the general housekeeping of the plant. 6. Shop order 031-13000-250 is for replacing the top of the perlite fur nace and installing temperature and flame safety control equipment. Z can start work on this shop order as soon as final approval is made. In stalling the bag house on the perlite bagging tower will require an RCA; and I hop* to have the estimate complete in approximately two weeks. 7. There is a great need for improved housekeeping at and around all equipment. FWE:jrs F. W. EATON