Document O1o9aovDvd7GJ562j9kyDKrrj

Interoffice Communication To J. C. Ledvi na - Houston From J. A. DeBer nardi Date August 7, 1981 Subject Letter to ^PA on Fugitive Emissions NSPS Non-Applicability to LCVCM Expansion With reference to yoi r letter of July 27 on the subject, the items you asked be checked have been checked with the following results: 1) As we understand it, if the retro-fit part of the law is promulgated we have no choice ir complying or not. Therefore, the answer must be yes all VOC equipment must have double mechanical seals and vents. 2) Tests run on the incinerator vent by Kemron indicate the incinerator is 99.9% efficient i n destroying VOC's. The expansion will put additional load on the syste m, however our best engineering judgement is that the units will remair 99.9% efficient with the additional load. 3) The overall accur acy of the work done related to valve count is not exact No attempt was me.de to segregate liquid service from vapor service. We cannot defend all valves being in liquid service. It will be sometime before the new pi ant iso's will be available to get a more accurate count of valves c nd service. If this assurance is needed before the letter is submitlied, I would speculate we're looking at sometime in the second quarts r of 1982. 4) The number of compressors shown in Table I and II is correct. I have no significant comments on the letter. As we discussed by phone on August 6, the 1 ast s dntence in the first paragraph on page 2 needs revision, As I also mentioned ilhis entire matter and strategy needs to be discussed with R. D. Gamblin an d a determination made of where and if funds need to be budgeted in 1982 for retrofit of existing plant equipment. / J. A. DeBernardi Plant Manager br CC: RDG-BIR-PMY-GCB-JJH-(tLF VVC 000013337