Document QgJ55q7Gy1gpp4ROVbeQaOoJ4

r. W. FRASE CC: W. J. Henrick Re t Ashtabula County Gen Corp. - Diversitech General 02 04 01 0004 P001 Mr. H. Graff, Teohnioal Superintendent Gen Corp. - Diversitech General Polymers Division Middle Road, P.O. Box 61 Ashtabula, Ohio 44004 CMpQgMlpdBlFkMftf Dear Mr. Graffs During our meeting at your plant on October 12, 1904, we discussed the various aspects of Director Maynard's letter of September 24, 1984, to Roy L. Jackson of Diverslteeh General, We also discussed the various responses required by the letter which Diversiteeh General must submit to this offioo by Movember 12, 1904. Finally* we talked about the proposed sale of the plant and bow this eight affect our eventual issuance of a Permit to Operate for the PYC. polymerisation process. Our primary discussion concerned the Leak Detectlae and. BUnlnatlon (LOT) program. Tour peewioad swdsdttals have net been quite as oomprehaesive and detailed as we Quid like*' Bpseifioslly, you should resubmit your letter of by 29, 1944, aid lnelade the followingi (1) A more detailed plea of aetiea* Vho leek deteetiem response time list should be revised to sfcgv tint an Isms Hate attempt to fix all leaks will be made and that, failing Immediate repair, the eqnlpemst will be tagged aad the repair asda at the earliest possible time bat no left than the response time shown in year previous plan. (2) Your suhmdttay`abmid lnelude s revised Nn Z. This form inolude more detail as to the eewree er eagse of the leek aa well as the corrective action taken. (3) A casedtmeat to respond to a look, ss measured by the Bondix, on a 24-hour per day, 7 day per week basis. You should in dicate that the lab technician aad/or the foremen oa duty will make it their top priority tn respond to ell leaks and repair then as per your look detection response time list. You should include your suggested break-off point (ppm of leak and duration of search), Below this point, the search may bo put off until morning or other such time as personnel QENC 21952 Mr. H. Graff Gan Corp. - Diversitech General October 18, 1984 Page Two become available to continue it. Above this point, the OSHA Compliance Supervisor, Technical Superintendent, or other qualified personnel will be called in to continue the search. We will review your suggested break-off point and negotiate a change if necessary. (4) A new analysis of the leak definition done on the same basis as the original definition was set. It should be done using the previous full years monitoring data. If the analysis shows that the leak definition should be lowered, we can dis cuss this further at a later date. We will not raise the current leak definition. (5) A commitment to include in future semi-annual reports, a summary of the leaks which occurred during the previous six month period. This suxmary should include, by monitoring point 1.0., the following: a. number of leaks, b. maximum and average concentration during the leaks, c. most prevalent causes, d. the percentage repaired immediately, e. the percentage tagged for later repair, and f. the percentage where no cause could be determined. This summary is not necessarily meant to be a permanent addition to your semi-annual report. If your LDB program shows that continued progress is being made to reduce the quantity and magnitude of leaks, this requirement may be discontinued. (6) A commitment to have on hand at all tinea an adequate supply of spare parts and circuit boards to minimise the down tine of the Bendix units. The supply adequacy should be deter mined by a review of the maintenance and repair records of the equipment. Personnel trained to make these minor repairs should be at the plant or on-call at all times. If a major repair is required, so that one of the Bendix units has to be sent back to the factory, the Northeast District Office should be notified at the earliest opportunity. During my review of your monitoring and leak detection records, I concluded that your performance has improved. By reviewing your Form I's, and the Bendix printouts, I was able to follow the re sponse made to each leak and the time involved to reduce the levels to below the leak definition. Many of the leeks for which the source or cause could not be determined returned to acceptable levels in a relatively short (about 1 hour) period of time. GNC 21953 Mr. H. Graff Gan Corp. - Diversitech General October 18, 1984 Page Three You should also submit the Standard Operating Procedure required by 40 CFR Section 61.65 (c). I think that you now know what is required in this regard. Regarding the residual RCVM excursions, you should submit a more detailed explanation of the cause of the exceedance and what actions will be taken to minimise or eliminate future exceedances. You should do this for the three exceedances mentioned in the Director's letter as well as in future semi-annual reports. Iks ufttol 0-54 Peeked Tams fenpfeber meet be made operable batfeae the pleat asp be resrtssrtedU' A preventive maintenance program for both scrubbers should be instituted. The Agency has taken the position that the Permit to Operate cannot be renewed even if the deficiencies sited in the Directorrs letter and discussed above are satisfied, we need to be convinced that the new owners will operate the plant in full compliance with 40 CFR Subpart F, the applicable Ohio regulations, and the pro visions of this letter. At the very least, we will need to review the first semi-annual report submitted by the new owners and con duct a thorough inspection and records review prior to renewal of the Permit to Operate. We can say, however, that if all of these requirements ere met in full, the Permit to Operate will be renewed. I would like to thank you, Ron Frase, and d Klrkstead for your assistance and cooperation in this matter. I think that we have made significant progress toward satisfying the Agency that the plant car, be operated in full compliance with all of the applic able requirements. If you have any questions, please do not hesitate to contact me. Sincerely, Dennis A. Bush Unit Supervisor Division of Air Pollution Control DABtell cc: Bob Hodanbosi, DAPC, Central Office OSNC