Document VR6gw69d8M3gdgz4XQm6pZgq

* n mi Vista Chemical Company j 4 15990 N. Barker's Landing Rd. Post Office Box 19029 Houstonjexas 77224 Phone (713) 531*3200 Off /&K --> 4 August 8, 1984 Meredith Scheck The Vinyl Institute 355 Lexington Avenue New York, NY 10017 VIS1A SUBJECT: PROPOSED VCM STANDARD COMMENTS Dear Ms. Scheck: I've marked up the draft comments you sent out recently. I have additional comments in two areas. Under the definition of "in vinyl chloride service", we are concerned that equipment such as PVC reactors which are often "in VCM service" will be considered "in VCM service" even when they do not contain over 10% VCM. Vinyl Institute's comments do not consider situations where it is normal for equipment to be in and out of VCM service several times a day. All I can suggest is that we modify our comments to factor in the current condition of the equipment at the time of monitoring. Even considering the Vinyl Institute's suggested wording changes, a reactor undergoing a hydrostatic test that has a relief valve lift will be considered as having a RVD from equipment "in vinyl chloride service". This is ridiculous. My second comment concerns Section 61.64(f) -- Reactors used as strippers. The current standard allows averaging all batches of the same resin type produced during a calendar day. As currently written, 61.64(f)(1) and (2) do not allow averaging. Averaging is very important. I suggest language be added to both clauses to "...(1) The emissions of vinyl chloride is not to exceed 2.12 g/kg. (0.00202 lb/lb) weighted average for each calendar day ..." "...(2) The emissions of vinyl chloride ... is not to exceed 0.42 g/kg (0.00042 lb/lb) weighted average for each calendar VAB.0001113903 r IS Meredith Sheck Page 2 August 8, 1984 Comments are just coming in from our plants so we may have more to add later. Since we have some concerns that may be unique to Vista, we plan to comment at NAPCTAC on August 30. Sincerely, C* ^aosephr C. Ledvina, Director Environmental Activities ajo cc W. C. Holbrook - BFG Ron Bryan Mike Hayes Velden Messick Paul Warner A VAB.0001113904