Document YDr15vnqM6wVqX8G3zddny1oN

Vtrto Chamicol Compony J July 15, 1985 Thomas E. Souls Conoco Inc. Domestic Marine Division 630 Bagdad Road Westlake, LA 70699 RE: Exchange of Credits Proposal Dear Mr. Souls: We are in receipt of your offer to exchange emissions credits from the Concarb Bank for LC VCM hydrocarbon credits. Upon further review of your proposal we have the following comments. The first is the definition of contemporaneous emissions. The PSD regulations establish a five year limit on emissions changes for netting purposes. Under this scenario, it appears the Concarb reductions effectively expire in June 1986, and are of no useful purpose to Vista. One possible alternative for Conoco to explore is to get EPA approval for extension of the Concarb reductions for an extended period if traded. An additional five years for netting or offset purposes would considerably increase their attractiveness to Vista. Because of the bubble efforts which took place in 1982, the size of the VCM bank has been reduced. A recent review by EPA has also resulted in a deletion of a portion of the banked emissions. As such, this bank is reduced considerably and is of great value to Vista. Therefore, the factors for trade, are not acceptable as proposed. Based on the success of the recommendations in the paragraph above, Vista will repropose factors based upon your response to the above. One other alternative for trade is the Alcohol plant continuous reactor bank, which is recognized by the state but has not been clearly recognized by EPA. We may be able to trade using that bank provided DEQ approval of the trade and the usage. Use of some factors would be more palatable if Conoco xs willing to explore this possibility. Sincerely, Thomas G. Grumbles, C.I.H. Environmental Quality Manager ajo/007 cc WLM, (JCl) MGH, RTF, JAD, RAC, RDG S<t*L 00006493i