Document ZJknBjwmy9VJxGydqa5XVnY6O

NTLR.Offlcr MEMO I L n l. C1 L, u u t IVJ 1 U M L 5 , IU U. APR 2 $ 1377 to W, P. Anderson at Saddle Brook F MOM J. P. Sandstedt At Piscataway Subject VCM Monitoring Required by Standard d*u April 27, 1977 copy to D. C. G. P. J. C. Coldiron Crain I. Rozand R. Scarito T. Sweeney Paragraph 61.68(a) of the VCM Standard requires, "A vinyl chloride monitoring system to be used to monitor on a continuous basis the emissions from the sources for which limits are prescribed in 61.62(a), (b) - pertaining to ethylenedichloride plants 61.63(a) - pertaining to vinyl chloride plants 61.64(a)l - reactor exhaust 61.64(b) - stripper exhaust 61.64(c) - vent streams from mixing, weighing and holding containers 61.64(d) - monomer recovery system and for any control system to which reactor emission(s) are required to be ducted in 61.65(b)l(ii) - loading/unloading lines 61.65(b)2 - slip gauges 61.65(b)5 - manual venting of gases 61.65(b)6 (ii) - equipment opening 61.65(b)9 (ii) - vinyl chloride removed from in-process wastewater" Under Section 61.70 Semi-Annual Report, and particularly Paragraph 61.70(c)(1), the six month report is to include ". . .a record of any emissions which averaged over any hour period (commencing) on the hour are in excess of the emission limits prescribed . , . (The paragraphs listed above.}" In view of my recent discussions with Leon Lazarus concerning the wastewater stripper ("in-process wastewaters"), it is interesting to note that the Standard does not include a VCM check on the stripped waters. In my view, this omission means we don't have to monitor this stream at all. Perhaps we should get a legal opinion? COLORITE 018687 W. P. Anderson 2- ~ April 27, 1977 Please be advised that when this subject was raised at the SPI Technical Committee Meeting, it was agreed that industry would go for "one sample per day." This is the position I took with Leon on April 26. The above opinion could change this position. m 'djudxhdh Sandstedt JPS/db COLOR!TE 018688