Document a4BoZmGE7997GNpXGRqmKRreN

ver.i Plant Conoco Chomiculs Continental Oi! Company P.O. [>c* 60S Westlake. Louisiana 70669 (313) 491-621 1 September 16, 1977 Mr. Howard G. Bergmaifi Director, Enforcemen : Di vision Environmental Protect ior Agency, Region VI First International Bull ding 1201 Elm Street Dallas, IX 75270 Dear Mr. Bergman: A waiver of compliance f cm ^OCFR Part 61, Subpart F, was granted our EDC/VCM Plant located in Westlake, Louisiana on July 5, 1977. One of the requirements stated n your letter of July 5 was that CONOCO will report the information outli ned in Section 61.70 cn a semiannual basis, beginning September 15, 1977. As 1r. G. L. Foshee, Chief Process Engineer - CONOCO VCM Plant, discussed with Mr. Gary Bernath of your office on July 13, 1977; we have no vent souro es which 'were not included in the waiver of compliance. Therefore, it is our interpretation that the information requirements listed in Section 61 70 do not apply until the waiver period is over; and the initial complianc e test has been conducted. As reported in our 1 dtte r of August 1, 1977, we have ordered the major equipment items for he Thermal Incineration System, the Oxy Vent Heater, H-312, and the Ruptur e Discs for Relief Valves in VC Service. We have also obtained a permi t from the State of Louisiana for the Thermal Incineration System and hope to start construction before the January 1, 1978 date required by our waivdr. However, we are not g oind to be able to meet the equipment ordering date for the spare Wastewa ter Steam Stripper. We have been experiencing feed problems with the exi sting stripper, and had to modify the process design for the new system to alleviate this problem. These changes delayed the issue of the process design, and the mechanical design will not be at the point that equipment can be ordered on October 1, 1977. We estimate that equipment can be orde red by December 15, 1977. We continue to believe that the remaining dates o n the schedule for this item will be met. That is, with the December 15 equipment order; we project that on site construction will still commence by April 1, 1978 and be completed by August 1, 1978. Therefore, we request that the equipment ordering requirement be changed to December 15, 1977. VVC 000013064 Mr. Howard 6. Bergman Page 2 September 16, 1977 Please let us know if you have any objections to our interpretation of the semiannual report rec uirements or the change in equipment ordering date for the Steam St er.ipp Sincerely, Qrft&L2. J. A. DeBernardi Plant Manager y- is CC: J. F. Coerver, LACC BCC: REL-CRH-OEC-DAK-GLF-u RH- PLF-JD r- VVC 000013065