Document aB6vpGwEMgYNQ8gMaDpBDyM2R

E M )RANDUMFEB2 1973 Mr. R. S. Christian DATE SUBJECT: 1 January 26, 1973 BRNW REVISED COMPLIANCE SCHEDULE Mr. C. R. Walbridge, Mr. E. E. James Mr. T. D. Kent*^7^ A Zp~* Attached for your review is BRNW revised compliance schedule covering the deficient areas as referred to in the State's letter of November 9, 1972^. 77. Please advise if you have any questions. r ^*7? , ^ ^ Jr RMT:ef Attach. ASI-PR 0004177 Industrial Chemicals Division ALLIED CHEMICAL CORPORATION P.O. Box 271. Baton Rouge. Louisiana 70821 <504) 356-3341 t Mr. John E. Trygg Technical Secretary Louisiana Air Control Commission P. 0. Box 60630 New Orleans, Louisiana 70160 Dear Mr. Trygg: The attached is a revised Compliance Schedule requested by the Consnission covering the deficient areas referred to in your letter of November 9, 1972. Very truly yours. P. B. Cornell, Manager Baton Rouge North Works FPT/RMT:ef ASI-PR 0004178 BATON ROUGE NORTH WORKS INDUSTRIAL CHEMICALS DIVISION ALLIED CHEMICAL CORPORATION REVISED AIR COMPLIANCE SCHEDULE I. GENERAL One of the principle products at this location is soda ash (sodium carbonate) a white powdery dust product. The production pf this product involves the following operations: calcining, conveying, grinding, screening, packing and loading. The effect from this operation creates a fugitive particulate (dust) problem and our compliance schedule for abatement puts heavy emphasis on dust collection systems. The Works testing program has been primarily for dust fallout within its battery limits. The reason for this measurement is due to the relatively large and dense particles which agglomerate in a humid atmosphere and falls as fugitive dust within the perimetry of the Works. Relative to ambient standards, it is believed that fugitive particulate (dust) falls out much nearer source than can be predicated by dispersion calculations. There is also a question on the value of dispersion calcu lations considering the multiple sources involved in an industrial complex. The dispersion calculations should incorporate valid point source data, accountability for all variables (meteorology)and computer programs applicable to the problem. The above technique and expertise was not available at this location so that no dispersion calculations were made. Dust fallout data over the last year indicates the soda ash fugitive dusts settle out and meet the state ambient in a distance of less than a quarter of a mile from the source and, in general, within the boundaries of our plant. Limestone dust settles at a much faster rate. Attached for reference to this revised compliance schedule is the schedule submitted on August 23, 1972. II. PilSSIQN STANDARDS Section 18.0 - Smoke Control 1) General burning of natural gas as fuel for power generation, calcining soda ash and cracking is in compliance. These operations use natural gas which seldom produce smoke. 2) Emission of smoke from vertical kilns during intermittent charging operations is in compliance. Charging of each kiln with limestone and coke seldom exceeds RangeImann 1. ASI-PR 0004179 -2- 3) Smoke generated in decoking of furnace tubes in the vinyl chloride monomer operation is not in compliance. a. The furnace tubes are heated and blown with air and steam twice per month for 18 hours each time. During the initial stage cf this operation Ringelmann 1 is exceeded for a period of._LS*20----^ minutes. After the initial period during intermittent (spa lling^v with air, the smoke does not exceed Ringelmann 1 for morS thafT^^ four minutes in sixty consecutive minutes. b. The decoking procedure is a shutdown and start'-up operation and on this basis we are asking the commission to approve compliance status under exemption 18.4 and/or 18.6.2 based on the limited amount of smoke being emitted in an unpopulated area of the plant. 4) Flaring of Ethane and Ethylene from brine well storage system near Plaquemine, Louisiana is in compliance. a. Pressure release venting for repair of lines, etc., does not cause smoke to exceed Ringelmann 1 more than an aggregate time of six hours in any ten consecutive days. The location for this operation is in an unpopulated area. 5) Smoke emission from Test Burning of Standby Fuel Oil for power generation is in compliance. a. The standby fuel oil facilities are tested periodically for readiness in event of a natural gas outage. The smoke emitted during the changeover from gas to oil will be controlled within the limit of four minutes in any sixty consecutive minutes. 6) Flaring of gases from the Dichloroethane (EDC) and vinyl chloride operation is in compliance. a. Smoke emission from flaring during this operation does not exceed Ringelmann 1 more than an aggregate time of six hours in any ten consecutive days. 7) Smoke emissions from Lead Melting Furnace is in compliance. a. The lead recovery process used for rebuilding diaphragm cells contains some organic matter which burns off in the lead melting furnace. The smoke generated during this operation will be controlled so that a Ringelmann 1 will not be exceeded for more than four minutes in sixty consecutive minutes. ASI-PR 0004180 Seotion 19.0 - Particulate Control -3- 1) Soda ash loading operations into ships and barges--fugitive dusts are believed to bo in complaince as indicated by fallout sampling over the past year. Light Ash Loading - Process weight 175 tons/hr. Emissions allowable 56 Ibs/hr. Dense Ash Loading - Process weight 250 tons/hr. Emissions allowable 60 lbs/hr. The loading operation is located in a remote area fan the east bank of the Mississippi River. The shipping area is dusty during the loading operation, however, the dust fallout is within ambient standards. Data shows 13.8 tons/square mile/30 days at the south property line station and 5.8 tons/square mile/30 days soda ash at the north property line station. Ambient state standard is 20 tons/square mile/30 days. 2) Salt drying, conveying and loading operations are in compliance. Process weight Emission allowed Stack tests on wetscrubber 25,000 lbs/hr. 22 lbs/hr. 3 lbs/hr. 3) Decoking of furnace tubes in the vinyl chloride monomer operation are in compliance. Process weight Dnission allowed Calculated emissions 20,000 lbs/hr. 19 lbs/hr. 6 lbs/hr. The furnace tubes are heated twice per month for 18 hours. During this time the tubes are blown with air and steam for one to two minutes every thirty minutes. Estimate 200 lbs. carbon is half burned and blown out during each 18 hour period. 4) Lime slakers producing milk of lime are in compliance. Process weight Particulate emissions allowed Estimated omissions 1,650 tons dry lime + 5500 tons water per day 62 lbs/hr. None visible (steam) 5) Vertical lime kilns during charging operations are believed to be in compliance. Process weight Particulate emissions allowed 2,640 tonslimestone and 210 tons coke per day 52 lbs/hr. ASI-PR 0004181 4- These emissions, mostly fugitive, are believed to be in compliance as estimated by visual observations and evaluation of fallout data taken over the last year. Data shows less than the 20 tons/square mile/30 days (state requirement) at the Work's battery limits. 6) Other sources of particulate fugitive dust and their respective compliance schedules were designated as Plans 1-4 and were submitted to the Air Control Commission on August 23, 1972(see attached). Following is a review of emission data in these plans. Plan 1 - Design and install new dust collecting system^ on lime kilns discharges and conveyors. Process weight Particulate emissions allowed Estimated emissions 1650 tons/day 47 lbs/hour 260 lbs/hour Expected emissions after installation of planned equipment - 30 lbs/hour Plan 2 - Purchase and install three improved bag dust collector systems to replace present ones in Nos. 1, 3 and 4 elevator towers in soda ash section. Process weight Particulate emissions allowed Estimated emissions' 6600 tons/day 61 lbs/hour 600 lbs/hour Expected emissions after installation of planned equipment - 45 lbs/hour Plan 3 - Purchase and replace four bag dust systems in dense ash operating systems. Process weight Particulate emission allowed Estimated emissions 1800 tons/day 48 lbs/hour 300 lbs/hour Expected emissions after installation of planned equipment - 30 lbs/hour Plan 4 - Design and install dust collecting systems on soda ash loadings into trucks and rail cars. Process weight (Light Ash) loading 35 tons/hour Particulate emissions allowed 42 lbs/hour Estimated emissions 175 lbs/hour Design criteria to be satisfied 30 lbs/hour ASI-PR 0004182 -5- Process' weight (Dense Ash) loading Particulate emissions allowed Estimated emissions Design criteria to be satisfied 70 tons/hour 47 lbs/hour 88 lbs/hour 3S lbs/hour Section 20.0 - Incinerator Standards Question 1 through 4 under incinerator compliance schedule guidelines are not applicable as refuse is used for land fill. Section 21.0 - Fuel Burning Equipment Standards This item is not applicable as natural gas is used for steam and power generation. Section 22.0 - Volatile Organic Compound Control A supplemental schedule will be submitted based on federal approval of state regulations, as per guideline instructions. Section 24.0 - Sulfur Dioxide Control Sulfur dioxide from combustion of natural gas at Baton Rouge North Works and ethane gas at our brine wells near Plaquemine, Louisiana are in compliance. Both natural gas and ethane contain less than 1 ppm sulfur. The resulting combustion products are within state standards at the property lines. Section 25.0 - Carbon Monoxide Control Carbon monoxide from vertical kiln operations. In compliance based on being an existing operation and classified as a priority III region. Section 26.0 - Nitric Acid Industry Standards Not applicable industry. III. AMBIENT AIR STANDARDS Section 9.0 - Suspended Particulate Level Control and Section 10. 0 - Dustfall Level Control In reference to both of the above sections, as previously indicated, our problem area is fugitive dust. These fugitive dusts, soda ash and limestone, are relatively large, heavy particulate which settle rapidly after becoming airborne. Except for areas adiacent to the SDecific -6 operation our dust fallout data indicates complaince. However, in areas where compliance is not met, our original submitted compliance schedule should result in a reduction of particulate to meet state ambient standards. Section 11.0 - Outdoor Burning Standards Section 12.0 - Sulfur Dioxide Level Control Section 13.0 - Carbon Monoxide Level Control Section 16.0 - Nitrogen Oxide Level Control These above parameters (Sections 11.0, 12.0, 13.0 and 16.0) are in compliance or are not applicable as reported in the emission standards section. Section 14.0 - Hydrocarbon Level Control Section 15.0 - Oxidant Level Control A supplemental schedule covering Sections 14.0 and 15.0 will be submitted based on Federal approval of state regulations, as per guideline instructions. IV. INCREMENTS OF PROGRESS Increments of progress are given in the attachment of the original compliance schedule submitted. Periodic progress reports will be made to the Technical Secretary on the status of BRNW compliance schedule at six month intervals. ASI-PR 0004184 AND REGULATIONS' 3603 Tiled the proposal li hereby adopted to read as set forth below. As these amend ments are Intended to relieve a re lation they shall become effective .unedlately. 1. AS amended 29 CFR 1910.111(a) (2) (1) and (b) (1) read as follows; fc lr 0 a P 1910.111 Storage and handling of an. hydrou* ammonia. (a) General (2) Definitions. As used In this sec tion: (1) "Appurtenances"--All devices such as pumps, compressors, safety relief de vices, liquid-level gaging devices, valves and pressure gages. UO4 at j3.ue. Va. 23336 and from other proceeding with respect to any 9 *ctor, Bureau of Sport right that accrued, liability that was In za & * 'life, U.S. Post omce curred, or violation that occurred prior fan. Mass. 02109. to said date. < ^.Griffith, (Sec*. 5 and 7, 37 Stat. 318; 7 U.S.C. 189, 180; VU)l T q'I Director, 37 FR 28464, 28477) - Zq'I Wildlife. Effective date. The termination of the avocado seed quarantine (7 CFR 319.12) 31'--fcOy Sf n>l V I I| As shall become effective on February 9, 1973. Done at Washington, D.C., this 2nd day of February 1973, Q. H. Wise, Acting Administrator. Animal and ^ Plant Health Inspection Service. Doc.73-2506 Filed 3-7-73:8:46 am] (b) Basic rules. * * (1) Approval of equipment and sys tems. Each appurtenance shall be ap Sf*11 '19--FOREIGN QUARANTINE i NOTICES proved In accordance with paragraph (b) (1) (1), (11), (111), or (iv) of this section. (I) It was Installed before February B, iiJsj g"wg3 a q Termination of Quarantine Sugfl quarantine contained 1973, and was approved, tested, and in stalled In accordance with either the pro f-sisj u g -jereby terminated on ,, ga pien first promul- visions of the American National Stand ard for the storage and Handling of Siwil S s Z, 9 a U Wrantine was de S " h o g led States from Anhydrous Ammonia, KS1.1, or the t fc sweetpotato Fertiliser Institute Standards for the g > Hive treat- Storage and Handling of Agriculture Anhydrous Ammonia, M-l, in effect a' the time of Installation; or s l-slii-""fsl^on (II) It Is accepted, or certified, o listed, or labeled, or otherwise determine SalSiflS; to be safe by a nationally recognize testing laboratory, such as, but not lim ited to. Underwriter's Laboratories Inc. FertUiaer Institute, 1018, 18th Street Nw., ---H- _ _ Mid Factory Mutual Research Corpora Washington. DC 20038. Inspector, who will make a aeciemu >-- in; or (III) It Is a type which no nationally recognized testing laboratory does, or will undertake to, accept, certify, list, label, or determine to be safe; and such (See. 6, Pub. L. 91-898, 84 Stat. 1893 (29 UM.O. 666)) Signed at Washington, D.C., this 2d day of February 1973. consulting with Regional Counsel, If an attempt is made to compel the production of matters, decline to produce the In formation or matter, and state It may be exempted and cannot be disclosed or equipment Is inspected or tested by any Federal. State, municipal, or other local Chain Robbins, Acting Assistant produced without specific) approval of the Regional Chief Inspector, who'will authority responsible for enforcing oc Secretary of Labor. make a decision after consulting with cupational safety provisions of a Federal, State, municipal or other local law, code, r regulation pertaining to the storage, handling, transport, and use of anhy Not*: incorporation by reference pro visions approved by the Director of the Federal Register on January 23,1973. Regional Counsel. The Postal Service will offer every possible assistance to the courts, but the questions of disclosing In formation for which an exemption may drous ammonia, and found to be In com [FR Doc.73-3800 Filed 3-7-73:8:48 am] be claimed Is a matter of discretion. mence with either the provisions of the American National Standard for the Storage and Handling of Anhydrous Am* nonla, K61.1, or the Fertilizer Institute Standards for the storage and Handling Title 32--National Defense CHAPTER XVI--SELECTIVE SERVICE SYSTEM (6 U.8.C. 863, 39 UA.O. 401) Room P. Crajo, Deputy General Counsel. [FR Doc.73-2478 Filed 2-7-73;8:48 am] af Agricultural Anhydrous Ammonia. PART 1641--DUTY OF REGISTRANTS W-l. in effect at the time of Installa tion; or Registrants Classification Procedures Title 40--Protection of Environment (iv) It Is a custom-designed and cus tom-built unit, which no nationally rec- Correction In FR Doc. 72-20793 appearing at page CHAPTER I--ENVIRONMENTAL PROTECTION AGENCY JBUzed testing laboratory, or Federal, 25714 In the Issue for Saturday, Decem PART 52--APPROVAL ANO PROMULGA State, municipal or local authority re- ber 2, 1972, In 11641.7 the sixth line, TION OF IMPLEMENTATION PLANS Woniible for the enforcement of a Fed- reading "the 26th anniversary of the date **1. State, municipal, or local law, code of his", should be transposed so as to be Miscellaneous Amendments ar regulation pertaining to the storage, come the third line of that section. On October 28.1972 (37 FR 23087), the wansportatlon and use of anhydrous Agency amended Its disapproval of the aounonla Is willing to undertake to ac*<Pt, certify, list, label or determine to Title 32A--National Defense, Appendix State of Louisiana's Implementation plan control strategy for photochemical *afe. and the employer has on file a uacument attesting to Its safe condition tallowing the conduct of appropriate *** TTte document shall be signed by * registered professional engineer or CHAPTER XI--OIL IMPORT APPEALS BOARD OIAB--RULES AND PROCEDURES . Correction oxidants (hydrocarbons) In the Southern Louisiana-Southeast Texas Air Quality Control Region and promulgated regu lations to deal with the remaining defi "*<r Person having special training or In FR Doc. 73-1630 appearing at page ciency In that control strategy. Specifi atperience sufficient to permit him to 2684 In the issue for Monday, January 29, cally, the Agency approved State of FIMRAt MOISTIt, VOL 31, NO. IS--THURSDAY, FIRRUARY t, <973 ASJ-PR 0004185 -oOO RULES AND REGULATIONS Louisiana Regulations 22 and A22 (Con trol of Volatile Organic Compound Emisr sions from New and Existing Sources), disapproved the control strategy as In complete in that it failed to provide for adequate`control of hydrocarbon emis sions, and prescribed emission limitation and compliance schedule regulations for waste gas disposal sources not covered by the approved State regulations, In order to supplement the State's control strat egyThe amendments to 40 CFR 52.973(b) set forth below are designed to clarify the meaning of certain terms used In the regulation, to correct the Agency's inad vertent failure to expressly exclude ethylene producers from the regulation, and to correct a cross reference. The Intended applicability of the regulation Is also clarified by the exemption of cer tain organic compounds which are known to have little or no photochemical re activity. This notice also Includes revisions to the regulation for review of new and modified sources promulgated for Louis iana on October 28, 1972. These revi sions allow the Administration to waive requirements for performance tests after the new or modified source commences operation. It Is recognized that compli ance with applicable emission limita tions can be determined in certain cir cumstances without the need for per formance testing. Also, the list of sources exempt from the new source review re quirements Is expanded to cover addi tional sources of minor pollutant contri bution. The- emissions from the additional sources exempted are similar In magnitude to those sources already exempt and are considered to have an Insignificant effect on air quality. Amendments are also set forth below changing the latest dates for attainment of the national ambient air quality stand ards for sulfur oxides and particulate matter In Texas. The Texas implementa tion plan, which contained conflicting statements concerning the intended at tainment dates, has subsequently been clarified by the State by supplemental Information submitted on November 10, 1972. Accordingly, the latest attainment date for the primary standards has been changed from December 1973 to July 1975, which is consistent with the Clean Air Act and with clarification provided by the State. The dates are underlined because a specific month was not pro vided and were therefore specified by ERA. The supplemental Information In dicated that secondary standards would be attained within "reasonable time"; however, no date was provided. The par ticulate matter and sulfur oxides control strategies for the secondary standards do not require the application of control technology beyond that which Is rea sonably available. Thus, the latest talnment date for secondary standards Is prescribed as July 1975, as required by 40 CFR 51.13(b)(1), The attainment date table for Texas Is also corrected to Indicate that the sul fur dioxide air quality levels in the five priority III Regions (Austin-Waco In trastate, Brownsville-Loredo Intrastate, Metropolitan Dalias-Fort Worth Intra state, Metropolitan San Antonio Intra state, and the Texas portion of the Shreveport-Texarkana-Tyler Intrastate Region) are "presently below secondary standards." The attainment dates for the sulfur dioxide ambient air quality stand ards for these Regions were erroneously listed as December 1973. Since the amendments have no signifi cant effect on the attainment or mainte nance of national standards and impose no additional regulatory burden, the Agency finds that good cause exists for not Issuing a notice of proposed rule mak ing, Inasmuch as it is unnecessary and for making the amendments effective February 8, 1973 without a deferred effective date. (43 Ufi.C, 18S7C-0) Dated: February 2, 1973. WlLlTAM D. RtJCKELSHAUS, Administrator, Environmental Protection Agency, Subpart T--Louisiana . In 5 52.973, paragraph (b) is revised as follows: 52.973 Control strategy and regula- ' lions: Photochemical oxidants (Hy drocarbons). m**** <b> Regulation for control of hydro carbon emissions, (1) The requirements of this para graph are applicable to waste gas dis posal sources, except those In ethylene producing plants, In the Louisiana por tion of the Southern Louisiana-Southeast Texas Interstate Region (5 81.53 of this chapter). (2) No owner or operator of a waste gas disposal source to which this para graph is applicable shall discharge or cause the discharge of organic com pounds into the atmosphere in excess of 15 lbs. <6.8 kg) per day (24 hours) from a waste gas disposal source unless the waste gases are incinerated, burned by a smokeless flare, or controlled by some other method approved by the Admin istrator. (3) For the purposes of this para graph: <1) "Organic compound" means any compound containing carbon and hydro carbon. (11) "Waste gas disposal source" Is any point of organic compound process muslons resulting from disposal of emer gency and waste gases from petroleum refineries and other hydrocarbon proc essing plants. (4) The requirements of paragraph (b) (2) of this section are not applicable to waste gas streams which contain only the following organic compounds, singly or in combination; C,-C, n-paraflas, saturated halogenated hydrocarbons, perchloroethylene, benzene, acetylene, acetone, cyclohexanone, ethyl acetate, diethylamlne, isobutyl acetate, isopropy: alcohol, methyl benzoate, 2-nltropropane, phenyl acetate, and triethylamlne In 5 52.976, paragraph (b)(8)(lv) I added and paragraph (b) (9) (111) Is re vised. As amended, ( 52.976 reads c follows: 52.976 Review of new sources *i modification*. # (b) * * (8) * * * (lv) The Administrator may waive t requirement for performance tests the owner or operator of a source ) demonstrated by other means to the t mlnistrator's satisfaction that the sou is being operated In compliance with State and Federal regulations which part of the applicable plan. (9) * * (ill) Fuel burning equipment, ot than smokehouse generators, which a heat input of not more than 250 mil B.t.u. per hour (62.5 billion gm-cal and bums only gaseous fuel cental not more than 0.5 grains ILS per standard cubic feet (5.7 grams standard cubic meters); has a heat 1 of not more than 1 million B.t.u. hour (250 million gm-cal/hr) and t only distillate oil; or has a heat lnp not more than 350,000 B.t.u. per (88,2 million gm-cal/hr) and burnt other fuel. Subpart SS--Texas In 5 52.2270, paragraph (c) (3) vised to read as follows: 8 52-1270 Identification of plan. (C) * (2) July 31 and November 10, 1 Section 52.2279 Is revised as folic S 52.2279 Attainment date* for m standards- The following table presents the dates by which the national sta. are to be attained. These dates the information presented in Tnm except where noted. r0MAl HOISTEt, VOL St, NO. 24--THUSSOAY, FIMUAtY , if71 ASI-PR 0004186 v, Ik. ^ if ' Industrial Chemicals Morristown, N. J. Hr. C. R. Walbrldge LOUISIANA AND ERA AIR COMPLIANCE FLANS Industrial Chemicals T CO- Baton Rouga North Works Dacambar 11, 1972 Attached for your Information arc the following: 1) ERA latter of request for caapliancs schedule of waste gas disposal systems for ethylene users. 2) Louisiana State Air Control Commission request for updating of BRNW compliance schedule where deficient, except for volatile organic portion. TDK GwC ; 4 i 3) Latest adoption of Revisions to Louisiana Implementation Plan received at Louisiana Air Control meeting on November 21, 1972. 4) Two copies of LCA news letters regarding the actions tak n by LCA on the waste gas disposal Issue. 5) Copy of LCA letter to EPA and newspaper report of recent Louisiana Air Control Meeting. The latest Information received (12/7/72) on the volatile organics issue is the probable revision by EPA towards the LQk's proposed plan with state support on the waste gas disposal clause for ethylene users. In view of the confusion between LCA, State Air Control Cooanlsalon and EPA on ths athylane users exemption, development of a compliance plan for organics la in question. Under the waste gas disposal clause developed by LCA with state approval, BRNW may be exempt and In compliance with the state plan which proposes that "any waste gas stream containing organic compounds from any ethylene producing plant or other ethylene emission source shall be burned at 1300F (704C) for 0.3 second or greater in a direct flame afterburner or an equally affective device. This section does not apply to emergency reliefs and vapor blowdown systems." The state has accepted the LCA'3 addition to the above for ethylene users which says "all waste streams from ethylene user plants which contain 5X by voluae or more ethylene and which will support their own combustion In air shall be disposed of by burning or other acceptable means. The Commission may waive ASI-PR 0004187 Mr. C. R. Walbridgs 2 Decmaber IX, 1972 this requirement when ths products of combustion will crssts a more serious sir pollution problem. This section does not apoly to emergency reliefs and vapor blowdown systems." However the PUU-ldtedUm ks la ant in. coanHence with the. EPS vmralon `jgjgjjg-* y tie hoursJ ram a waste gpe dispose 1 system unless the waste gas stream is incln- crated by a mnokeless flare or other device approved by the Administrator." The federal version requires that when a facility is in compliance a letter so stating compliance be sent to EPA by December 31, 1972. If tfrs facility is not, iq for compliance la required bv February 26. 107T. Hopefully, more concrete information will be forthcoming by December IS, 1972 from CPA which is reconsidering the LCA/State recommendation, however, during the "F'F'Trf TM rpA yr^l^ Which would require abatement of any emission containing organic*. This would htinHai capital Investment to reduce all oraanlo emissions to EPA requirements. Please advise if you have any questions. J'-'i'M.-`-t.L r. B, 'C>: **- -:iV RMT;ef P. B. Cornell, Manager Baton Rouge North Works cc: Mr. E. E. Jamaa Mr. T. D. Kent ASI-PR 0004188