Document aBmZywezJNDNGqYoqzxZ28mQy

INTERNAL CORRESPONDENCE A^2-7 .MINING AMD METALS DIVISION ro'Hwi u. G, Beverly Mining & Metals Grand Junction c'J. F. Emerson Johnson V. C. Tburber Dr. J. S. Vhitaker Received P. 0 BOX K. KING CITY. CALIFORNIA 93930 JUL 5 ;cr doi. June 14, 1973 OriyMetioy Depf. :fi AsvweWn? Ut1*r Jot* ***"' Attached find a copy of the waiver request, and accompanying cover letter, which was submitted to the EPA on 6-14-73 regarding operation of the main circuit dryer at the King City Asbestos Mill. The mine operation was inspected 6-14-73 by Mr. Ed Davies of the California Division of Industrial Safety. Be informed the mine foreman, B. 0. Hopper, that be closed down the Atlas Chemical Asbestos Plant an June 12 due to dust pollution and safety hazards. F, H. Larrison, Jr.// /clg PLAINTIFFS [| EXHIBIT a UC-1591 4 *iASBESTOS THE DISCOVERY COMPANY UNION CARBIDE CORPORATION MINING & METALS DIVISION P.0. BOX K KING CITY. CAUF. 93930 TEL: 408-285-5961 June 14, 1973 Mr. S. L. Zwicker Enforcement Division-Region IX 100 California Street San Francisco, California 94111 Dear Mr. Zwicker: This is a waiver request for one emission source at Union Carbide's King City, California Asbestos Plant as provided for in Section 6l.lO, of the Federal Register dated April 6, 1973* This was discussed with you by phone by Mr. R. G. Beverly, Director of Environmental Control, on June 7, 1973 In October, 1973 we initiated projects to install two bag collectors on two product drier discharges. These projects are essentially complete and we expected to be in complete compliance with the National'Emission Standards for Asbestos prior to the compliance date of July 5, 1973* For this reason we did not file a waiver request earlier. One of the bag collectors was installed and put in operation early in June. Tests of the second collector show that the manufacturer's fan curves were in error and that a larger fan is required. This waiver request is for a period until December Jl, 1973 in order to purchase and install a larger fan and the required accompanying electrical distribution equipment. During this period we expect to be in compliance with the emission standard a large portion of the time in that there will be no visible emission. While producing certain products slight emissions are visible. Ambient air samples and observations indicate no significant offproperty discharge will occur. Completed Waiver Request Form 0MB No. I58-ROO98 is enclosed along with a chart showing the project schedule and significant dates pertaining to the completion of the project. If there are any questions concerning this waiver request, please call me at 408-385-5961. Floy a H. Larrison, JrW Manager King City Operation /clg enc: This paper contains "Calidria" asbestos T-135, an efficient, low-cost opacifier. It is 60-lb. Fairmount offset produced by Tileston & Hollingsworth Co., a subsidiary of Diamond International Corporation1. II. WAIVER REQUESTS FORM APPROVED QMS NO. 1S8-R009S epa use only A. WAIVER OF COMPLIANCE. Owners or operators of sources unable to operate in compliance with the National Emission Standards fot Hazardous Air Pollutants by July 5, 1973 may request a waiver of compliance from the Administrator of the U.S. Environmental Protection Agency for the time period necessary to install appropriate control devices or make modifications to achieve compliance. The Administrator may grant a waiver of compliance with the standard for a period not exceedi ng two years from the effective date of the hazardous pollutant standards, if he finds that such period is neces-r sary for the installation of controls and that steps will be taken during the period of the waiver to assure that the health of persons will be protected from imminent endangerment. The reporting information provided in Section I must accompany this application. Applications should be sent to the appropriate EPA regional office. 1. Processes Involved - Indicate the process or processes emitting hazardous pollutants to which emission controls are to be applied. Asbestos Product-Kiln type-Rotary Dryer 2. Controls a. Describe the proposed type of control device to be added or modification to be made to the process to reduce the emissions of hazardous pollutants to an acceptable level.{ Use addi tional sheets if necessary.) Mdl. 500-12 ICA Clean Dust Collector with single hopper-480 tubes and pulse clean cleaning system. Manufacturer-Industrial Clean Air Inc. o. Describe the measures that will be taken during the waiver period to assure that the health of persons will be protected from imminent endangerment. (Use additional sheets if necessary). Dryer off-gas currently meets emission standard for particulate matter as required by Monterey-Santa Cruz County Unified Air Pollution Control District. 3. Increments of Progress - Specify the dates by which the following incre ments of progress will be met. . Date by which contracts for emission control systems or process modi fications will be awarded; or date by which orders will be issued for the purchase of the component parts to accomplish emission control or process modification. mu mu luu 01 Date of initiation of non-site construction or installation of emis sion control equipment or process change. mu Ulil LUll MONTH DAY 02 . Date by which on-site construction or installation of emission control equipment 'or'process modification is to be completed. mU lilAl I7j3j month day yea* 03 Date by which final compliance is to be achieved. ) 1|2 I 1313-1 17 151 04 SIGNATURE OF OWNER[ OR OPERATOR - t/'-O-i PACE 3 OF 4 PAGES