Document bO574XopyGaJgNd3LZ1nokXxo

Hooker Chemical PLASTICS DIVISION Firestone Blvd P.O. Bo* 699 Potlstown. PA 19464 215 / 326-2000 July 15, 1981 Mr. T. Moore Tenneco Chemicals, Inc. P. 0. Box 849 Pasadena, Texas 77501 Dear Tom: Other than the specific questionnaires which accompanied your letter of June 1 and which will be submitted separately, we have other suggestions for the agenda for Hilton Head: A. VCM Standard 1. We suggest a poll on Emergency Discharges. a. Number of plants reporting all Energency Relief Valve Discharges regardless of pounds of VCM emitted. b. Number of plants not reporting minor discharges. e. Prom b., what are definitions of minor discharges omitted? d. Repeat the poll for Emergency Discharges other than those from relief valves. 2. We suggest a poll on Semi-Annual Reports. a. Number of plants having had government inquiries on past performance as follows: 1.1 By telephone. 2.1 By call to meeting. 3*) By notice of violation. 4.) By other formal document--letter, 114 letter, citation or other. .--eseW b. Number of plants fined for excursions in reports. HOOKCM Oil'MH'At 5 A PIAMICS CORP HtUIMtMAHv ill III ( Mil M4| I Iti M \ llM I UIH <H4 III 44 OCC 5416 Hooker Chemical PtASTICS DIVISION Firestone Blvd P.O. Box 699 Pottstown, PA 19464 215/326-2000 July 15, 1981 Mr. T. Moore Teaneco Chemicals, Inc. P. 0. Box 849 Pasadena, Texas 77501 Dear Tom: Other than the specific questionnaires which accompanied your letter of June 1 and which will be submitted separately, we have other suggestions for the agenda for Hilton Head: A. VCM Standard 1. We suggest a poll on Bnergency Discharges. a. Number of plants reporting all Emergency Helief Valve Discharges regardless of pounds of VCM emitted. b. Number of plants not reporting minor discharges. c. Prom b., what are definitions of minor discharges omitted? d. Repeat the poll for Emergency Discharges other than those from relief valves. 2. We suggest a poll on Semi-Annual Reports. a. Number of plants having had government inquiries on past performance as follows: * 1.) By telephone. 2.) By call to meeting. 3*) By notice of violation. 4.) By other formal document--letter, 114 letter, citation or other. b. Number of plants fined for excursions in reports. HOOKr.H CH* MH'AI *} A PI AM ICS COflP ill * lIM lllilM HM I i MIA I h OCC 5416 *>-Mr. T. Moore -2- July 15, 1981 A. VCM Standard - continued 3. We suggest a poll on carbon adsorbers: a. Number of plants using these alone. b. Number of plants using these as adjunct to other type control. c. Number of plants using carbon adsorbers, but who are changing or will change to other type control. B. Effluent Quality 1. We suggest a poll of VCM/Vinyl Acetate Copolymer producers. a. Number of plants producing this copolymer. b. Number discharging to FOTWS. Of these, number removing hydrocarbons from effluent prior to entry into POTW and means of removal. Number preventing discharge of hydrocarbons into effluent. c. Number discharging under NPDES Permits. Of thes , means of removal of hydrocarbons. Number preventing discharge of hydrocarbons into effluent. C. Safety We suggest an up-date presentation on stress corrosion cracking. We also suggest a presentation on engineering safeguards to prevent an operator's opening the wrong reactor. Very truly yours, Manager, Environmental Compliance JAK:slp . occ 5417