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Tenneco Chemicals A Tenneco Company Turner Place, P.O. Box 365 Piscataway, New Jersey 08854 (201) 981-5000 Organics & Polymers Division January 11, 1977 Mr, Herbert A, Howiett, Chief Engineer Delaware River Basin Commission P.O. Box 7360 West Trenton, New Jersey 08628 Dear Mr, Hewlett: Under provisions of the Emission Standard for Vinyl Chloride, National Emission Standards for Hazardous Air Pollutants 40 CFR 61 - Part F, Tenneco Chemicals must install air pollution control devices and make significant mecharv ical/procedural changes to reduce the amount of vinyl chloride (VCM) emitted to the atmosphere at its Burlington, New Jersey site. The major control devices include an "in-process-wastewater" stripper and a carbon adsorption system.- These units are of sufficient size and operating character that revision of the existing cooling water system is necessary, which will increase the . temperature of the water wasted from the system. As you know Tenneco operates a waste treatment facility at Burlington. Treated effluent from this facility is mixed with the cooling tower blowdown prior to discharge into the Delaware River. The treatment plant is operated under NPDES permit NJ 0004391. An average volume of 2050 gallons per minute (gpm), or 4,6 cubic feet per second are discharged, with temperature regulated as follows: Season Temperature C (eF) Average Maximum Winter (Nov, - Apr.) 18 (65) 26 (79) Summer TMay - Oct.) 26 (78) 31 (88) This limitation compares with, for example, that of Public Service Electric and Gas Company's Burlington generating station which discharges at temperatures of up to 116 F (their regulated maximum). COLORITE 018056 Mr. Herbert A. Hewlett -2- January 11, 1977 It is estimated that the changes required will cause a 2.8 C (5 F) increase in the maximum discharge temperature of the effluent. We believe that such an increase should have no significant effect on the temperature character of the River, based on temperatures and flows reported in the most recent U.S. Geological Survey "Water Resource Data for New Jersey - Water Year 1975." These data are summarized in Exhibit I. We will seek from EPA a modification of the temperature limits in our NPDES permit to the following Season Temperature C (F) Average Maximum Winter 25 (77) 31 (88) Summer 28 (83) 34 (93) This modification is required to allow the Burlington plant to be brought into compliance with the EPA Standard on Vinyl Chloride. We request your approval of this proposal so that prompt action may betaken by EPA, permitting Tenneco to fulfill its obligations under the Clean Air Act, Should you have any questions concerning this request, please contact me. Very truly yours, TENNECO CHEMICALS JPS:db h.ir J. P. Sandstedt Manager of Environmental Engineering cc: Mr. Robert Reed New Jersey Department of Environmental Protection Bureau of Water Resources bcc: W, P, Anderson D. C. Coldiron N. J. Quist P. R. Scarito T. T. Zuhl COLORITE 018057