Document g2L600X6K8R4xREZoXNZm9J8J

r r' August 14, 197S Conor.n ('.hiMnicuU (' 11 n I1111 ' i (, 11 (' 11 1' (111 < j < ,i n v I' p n-',Oi Nu.- Ahnnlron, 3^ 730 United States Environmental Suite 300 1421 Peachtree Street Atlanta, Georgia 30309 Protection Agency Attention: Mr. Thommic A. Gibbs, Chief Air Engineering Branch Dear Sir: Attached for your review is a "Compliance Manual" for our plant. this document is intended principally for internal use within our plant. It. describes facilities and procedures necessary for ns to maintain compliance with the vinyl chloride emission standard. Its primary use is to identify for plant operations, maintenance and engineering personnel the specific conditions which arc necessary for emission control. Contained within tlae booklet are our proposals concerning compliance emission testing. These arc specified in Sections VI1 and VIII. These sections can sr'rve as a discussion basis on the emission sampling for compliance verification which we will conduct ns soon as possible. Contained in Section VI is a cn1cu1 ationa 1 method relative to the reactor opening loss emission requirement. In our process, the reactor atmosphere prior to opening is above 212^l7, at: a, slight vacuum and in excess of 9 3 A water vapor. We have been unable to sample Ibis source. Wo would like to have the calcu1 ationa1 method, with associated reactor operating data for cacti batch, certified as an cqui 1 valency. Contained in Section VIII is a discussion of the analytical methods for analyzing emission samples. Method 10b contains very slight differences from the method in the federal Register. The differences simplify the calculation and have no effect on the calculated result. We ask that the method described in Section VIII be certified as equivalent. Section EX contains our proposals concerning emission recordkeeping following, verification of compliance via emission testing. The recordkeeping described will allow us to determine net plant vinyl chloride cmissions as we 11 ns allow us to insure proper operational maintenance of compliance equipment. l'lease review this proposal for adequacy within the intent of the Emission Standard. DTH 000096068 rase : I will he in contact with Dr. .lame? Ku of your office later this week concerning a meeting on emission compliance testing. In the meantime if there are any questions please contact me. Pouglas Michels Chief Process lingineer cjt Attachment \ 000096069