Document mLDDOygr8eOe6wXGQnw9v6X0

TO: R. D. Gainblin Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles March 15, 1991 PROGRESS REPORT VISTA 1. JCL met with GMA and EPA to discuss progress on Clean Air Act air toxic regulations. EPA is slowly formulating positions on issues and will begin proposing regulations this month defining the scope of the program. No surprises came out of the meetings. Emission standards (MACT) will be based on existing benzene control regulations. Operations at Baltimore, LCCC, and possibly the Aberdeen plasticizer unit will have MACT standards proposed by 11/91 and promulgated by 11/92 if EPA meets the schedule mandated in the Clean Air Act. Compliance with MACT must be accomplished three years after promulgation, 11/95. 2. JCL met with the Hammond Plant and the Hammond Sanitary District and Rhone-Poulenc to work out several issues regarding wastewater permits. Follow-up discussions will occur, but the issues are on a track toward resolution. 3. EPA promulgated the RCRA Boiler and Industrial Furnace rule on February 21. Memos on that subject were issued. LCLAB will be impacted because of ASO burning. LCCP may be affected if future burning of ethanol from the Alcohol Plant or methanol at the Ethylene Plant is necessary. Facilities wanting to burn hazardous waste fuel in boilers or industrial furnaces must file a RCRA Part A by August 21, 1991. 4. JCL participated in phone conversations regarding the regulatory status of LCVCM decoking waste. 5. JCL worked with Premiere and Legal regarding plasticizer contamination beneath a former tank storage area. 6. JCL met with Conoco, Dupont Environmental Remediation Services (DERS) and the Aberdeen plant to discuss activity on the Aberdeen waste site clean-up. 7. JCL coordinated development of Vinyl Institute comments to the State of Louisiana on the most appropriate unit risk factor for the air toxic program. 8. JCL and TGG participated in a CLER Steering Committee meeting. T. G. Grumbles dlj 00qqq621i