Document mbp8xZ6JOy9D8LQ0yddEzMdak

INTERNAL CORRESPONDENCE UC t49~ l HEALTH, SAFETY AND ENVIRONMENTAL AFFAIRS P. O. BOX 471. TEXAS CI TV, TEXAS 77590 June 13, 1984 To: S. M. Norwood Texas City Plant Copy to: T. T. Do-Hoang J. B. Leverton/S. J. Footer W. P. Nickles F. S. Provenzano E. R. Saldua Subject: Leak Detection and Elimination Plan, NESHAPS for Vinyl Chloride, Acct- #GB-0076-J, Solution Vinyl Resins, Texas City Plant, Approval of Plan, TACB Letter Dated June 5, 1984 Dear Sam: Attached is the letter of approval for the above cited Leak Detection and Elimination Plan for your production facilities. Please note that this approval is contingent upon the incorporation of the measures previously cited in the October 5, 1983 letter and my recent letter of May 17, 1984 into your standard operating procedures. This includes all the necessary record keeping, as well. If there are any questions about what should be done, we can schedule a short status review meeting in the near future to fix an action plan to avoid any future problems in this area of your activities. You can be fairly certain that the next TACB Annual Compliance Inspection will include a followup on this matter. Also, any internal UCC audits will require reporting of the matter and the remedial action taken to comply with Corporate policy. I would like to commend Thuy Do for her diligence and quick action in providing the information requested by the TACB in their original letter. Please contact me if there is any more I can do to help. Sincerely, JFE:IR Attachment LeakSVR2 UCC 060573.01 6/8/84 Orig. to: J. F. Erdmann cc: J. B. Leverton, S. J. Footer, F. S. Provenzar TEXAS AIR CONTROL BOARD JOHN L. BLAIR Chairman CHARLES R. JAYNES Vice Chairman BILL STEWART, P. E. Executive Director 6330 HWY. 290 EAST AUSTIN. TEXAS 78723 S12/451-5711 VITTORIO K. ARGENT0, P. E. 60S G. BAILEY FRED HARTMAN . JACK KILIAN, M. D. OTTO R. KUNZE, Ph. 0.. P. E. R. HAL MOORMAN HUBERT OXFORD, III L .`r\J L~' June 5, 1984 Mr. F. S. Provensano Plant Manager Union Carbide Corporation Post Office Box 471 Texas City, Texas 77590 ; W* i 0* J.F.EJUN12884 Re: Leak Detection and Elimination Plan National Emission Standard for Vir\yl Chloride (40 CFR 61.65(b)(8)) Account No. GB-0076-J Dear Mr. Provensano: We have completed our review and evaluation of the Information contained In your October 5, 1983 and May 17, 1984 letters regarding the referenced matter. Based on information provided in your letters, we have determined that your leak detection and elimination plan can be approved. Plan approval is dependent on full incorporation of its measures into standard operating procedures and is subject to verification during agency investigations. Your cooperation in this matter is appreciated. If you have any questions, please contact us. Sincerely, Sabi no Gontez, M.P.Hr, Acting Director Compliance Division cc: Mr. Herbert W. Williams, Jr., Regional Director, Houston Celebrating 150 Yean of Texas Independence 1836 -1986 ucc o60574 UNION CARBIDE CORPORATION p a uax 4X1, rtEXAS CITY, TEXAS 775gO HEALTH, SAFETY AND ENVIRONMENTAL AFFAIRS May 17, 1984 Mr. Sabino Gomez, MPH Acting Director, Compliance Division Texas Air Control Board 6330 Highway 290 East Austin, TX 78723 Subject: Leak Detection and Elimination Plan, NESHAPS for Vinyl Chloride, Acct. No. GB-0076-J, Texas City Plant, Solution Vinyl Resins Dear Mr. Gomez: This is in response to your inquiry on the above subject to Mr. F. S. Provenzano, our Plant Manager, in a letter dated April 20, 1984. The following information is submitted in connection with your specific listed questions: 1) The concentration of vinyl chloride monomer in the standard gas used to calibrate the portable monitors is 100 ppm, by volume. 2) The standard gas, which is a mixture of vinyl chloride with either air or nitrogen, is prepared by our plant analyzer group here in the plant. An assigned instrument man is in charge of making this standard calibration gas mixture according to detailed procedures which have been written for this purpose. Pure vinyl chloride purchased from Matheson is certified. 3) Ambient air background vinyl chloride samples have not been taken on a frequent basis because the Solution vinyl Resins unit is the only source of vinyl chloride in our plant and in the Texas City area, to our present knowledge. As you know, the Suspension and Non-Solvent process units at this location were permanently shut down and completely dismantled. The monitoring system frequently prints out "zero" VCM concentrations from the various sample points, which indicates that the VCM levels are below the 0.1 ppm detection limit of the analyzer. This low level is thus not significant as a background concentration to require any correction to the monitor printout in deciding the presence of a leak anywhere within the unit battery limits. ucc 060575 Mr, Sabino Gomez May 17, 1984 Page 2 4) In case the continuous vinyl chloride monitoring system (VFA) fails, our highest maintenance priority, including overtime, is applied to return the monitor to service in the shortest possible time. If the system is projected to be out of service for more than two days, additional personnel monitoring will be conducted to protect personnel from exposure. The autoclave operators are responsible for monitoring the VFA results because they are most suitably situated in terms of job characteristics and physical proximity. The analyzer computer and printer are all located in the Bldg. 115 control room next to one of the main operating panelboards which are attended constantly by the operators, so it is a part of their duties to monitor this system along with the regular process controls. The VFA system is equipped with an audible alarm and it sounds off at a pre-set level (5 ppm VCM, at present) to notify the operators immediately of the presence of a VCM leak. Corrective action can then be taken under our prescribed procedures to stop the leak. All of the above information has been obtained through consultations with our production unit supervisors and environmental protection unit representative at the Solution Vinyl Resins Unit. Please contact me if there is any need for additional information or if you have further questions. Very truly yours, JFE:IR TLeakSVR bcc: J. B. W. P. F. S. S. M. T. T. E. R. Leverton/S Nickles Provenzano Norwood Do-Hoang Saldua J. Footer ^J'. F. Erdmann, P.E. Environmental Protection Coordinator (409) 948-5126 UCC 060576 YjCC 0605^ OiuJ tr Asfbttfi r > jiff* by (rft S' kj w^~~ :!< fhfit'? CfrtP?f/7?& --kmtiGfi A/ r*^ 7h^3-s~ UCC 060578