Document mmj3Xmrk0QE6mn1jK43zMk7BZ

Tenneco Chemicals 1A Tenneco Company Turner Place, P.O. Box 365 Piscataway, New Jersey 08854 (201) 981-5000 January 25, 1978 Mr. Don R. Goodwin, Director Emission Standards & Engineering Division U. S. Environmental Protection Agency Research Triangle Park North Carolina 27711 Dear Mr. Goodwin: RE: Part 61 National Emission Standards for Hazards Air Pollutants - Appendix B: Methods 106 and 107 - Alternative Methods Tenneco Chemicals, Inc. requests approval of its Analytical Methods: GCF-3.0 Determination of Vinyl Chloride from Stationary Sources (Revised 1/12/78) and GCF-1.0A Determination of Vinyl Chloride Content in Polyvinyl Chloride Resin Samples (Revised 11/18/77) GCF-4.0 Determination of Vinyl Chloride Content in Polyvinyl Chloride Resin Slurry Samples (Revised 11/2/77) GCF-5.0 Determination of Vinyl Chloride Content of In-Process Wastewater Samples (Revised 11/4/77) as alternates to Reference Methods 106 and 107, respectively. These methods have been revised to reflect specific comments by Mr. William Grimley in an August 16, 1977 letter to Mr. Marcus Kantz (Region II NESHAPS Coordinator). The formal procedures include specific sampling methods which are appropriate for the individual sample type, the particular process or equipment limitation, etc. These are geared to minimize inaccuracies due to loss of vinyl chloride resulting from improper handling. The methods were developed by our R & D staff based on GC principals accepted by analytical chemists. These have been incorporated into COLORITE 018958 Hr. Don R. Goodwin Page Two January 25, 1978 Director plant procedures at our Burlington and Fleminton, New Jersey (Region II) and Pasadena, Texas (Region VI) sites. Should you have any questions concerning this request, please contact me. Very truly yours, TENNECO CHEMICALS, INC. JPS:cg J./ P. Sandstedt, Manager Environmental Sciences cc: Mr. K. W. Grimley, Jr. -- EPA, Emission Testing Branch Mr. Marcus Kantz -- EPA, Region II Mr. Gary Bernath -- EPA, Region VI Dr. Louis R. Roberts -- Texas Quality Control Board bcc: Mr. W, P. Anderson Mr. G. I. Rozand COLORITE 018959