Document nZJvowrxXKJ6wbvbroX9Bog1
To: Distribution
interoffice Communication
From:
Date:
Subject:
S. C. Racca February 3, 1986
HCL Column (C-202) Release Reporting Guidelines
Attached are guidelines for reporting the release of
HCl and/or VCM during periods when the HCl Column
(C-202) must be vented, to C-500 or an incinerator
absorber, to relieve on overpressure condition.
The
guidelines reflect the commitment made in the "Emission
Control Plan" submitted to the EPA in partial
satisfaction of the conditions in the U.S. vs. Conoco
Consent Decree. The guidelines are divided into two
time frames - during pendency and following termination
of the Decree. This separation will insure compliance
with commitments in the Plan, as well as, applicable
state (LESHAP and Notification Regulations and
Procedures for Unauthorized Discharges) and federal
(Superfund) regulations.
Please review the attached and if there are any questions or comments, contact me.
Stephen C. Racca Process Engineer
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CWH 000001224
HCL COLUMN (C-202) RELEASE REPORTING GUIDELINES
During Pendency of U.S. vs. Conoco Consent Decree
A. Documentation
All incidents in which HC1 is vented from the overhead
of the HCl Column must be documented.
Documentation
must include a description of the nature and cause of
the incident and is to be retained for at least two
years.
B. Reporting
1) Greater than 10 ppm VCM in HCl Column Overhead*
All incidents in which HCl is vented from the
overhead of the HCl Column and the concentration
of VCM in the overhead is greater than 10 ppm
must be reported in LESHAP (Louisiana Emission
Standards for Hazardous Air Pollutants) quarterly
reports in a manner consistent with that of the
June 15, 1984 LESHAP quarterly report
(per
Emission Control Plan commitment).
2) Greater than 10% VCM in HCl Column Overhead.
All incidents in which HCl is vented from the overhead of the HCl column and the concentration
of VCM in the overhead is greater than 10% must be reported in accordance with LESHAP Sections 77.6(a) and 76.18.
3) Greater than 5,000 lbs. HCl or 1 lb. VCM Released in 24 hrs. or 100 lbs. HCl Released in any Consecutive 3 hr. Period
Make the appropriate verbal (immediate)
and
written notifications to the Louisiana Department
of Environmental Quality (LDEQ) and National
Response Center (NRC) in accordance with the
Release Reporting Guidelines (Revision - 1) IOC
from E. R. Taylor to Distribution dated January
14, 1986 (or the appropriate revised versions of
this IOC). Note that this IOC states that "...
Superfund reporting is not required if...
A
report is made under NESHAP or LESHAP...".
In
other words, if a notification under item B.2.
above is made, then notification to the NRC in
accordance with Superfund is not required.
CUH 000001225
Following Termination of U.S. vs. Conoco Consent Decree
A. Documentation
All incidents in which HC1 is vented from the overhead
of the HC1 Column must be documented.
Documentation
must include a description of the nature and cause of
the incident and is to be retained for at least two
years.
B. Reporting
1) Greater than 10 ppm VCM in HCl Column Overhead.
No reporting required.
2) Greater than 10% VCM in HCl Column Overhead.
All incidents in which HCl is vented from the overhead of the HCl column and the concentration of VCM in the overhead is greater than 10% must be reported in accordance with LESHAP Sections 77.6(a) and 76.18.
3) Greater than 5,000 lbs HCl or 1 lb. VCM Released in 24 hrs. or 100 lbs. HCl Released in any Consecutive 3 hr. Period.
Make the appropriate verbal (immediate)
and
written notifications to the Louisiana Department
of Environmental Quality (LDEQ) and National
Response Center (NRC) in accordance with the
Release Reporting Guidelines (Revision - 1) IOC
from E. R. Taylor to Distribution dated January
14, 1986 (or the appropriate revised versions of
this IOC). Note that this IOC states that "...
Superfund reporting is not required if...
A
report is made under NESHAP or LESHAP...".
In
other words, if a notification under item B.2.
above is made, then notification to the NRC in
accordance with Superfund is not required.
CUH OOOooi