Document np58BRdgNxaje1g3agkd1Bbvm

bcc: Mr. Wallace F. Armstrong Mr. H. O. Bourque Mr. C. B. Hunt Mr. J. C. Klock Mr. S. D. Motsinger Dr. W. E. Rinehart June 15, 1973 Mr. Arthur W. Busch Regional Administrator Environmental Protection Agency Region VI 1600 Patterson, Suite 1100 Dallas, Texas 75201 Dear Mr. Busch: Compliance with National Emission Standards for Hazardous Air fblfutants Attached is a ce/nplated Compliance Status Information Source Report on hazardous clr pollutants at Ethyl's Baton Rouge plant. Ethyl uses asbestos for renewal of diaphragms in caustic-chlorine cells at the plant, but the slurrying, diaphragm deposition, and washing operations involved result in no visible emissions to {he outside air. Ethyl does not surface the plant's roadways with asbestos tailings, nor is there any spray on application of asbestos containing materials for insulating or fireproofing purposes. In the past, some facilities at tho plant have been insulated with asbestos containing materials. Any significant demolition of such facilities in tha future will be preceded by ;ho required notification to the Admini strator and will be in accord with procedures specified in 40 CFR 61 Subpart B. Regulations governing beryllium and mercury emissions are not applicable to Ethyl's Ba'.on Rouge operations. Vary truly yours. W. C. Srracor Res? cunt Mencccr V/CSrjd Attach. ETC 15899 E-02055 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS COMPLIANCE STATUS INFORMATION I. SOURCE REPORT FORM APPROVED OMB NO. 1S8-RU098 EPA USE ONLY INSTRUCTIONS: Owners or operators of source of hazardous pollutants subject to the National Emission Standards for Haz ardous Air Pollutants are required to submit the information contained in Section I to the appropriate U.S. Environmental Protection Agency Regional Office before July 6, 1973. A listing of regional offices is provided in 61.04. I I I II f R I S I I I I II I I I CI SC 13 I I I I l-l-l-l-l I I It AQCR RP I CITY 25 Li NDC e A. SOURCE INFORMATION 1. Identification/Location - Indicate the name and address of each source. |E|T|H|Y|L| |C|Q|R|P|qR|A| T|l|0|N| | | | COMPANY NAME |P|| |B|0,X| |3[4, l| | | | | , | | | | | k4 NUMBER 1 STREET NAME ASS ||A|T1Q|N| 1R IQimGI El 111! |LjAj |7|0|8|2|1| | B33 STATE BS 4 21 P CODE B36 E| |B|A|T|Q|N|R|qU|G| E| 2. Contact - Indicate the name and telephone number of the owner or operator or other responsible official whom EPA may contact concerning this report. |W| |C| IS | T| R|A1D| E | R | II I 1 I I I I 1 | 5|0 |413 | 5| 7|4 | 316| 11 BS3 64 TELEPHONE 3. Source Description - Briefly state the nature of the source (e.g., "chloralkali Plant," or "Machine Shop"). |C|H|L |0|R| -|A|L |K|A|L| I | I I II I I I I II I II CIO C43 4. Alternative Mailing Address - Indicate an alternative mailing address if correspondence is to be directed to a location different than that specified above. l I i i i I i i i i i i M ii i i i i i i i i i i C44 NUMBER * STREET NAME C63 C7S C7S I............... I........................... LLJ I I I I I I C* CITY c77 STATE 075 ZIP CODE D7B 5. Compliance Status - The emissions from this source / X / can / 7 cannot meet the emission limitations contained in the National Emission Standards on or before July 5, 1973. SIGNATURE OF OWNER, OPERATOR OR OTHER RESPONSIBLE OFFICIAL NOTE: If the emissions from che source will exceed those limits set by the National Emission Standards for Hazardous Air Pollutants, the source will be in violation and subject to Federal enforcement actions unless granted a waiver of compliance by the Administrator of the U.S. Environmental Protection Agency. The information needed for such waivers is listed in Section II of this form. j ETC 15900 PAGE 1 OF 4 PAGES T, -02056 I. &. PROCESS INFORMATION. Part B should be completed separately for each point of emission for each hazardous pollutant. FORM APPROVED OMB NO. 1S8-R0098 epa use only 1 II 1 1 1 1 1 1 614 EP CIS 646 s CC I _i 6 33 1. Process Description - Provide a brief description of each process (e.g., "hydrogen end box" in a mercury chloralkali plant, "grinding machine" in a beryllium machine shop). Use additional sheets if necessary. |A|S|B|E|S|T|qS| |S | L |U| ft [R | Y| I | N|G| I | | M | I 621 G4S 2. Pollutant Emitted - Indicate the type of hazardous pollutant emitted by the process. Indicate "AB" for asbestos, "BE" for beryllium, or "HG" for mercury. [Alii 61 ^620 3. Amount of Pollutant - Indicate the average weight of the hazardous material named in Item 2 which enters the process in pounds per month (based on the previous twelve months of operation). I l 1 i5l3lll es4 ceo 4. Control Devices a. Indicate the type of pollution control devices, if any, used to reduce the emissions from the process (e.g., venturi scrubber, baghouse, wet cyclone) and the estimated percent of the pollutant which the device removes from the process gas.stream. iii i ii i iii ii iiii i PRIMARY CONTROL OC VICE TYPE "Lu lT PERCENT REMOVAL EFFICIENCY III IIl Ilii Il IM iI SECONDARY CONTROL DEVICE TYPE H60 ""LU U"" PERCENT REMOVAL EFFICIENCY b. Asbestos Emission Control Devices Only i. If a baghouse is specified in Item 4a, give the following information: . The air flow permeability in cubic feet per minute per square foot of fabric area. Air flow permeability = cfm/ft^ . The pressure drop in inches water gauge across the filter at which the baghouse is operated. Operating pressure drop = inches w.g. If the baghouse material contains synthetic fill yarn, check whether this material is / / spun / / or not spun. If the baghouse utilizes a felted fabric, give the average thickness in inches and the density in ounces per square yard. Thickness inches Density oz/yd^ ii. If a wet collection device is specified in Item 4a, give the designed unit contacting energy in inches water gauge. Unit contacting energy = inches w.g. ETC 159Q1 PAGE 2 OF 4 PAGES -02057 II. WAIVER REQUESTS FORM APPROVED OMB NO. I58-R0098 WAIVER OF COMPLIANCE. Owners or operators of sources unable to operate in compliance with the _______ National Emission Standards for Hazardous Air Pollutants by July 5, 1973 may request a waiver of compliance from the Administrator of the U.S. Environmental Protection Agency for the time period necessary to install appropriate control devices or make modifications to achieve compliance. The Administrator may grant a waiver of compliance with the standard for a period not exceeding two years from the effective date of the hazardous pollutant standards, if he finds that such period is neces-r sary for the installation of controls and that steps will be taken during the period of the waiver to assure that the health of persons will be protected from imminent endangerment. The reporting information provided in Section I must accompany this application. Applications should be sent to the appropriate EPA regional office. 1. Processes Involved - Indicate the process or processes emitting hazardous pollutants to which emission controls are to be applied. 2. Controls a. Describe the proposed type of control device to be added or modification to be made to the process to reduce the emissions of hazardous pollutants to an acceptable level. ( Use addi tional sheets if necessary.) b. Describe the measures that will be taken during the waiver period to assure that the health of persons will be protected from imminent endangerment. (Use additional sheets if necessary). 3. Increments of Progress - Specify the dates by which the following incre ments of progress will be met. . Date by which contracts.for emission control systems or process modi fications will be awarded; or date by which orders will be issued for j the purchase of the component parts to accomplish emission control or process modification. i.59 LLJ 1--1--1 [_U oi MONTH OAY YEAR . Date of initiation of non-site construction or installation of emis sion control eqquuiippmmee: nt or process change. I-.B64 HLsa LULULU 02 MONTH Date by which on-site construction or installation of emission control equipment or process modification is to be completed. LB4 LLJ LU LU WnTm day year 03 Date by which final compliance is to be achieved. u ee LU LU L 04 "***? * ETC 15902 PAGE 3 OF 4 PAGES E--02058 runm /.r-i-r\w . t-w OMB NO. 1S6-R0096 l'l, B. WAIVER OF EMISSION TESTS. A waiver of emission testing may be granted to owners or operators of sources of beryllium or mercury pollutants if, in the judgment of the Administrator of the U.S. Environmental Protection Agency the emissions from the source comply with the appropriate standard or if the owners or operators of the source have requested a waiver of compliance or have been granted a waiver of compliance. This application should accompany the reporting information provided in Section I. 1. Reason - State the reasons for requesting a waiver of emission testing. If the reason stated is that the emissions from the source is within the prescribed limits, documentation of this condition must be attached. n i im ,'ilii4 iii^ i M .'iit> < ii_ ^ i^ w IE I i i r f ~ - ^ i \ * fc iT^- ^ *~/ * - -V - r V n i i~ T ~ t -- !-** i SIGNATURE OF THE OWNER OR OPERATOR it U.S. GOVERNMENT PRINTING OFFICE : 1973-726-697/503 3-1 : '''HT1' VTV^.T--i'TV'Jpp- ' ` 'f - ETC 1593 DATE PAGE 4 OF 4 PAGES E--02059