Document ppVxx7j3zry8RYkVaaR2p1EnD

9^ H O' r ICC K' TEKNECO CHEMICALS, INC. W. P. Anderson J. P. Sands ted L FOIA Request Al Saddle Brook Piscataway OAir. July 25, 1978 Ccjfv m Miringhoff P. Scheiner Mr. Marcus Kantz of EPA Region II called on July 25 relative to a Freedom of Information request from Mr. Henry J. Plog, Esq. of Cleary, Gottlieb, Steen and Hamilton. Information is being sought relative to any and all requests for approval of modifications or facility's expansion under NESHAPS regulations. After much discussion with Mr. Kantz, I feel certain that little if any of the information we have submitted to the Agency will be released since we were smart enough in our cover letters to claim confidentiality treat ment . J. P. Sandstedt COLORITE 016988 r l i \ i i L- -- . ,1,. .j.Vl-l'1" - 1 " 1 ' ' - ' ` ' 1` Office of Air Qualit Planning and Standards Research Triangle Paik, North Carolina 2771 1 f v- S'^!>.:-.cT: Rev1-ew 0f vinyl Chloride Methods Submitted DATE: AUG 13 1977 r" by Tenneco Chemicals fruu: William Grimley Emission Measurement Branch Marcus E. Kantz Chemical Engineer Air Facilities Branch In accordance with your request of June 28, 1977, and in collaboration with the Quality Assurance Branch of LbiSL, v:e have reviewed the methods for analysis of vinyl chloride submitted by Tenneco Chemicals that correspond to EPA Methous 105 and 107. Con sideration has only been given to the approval of each as an alternative method, since guidelines for determining the equivalency of methods have not yet been established. The basis of our review and our conclusions which I transmitted to you on the phone on August 15 are as follows. The principal considerations of this review have been whether each method is written in sufficient detail to assure acceptable precision, and the likelihood of good comparabi1ity between results generated by each candidate method and the corresponding EPA method. As To.ineco points out, their written methods only cover the analysis of samples. Thus, any alternative method approval would be limited to the analysis portion of the EPA Reference Method; the candidate methods would not be an alternative to the entire Reference Method. More specific comments are as follows: Jtem_K Metho_d_No. GCF-3.0 for Vinyl Chloride in Ai_r Description of technique for obtaining repre:dilative samples, if different from Method 106, must be provided. The accuracy and reproducibility must both be within +. 5 relative at 10 ppin (volume/ volume), or a correction factor must be determined and applied. Provision should be made for resolution of interferences in analysis. If cylinder standards are used, they must be certified by an EPA approved procedure. (See clarifications to Methods 106 and 107 as published in the June 7, 1977, Federal_ Register, p. 29008.) Validated limitations must be placed on the life of samples and standards, and standards must he relevant concentrations. Qualiiy of gases (helium, hydrogen, air) must be specified. n EPA Poim I 32C-6 [rrv. fc-72) COLORITE 016989 2 Items 2, 3, and 4. Methods No, GCE-1.OA, 6CF 4,0 and GCF 5.0, Descriptions of technique for obtaining representative samples must be provided. Preparation of sample containers must be included. Quality of gases (helium, hydrogen, air) must be specified. In viev. of our requirement of zero grade gases, this grade must be used unless comparative data is submitted that demonstrates no loss of precision. Sample handling must be further detailed, as careless handling will result in loss of vinyl chloride. Item 5. Waiver Regarding Requirement Ttat Anal ys_i_s_ of_ CaJ i brat ion "Cy IT rider's be Tracea ble to the Rati ona 1 Bureau of Standards. This requirement has been clarified in the Federal Register (see response to Item 1). Gravimetric techniques are not acceptable for cylinder certification. ConcUjsjon In final summary, approval of these methods must be withheld until Tenneco can add the details previously described. The procedures are acceptable in principle, but to be eligible for approval as an alternate method, a candidate method must be equally rigorous to the reference method. The deficiencies cited are of particular concern since approval is not limited to one plant or even to Region II. For this reason, the methods must be written in sufficient detail and must involve f**' procedures adequate enough to assure that the methods will produce accurate and precise results when used by any competent laboratory. For this reason also, any approval decision should be made by OAQPS in coordination with OF, ORD, and affected Regions. In addition a Federal Register package would be prepared by OAQPS to formally document such approval. Tenneco should be encouraged to pursue approval of their alternative procedures, but I would ask that you advise them that any further submittal should he to Don R. Goodwin. (See enclosed memorandum dated September 4, 1575, regarding approval of altern.ilive methods.) If you have any questions or need further information, please contact me. Enclosure cc: B. J. Steigerwald (* ID 10) John Clements (MD 77) Joe Knoll (MD 77) Richard Biondi (Eh' 341) Myron Knudson, Region VI, Director, SEA Division n COLORITE 016990 Tenneco Chemicals A Tenneco Company Turner Place, P.O. Box 365 Piscataway, New Jersey 08854 (201) 981-5000 January 12, 1978 on Mr. Marcus Kantz U. S. Environmental Protection Agency 26 Federal Plaza New York, New York 10007 RE: EPA Compliance Schedule -Letter of February 25, 1977: EPA to Tenneco -Letter of October 25, 1977: EPA to Tenneco Dear Mr. Kantz: This is to confirm our discussion during the December inspection at Burlington with respect to the installation of double mechanical seals on our rotating pumps. To date we have completed the installations on all but seven pumps. Six of these are SIHI pumps, imported from Europe, and unique to Tenneco's disper sion resin process. Standard seals were installed, but failed within 24 hours. The seal manufacturer is presently redesigning the seal assembly; however, we have been advised that delivery can not be made for six months. The seventh unit is a Peerless Pump. The particular model is no longer being manufactured and, accordingly, conversion parts to allow this unit to accept a double mechanical seal are not available. We now plan to modify the unit at a local machine shop. For the reasons detailed above we request that the date for the Completion of Con struction and Compliance, under Paragraph 61.65(b)3 be extended until September 1, 1978. We would also point out an inconsistency with regard to the Schedules pertaining to Paragraph 61.65(b)6-Equipment Opening, Paragraph 61.64(d)-Monomer Recovery, and Paragraph 61.65(b)9-Wastewater Stripper. Since techniques for meeting the opening requirement depend on the final control device (incinerator) and wastewater stripper, final compliance with Paragraph 61.65(b)6 cannot be achieved until these units are operational and in compliance. Therefore, we request that the date for Increment #4 [Paragraph 61.65(b)6] be changed to October 21, 1978. Should you have any questions concerning these requests, please contact me. Very truly yours. TENNECO CHEMICALS, INC. JPS:eg J/ P, Sandstedt, Manager Environmental Sciences COLORITE 016991 Tenneco Chemicals A Tenneco Company Turner Place, P.O. Box 365 Piscataway. New Jersey 088S4 (201) 981-5000 December 21, 1977 Mr. Marcus Kantz U. S. Environmental Protection Agency 26 Federal Plaza New York, New York 10007 Dear Marcus: Per our conversation on Tuesday, please find: 1. MCA - Workshop on Ramifications of Clean Air Act Amendments of 1977. This is an easily readable copy of the amendments. In addition, MCA Staff Comments summarize some of the more "challenging" points. 2. Copy of Federal Register - Ambient Air Quality Standard for Lead. You indicated that you might not receive your copy for several ,, months. 3. Copy of D. J. Steigerwald's letter of September 4, 1975. This is "a reasonably readable" copy. Finally, I would appreciate it if you could send me a copy of the report on the Burlington Inspection. Thanks. Very truly yours TENNECO CHEMICALS, INC. JPS:cg Enc. J. P. Sandstedt Manager, Environmental Engineering COLOR!TE 016992 yfrice of Air Heal i'ey pi;.", wig nod Suar/Jards Research Tri angle Par!:, .'-'-ri;li Carol inn 27711 /ipprovsl of Alternative end Equivalent Source T, bethods Applicable to Enforcement of national Emission Standards C. d. Steigerwald, Director Original signed by t Office of Air Quality Planning and Standards (ifj-Ul) 4 SEP W/5 Director, enforcement Division, MPA Regions I - X Director, Surveillance and Analysis division, ERA Regions I - X In the 'lurch C, 1274, Federal Register , the definitions of "Cquivalent Method" and "AlternativeTiediod" were h dried to 40 CFR 0--Standards of Performance for Dew Stationary Sources, Siriilor provisions arc containod in 40 CFR 01, pertaining to hazardou s pollutant standards. These provisions provide n mechanism for approval of non-refcrer.cn source test r,i2tiiods. The purpose of tin's memorandum is to set forth procedures which clarify the responsibility for approval of alternative or equivalent aetliods. Under these procedures the Regional Offices retain that flexibility needed to neat CPA and State testing needs-, 0ARPS will serve as a point of coordination and will retain approval authority and provide technical assistance in cases where decisions could affect uniform application of standards. The establishment of CARPS as a focal point for tins authority, and the procedures outlined in this nemorandan have been discussed v.ith and received concurrence from the ft vis I on of Stationary Source Enforcement and the Office of Research and Development programs which are Involved in source test activities. purpose of Alternative Methods The primary Intent of the alternative method provisions is to accom modate two situations: (1) The need to approve a method which would probably produce results equivalent to reference method results but which could not (due to lack of time, excessive cost, etc.) he demonstrated as an equivalent method. Examples would be substitute probe .T.ater'als, differing sample train component configurations, awl procedural deviations. Approval may be based on engineering evaluation or other relevant lufonuation. (2) The need to approve less complex methods which, based upon oyalnation cr test data, produce results sufficiently accurate to assure compliance in specific cases. Due example would be the case whore an additional filter or wot collector is added to the reference method sample train. Sub-isokinetic V M t* W i t r I V. l rv* v.* \>-r*s COLORITE 016993 sampling would be a second swell example. In either case, tiie results would not bo equivalent to re Terence method results, but 'would nevertheless assure compliance. Meitner of these newls can to readily accom-iodatcd under the pre visions allcwi;:\i 'equivalent no If (s)since these require demonstra tion oT n "consistent and quantitatively !mov:n relationship to the reference milled." In feet, demonstrating the equivalency of source tost methods is cown]ox ar.d rot, os .yet, adequately resolved. This is discussed in further detail on pane 3 of this memorandum. Approval Agfion ty Approval of alternative methods may bo desired In a number of instances. These range fro:; the. caso where an engineer must decide . in the field whether-to arprnvo use of loss than the full number of required sample points In a traverse (as might ba desired due to limited sample space), to the case where a State desires fclcnhct approval for use of an alternative method in carrying out delegated authority for enforcement of federal standards. The former case Is one which would not seriously affect uniform application of standards and approval authority is in the r-uqlon.,1 Offices- The latter- case could result in a standard holng applied differently in different areas. Therefore, to insure uniformity rod technical quality in tosh methods used in tho enforcement of national standards, OAnfS will retain approval authority for cases where an alternative method waul-.! effectively replace ?, reference method, l-hhile precisely defining all requests which may fall in this category Is not possible, generally CAPPS approval will apply to all methods affecting more than cue source. In such cases, requests for approval should be forwarded to tho Director, Emission Standards and Engineering division, OAQPS. If/ion such a request is received, Tf.CD will perform a technical review of the method. Tills review will consider, for example, whether the method is written in sufficient detail to assure acceptable precision and tho likely comparability of results between tiie candidate method and tho reference method. Tito results of tho revi.'vi after appropriate consultation and coordination with tho Division of Stationary Source Enforcement, will bo provided to tho respective feci oral Office, along with a decision on opprovnbility. The decision will constitute* a strictly technical interpretation cf tho method and, thereby, of tho applicable; standard. This Interpretation Is out side tin scope of, and is not intruded to duplicate or supersede any Office of Enforcement decision which might otherwise be Involved in an enforcement action. -*x *.>.-f '**.`*. V :A COLORITE 016994 Generally, any basis for a negative decision will bo clear and ,/ill net likely bo subject to serious dispute by the requesting agency. However, 'in tiio case of a State test method whore the question of delegation of authority is involved, failure to approve an alternative method could present a potential problem. Here tiie need to assure that valid, supportable test methods necessary for enforcement of national standards may come in conflict with the desire for uniform intrastate methods, or for preservation of longstanding local test methods. When sucii cases occur, resolution will be needed on a caseby-case basis. In this event, OAQPS will be available to assist the Regional Offices In working with technical staff from the affected agencies. Through a close working level relationship, resolution of those problems should be possible. Equivalency Criteria As noted briefly above, the natter of equivalency Is more com- plicated than determining adequacy of an "alternative method" and should be noted. Essentially, a determination of equivalency means that the candidate method and the reference method produce the same results under specified conditions. This assumes that tiie reference method can be characterized exactly In terms of accuracy and precision and that procedures are available which allow comparison of the two methods. In fact, such procedures and information are not available for field sampling aspects of source testing. Further these procedures may be prohibitively expensive to apply In the field. Thus, for particu late matter, which is not an absolute quantity, and whore tiie field procedure constitutes the major portion of the method, equivalency may be a mute issue. On the other hand, the analytical portion of methods involving identification of specific compounds, such as fluoride or beryllium, are mure amenable to determination of equivalency. The Office of Research and Development Is currently involved in standardizing reference methods and in considering equivalency criteria. These are not available yet; however, requests for equiva lency determinations can bo considered cn a case-by-case basis. Such requests should also be directed to the Emission Standards and Engineering Division which will coordinate the evaluation with appropriate Office of Research and Development Laboratories. Generally, a determination of equivalency will require, as a minimum, a detailed written method, results of tests comparing the candidate method against tiie reference method, and results involving inter-comparison of the candidate method performed by different laboratories and/or personnel. cc; Aubrey P. Altshuller Doyle Borchors John S. .Mador S. David Shearer Roger Strelow Edward F. Tucrk Richard Wilson Director, Air and Hazardous Materials Division, EPA Regions I - X I 1 j ! i i O'* . *' * -r*-' /* # -*f . a.*? * . *\ a. 1 A*,* cm y COLORITE 016995