Document qaNjLenpBY56kp3xnXQv2b95n

JP* 1- ,t W- I 4' <* - ) I August i, 1972 l! . PLAINTIFF'S i EXHIBIT # j WEGk345 Mr. R. L. Junker Texts Vemic.ilitc Company P. 0. Box 6306 2651 Manila Read Dallas, Texas 75222 Dear Bob: I want to apologise for the delay in sanding certain specific information that you requested pertaining to pollution control devices, and on certain pieces of equipment that have recently been installed at our new Forpano Bench facility. Before getting into this phase cf it, I would like to comment on your recent notices'of violation from the Dallas Health Beparceent and make reccnnencations of how you should handle a program* of ccmpliance. As you stated over the phone July 31, 1972, you received a notice of violation July 5, 1S72 for visible emissions in excess of allowable from the Perlite bag house. Hie measured emissions had an an opacity of 48:5 and 42.8 which was in excess of the allowable 40, or a Number TWo Ringleir.cn. These emissions were due to holes in the bag house fabric. On July 28, 1972 you received a final notice of violation while ex>anding ?4. This was a violation of city ordinance 8737 and I assune that this ordinance pertains to visible emissions. Violations for visible emissions that have not been measured can be con tested, but if any part of the violation had to do vrith fugitive dust or the so-called nuisance violation, there isn't much you can co but comply. The violation dated July 2S requested that plans to correct emissions be* submitted to the Environmental Health Division cn or before August 11, 1972. I feel very strongly that this reply should consist only of a compliance schedule and no mention should be made or the type of control devices that you are planning to install. As I stated over the phene the compliance schedule should be as long as possible, and if you plan to nave the Construction Products Division do the engineering, purchasing and installation, the minimum tine would be nine months. Jh** //'*'* -O f/'/n //- /**<- & 'T"~ JZ*-***'~*` i I IQ0 . X--Lr-Junke "c* August 1, 2372 The fcllov.'ing is a draft of a compliance schedule that I would submit to the Dallas City Health Department*: Gentlemen: In accordance with & notice of violation dated July 2S, 1372, from the Environmental Health Division, The Texas Vermiculite Company submits the following schedule to place its two Veraiculite Expanding Furnaces in complete compliance with-air pollution regulations established by the City of Dallas and the Texas Air Control Board: Date Start Finish Description 9/1/72 1/1/73 Engage engineering services in the field of Air Pollution Abatement and conduct a preliminary investigation of manufacturing equipment and building changes required fer new control devices. After review of this preliminary investigation, engineer will conduct detail design to incorporate control devices on the two verniculite expanding furnaces. 1/1/73 2/1/73 Submit plans and specifications for review to the Control Agency. 2/1/73 S/1/73 "S/1/73 7/1/73 After receipt of approved plans and specifications, and a permit to construct, procure all required equipment to place two vermiculite expanding furnaces in compliance with controlling air pollution regulations. Install all equipment in accordance plans and specifications approved by the controlling agency. In order to fulfill sales conni ttments during this period of ccmpliance, one furnace at a time will be shut down for modifications and the installation of the control device. 3/1/75 Both vermiculite expanding furnaces operating in compliance with established air pollution regulations and available for inspection by the controlling agency. d PLAINTIFF'S EXHIBIT L. Junker -j August 1, IP" The Texas Vemiailite Company will do everything possible to expedite its program of cowpliar.ce/but would appreciate confirmation from the Environmental Health Division that it accents the schedule set forth. Very truly yours. R. L. Junker As I stated over the phone, ve have had no problem in the past in obtaining approval for a nine to twelve month conpliar.cc schedule. Minneapolis is a typical case, where CPD changed its mind many times and after approximately two and a half years, submitted a final compliance schedule. For your information, I am attaching a copy of the conpliance schedule submitted to the State of Minnesota and the City cf Minneapolis and the plans and specifications covered in item 1 of-the conpliance schedule*. If Texas or the City cf Dallas does not issue permits to con struct, you should receive written confirmation from the agency that they accept your plans and specifications as presented. I am enclosing a print of the Trenton Model "A" bag house installation, which will be similar to your installation, although location of the control device will be different. We have standardized, on the Flex-lQeen bag house Model 84RA30, but the Mikro Pul Model 1F1 Collector is a near equal substitute. The Flex-Kleen unit has approximately 120 sq.ft, more fabric area and costs about $200 less than the Mikro Pul. I* am enclosing specs and costs on both units. Also enclosed are prints of the VonoKote mixer that we have installed in Pompano, Muirkirk, Trenton, and Santa Ana. I am also enclosing prints of the Pompano Perlite collection tower and vent system. If time permits, I will include a cost estimate for these two items in this letter, if not, it '.all be sent along in a few days. Again, I apologize for my procrastination, but if I can be of any help in any problems that you have, especially pollution abatement, I will try to be a little more prompt next time. cc: M. Mornn/Tex.Verm,w/o attach. T. Lyall -w/o attach. J. Timmons/T.R.- w/o attach. FWErhll Very truly yours, Frederick W. Eaton .Project Engineer Pollution Control PLAINTIFF'S l EXHIBIT 1