Document wD80O14dmOzvxEwzN76MLQGxQ

TO Distribution Interoffice Communication FROM: DATE: SUBJECT D. R. Booth July 10, 1990 EPA's Section 114 Request Response VISTA Enclosed is the final Section 114 Response. through the efforts of the following team: It was prepared Glen Hollinger Dana Neely Ray Plewa Sean Shephard Sam Watson I would like to thank each team member for his/her contributions, all of which made this response possible in a timely and professional manner. This report provides a valuable service for the future. Q.nJ. D. R. Booth Sr. Environmental Coordinator br(5) Distribution JF CRD MGH RAP SPS (LCCP) JWW AAS (LCLAB) RAC SAR GWB SAW DRB (VCM) JCL WLM DMN GMH TWH (Houston) VVV 000003200 Vttto Chemical Company Lake ChariesVCM Plant VCM Plant Rd, RO. Box 605 CERTIFIED MAIL #906 689 532 RETURN RECEIPT REQUESTED June 28, 1990 Westlake, Louisiana 70669 Phone (318) 494-5000 Ms. Penny Lassiter U.S. Environmental Protection Agency Office of Air Quality Planning & Standards Research Triangle Park North Carolina 27711 \Yi II Dear Ms. Lassiter: In response to Jack R. Farmer's letter of March 16, 1990 and your letter received in April, the following items are being submitted. 1) Enclosure 1, revised to include the additional production data requested. 2) Enclosure 2 for Vista's Ethylene Unit (Process 1), LAB Plant (Process 6), and one submission for both EDC Process (Processes 2 & 5) and the Vinyl Chloride Process (Process 4). As you recall, you waived the request for information regarding the Alcohols Unit (Process 8) during our phone call in April. In addition Vista believes it necessary to caution the U.S. EPA regarding the use of this information. This data as you requested is based on 1989 operations. With the promulgation of the new Toxicity Characteristic Rule, a large number of organic chemical manufacturers will have newly regulated RCRA wastewaters. Many manufacturers are so dramatically modifying their wastewater sources, and treatment systems that the data submitted will most likely not be representative in two years. We request that this be given due consideration in the development of any new standards. If you have any questions regarding these submittals, please refer them to David Booth of our Environmental Department at (318) 494-5031. Sincerely, Plant Manager br(C2) 00003201 VVV 0