Document zd1RpLpR2brN7Mk0MeZVezEDB

M EMORANDUM TO: Mr. d. M- DeVoe w.F.R 7k DEC 91974 DATE December 3, 7 7? KM*/- 147 4 suf3ject: Communications from the La. Air Control Staff 2) Revised Air Compliance Schedule For submittal to State Jr your review and disposition of the attached subject matter, please consider the. following: 1) We Hive informal information from the Commission Staff to the effect 1 that any revised comel.iance schedule extending beyond the Federal deadline of May 3 1, l'7S, will not be submitted to the Commission for approval. Such, schedule will pe forwarded to EPA .in Dallas where the company will be declared in violation and wind up with some litigation and a negotiated deal. 2) V.'s thought it best to await further confirmation of vinyl in the Heads Column Vent 2 and .in the Lights Column Vent 17 by future stack sampling be :`o"e injecting same in our revised compliance program at the present time. 3) A local PC-1 has been written toward an appropriation renuest for a condenser on the direct chlorination vent. This would recover EDC which is now vented to the HC1 absorption pond and flare when the oxyhydroehlori r.a L ion U..i: ,I*.4L-- *io.. ',J1 UW_ U. - , l.?,, cP,JLtr IlnUeL L- U--K, 1I .i\ 1 J. , +--tl -rK lr-*i3 n J.viI-.h 1r*.tf W+J*hICfi f 1- i4 ^^ n*^Winw- n` ri ( - `i^'i1C' at the ore sc time because we are not suT,e of anoropriation approval. 4) Should we delete plan 4 from the timetable and state reasons for ed'1 * being the noun ash section is scheduled to be shut doer) in 1077- We estimate this plan to cost in the range of -3100,000 - 3130,000. Please advise. t^- ! Wr/AJL:cf At Inch. cc: Mr. Mr. Mr, i., i.. James T. 0. bent A. .i. von Frank J *^P. B. Cornell, Manager j Baton Rouge North Works ^ T.O. K. r l d : n i j *\ a ASI 00005900 Industrial Chemicals Division i ALLIED CHEMICAL. CORPORATION -j P O. Box 271. Baton Rout'e. Louisiana 70821 (504) 35G-3341 Mr. James Coerver Technical Secretory Louisiana Air Control Commission F. 0. Box 0063D New Oi lcans, r,a . 70160 Dear Mr. Coerver: As ner your letter of November 8, 1974 and further communications by our Environmental Control Section with Mr. Atley Brasher in your Technical Section, we are submitting herewith a revised compliance schedule for your appvnva1. The compliance schedule in question was approved at the June 6, 1974 public her.riq- of the Louisiana Air Control Commission. This approval covered the fol loving: 1) Inorganic plan originally submitted August 23, 1972 (revised 1/25/74) 2) Hydrocarbon plan originally submitted 10/10/73. The reasons for delay in meeting our original timetable and for the extended nature of the presently revised timetable are as follows: Required additional engineering study and decisions to expand the vinyl chloride monomer systems to meet the more stringent OSIiA regulalions. There was an overload of other environmentally related work, inelud ir OS I (A a nd water pollution control^ ^ v e Experienced a shortage of engineering personnel."^" --- ----------- Experienced slow delivery of equipment and materials of construction and expect more of same. Very truly yours, P. B. Cornell, Manager Baton Rouge North Works n.q ASI 00005901 am.inn cm>11 cat, /CH/ncr/ timctaui.c ion - ipton pouhd north corks NOVUM!'PR 25 , 1 '>7 4 Design and install new dust collecting system on lime kilns discharges and conveyors. Status Tjmo tn a ! e Prel.iminarv engineering Approuria tion Request Appronriat ion Anorova1 Cewp'J e te Pngi nee ring Comp tote liirchasing Mate rial equipment Delivery Compiete 1 ns ta1lation Start Operation Tn progress In progress - - - - - 2/1/75 2/13 '7 5 4/1/75 4/15/73 5/1/75 4/1/73 11/1/73 12/1/73 Purchase and install an improved hag dust collector system to replace present one in No. 4 elevator tower in soda ash section. (S imi ] qr actions on Nos. 1 and 3 elevator towers have been completed). Prelimina ry fngineering Appropriation Request Anpropi'.iat ion Approve L (3imp 1 ete Peg ineor i ng Cornu 1 ete Purehos.ing MMerial & equipment Delivery Comp I ele Ins La llation Start ((aeration Completed Completed Completed - - - - - - 12/15/74 12/15/74 1/1/75 3/1/75 4/1/75 Purchase end replace ('our (4) bay dust systems in dense ash operating systems. Installation of three (3) of those bay dust collector system have been cornel e ted. The remaining system will he made a part of Plan 4 (heJ-.v,). Design and install dust collecting systems on soda ash loadings into trucks and rail cars. Pro 1 im i na ry Pngi n^er j rig Aoprouriation Request Apnropr.ia t ion Approve 1 Ci >n.r' i e t<* l.ng i nct'r i ng L e i ' i ? f ha s i ng '; ; l i -1 i ;i i i'. ; .nn i p.iront !/! ivory C< - i' I ot e I a ., ) 1 a t i on S tart Opera I i on Completed In Progress 4/1 S/7 5 7/13/7.3 0/1 '73 ASI 00005902 -2- r:--\K' 5 - Design and install a vapor recovery system for vinvl. chloride monomer vapor. Status T i me table raary engineering Appron r in t i on keenest A m ropriat. ion Approval " nlete Cng i neer i ng j plete I'urchas i ng Material & Leuipment Delivery Start fnslc! 1 la L ion Comolete 1 nstn1 la tion art Operation Completed Completed Completed 3/31/75 `1/30/75 *!/3 0/7 0 5/3 1 /7 0 8/31 /7 0 10/31/70 an of Quench Column Vent. This vent will be put through the proposed VCM vapor recovery system. It will thus be a part of the preceding Plan 5. ..an 7 - Install condenser on Vent 2 exiting the heads column. :: Mary Engineering tion Request - vion Approval Engineering f'urcha sing f .a t cr ia j > i.au * pment Delivery Sturt f ns It! 1 1 at ion Comp let e insta11a tion start Operation Completed Completed Completed In Progress In Progress In Progress In Progress 12/31/7" 12/31/7 4 5/31/75 5/31/75 0/30/7 S 10/31/75 Plan 7A- A nressurized, condensate storage will be required in the preceding Plan 7, but due to slow delivery, a currently available regular store tank will be substituted and then replaced under this plan 7A. Orel imiu-i rv engineering Appron ; t i on itenuest Appropr?ation Anurova 1 Complete engineering f rmlote Purchasing , te!-'nl Lauipmorit Delivery - " ' Hat i on sta3.In tion .Start Operation !'l jj\ H - Install eendenser on vent 17 ex ting the lights eolumn. 4/30/75 5/31/75 7/31/75 8/31/75 9/30/75 12/31/70 1/31/7 7 4/30/77 5/31/77 Pn 1 im : i e. i. i r Lug i rv -vr i ng n keenest' 1 ApproveL neeripg has i n-' u i piMe n t De 1 i vr ry Sturt Ip, l lotion Sturt tjoP Corn:: 1 < t-'d In I'rogress 3/31/75 5/31/75 a/30/75 .10, 3 1./75 10/31/70 0/'!/7 7 0/31/7 7 ASI 00005903 -3- ijr a n n - Modify caustic scrubber piping to make use of the proposed Veil vapor recovery system give in in the preceding flan 5. T!i is vent win be put through the proposed VOM vapor recovery system. It will thus be a part of the preceding Plan 5. ASI 00005904 _L P.O. {:Qy, C 0630 K'cr;r Orfccns 7Ci60 November 18, 1974 Mr. P. B. Cornell Manager Allied Chemical Corp. (North Works) P. 0. Box 271 Baton Rouge, LA 70821 Dear Sir: A review of our files indicates that some "increments of progress" listed in your compliance schedule were scheduled for completion during the past month. Please in form this office of the status of these increments of pro gress by using the attached form. If any of these incre ments have not been accomplished by the scheduled date, please submit a revision to the compliance schedule reflect ing the projected date the increments will be aceomplished, as well as the final date for compliance and the reasons for the delay. Your cooperation in providing this information will be appreciated. If you have any questions, please contact Mr. Atly Brasher of our staff at 504/527-5119. Very truly yours RCCC.1V BATON Hi, NORTH Wi AB:jad Enc. cc: Mr. H. Ledet, S.E. Regional Office PRC PROD, I ASI 00005905 LOUISIANA ATR CONTROL COMMISSION This report is necessary to keep this office informed of progress Industries have made toward completion of their compliance schedules. It also serves to keep this office informed of difficulties industries are having in meeting their incre ments of progress. Any explanation of the reasons for the delays in accomplishing increments are not required with this report. These should be Included with the semiannual re port and the compliance schedule revisions. A revised compliance schedule should be submitted whenever there is a change in the date of an increment of over 30 days. These compliance schedule revisions have to be approved by the Air Control Commission and then submitted to the Environmental Protection Agency before becoming an official part of a company's compliance schedule. Please fill out below and return to the Air Control Commission within 10 days of receipt. MONTH: OCTOBER PROJECT Title or Description INCREMENTS OE PROGRESS REPORT FORM COMPANY NAME: ALLIEO CHEMICAL CORP. (NORTH WORKS), Baton ------------------------------------------------------------------------------------------------ Ptmge, DATE Accomplishad La. Completed by: ASI 00005906