Document zz3Le7d8qazamyae1nYLXJBvz

V > CertainTeed Corporation Pipe & Plastics Group P.O. Box 253 Sulphur, LA 70663 (318) 882-1441 (CCrtrj^if . uXI ^^<-6 6 iJf-prc< 1 X V + Y ^ 7 .`Trx`, CertainTeed El August 24, 1988 Mr. Chris Roberie Program Manager Air Quality Division Louisiana Department of Environmental P. 0. Box 44096 Baton Rouge, LA 70804-4096 Quality Dear Mr. Roberie: SUBJECT: SEMI-ANNUAL LESHAP PERFORMANCE MEETING - AUGUST 2, 1988 On November 30, 1987, in a letter to Gustave VonBodungen, CertainTeed committed to two capital improvement projects designed to reduce the number of hours out of compliance with the 10 PPM Vinyl Chloride emission limit from CertainTeed's incinerators. For the first project, approximately *40,000 was spent to increase the surge capacity of the incinerator feed system. The objective was to reduce variations in flow, pressure, and concentration to the i ncinerators. This project was completed during a plant turnaround in February, 1988. A second project costing approximately S100,000 involved the replacement of the combustion chamber on the oldest incinerator. This was done to incorporate the manufacturer's newest burner and fume inlet design features and was completed during a plant turnaround in February, 1988. In a continuing effort at improvement, CertainTeed has budgeted approximately *100,000 for replacement of the combustion chamber of the 1979 incinerator. This will insure that both incinerators have the latest combustion technology, and should mean that emissions of Vinyl Chloride are well below the 10 PPM emission limit. This project is scheduled for completion in January, 1989. A review of the LESHAP violation incidents discussed meeting reveals three significant areas: in the August 2 1) Timing of the Incidents A11 six teen (16 above mentioned occurred in the and May. incidents occurred before completion of the projects in February, 1988. No incidents second quarter report covering March, April, 01-91 *0283 CTL000598 Mr. Chris Roberie Page 2 August 24, 1988 2) Quantity of Vinyl Chloride Released Seven of the six teen incidents involved releases of less than 1.00 pounds each. The remaining releases were between 1.03 and 4.95 pounds each, This data is presented in Table I. None of these incidents involved the release of any significant quantity of Vinyl Chloride. 3) Failure of the Continuous Emission Monitor CertainTeed's Instrument/Electrical Technicians are capable of performing routine maintenance and troubleshooting on the Areas gas chromatograph used as the Continuous Emission Monitor. The failure reported on the CEM was extremely unusual in that several printed circuit boards failed simultaneously. This was beyond the diagnostic capabilities of CertainTeed personnel so a factory-trained serviceman was flown to Lake Charles to perform the diagnostic and repair work. The unusual nature of this falure could not be anticipated, and therefore; would not be covered during the preventative maintenance that is performed yearly on the CEM. CertainTeed has responded positively to environmental challenges and in recognition of its environmental performance, has received Environmental Achievement Awards from the Vinyl Institute for 1986 and 1987. In considering proposed penalties relating to LESHAP discussed in our August 2, 1988, meeting, CertainTeed would Department of Environmental Quality personnel considering mentioned facts in our favor to assess the minimum applicable violations appreciate the above penal ties. Sincerely, (V--^ Bruce J. Brocka Technical Supervisor - cma Attachment CTL000599 TABLE 1 CERTAINTEED CORPORATION SUMMARY OF LESHAP INCIDENTS DATE 09/30/87 10/22/87 11Z06/87 12/16/87 01/06/88 01/22/88 02/13/88 02/14/88 02/15/88 TOTAL HOURS 16 AVERAGE 16 12 30 17 29 28 24 12 38 61 33 87 37 106 102 41 VINYL CHLORIDE IN EXCESS OF ALLOWABLE EMISSION LIMITS 0.31 POUNDS 0. 10 1.03 0.36 0.98 0.93 0. 72 0. 10 1.45 2.63 1. 19 3.97 1.39 4.95 4. 75 1.60 26.48 POUNDS TOTAL CTL000600 EXPRESS MAIL next day [B 6 i' ' 8 Service Guarantee: Oomestic mailings under this service made at designated USPS facilities on or before a specified deposit time will be accepted for express shipment to a designated USPS delivery area having Express Marl service for next day delivery to an addressee or agent on or before the time specified by the USPS at mailing. USPS will refund upon application to originating office the postage for any shipments mailed under this service and not meeting the service standard except for those delayed by strike or work stoppage See chapter 2 of the Domestic Mail Manual for details. Customer: Please tear off this stub and keep it for reference when depositing prepaid Express Mail Next Day Service shipments in Express Mail collection boxes or when giving prepaid Express Mail Next Day Serviceshipmentsto Postal Servicedelivery personnel. Affix the remaining label set to your shipment. For reference, write on this stub the date that the shipment was mailed (if deposited in an Express Insurance Coverage: See section 294 of the Oomestic Mail Manual for exclusions of Date Mailed: Initials: Orno^ coverage. (1} Merchandise insurance. Merchandise is insured against loss, damage or rifling up to a maximum of $500. Indemnity will not be Mail Collection Box, also initial the stub). Deadlines for deposit for next day delivery differ according to paid for spoilage of perishable items. the destination. To ensure nextday delivery consult (2) Document Reconstruction Insurance. Non-negotiable your local Express Mail Directory documents are insured against loss, damage or rifling up to i $50,000 per piece subject to a limit of $500,000 per occurrence. Postal Acceptance Employee: Signature is required upon delivery. Claims for delay, loss,damage or rifling must be made within 90 days. Claim forms may be obtained at the post office of mailing. The Customer Receipt must be presented when a claim is filed. After completing the "Origin" and "Acceptance" blocks on the mailing label, give this stub to the mailer along with the Customer Receipt copy. Label fl-B (8-64) CTL000601