OAR Box 1107 

Prepped by Ollie Stewart 

Document Number: 

49) IV-E-5 

Docket Number: 

A-81-21 

Printed 4/11/2008 3:03:47 PM Sheet 49 of 90 

p.1 
P.2 

A-8I-2I. 

IV-E-5 

MEMORANDUM 

DATE: March 25, 1985 

TO: W. Fred Dimmick, Standards Development Branch 

FROM: Karen K. Fidler, Radian Corporation 

SUBJECT: Vinyl Chloride - Report of Visit to Louisiana Department of 

Environmental Quality/Air Quality Division 

Purpose of Visit 

A visit was made to the Air Quality Division of the Louisiana 

Department of Environmental Quality in Baton Rouge, Louisiana on March 21, 

1985 for the purpose of collecting information on incinerator bypass 

occurrences in the vinyl chloride (VC) industry in Louisiana. Reports 

containing information on incinerator bypass occurrences during the period 

March 1983 - February 1985 were obtained for the one EDC plant, six EDC/VC 

plants and five PVC plants currently operating in Louisiana. Attachment 1 

lists the plants for which information was obtained. Afterward, a meeting 

with three representatives of the NESHAP Unit of the Air Quality Division 

was held to discuss the incinerator bypass situation in Louisiana. Observations on the January 9, 1985 proposed revisions were also presented during 

the meeting. Attachment 2 lists the meeting attendees. A summary of the 

meeting discussion is given below. 

Discussion on Incinerator Bypasses 

- Authority for administering the VC NESHAP was delegated to the 

State of Louisiana in 1983. 

- Currently, the State LESHAP regulations are consistent with the 

federal NESHAP regulations. 

- Louisiana interprets the standard as strictly prohibiting 

incinerator bypasses to the atmosphere containing VC. 

- PVC plants (particularly the nonintegrated PVC plants) have less 

of an incinerator bypass problem than EDC/VCM plants. Possible 

explanations for this include smaller vent gas flow and absence of 

wet vents. 

- PVC plants tend to have 10 ppm exceedences instead of bypasses. 

- Louisiana is currently working with plants on an individual basis 

to reduce the frequency and amount of incinerator bypasses. 
P.3 

y 

Although they are pleased with the results to date of their 

program to reduce incinerator bypasses, Louisiana believes the 

plants are capable of further improving their performance. (For 

example, they expressed confidence that Borden can achieve an 

agreed upon 90 percent reduction in bypass occurrences in the near 

future by upgrading instrumentation, modifying the incinerator 

switching mechanism and performing simple changes in operational 

procedures.) 

Louisiana's goal is for plants to reduce bypass frequency to a few 

per quarter by performing inexpensive modifications to existing 

incineration systems and operational procedures. 

Examples of effective and inexpensive measures that have been (or 

could be) taken by plants to reduce bypasses include: 

(1) thorough investigative analyses of individual bypass incidents, 

(2) first-out indicators on incineration equipment, and 

(3) official preventive maintenance programs. 

No enforcement actions on incinerator bypasses alone* have been 

filed to date for several reasons: 

(1) Their plant-by-plant approach to reducing bypasses has been 

effective. 

(2) Since the standard prohibits all bypasses, they don't feel 

justified in singling out one or two plants to enforce against. 

(3) Manpower is not available to handle paperwork associated with 

enforcement actions against all plants. 

Enforcement action may be used in the future to "encourage" 

noncooperative plants to improve performance (particularly if 

other plants have reached performance goal). 
P.4 

ATTACHMENT 1 

Louisiana Plants for Which Incinerator Bypass Information was Obtained 

Plant/Location 

B.F. Goodrich/Plaquemine 

Borden Chemical/Geismar 

CertainTeed, Inc./Lake Charles 

Dow Chemical/Plaquemine 

Formosa Plastics/Baton Rouge 

Georgia-Gulf*/Plaquemine 

Occidental Chemical/Baton Rouge 

PPG Industries/Lake Charles 

Vista Chemical/Westlake 

Vulcan Chemicals/Geismar 

Product, 

PVC 

EDC/VC, PVC 

PVC 

EDC/VC 

EDC/VC 

EDC/VC, PVC 

PVC 

EDC/VC 

EDC/VC 

EDC 

•Formerly Georgia-Pacific. 
P.5 

ATTACHMENT 2 

List of Meeting Attendees 

Bill Davis, Chief of NESHAP Unit/Air Quality Division 

Frank Berry, NESHAP Unit/Air Quality Division 

Cliff Janney, NESHAP Unit/Air Quality Division 

Karen Fidler, Radian Corporation