P.1 

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UNION CARBIDE CORPORATION 

POLYOLEFINS DIVISION 

UNION 

CARBIDE 

P. O. BOX 186 

POET LAVACA, TEXAS 77979 

September 18, 1986 

Regional Administrator 

EPA Region 6 

1201 Elm Street 

Dallas, TX 75270 

National Response Center 

Commandant - G TGC - 2 

2100 Second Street SW 

Washington, DC 20593 

Dear Sir or Madam: 

RECEIVE D 

SEP, 3 ". 1980 

R. F. KEUEVJ 

Re: Superfund Reporting - Continuous Releases 

As you are aware, there has been considerable confusion regarding the 

hazardous substance release reporting requirements under the Superfund or the 

Comprehensive Environmental Response, Compensation, and Liability Act of 1980 

(CERCLA) provisions addressing continuous releases (Section 103(f) and federally 

permitted releases (Section 101(a) (10). Indeed, in EPA's promulgation of the 

final regulations addressing reporting requirements generally, EPA stated that 

"due to the complexity of the issues involved, the Agency has decided to study 

[these issues] further: today's rule does not resolve [these issues]." 50 Fed. 

Reg. 13458, April 4, 1985. 

The most recent Regulatory Agenda indicated that EPA intends to propose 

regulations on both subjects by the end of this year. Union Carbide Corporation 

is attempting to assist EPA in developing technically sound and consistent 

regulations. To that end, Union Carbide, together with several other interested 

companies, has met with EPA in Washington and explored various issues and concerns regarding continuous and federally permitted release matters. We intend 

to continue these discussions. 

In addition, the Seadrift, Texas, Plant of Union Carbide wishes to share with 

EPA and the National Response Center data and information regarding certain air 

releases which it believes may fit within the continuous release or federally 

permitted release reporting exemptions. These data and information, which are 

enclosed, relate to emissions which are routine, anticipated releases to the air 

incidental to the normal manufacturing, treatment processes, and operation of 

facilities and vessels at the Seadrift Plant. These releases, which may equal 
„R2_ 

Superfund Reporting - Continuous Releases • -2-

or exceed the applicable reportable quantity, are stable in quantity and rate and 

are generally predictable during normal operations. Most of the enclosed data 

were previously submitted to the state agency in the form of an Air Emissions 

Inventory, dated.March 15, 1986. 

It must 'be recognized and emphasized that the emission values (which are 

reported in the attached data as ranges of emissions) are estimates of actual 

releases. These estimates are based on one or more variable factors and sources, 

which may include process design calculations (both operational and treatment), 

sampling data, emission factors, and often require individual engineering judgments. For example, the use of controversial emission factors in calculating 

fugitive losses (as required, for example, in our Air Emissions Inventory) can 

lead to widely varying results. 

In the absence of guidance from EPA as to what constitutes a "statistically 

significant increase" for a continuous release, the Seadrift Plant intends to 

report any releases which are known to exceed the upper limit of the identified 

range. Reportable releases not covered by the (above or enclosed) information 

will continue to be reported on an individual basis. 

In the course of our data compilation and review, we identified an issue of 

broad application which we wish to bring to your attention. As you are aware, 

nitrogen dioxide, which is both a hazardous substance under CERCLA and a criteria 

pollutant under the Clean Air Act, is generated as a product of combustion in 

industrial boilers, flares, and other combustion devices. From all such sources, 

nitrogen dioxide is produced at rates often measured in tons per day. 

Union Carbide assumes that these combustion product emissions were not 

intended to be included" in CERCLA's reporting requirements. As a criteria 

pollutant, nitrogen dioxide emissions are either directly permitted or generally 

regulated (for the larger sources) under State Implementation Plans. 

In either case, EPA is aware of their existence and has no reason to exercise 

its authority under CERCLA in response to such emissions. Accordingly, we are 

not submitting any data regarding such nitrogen dioxide emissions. 

The Union Carbide Seadrift Plant believes the data and information contained-' 

in this submission establish for it the identified air emissions as continuous 

releases under CERCLA. If NRC or EPA wants to receive additional data or information, or if you have any questions regarding the contents of this letter or its 

attachments, please advise me. 

Very truly yours, 

D. L. Goris 

Plant Manager 

DLG:jh 

Attachments 
P.3 

Superfund Reporting - Continuous Releases -3-

cc: Mr. A. E. Bell 

Executive Director 

Texas Air Control Board 

6330 Highway 290 East 

Austin, TX 78723 

Mr. L. Sowards 

Executive Director 

Texas Water Commission 

P. 0. Box 13087, Capitol Station 

Austin, TX 78711 

Mr. J. R. Battalora - UCC Seadrift 

Mr. W. C. Dedeke - UCC Houston, Suite 109 

Mr. R. E. Graebert - UCC Danbury, M2 

Mr. R. F. Kelley - UCC Danbury, P2610 

Mr. R. A. Matthews - UCC Danbury, E3249 

Mr. J. D. Moore - UCC Seadrift 
SUMMARY OF CONTINUOUS EMISSIONS FOR THE SEADRIFT PLANT 

(1) 

Chemical 

Name 

Ethylene Oxide 

Ethylene Oxide 

CAS No. 

75-21-8 

(2) 

Source 

(*Process Unit, 

Facility ID, etc.) 

Oxide-Glycol Unit 

Butyl Glycol Ethers 

Ethanolamines 

Glycol Ethers 

(3) 

Cause of Release 

Secondary Emissions 

from wastewater 

Unit Start-up/Shutdown 

#2 Evaporator Vent 

Fugitive Emissions 

Vent Absorber 

#2 BRC Jet Vent 

Fugitive Emissions 

Fugitive Emissions 

Fugitive Emissions 

(4) 

No. of 

times RQ 

equaled 

or 

exceeded 

per year 

365 

12-18 

333 

333 

333 

333 

333 

333 

333 

Range of 

Minimum \ 

(Lb/Day) j 

i 

0 ' 

° i 

0 J 

} 

0 ' 

b i 

0 ; 

0 

0 ' 

0 i 

0 -

: 

(5) 

Release ., 

Maximum 

(Lb/Day) 

1.1 

2.9 

961 

3 

6 

1 

10 

8.2 

2.7 

Note 
SUMMARY OF CONTINUOUS EMISSIONS FOR THE SEADRIFT PLANT (cont.) 

(1) 

Chemical 

Name 

CELLOSOLVE 

CELLOSOLVE 

. 

Ammonia 

CAS No. 

00110-80-5 

7664-41-7 

(2) 

Source 

(*Process Unit, 

Facility ID, etc.) 

Distribution 

Distribution 

CELLOSOLVE Acetate 

Glycol Ethers 

Distribution 

Ethanolamines 

' 

(3) 

Cause of Release 

Tank Car Cleaning 

Tank Car Samples 

Hoses Vacuumed 

Sample Hood Col lection 

Header 

Tank Losses 

Fugitives 

Tank Losses 

Fugitive Losses 

Tank Breathing/Filling 

Losses & Associated 

Fugitives Emissions 

Flare 

(Incomplete combustion) 

Fugitive Losses 

(4) 

No. Of 

times RQ 

equaled 

or 

exceeded 

per year 

104 

260 

260 

260 

365 

333 

208 

208 

365 

333 

333 | 

Range of 

Minimum 

(Lb/Day) 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

7 

[Release 

Maximum 

(Lb/Day) 

f 

f 711 

| 13.4 

f • 

r 

1. 1.4 

f 4.5 

j 

f. 

\ 36 

1 17 

j

 ?4 

77 

1 104 

\ 

j 403 

138 

Note