OAR Box 1107 

Prepped by Ollie Stewart 

Document Number: 

36) IV-C-4 

Docket Number: 

A-81-21 

Printed 4/11/2008 3:03:46 PM Sheet 36 of 90 

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A-8I-2I 

IV-C-4 

;. DEC 1984 

€ 5 DEC '•%*• 

Hr. K. S. Komeroskl 

P. P.&Industr1es 

Post Office Box IOOO 

Lake Charles, IA 7G6P2 

Dear Pr. Kocoroskl; 

Th1s letter is to conflra our November 29th telephone conversation 

/ that a Besting has been scheduled for December 11th at 8:30 A.M. 1a 

Durham between representatives of the U.S. Environmental Protection 

Acency (£PA), Radian Corporation, and your company. As we discussed, 

the purpose of the meeting 1s to gather Information that win Improve 

our understanding of the need for adding a control device bypass provision to the vinyl chloride (VC) eBlsstoo standard, A second purpose Is 

/ to Identify additional data required for any further Investigation of an 

appropriate bypass provision. 

Specifically, we are seeking Information freo yoor cospany about the 

following: 

1. The general design and operating parameters of the control 

devlce(s) used at your EK/VCH facilities to control exhaust gases subject to the VC standard. For Incinerator controls, general design and 

operating parameters of Interest Include operating temperature ranee, 

design capacity, maxlmue capacity and turndown capabilities. Also of 

Interest Is the usual state of the backup control device (cold, warn, 

or hot) and the t1«e repaired to switch to tht backup device. 

2. The types of process upsets (or other conditions) that could 

lead to the bypass of Incinerator system 9n6 how such conditions wight 

be avoided. 

3. The types of Incinerator »alfunction that could lead to the 

bypass of the Incinerator system and how such malfunctions alght be 

avoided. 

4. The method used te estimate the amount of VC 1n the bypassed 

exhaust gas streams. 

5. Any sethed used to monitor t*e VC content of tbe Incinerator 

discharge or bypass. 
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. Far f.OC/VC facilities . tfUM&rtlon of exhaust gas that coses 

fro© the tDf/vc purificatio n vents and the ox^chlorinatlon reactor vent 

aw* the impact of the exyehlorlnatlon vent fluctuation on control device 

bji>ass frequency and duration. 

7. A srle f description (reason ind gjsotjnt) of any ^C emissions 

caused by plant, start-ap or shutdown. 

9. An "Incineration Bypass History" stella r to that presented at 

our October SO, 19M meeting but with reasons for bypasses (i f possible). 

I f yon have any questions about these discussion 1tess, please cal l 

ine at (?19) 541-5671. We appreciate your continued cooperatleo 1n our 

reviev* of the VC standard and look forward to aeeting with you. 

Sincerely, 

Leslie 8. £vans 

Chemicals ?*dnufactur1ne. Section 

Cfceelcals *n4 Petroleus Branch 

0A0PS,ES£D,CPB,CHS,L.EVAKS,1hanzely,HCH,MD-13,ta737,x5671.12-03-84, 

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Identical letters were sent to the following companies with the noted changes 

W.B. Barton 

Director, Environmental Affairs 

Borden, Inc. 

1800 East Broad Street 

Columbus, Ohio 43215 Line 2: January 3, 1985 

Mr. W.C. Holbrook 

BF Boodrich 

Department 5456 

6100 Oak Tree Boulevard 

Cleveland, Ohio 44131 Line 2: January 7, 1985 

Mr. J.C. Ledvina 

Director, Environmental Activities 

Vista Chemical Company 

15990 North Barker's Landing Road 

Houston, Texas 77224 Line 2: December 12, 1984