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UNION 

CARBIDE 

RECEIVE D 

AGRICULTURAL PRODUCTS COMPANY, INC. §gp . 

PO SOX 428. WOODBINE. GEORGIA 31569 

Woodbine Plant 

(912) 729-9100 

012)265-0180 September 17, 1986 

Jack E. Ravan 

Regional Administrator 

United States Environmental Protection Agency 

Region IV 

345 Courtland Street 

Atlanta, Georgia 30365 

National Response Center 

Commandant - 6 T6C - 2 

2100 Second Street, S.W. 

Washington, DC 20593 

Reference: Superfund Reporting - Continuous Releases 

Dear Sirs: 

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, 1n 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 1s attempting to assist EPA 1n developing technically sound and 

consistent regulations. To that end, Union Carbide, together with several 

other Interested companies, have met with EPA 1n Washington and explored 

various Issues and concerns regarding continuous and federally permitted 

release matters. We Intend to continue these discussions. 

In addition, the Woodbine, Georgia Plant of Union Carbide wishes to 

share with EPA and the National Response Center data and Information 

regarding certain air releases which 1t believes may fit within the 

continuous release or federally permitted release reporting exemptions. This 

data and Information, which are enclosed, relate to emissions which are 

routine, anticipated releases to the air Incidental to the normal operation 

of the pesticide formulation facilities at the Woodbine Plant. These 

releases which may equal or exceed the applicable reportable quantity, are 

predictable during normal operations. The quantities and rates of emission 

are directly related to the rates of pesticide formulation and vary with the 

cyclical operation of the formulators. 
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It must be recognized and emphasized that the emission values (which 

are reported 1n the attached data as ranges of emissions) are estimates of 

actual releases. They are based on a combination of design calculations, 

material balances, and sampling data and Include engineering Judgments. 

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

"statistically significant Increase" for a continuous release, the Woodbine 

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, nitogen dioxide, which 1s both a hazardous substance under CERCLA 

and a criteria pollutant under the Clean A1r Act, 1s generated as a product 

of combustion 1n Industrial boilers, flares and other combustion devices. 

From all such sources, nitrogen dioxide 1s produced at rates often measured 

1n tons per day. 

not 

Union Carbide 

Intended to be 

assumes that 

Included 1n 

these combustion product emissions were 

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 1s aware of their existence and has no reason to 

exercise Its authority under CERCLA 1n response to such emissions. 

Accordingly, we are not submitting any data regarding such nitrogen dioxide 

emissions. 

1 

The Union Carbide Woodbine Plant believes the data and Information 

contained 1n this submission establish for 1t the Identified air emissions 

as continuous releases under CERCLA. If NRC or EPA wants to receive 

additional data or Information, or 1f you have any questions regarding the 

contents of this letter or Its attachments, please advise me. 

Very truly yours, 

Attachment 

cc: Mr. Lou Musgrove 

Environmental Engineer 

A1r Pollution Compliance Program 

Georgia Department of Natural Resources 

205 Butler Street, S.E. 

Floyd Towers East 

Atlanta, Georgia 30334 
SUMMARY OF CONTINUOUS EMISSIONS FOR THE WOODBINE PLANT 

CHEMICAL 

Name CAS No. 

SOURCE 

Process Unit/Facility ID/Etc. 

CAUSE OF RELEASE 

No. of 

Times RQ 

Equalled 

or 

Exceeded 

per Year' 

Range of Release 

Minimum Maximum 

(lb/Day) (lb/Oay) 

RQ 

Methylene Chloride (DCM) 75092 TEMIKR-On-Grit Formulation DCM emissions occur during 

the unloading of aldicarb/OCM 

solution from tank trailers, 

the addition of a binder to a 

batch tank, breathing of the 

solution storage tanks, reloading 

of DCM to return tank trailers, 

air conveying of formulated 

product, product screening, and 

breathing of storage bins. 

260 120 5500 1000 

TEMIKR-On Gypsum Formulations Emissions result from the 

weathering-off of residual DCM 

in the formulated product during 

mechanical conveying, screening, 

and breathing of storage bins. 

200 200 2900 
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Blind Internal Distribution: 

D. K. Wagner 

D. L. McKenzle 

W. M. Lanham 

D. E. Arnold 

D. B. Cunningham 

A. A. Komarek 

Chris Smith - RTP 

J. A. FUzerald - RTP 

G. R. Kraft/P3 - Danbury 

R. F. Kelley/J3 - Danbury 

R. A. Hatthews/E3 - Danbury