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. e e DuPont Specialty Chemicals P.O. Box 347 12501 Strang Road laPorte, TX 77572-0347 C[(J PON] DuPont Specialty Chemicals February 8, 1996 Mr. Dan Pearson Executive Director Texas Natural Resource Conservation Commission P.O.8'ox 13087 Austin Texas, 78711-3087 A TTN: Dr. Charles Mauk Re: DuPont La Porte Facility ISW Reg. No. 30046 Permit No. HW-50213-000 EPA 10 No. TXD 008079212 Dear Mr. Pearson: This letter is a request by. the La Porte Plant to modify the site RCRA Part B permit (dated October 31, 1990) to allow treatment of several new waste streams in facilities 11.8.2,3,11 (Central Scrubbed Incinerator, CSI area). In addition, as required by the new Carbamate Listing last year a Class II permit modification is required to follow-up the Class I modification required on the effective date of August 9,1995. In short we are requesting the following changes: 1) Class II - Add the light organic stream currently stored and treated in facilities 11.8.7 & 14 to facilities II.B.2, 3, & 11. 2) Class II - Add miscellaneous wastes from our laboratories to facilities II.B.2, 3, & 11. 3) Class II - Add the K156/K157 listing to waste streams g, h, jj, and mm. Also this listing was added to permitted facilities 2 and 3. The first waste stream is listed in our permit as "1I.A.2.bb. Light Organics" and is currently stored in Permit Facility II.B.7. and treated in Permit Facility II.B.14. (P&IP area). DuPont would like the flexibility to handle this stream in Permit Facilities II.B.2, 3, and 11. Orthodichlorobenzene (ODCB), along with Carbon Tetrachloride, was used successfully in our trial burn as a Principal Organic Hazardous Constituent (POHC) for Permitted Facility # 11. ODCB is listed with a rank of 23-24 as a Class 1 Principal Hazardous Organic Constituent in the Thermal Stability Index. There are no new POHCs in the proposed waste stream "bb". As seen from the attached waste classification form (ATTACHMENT V), the waste (Plant code VS-8) is a 0001 stream containing water, methanol, acetic aci~, vinyl acetate, and acetaldehyde. Part of the permit modification process requires a determination be made as to the type of permit modification this request represents. Because the stream contains no new POHCs under TNRCC rules, it would be categorized as a Class II permit modification under Texas Administrative Code (T AC) 305.69; Appendix I, L. 6, b. regarding "Burning different wastes: If the waste does not contain a POHC that is more difficult to burn than authorized by the permit and if burning the waste does not require compliance with different regulatory performance standards than specified in the permit". E l. du Pont de NcmO'JiS Jnd Company ~ --