Document 1y1dr9N06MJ72ZVmYjZBjK6Xa
VCM Plant
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March 23, 1977
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Conoco Cliomicult Continental Oil Ctunp.iny I'.O. Dox 605 Westlake, Loiiisiann 70669 (3 1C) 002-0660
Mr. Paul D. Fahrcnthold Chief, Engineering Section Air Comp!ia.ice Branch Region VI, Environmental Protection Agency First International Building 1201 Elm Street Dallas, TX 75270
Dear Mr. Fohrenthcld:
Attached is the additional information relative to the waiver of compliance and-waiver of emission testing request for the Continental Oil Company VCM Plant that you requested in your letter of February 28, 1977. This informa tion is in addition to the information submitted in our original letter of December 21, 1976. l'e have tried to answer your requests to the best of our
Sincerely,
J. A. DeBernardi Plant Manager
is Enc CC + enc: Mr. Howard G. Bergman Director. Enforcement Division Region VI, ERA 1201 Elm Street Dallas, TX 75270
Mr. James F. Cosrver Technical Secretary, LA.CC P. 0. Box 6OS30 Row Orleans, LA 70160
BCC: RDG-CRH-JEC-DAK-vlF-G'.F-JHM-JR'I-JOG-PLF
[.Vf.iiiniiiit AnnUnN- Century of Sin vice - YVitli Cnnifjy
CCR 000021750
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REQUEST OF WAIVER OF COMPLIANCE - ADDITIONAL INFORMATION
As described in the Source Report of December 21, 1976, the Continental Oil Company VCM Plant presently has six emission points which cannot comply with sections of the National Emission Standard for vinyl chloride. The vent sources for each emission point and the particular paragraph of the regulation which applies to each source are listed below. A waiver of compliance from the listed paragraphs is requested for each source.
1) C-500 Stack, V5-391
This emission point contains the vent gases from ethylene dichloride purifica tion and oxychlorination reaction. Waivers of compliance from paragraphs 61.62(a) and 61.62(b) are requested for this emission point and the following emission sources:
Ethylene Dichloride Purification 61.62(a)
Light Ends Column Overhead Accumulator S-102 Heavy Ends Column Overhead Accumulator $-103
Oxychlorination Reactor 61.62(b)
Oxy Vent Heater 11-310
Control of the ethylene dichloride purification vents to VS-391 is not possible until CONOCO;s thermal incineration system is installed and operational. The oxychlorination reaction vent is to be controlled by the oxychlorination vent cleanup reactor, R-305. As indicated in CONOCO's letter of December 21, 1976, our oxychlorination vent cleanup reactor was the first such unit to be placed in operation; and several problems involving control, catalyst loading, and catalyst change-out have been experienced. A waiver of compliance of paragraph 61.62(b) Tor the oxychlorination reaction vent has been requested to allow time for control optimization, catalyst aging experience, and to install cool-down and heat-up piping for catalyst change-out.
2) EDC Wash System Vents
A waiver of compliance from paragraph 61.62(a) is requested for the EDC wash system vents. These vents are frem the following vessels:
Acid Wash Tank Caustic Wash Tank Steam Stripper Feed Tank
T-103 T-102 T-110
EDC wash system vents cannot be controlled until the thermal incineration system is installed and operational.
3) Process Waste Water Steam Stripper
A waiver of compliance from paragraphs 61.65(b)(9)(i) and 61.65(b)(9)(ii) is requested for the process waste water steam stripper, C-'IOl. All inprocess wastewater is fed to tin's unit i or chlorinated hydrocarbon removal. Preliminary
OCR 000021751
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testing of the stripper discharge has indicated that the vinyl content in the stripper bottoms can be controlled to less than 10 ppm during proper operation. It has been impossible to maintain proper operation, however, because of the materials and design problems mentioned in our letter of December 21, 1976. Therefore, a waiver of compliance from paragraph 61.65(b) (9)(i) is requested to allow the design and installation of a second steam stripper. A waiver of compliance from paragraph 61.65(b)(9)(ii) is requested to allow time for the installation of the thermal incinerator. Any vinyl chloride removed from the wastewater will be returned to this device.
4) EDC Purification Tanks
A waiver of compliance from paragraph 61.62(a) is requested for the vents from storage tanks in EDC purification service. The three tanks are:
Dry Crude EDC Tank Wet Crude EDC Tank Light Ends Tank
T-450 T-453 T-402
These vents will be controlled by the thermal incineration system.
5) Loading Vent Stack, VS-400
The loading vent stack is the point of emission for the fugitive emissions associated with rail car loading and a portion of the fugitive emissions associated with ship loading. A waiver of compliance from paragraph 61.65(b) (l)(ii) is requested for the rail car loading line emissions vented to VS-400. A waiver of compliance is also requested from paragraph 61.65(b)(2) for rail car slip gauge emissions which arc vented to VS-400, and from 61.65(b)(7) for rail car samples which are vented to VS-400. In addition, a waiver of compliance is requested from paragraph 61.65(b)(5) for the manual venting of rail cars and ships to VS-400. With the installation of the thermal in cineration system, all emissions presently vented from VS-400 will be controlled.
6) Dock Vent Stack, VS-6C0
The dock vent stack, VS-600 is the emission point for the fugitive emissions from line clearing and sampling during ship loading. A waiver of compliance from paragraph 61.65(b)(1)(ii) is requested for the ship loading line and hydroquinone injection line clearing emissions vented to VS-600. A waiver of compliance from paragraph 61.65(b)(7) is also requested for ship sampling emissions which are vented to VS-600. A portable carbon adsorption system will be used to control the vinyl emissions at the dock area. The vinyl emission vent created during the regeneration of the carbon beds will be ducted through the thermal incinerator for control.
CCR 000021752
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WAIVER REQUEST, FUGITIVE EMISSION SOURCES - ADDITIONAL INFORMATION
The additional information requested on February 28, 1977 for the fugitive emission sources is listed below.
Rotating Pumps
A waiver of compliance from paragraph 61.65(b)(3)(i) is requested for the thirteen pumps in vinyl service which do not have the emission from between the double mechanical seals ducted to a control device. The thirteen pumps
are:
P-202 A, B P-203 A, B P-204 A, B
P-401 A, B P-411 A, B, C P-415 P-490
Quench Column Reflux Vinyl Column Feed Vinyl Column Reflux
Vinyl Transfer Vinyl Loading Vinyl Rerun Vinyl Vent Recovery
The seal emission from these pumps will be controlled by the thermal incinera tion system.
Rotating Compressors
A waiver of compliance from paragraph 61.65(b)(3)(iii) is requested for the emission from the double mechanical seals on the dock vinyl vent recovery compressor, EL-625. This emission will be controlled by the portable carbon beds which will be regenerated to the thermal incinerator.
Reciprocating Compressors
A waiver of compliance from paragraph 61.65(b)(3)(iv) is requested for the emission from the double packing seal on the vinyl vent recovery compressor, BL-409. This emission will be controlled by the thermal incineration system.
Relief Valves
A waiver of compliance from paragraph 61.65(b)(4) is requested for the relief valves in vinyl service which do not presently have a rupture disc under the relief valve. There are 45 such valves in the CONOCO VCM Plant, not 48 as had previously been reported. One of the valves which had pre viously been reported is no longer in service, and two other valves dis charge to a closed piping system and thus do not require rupture discs. The 45 relief valves and the equipment that they protect are as follows:
CCR 000021753
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RV-206 A&B - C-203, Vinyl Column
RV-209
- S-206, Vinyl Caustic Decanter
RV-210
- S-207A, Vinyl Flake Caustic Dryer
RV-211
- S-207B, Vinyl Flake Caustic Dryer
RV-319
- Vinyl Line to T-411C, Vinyl Sphere
RV-320
- P-401A Disch. Hdr., Vinyl Transfer Pump
RV-321
- P-401 A&B Suction Hdr., Vinyl Transfer Pump
RV-322
- P-411 A&B Disch. Hdr., Vinyl Loading Pumps
RV-323
- F-402, Vinyl Product Filter
RV-324
- F-402 Inlet, Vinyl Product Filter
RV-325
- F-402 Outlet, Vinyl Product Filter
RV-326
- P-411 A,B,&C Suction, Vinyl Loading Pumps
RV-327
- P-401 A&B Disch., Vinyl Transfer Pumps
RV-328
- P-401 A&B Disch., Vinyl Transfer Pumps
RV-329
- P-401 A&B Disch., Vinyl Transfer Pumps
RV-330
- P-401B Suction, Vinyl Transfer Pumps
RV-331
- P-401 Hdr., Vinyl Transfer Pumps
RV-342
- T-401 A,B&C Hdr., Vinyl Check Tank
RV-413
- F-401, Vinyl Transfer Filter
RV-414
- F-402, Vinyl Product Filter
RV-454
- Railcar Loading Header
RV-491
- P-491 Suction, Refrig. Vinyl Transfer Pump
RV-458
- H-491, Refrig. Vinyl Condenser
RV-459
- P-491 Disch., Refrig. Vinyl Transfer Pump
RV-461
- H-485, Refrig. Vinyl Liquid and Vent Heater
RV-462
- H-486, Refrig. Vinyl Liquid and Vent Heater
RV-463
- H-491, Refrig. Vinyl Condenser
RV-485
- H-485, Vinyl Recovery Fin-Fan Cooler
RV-486
- T-490, Vent Recovery Tank
RV-490
- T-490, Vent Recovery Tank
RV-491
- T-490, Vent Recovery Tank
RV-492
- P-490 Disch., Vent Rec. Transfer Pump
RV-625
- BL-625, Dock Vinyl Vent Recovery Comp.
RV-564
- S-626, Dock Compressor Disch. Drum
RV-627 RV-628
- F-625, Dock Product Filter - F-624, Dock Product Filter
RV-638
- Railcar Loading Rack
RV-639
- Railcar Loading Rack
RV-640
- F-403, Vinyl Rerun Filter
RV-642
- S-401, Loading Caustic Dryer
RV-643
- S-402, Laoding Bauxite Dryer
RV-652
- Dock Vent return line
RV-654
- BL-409, Rec. Unit Corken Comp.
RV-665
- T-626, Dock Compressor Suction Drum
CCR 000021754
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As indicated in CONOCO's letter of December 21, 1976, the rupture discs will be installed by February 1, 1978.
Manual Equipment Venting
A waiver of compliance from paragraph 61.65 (b)(5) is requested for the manual venting of inert gas build-up from the vinyl column accumulator S-205;
and the vinyl check tanks and product spheres T-401A, T-401B, T-401C, and T-411A, T-41 IB, T-411C, T-41 ID. This venting will be controlled by the thermal incinerator.
Opening of Equipment
A waiver of compliance from paragraph 61.65 (b)(6)(ii) is requested for the opening of equipment in vinyl chloride service to allow maintenance, re charging, or inspection. The following items are in vinyl service at the
CONOCO VCM Plant.
R- 201 A&B C-201 S-202 H-211 & $-217 H-202 A&B H-203
C-202 T-202 H-203 C-203 H-207 A&B S-2C5
S-205 S-207 A&B T-401 A,B,C T-411 A,B,C,uD S-401 S-402 T-626
S-626 T-490 T-491
H-491
H-4C5 H-485 H-625
- Cracking Furnaces - Quench Column - Quench Column Bottoms Drum - HC1 Interchanger & K.Q. Drum - Quench Column Condenser - Quench Column Reflux Cooler - MCI Column - HC1 Column Bottoms Drum - HC1 Column Reboiler - Vinyl Column - Vinyl Column Condenser - Vinyl Column Accumulator - Vinyl Caustic Decanter - Vinyl Flake Caustic Dryers - Check Tanks - Vinyl Product Spheres - Loading Caustic Dryer - Loading Bauxite Dryer - Dock Comp. Suction Drum - Dock Compressor Discharge Drum * Plant Vent Recovery Tank - Plant Refrig.. Vent Rec. Tank - Refrig. Vinyl Condenser - Refrig. Vinyl Liquid and Vent Heater - Plant Vent Recovery Fin-Fan Cooler
- Dock Vent Recovery Fin-Fan Cooler
Samp!os
A waiver of compliance from paragraph 61.65 (b)(7) is requested for the
vinyl sample emissions from low pressure sources which cannot be returned
to the process. These samples will be vented to the thermal incineration
system.
cc 000022 755
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REQUEST FOR WAIVER OF EMISSION TESTING-ADDITIONAL INFORMAT10N
The Continental Oil Company VCM Plant requests that a waiver of the emission testing requirements as defined by Section 61.67 be granted for those emission sources which are granted a waiver of compliance. Specifically, a waiver of emission testing is requested for the six existing emission points and the fugitive emission sources which will be ducted to the thermal in cinerator. After the installation of the proposed control devices, emission testing will be required at four emission points: the thermal incinerator vent, oxychlorination cleanup reactor vent, steam stripper bottoms line (C-101 and spare), and the portable carbon bed system at the dock.
The emission source areas which will be controlled by the proposed devices are as follows:
Thermal Incineration System
This system will control the emissions from the ethylene dichloride purifica tion section as required by 61.62 (a), and any fugitive vapor emission sources for the plant area which must be controlled as required by 61.65 (b).
Oxychlorination Vent Cleanup Reactor, R-305
This system will control the omissions from the oxychlorination reactor as required by 61.52 (b). The R-305 vent will be vented through the C-500 stack.
Steam Stripper Bottoms
This system will control the vinyl emissions from inprocess wastewater as required by 61.65 (b)(9).
Portable Carbon Bed System
This system './ill control fugitive vapor emissions at the dock area which cannot be returned to the plant. This will ensure compliance with Section 61.62 (b) for the dock area.
As indicated in the CONOCO VCM Plant letter of December 21, 1977, none of these control devices will be in final compliance until 1978. Therefore, no compliance testing is possible at this time. Rather, all compliance testing for tha four emission points at the CONOCO VCM Plant can be conducted in October, 1978.
CCR 000021756