Document 2j8ZwZoR6dKrdm11e79KaOa2R

This letter is in response to your letter to Mr. Don R. Goodwin of April 16, 1973, regarding incineration costs at vinyl chloride monomer plants. Since your letter addresses a subject that falls within my area of responsibility, Mr. Goodwin has requested that I respond to you. I have attached a copy of the specifications that our'contractor used to develop his estimate of incineration, co&ts-for ;a 700 mill ion lb/yr. vinyl, chloride monomer plant as well as one copy of the. final incinerator capital cost estimate of $921,750. In addition, we have attempted to reconcile the differences between our estimate and Shell's estimate by trying to put both estimates on a comparable basis. While it has not been possible to precisely reconcile all cost differences, it does appear that the major area where differences exist is in the "other cost" section - engineering, field changes, and start-up costs specifically. While differences in the areas of purchased equipment and installation also exist, it would appear that these differences might partially be explained by the inclusion of an acid recovery system in the Shell estimate. The'EPA estimate included neutralization of the acid, not recovery. Whereas we cannot dispute the fact that Shell has actually expended the amount in question - $1,768,000 - we still believe that this amount would not necessarily be duplicated at some other installation. In particular, we believe the amounts expended for engineering, field changes, and start-up costs appear to be extraordinary. Another area in which differences exist is in the escalation of the original capital expenditure to a value representative of the EPA model plant. The Shell methodology is to take the original value of $1,768,000, multiply it by a factor of 1.67 to account for inflation. see 3-0646 l 2- add $260,000 for an acid mist eliminator^-find then multiply the sum by a factor of 1.4 to account for the increased gas volume that must be treated. This methodology results in a total capital cost estimate of $4,500,000. EPA, on the other hand, believes that an inflation factor of 1.29 is more appropriate based upon the values of the CE Index in January 1973, and January 1975. Also, EPA does not believe that an acid mist eliminator of the size included in the Shell estimate would be required. EPA has included a mist eliminator in its original equipment estimate as is noted on the attached reconciliatory sheet. Finally, we believe that a volume scaling factor of 1.15 is the appropriate factor to use. This factor is based upon scaling the original gas volume at the burner exit of 60,000 SCFM to 73,000 SCFM at the 0.7 power. The EPA methodology, then, gives a value of $2,600,000 as opposed to the Shell estimate of $4,500,000. We realize that even this value, however, is considerably in excess of the EPA capital estimate of $922,000. Whereas we believe that part of the discrepancy is due to factors mentioned before acid recovery cost, engineering, field changes, and start-up costs - we feel that more analysis in this area is needed. I hope that we will be able to discuss these matters with you and other Shell employees in order to obtain mutually agreeable cost estimates for control of emissions at vinyl/chloride'monomer' plants'. 5inc^raly yours \Jk \ JQi John R. O'Connor, Chief Standards and Cost Analysis Branch Strategies and Air Standards Division Enclosure see ;-0647 The thermal incineration systems specified for VCM control' under this task consist of a thermal incinerator and a caustic scrubber system to remove from the incinerator exhaust gases the HC1 made in the incinerator. Cost information for these systems was developed from a conceptual design basis of an 1800F incin eration temperature and a 2 second residence time to achieve. 99% removal of VCM. This is felt to be a conservative basis but it is not based upon operating data. The installed cost data presented herein is of necessity based on a model situation and must be adjusted by the reader to meet his particular situation. To help in this adjustment, various cost bases'used in this study are.listed below: 1) 5% caustic solution 'is .'available within . 50 feet of unit * battery limits. 2) Cost of caustic is 35$/8 which includes delivery, unloading and surcharge from existing facilities. 3) An adequate supply of natural gas auxiliary fuel is available at $2.00/MM Btu. 4) Caustic scrubber effluent will be processed in existing treatment facilities. Existing chemical sewer tie-in is within 25 feet. 5) The equipment will be placed on a concrete pad sized for equipment only. Soil bearing pressure is 2000 .psf. Backfill, piling, etc., is not included. * ,* * * * -:' . ' - see 3-0648 2-" - 6) Area classification will be Class I, Group D, Division. II. Motors wxlM be TEFC. Arcing controls will be NEMA 7, nonarcing controls will be NEMAt. 4^, control cabinets will be pressurized and purged NEMA 4. Existing electrical power supply 440,220 and 110 volts is adequate. 7) Incinerator will be designed for the 2 seconds residence time at 1800F. Fuel consumption will be based on anti cipated operating temperature of 1600F but system will be capable of 1800F operating temperature. Air will be added in excess of that required for fuel combustion to assure a 1% 02 concentration in incinerator outlet gases, for VCM balanced operation. 8) -Scrubber presaturator'will be designed for.0.3 sec.resi dence time. Material of construction will be suitable for service. Process water will be used for cooling. Fire water is available for backup emergency cooling. 9) The scrubber'will be designed for 95%+ HC1 removal efficiency. Caustic scrubber effluent will go directly ' to chemical sewer on scrubber sump level control. 10) Pumps will be spared and material.of constructions will be C.S. for caustic pump and epoxy FRP for scrubber liquor. 11) In the absence of specific available experience, operating labor cost estimates will be projected from general . incinerator and scrubber knowledge. 5 '' ' SCC 3-0649 -512) Process vent Stream conditions supplied to the control o system are suJfferized in cost data tables. 13) Maintenance and repairs will be 'figured at 53 of fixed capital investment. 14) Stack will discharge at 100' above grade Q see 3-0650 4 > ESTIMATED CAPITAL'COST-DATA * (COSTS IN DOLLARSr Thermal incinerator for balanced VINYL CHLORIDE MONOMER PLANT (700 MM Ib/yr) (OXYCHLORINATION, "LIGHTENDS," and vinyl finishing COLUMN VENTS) Effluent Gas Flow ACFM F SCFM Effluent Contaminant Loading (ppm) VCM Ib/hr VCM 12,000 70 12,000 1,625 189 Cleaned Gas Flow ACFM F SCFM Cleaned Gas Contaminant Loading (ppm) VCM Ib/hr VCM Cleaning Efficiency, % * .. 36,000 175 30,000 2.17 1.89 99 (1) Gas Cleaning Device Cost (2) Auxiliaries Cost (a) Fan(s) (b) Pump(s) (c) Damper(s) (d) Condition, (Incl. Inst.) Equipment (e) Dust Disposal Equipment (3) Installation Cost (a) Engineering (b) Foundations & Support Ductwork & Stack - 100' above Electrical (Incl. Inst.) Piping Insulation Painting Supervision .. * - Startup PerformanceTest Other (4) Total Cost *99% for VCM, 95% for HC1 .. " 245,000 73,500 46,500 9,000 9,000 9,000 603,250 71,250 285,000 28,50Q 38,000. 38,000 61,750 23,750 9,500. 9*500 9,500 28,500 921 ,750 SCC 3--'0651 ANNUAL OPERATING COST DATA (COSTS IN S/YEAgJ THERMAL INCINERATOR FOR BALANCED VINYL CHLORIDE MONOMER PLANT (700 MM lb/yr) (OXYCHLORINATION, LIGHT ENDS, AND VINYL FINISHING COLUMN VENTS) Operatinq Cost Item Unit Cost Operating Factor, Hr/Year 8,000 Operating Labor (if any) Operator Total Operating Labor $6/Hr $8/Hr $ 12,600 8,400 21,000 Maintenance Labor Materials Total Maintenance & Replacement Parts $' 46,100 Rep!acement Parts Total Replacement Parts Utilities Electric Power Fuel Water (Process) Water (Cooling) Caustic Soda Total Utilities $.03/Kwhr $2/MM Btu $.25/Mgal $.05/Mgal $.35/1b $ 34,200 592,000 8,000 0 309,900 944,100 Total Direct Cost $1,011,200 Annualized Capital Charges 113,200 Total Annualized Cost $1,184,400 see 3-0652 > COMPARISON OF INCINERATOR CAPITAL COSTS - SHELL vs. tr* .. * . . . ..___ . . .. PURCHASED EQUIPMENT 1. Incinerator 2. Blower & Driver 3. FRP Equipment & Duct Work incl. column 4. Exchanger 5. Pumps 6. Filters 7. Tanks (less lining) 8. Instruments 9. Electrical 10. FRP Piping 11. Valves 12. Structural Steel 13. Column Packing 14. Piping Labels 15. Freight . 16. Conditioning Equipment0 17. Dampers Subtotal CONSTRUCTION CONTRACTS 1. Piling. & Foundations 2. Mechanical & Piping 3. Instrumentation 4. Electrical Subtotal OTHER COSTS .* - Shell ^ (Norco," La.) Mi 113 U3 67 10 19 1 25 63 15 33 36 62 1 1 6 -- -- 495 170 270 ~ 76 60 576 - EPA ... Estimate1 'M$ 245a 46.5 (Incl. in Item B2) None 9.0 None -- (Incl. in Item B3) (Incl. in Item B4) (Incl. in Item B2) None (Incl. in Item B1) (Incl. in Item A1) None 9 9 318.5 285d 152* (Incl. in Item B4) 38 475 1. Engineering (Contractor) 2. Sales Tax 3. Shell Engineering 4. Field Changes 5. Start-up Costs 6. Supervision 7. Other (Contingencies, etc.) Subtotal 229 71.3 20 None 102 (Incl. in Item Cl) 195 None 151 19e ' -- 9.5 -- 28.5 697 128.3 GRAND TOTAL $1 ,768M $922M aIpcludes burner and burner controls, combustion chamber, and scrubber (includes mist elim inator). Cost is FOB vendor* ^Includes oost ..of.qufencher and quencher controls. ^Includes cost of foundations and support and Tabor to install them.- \ includes cost of: duct work arid stack (100'), piping, insulation-, and painting materials and labor. includes cost of: startup and performance test. . see 3-0653