Document 4J6j8X425QpJMZL88Gn2ZdzaN

AR226-2292 Chris EShoop 10/17/2002 10:07 AM To: Robert L RitcheyVCL/DuPont@DuPont ck OscarT Garza/AE/DuPont@DuPont, Ta-Wei Fu/SE/DuPont@DuPont, Fred M Lentz/SE/DuPont@DuPont, Karl GKronberg/AE/DuPont@DuPont, Debbie J Mulrooney/AE/DuPont@DuPont, Robert I Wevodau/SE/DuPont@DuPorrt Subject Explanation of input Data for Modeling Studies Bob, Per your request and in preparation for discussions with the Ohio EPA, please see the foltowing descripflon of the development o f the emission numbers used in the modeling studies for 2002 and 2003. The attached Excel workbook has date for the years 2001,2002, and 2003. We used a separate sheet to summarize the. emission point data for Mulrooney. I can provide that one as'well if you wish, but the one attached contains all the assumptions and adjustments. The emissions data fo r 2001 and fo r 2002 through July is based on the C-8 mass balance sheet we use for reporting air emissions to the W V DEP. The date for the remainder o f2002 and for 2003 is based on projections Karl and I obtained from the two area schedulers. The monthly numbers are shown ju st below the main calculation tables. Note the Fine Powder production is broken out into FP-1, -2, and -3 figures. The emissions for Fine Powder in 2002 are based on use of the original (primary) scrubber from January through April and use o f the new Deep-bed scrubber from May through July. The projection for the remainder of the year also based on use of the Deep-bed scrubber. The C-8 mass balance calculations provide a single emissions number and do not provide for allocation of emissions to the respective vents. I distributed the emissions stated from that calculation (2001 and 2002 January though July) as follows. First, I presumed the efficiency of the Fine Powder primary scrubber to be 50% which is consistent with the test results from February 2002 and ZfpfeTs earlier data. We used 95% as the efficiency for the Deep-bed scrubber. Though the August 13 test data indicates the Deep-bed scrubber efficiency is higher, the pound per hour emission rates is not that different so we chose to be conservative here. Second, Karl and I assigned an efficiency to PFA, based on test data and o r internal studies conducted in the 2001 to early 2002 time frame Finally, I assumed that all three FEP scrubbers had the same efficiency, which probably is not quite true, and used the Excel "Goal Seek" function to "fit" the efficiency to meet the total reported emissions. Please see the "fitted" efficiencies cited on the sheet fo r each year. Note that emissions from Granular are not recovered, so they are calculated directly and are not part of the "fitting" process. For the projections in 2002 remainder and for 2003,1applied the following conversion from production date to emissions estimate. The production number is multiplied by the QPU for C-8 concentration (lb C-8 per lb dry product). This value is adjusted for the split o f C-8 to the polymer versus water in the coagulators (and other water separation devices). The is also adjusted based on the expected efficiency o f the control devise fo r the emitting vent. The QPU's, fractions to dryer, and efficiencies are shown in the main table. The fraction to dryer values are consistent with the assumptions we have used for the earlier modeling studies and were the best available at the time we assembled the table. The efficiencies were also stated at the values we fe lt were being and can be achieved, for copoly as well as for Fine Powder. For the pending application for FEP, Karl has applied a fraction to dryer of 0.35 after discussion with Ta-Wei. He has also stated the efficiencies of the scrubbers to be 87.5% which results in the emission rates being unchanged from those stated in the attached sheets. DOMOOH41 E ID 64X 220 After several discussions with Ta-Wei and Trim, we have reached the understanding that the mass balance calculations we are using fo r the reporting, and the modeling study, tend to over-estimate the actual emissions. The impact of this on the modeling study is that much o f the over-estimated emissions are forced to the shorter copoly stacks which causes higher modeled emissions at the closer receptors. We believe the efficiencies o f the copoly scrubbers are actually at or dose to 90%. But the conservative nature o f the mass balance calculation makes it difficult to show this. The planned preliminary testing at FEP to be conduded later this month w ill be valuable for our reassurance that we can achieve the emission rates described in the projections. Chris Shoop Stack Em issions Protect DJMOOH42 E ID 641221 Current Permit/Appllcatlon/PDF # 815D (FP/D Scrubber) 815D (FP/D Deep Bed) 1353A Granular L2) Pre-Existing (Granular L1) 614A (PEP L1) 614A (FEP L2) 1953 (FEPL.3) 2365A (PFA) 2001 Actual E m issions Ib/yr1 11058,0 0.0 2.5 5,5 4238,0 4112.3 2300.7 4296.0 28005.0 ''Fitted Efficiencies" 0.5 0.95 0.477614 0.477614 0.477614 0.5 wH O DJM001143 c Current Permit/Applicatlon/PDF if 815D (FP/D Scrubber) 815D (FP/D Deep Bed) 1353A Granular L2) Pre-Existing (Granular 11) 614A (FEP 11) 614A (FEP 12) 1953 (FEP L3) 2365A (PFA) 2002 2002 VTD Actual Projected Emissions Production lb /y r1 lb/yr1 QPU 3851.9 358,1 3.511.560 {Seente 1,7 3.3 1247.8 1799.1 697.8 2644,3 mmm 10599.0 Fraction to Dryer Projected Total Calculated Calculated Scrubber Emissions Emissions Efficiency lb/yr lb/yr 01 . . . 527.3 1 11.0 | -wB26.3 1"Sip--- 544.3 1 272.1 1 HI64.3 504,4 1949.7 12553.7 Production Projections: FP-1 FP-2 FP-3 1711967 914827.5 884765 0.0025 0.0035 0.0045 0,92 0,92 0.92 0.95 196.8762 3937.524 0.95 147.2872 0.95 183.1464 "Fitted E ffic ie n c ie s 0.652208 0.652208 0.652208 0.55 FEP lines 1/2 FEP line 3 PFA process K Aug-02 747 11 230 Sep-02 583 120 143 Oct-02 877 170 219 Nov-02 934 14 219 Dec-02 End 2002 861 4002 0 315 206 1017 2003" 11566 744 2542 D JM O O H 45 2003 Calculated I Current Production Fraction Scrubber Emissions Perm it/Appilcation/FDF# Ib/yr1_____ qpo to Dryer Efficiency Ib/yr I 815D (FP/D Scrubber) 815D (FP/D Deep Bed) 1353A Granular L2) 9,631,432 (See note 1)j llC ii1 1446.2976 33.0 Pre-Existing (Granular 11) 79.0 614A (FEP L1) 1,573.0 614A (FEP L2) 1953 (FEP L3) 2365A (PFA) 786,5 151,8 1,260.8 5330.37 Production Projections: FP-1 4695544 0,0025 0.92 0.95 539.9876 FP-2 2509104 0.0035 0.92 0.95 403.9657 FP-3 24267B4 0.0045 0.92 0.95 502.3443 c HH Da\ J1s