Document 4JyybM4qe9z1NwMeqL97GRqaj

RECEIVED (conoco) OGT 1 G 1981 Interoffice Cu irnmunication RECEIVED To From J. C. Ledvi na - Houston V. M. Fishe r OCT 1 5 1981 CHEM. MKTG. Date October 9, 1981 Subject VOC Regulat ions Impact on VCM Plant's/Oxychlorination Revamp Proj ect REVISIONS Attached is the new able I which was previously issued in the letter, "VOC Regulations Impact on VCM Plant's Oxychlorination Revamp Project," September 22, 1981. Since thi letter the number of valves in light liquid and vapor service for both the entire expansion (Case I) and the oxychlorination revamp and direct chlorinat* on modification (Case II) have been estimated. Based on these updated numb ers the total available offsets from modifications in the existing plant w 11 not compensate for the increased emissions from the entire expansion but will for the Oxy revamp only. It was assumed that al 1 valves in vapor service have an uncontrolled emission factor of 0.0463 Lb/H r, while the valves in light liquid service have an uncontrolled emission factor of 0.022 Lb/Hr. These factors are found in Appendix D of the Gui deline Series for the Control of Volatile Organic Chemical, Polymer, a nd Resin Manufacturing Equipment. Originally, the un controlled fugitive imissions from the additional valves were computed using the uncontrolled emi sion factor for light liquid service, 0.022 Lb/Hr. Since then, an estimate hat been made of the number of valves in either vapor service on 1ight 1iquid servi ce. It should be noted that the emission factor for valves in gas servi was used for valves in vapor service. This assumption seems to be valid fnb m definitions in the EPA proposed standards but needs verification as to i ts applicability. Using this informati on the increased emissions from the valve additions for the entire expansion and oxychlorination revamp/direct chlorination modification are 44.337 b/Hr and 16.622 Lb/Hr, respectively. Thus, the total available offsets frb m the existing plant would limit the compensation of the increased emissions to Case II. Lbs/Hr Voc Total available fugitive emissions offsets 36.499 Total increa sed fugitive emissions Entire Expa ns ion - Case I 44.337 Total increa sed fugitive emissions Entire Expant ion - Case II 16.622 Wc OOOOlajo, The increased fugitive emissions from the entire expansion exceed the total available fugitive emi ssions offsets from modifications of the existing plant by 8.0 Lb/Hr. V{ays to offset this excess need to be investigated to avoid the recordkeepir g and reporting requirements. One method would be the elimination of 173 va ves in vapor service or the elimination of 364 valves in light liquid servi <te. The inability to offset this excess would increase the probability of the VCM Plant being subjected to the rigors of the regulations. In addition, the following items need clarification. 1) It is being assume d that the regulations (in particular, the monitoring and reporting reqi irements) are not applicable to modified facilities provided there is no net increase in the overall VOC fugitive emissions, Is this a valid as sumption ? 2) It is also being cssumed that offsets of new fugitive emissions can be accomplished by ccntrolling dissimilar equipment. For example, increased fugitive emissions from valves installed as part of the revamp do not necessarily have to be offset by the removal of an existing valve in VOC service. These emissions could be offset by the modification of existing pumps, compressors and relief valves. 3) What time duratior does the EPA allow for the completion of a modified or expanded facili ty ? (i.e., if the oxy revamp were completed on schedule and the remainder of the Expansion work delayed 2-4 years.) 4) Assuming there is a substantial time lag between the Oxychlorination revamp and the remainder of the plant expansion, would equipment modifications have to be made be fore the completion of the revamp ? Or before the completion of the entire plant ? Or staggered to just offset each increment as it is ompleted ? 5) What would be the most economical way to offset the increased emissions through the modifi cation of a certain number of existing fugitive emission sources ? (e .g., if just the oxy revamp were to be offset, it could be accomplished by or ly installing rupture discs under existing relief valves and double mech. Seals on two pumps.) A response to the ques tions above is requested as soon as possible. Please contact me concerning any questions or comments you have regarding this letter Virgil M. Fisher Process Engineer br CC: JAD-JWW-GLF-MLA-DLD-MQH-JJH-GCB-JGC-BIR-GJF 0OOO13*10 vvc < o o o TABLE I o o -- NEW VOC FUGITIVE EMISSIONS FOR OXY REVAMP U) w h*-* Fugitive Emission Source Number of Sources Uncontrolled Emission Factor lb/hr _________________ 2____________________________________________________________________________ New Punps (Controlled) 2 Total Uncontrolled Emissions lb/hr New Relief Valves (Controlled)2 2 New Non-Vinyl Compressors (Controlled) 6 3 1 New Valves Case 1: ^ Process Valves in Vapor Service 241 0.0463 11.158 Process Valves in | Liquid Service 500 0.022 11.000 i Instrument Valves in i Vapor Service | Instrument Valves in 1 Liquid Service ; Total ; Case ?;(2) Process Valves in Vapor Service 298 381 1 ,420 107 0.0463 0.022 0.0463 13.797 8.382 44.337 4.954 Process Valves in Liquid Service 98 0.022 2.156 Instrument Valves in Vapor Service 185 0.0463 8.566 Instrument Valves in Liquid Service Total 43 0.022 433 0.946 16.622 Controlled Emission Factor Total Controlled Emissions lb/hr -------------------- UTUd--------------------.---.--.---------ortra--------------------_----,,-,,---------------------------- 0.00 0.00 0.00 0.00 (Table I) NOTES: 1) A definitive esti mate of the entire expansion from PED. 2) A preliminary estimate of the oxychlorination revamp and direct chlorination mod'fication from PED. 3) Estimated valve split for the entire expansion is 40% in vapor service and 60% n liquid service. Estimated valve split for the oxychlorination revamp and direct chlorination modification is 70% in vapor service and 30% in liquid service. VVC 000013312 TABLE II AVAILABLE OFFSETS FROM EXISTING VOC FUGITIVE EMISSION SOURCES Fuqitive Emission Source Existing Pumps_________________________ Existing Safety Relief Valves Existing Sampling Connections Existing Compressors Number of Sources 5? 46 20 6 Uncontrolled Emission Factor Ib/hr 0.265 0.353 0.033 0.97 Total Emissions Ib/hr 13.780 16.238 0.661 5.820 Controlled Emission Factor 0.00 0.00 0.00 0.00 Total Available Offsets 1 b/hr 13.780 16.238 0.661 5.820 36.499 P 000013