Document 6RYdqbmm43XaraYLQYwVyxyKm

INDUSTRIES PPG INDUSTRIES, INC. CHEMICAL DIVISION U.S. P. 0. BOX 1000 LAKE CHARLES, LA. 70602 June 6, 1986 Mr. Gus VonBodungen Department of Environmental Quality Air Quality Division Office of Environmental Affairs P. O. BOX 44096 Baton Rouge, LA 70804-4096 Re: LESHAP VCM Quarterly Report Dear Mr. VonBodungen: In accordance with Section 17.11 of the LESHAP regulations, PPG Industries' Lake Charles Complex submits the attached quart rly report for the period March 1, 1986 through May 31, 1986. Attached as Exhibit I is a record of emissions in excess of 10 ppm (averaged on an hourly basis) which resulted from temporary by-passes of incineration. An estimated 81.6 pounds of VCM w re released as a result of these 10 incidents. Attached as Exhibit II is a record of sudden discharges of VCM which occurred during this reporting period. An estimated 179 pounds of VCM were released as a result of these 3 incidents. Written notification of these incidents was made within 7 days of their occurrence. There were no emissions in excess of 10 ppm (averaged on an hourly basis) in the stack gases exiting the incinerators during this reporting period. Respectfully, APP:lr Attachments Andy P. Plauche' Environ. Control Specialist SL 026392 EXHIBIT I Non-Incineration of VCM Vents March 1, 1986 - May 31, 1986 Page 1 of 2 SL 026393 3/1/86 3/20/86 Xiss 28 min between 0409 & 0441 1712 to 1751 3/28/86 2220 to 2228 4/12/86 1218 to 1237 * Sources Not Incinerated VC Ilr css VC Ilr css VC Hr css VC II, css Estimated Quantity VCM Vented ?lbs) 9.6 25.6 4.0 11.7 Comment #1 Incinerator tripped due to a malfunction of the flam scarm r. #1 Incinerator tripped due to a malfunction of the natural gas regulator (natural gas fu 1 pressure became too high). #1 Incinerator tripp d due to loose electrical connecti ns on the shutdown control system. #1 Incinerator tripped du to loose connections on the Modicon (computer control syst m). 4/12/86 4/12/86 1602 to 1613 1637 to 1652 VC II, css VC Ilr css 6.8 Same as above* 9.2 Same as above* 4/12/86 2058 to 2107 VC II, css 5.5 Same as above* 5/10/866 2041 to 2044 VC II 1.2 VC II vents were tripped out of #1 Incinerator in order to prevent the automatic shutdown of the incin rator due to a high temper ature condition. * The loos connections n th Modicon system were not located until aft r the 4th trip. SL 026394 Pat? 5/16/86 Tine 0852 to 0900 5/17/86 2014 to 2018 EXHIBIT I Non-Incineration of VCM Vents March 1, 1986 - May 31, 1986 Page 2 of 2 Sources Not Incinerated VC II, css VC II, css Estinated Quantity VCM V?nt?d fibs) 5.3 2.7 Comment #1 Incinerator tripp d due to operator error in ov r-c rrecting for a high temperature condition. #2 Incinerator tripp d du to flame failure when a th rmoc uple failed. SL 026395 Bafes 3/17/86 5/29/86 5/30/86 EXHIBIT II Sudden VCM Discharges March 1, 1986 - May 31, 1986 Tine Duration 1700 to 1701 (1.25 minutes) Estimated Quantity VCM Released (lbs) 155 0950 to 0955 (5 minutes) 1 0300 to 0400 (60 minutes) 23 Comment A hose being used to provide t mporary recirculation to the TE-II VCM stripper reflux pump failed. (Written n tificati n was made on 3/19/86.) Low pressure HC1 system accumulator was inadvertently blocked in with the HC1 c mpressor recirculation line still p n. Th resulting pressure buildup caus d th accumu lator's SRV to relieve. (Writt n notification was made on 6/3/86.) DCE Rx overfilled due to malfunction of th level transmitter and caused liquid rganics to enter the HC1 vent distribution h ad r The liquid caused an overpressurization d. ./i stress in the header at VC II causing th vents to be diverted to the VC II Es rg ncy Scrubber. (Written notification was sad on 6/3/86.) PATRICIA L. NORTON SECRETARY OFFICE OF AIR QUALITY AND NUCLEAR ENERGY December 16, 1985 GREG J. GASPERECZ assistant secretary Mr. Grover C. Strieker Plant Manager PPG Industries, Inc. P. 0. Box 1000 Lake Charles, LA 70602 Dear Mr. Strieker: The Air Quality Division is in receipt of your quarterly report dated December 9, 1985 which covers September, October and November 1985. This report is complete in that it contains all of the information required in Section 77.11 of the Louisiana Emission Standards for Hazardous Air Pollutants (LESHAP). We are pleased with the major reduction of incinerator by-passes and the poundage of vinyl chloride emitted over last quarter. Also, we appreciate the change in the reporting format showing more information as to the causes of the by-passes. We hope that this last quarter represents a real turning point in PPG's efforts to come into compliance with the vinyl chloride emission standards. Sincerely, WHD/CCJ/bs cc: Southwest Regional Office File; 35.40.9 SL 26396 PATRICIA L NORTON SECRETARY OFFICE OF AIR QUALITY AND NUCLEAR ENERGY March 13, 1986 GREG J. GASPERECZ ASSISTANT SECRETARY Mr. Andy P. Plauche PPG Industries, Inc. P. 0. Box 1000 Lake Charles, LA 70602 Dear Mr. Plauche: We have received PPG's quarterly report on vinyl chloride for the period beginning December 1, 1985 and ending February 28, 1986. We . summarize your report as follows: 1) In accordance with Sections 77.11(c)(1) and 77.4(a) of the Louisiana Air Quality Regulations, there were five excursions of the 10 ppm hourly average standard from the incinerators. 2) In accordance with 77.11(c)(1) and 76.18(d), there were twenty incidents of incinerator bypasses resulting in a total of 140.3 pounds of vinyl chloride being emitted to the atmosphere. The bypass on February 13, 1986, exceeding one hour, was handled in accordance with 76.18(b)and (c). 3) In accordance with 76.18(d), there were three incidents of relief valve discharges resulting in a total 1636.6 pounds of vinyl chloride being emitted to the atmosphere. These events were handled in accordance with 76.18(b)and (c). Your report fulfills the requirements of Section 77.11(a). For any questions, please contact Chris Kuttruff of my staff at (504) 342-9046. Sincerely, imS WillTam H. Davis Chief, LESHAP Unit WHD:CK:aa File: 35.40.9 SL 026397 PATRICIA L NORTON SECRETARY OFFICE OF AIR QUALITY AND NUCLEAR ENERGY June 12, 1986 GREGJ GASPERECZ ASSISTANT SECRETARY Mr. Andy Plauche Environmental Control Specialist PPG Industries P. 0. Box 1000 Lake Charles, LA 70602 Dear Mr. Plauche: We are in receipt of PPG'a quarterly report for vinyl chloride emissions for the second quarter of 1986. .During the period, ten bypass incidents resulted in the excess emission of 81.6 pounds of vinyl chloride. Three sudden discharges (two relief valves and one by-pass from an process upset) were also reported. Your submittal fullfills the requirements of Section 77.11 of Subpart B of Part IV of the Louisiana Air Quality Regulations for the second quarter. WHD:CK:aa File: 35.40.9 Chief, LESHAP Unit 026398 SL