Document 716knvVNGdX2KvDQdnnrQ09Bo

(conoco) Interoffice Communication to J. C. Ledvina - Houston From V. M. Fisher Date October 9, 1981 subject VOC Regulations Impact on VCM Plant's Qxychlorination Revamp Project REVISIONS Attached is the new Table I which was previously issued in the letter, "VOC Regulations Impact on VCM Plant's Oxychlorination Revamp Project," September 22, 1981. Since this letter the number of valves in light liquid and vapor service for both the entire expansion (Case I) and the oxychlorination revamp and direct chlorination modification (Case II) have been estimated. Based on these updated numbers the total available offsets from modifications in the existing plant will not compensate for the increased emissions from the entire expansion, but will for the Oxy revamp only. It was assumed that all valves in vapor service have an uncontrolled emission factor of 0.0463 Lb/Hr, 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 Guideline Series for the Control of Volatile Organic Chemical, Polymer, and Resin Manufacturing Equipment. Originally, the un controlled fugitive emissions from the additional valves were computed using the uncontrolled emission factor for light liquid service, 0.022 Lb/Hr. Since then, an estimate has been made of the number of valves in either vapor service on light liquid service. It should be noted that the emission factor for valves in gas service was used for valves in vapor service. This assumption seems to be valid from definitions in the EPA proposed standards but needs verification as to its applicability. Using this information the increased emissions from the valve additions for the entire expansion, and oxychlorination revamp/direct chlorination modi fication are 44.337 Lb/Hr and 16.622 Lb/Hr, respectively. Thus, the total available offsets from the existing plant would limit the compensation of the increased emissions to Case II. Lbs/Hr Voc Total available fugitive emi ssions offsets 36.499 Total increased fugitive emi ssions Entire Expansion - Case I 44.337 Total increased fugitive emi ssions Entire Expansion - Case II 16.622 CCR 000017739 The increased fugitive emissions from the entire expansion exceed the total available fugitive emissions offsets from modifications of the existing plant by 8.0 Lb/Hr. Ways to offset this excess need to be investigated to avoid the recordkeeping and reporting requirements. One method would be the elimination of 173 valves in vapor service or the elimination of 364 valves in light liquid service. 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 assumed that the regulations (in particular, the monitoring and reporting requirements) are not applicable to modified facilities provided there is no net increase in the overall VOC fugitive emissions. Is this a valid assumption ? 2) It is also being assumed that offsets of new fugitive emissions can be accomplished by controlling 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 duration does the EPA allow for the completion of a modified or expanded facility ? (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 before the completion of the revamp ? Or before the completion of the entire plant ? Or staggered to just offset each in crement as it is completed ? 5) What would be the most economical way to offset the increased emissions through the modification 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 only installing rupture discs under existing relief valves and double mech. seals on two pumps.) A response to the questions above is requested as soon as possible. Please contact me concerning any questions or comments you have regarding this letter. br CC: JAD-JWW-GLF-MLA-DLD-MGH-OJH-GCB-JGC-BIR-GJF CCR 000017740 -4 TABLE I *-* NEW VOC FUGITIVE EMISSIONS FOR OXY REVAMP Fuaitlve Emission Source 2 New Pumps (Controlled) 2 New Relief Valves (Controlled) 2 New Non-Vinyl Compressors (Controlled) New Valves Case 1: ^ Process Valves In Vapor Service Process Valves in Liquid Service Instrument Valves in Vapor Service Instrument Valves in Liquid Service Total Case 2:(2) Process Valves in Vapor Service Process Valves in Liquid Service Instrument Valves in Vapor Service Instrument Valves in Liquid Service Total Number of Sources 2 6 3 241 500 298 381 1,420 107 98 185 43 433 Uncontrolled Emission Factor Ib/hr Total Uncontrolled Emissions lb/hr 1 0.0463 0.022 0.0463 0.022 0.0463 0.022 0.0463 0.022 11.158 11.000 13.797 8.382 44.337 4.954 2.156 8.566 0.946 16.622 Controlled Emission Factor 0.00 0.00 0.00 Total Controlled Emissions Ib/hr 0.00 0.00 0.00 (Table I) NOTES: 1) A definitive estimate of the entire expansion from PED. 2) A preliminary estimate of the oxychlorination revamp and direct chlorination modification from PED. 3) Estimated valve split for the entire expansion is 40% in vapor service and 60% in liquid service. Estimated valve split for the oxychlorination revamp and direct chlorination modification is 70% _ in vapor service and 30% in liquid service. CCfc oooon7'*2 Fuqitive Emission Source Existing Pumps Existing Safety Relief Valves Existing Sampling Connections Existing Compressors TABLE II AVAILABLE OFFSETS FROM EXISTING VOC FUGITIVE EMISSION SOURCES Number of Sources 52 46 20 6 Uncontrolled Emission Factor lb/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 Ib/hr 13.780 16.238 0.661 5.820 36.499 OO 7= Oooo