Document 8RLOpj7g9zJ782ZQD9x723zem
Docket ID No. EPA-HQ-OAR-2002-0037 Viny l Institute Petition for Reco11sideratio11 and Request to Stay the Rule Pending Reco nsideration
VIII. Vapor Balancing
A. Vapor Balancing is Widely Used in This Source Categ01y
As Table 8 indicates, vapor balancing is used widely throughout the industry to load storage vessels and unload transportation vehicles (e.g., railcar). Indeed, it is virtually impossible to unload a vinyl chloride railcar without any HAP emissions without using vapor balancing. When unloading a vinyl chloride railcar, there a re two options for loading a storage vessel: ( I) use vinyl chloride pressure to push vinyl c hloride into the storage sphere and vapor balance the sphere back to the railcar; or (2) use nitrogen pressure to push vinyl c hloride to the storage sphere and send the vapors to the control device. The second option results in low-level HAP emissions through the control device. In contrast, when using vapor balancing, vapors from the railcar, the sphe re, and the lines are recovered, thus ensuring the re a re no HAP emissions from the process. Accordingly, the Working Group submits that EPA should reconsider and expressly allow the ongoing use of vapor balancing at PVC faci lities.
Yes No No No No No No Yes Yes Yes Yes Yes Yes Yes
B. Vapor Balancing is a Proven Control Teclinology
As the industry noted in its comments, vapor balancing is a proven control technology that EPA has allowed as a control option for storage tanks in many other MACT rules, including the Agency's recently proposed Uni form Standards.ill A lthough vapor bala ncing is not addressed in the fi nal PVC MACT rule, the Working Group submits that vapor balancing is not prohibited by the fi nal rule, particularly as no emissions are released from the practice. Nevertheless, both industry and the Agency would benefit from a common and consistent unde rstanding of the practice through explic it regulatory recognition. In addition, its widespread use throughout the industry would make compliance and enforcement of vapor balancing as a Section 6.36(g) alternative means of emission limitation impracticable, further elevating the need for correction on recons ideration.
lfil Docket Document No. EPA-HQ-OAR-2002-0037-0146, at 87.
39
Docket rD No. EPA-HQ-OAR-2002-0037 Vinyl lnstit111e Petition for Reconsideration and Request lo Stay the Rule Pending Reconsideration
C. Vapor Balancing Sliould be Explicitly Recognized in tlie Rule
In their comments, Working Group members requested that EPA allow vapor balancing as a means of controlling emissions from storage vessels. The final PVC MACT rule is s ilent on the issue, and according to EPA, it did not have data on the appropriateness of using vapor balancing on storage vessels in the PVC source catcgory..l.llii A Working Group member raised this issue with the Agency at their April 18, 2012 meeting, and reminded the EPA staff that vapor balancing is a widespread activity throughout the industry. Under the circumstances of a widely used and proven control technology that is fundamental to avoiding emissions during normal operations, such as railcar load ing, it would be arbitrary and capricious for the Agency not to exercise its d iscretion, grant reconsideration, and add a provis ion in the PVC MACT that explicitly allows vapor balancing.
IX. Requirements for Combined Process Vents Must be Reconsidered
Several PVC production facili ties share process vent and other control devices with facilities in other source categories, including facili ties that are in the ethylene dichloride and/or vinyl chloride ("EDCNCM") production industry or subject to the Hazardous Organic NESHAP ("HON") or Miscellaneous Organic NESHAP (" MON"). During the development of the PVC MACT, several EDCNCM manufacturers, many of which also are subj ect to the PVC MACT, received a Section I 14 Request from EPA for survey and test data to support the development of an EDCNCM MACT rule. Given this ongoing and clearly overlapping initiative, the Working Group urged EP A to postpone development of the PVC MACT in favor of a consol idated rule covering PVC, EDC, and VCM faci lities, or two rules that are consistent. In separately fil ed comments, a Working Group member maintained that EPA should allow compliance with the MON/HON if greater than 50 percent of the HAP flow is from a MON/HON-regulated facility. Another Working Group member recommended that EPA set process vent limits for combined flow control devices based on weighted average flow volumes.
A. It was Not Feasible lo Comment 011 tlie New Data on Wliich EPA Based the Final Rule Requirememsfor Combined Process Vents
In the proposed PVC MACT rule, EPA did not differentiate between PVC-only and PVC-combined process vents in setting emission limits. ln the final rule, however, EPA promulgated separate em ission limits for PVC-only process vents and PVC-combined process vents. The emission limits for combined process vents were a surprise to the PVC industry because the limits are based on EDCNCM data developed for purposes of the EDC/ VCM Section 114 Request and rulemaking. lndeed, EDCN CM sampling was not completed until well after the c lose of the PVC MACT comment period, and the data was not placed in the docket until January 25, 2012, less than three weeks before the Administrator s igned the final PVC MACT rule. Accordingly, it was impracticable for the Working Group to review and comment upon EPA's treatment of the EDCNCM data before publication of the fi nal PVC MACT rule.
.1.2!! Docket Document No. EPA-HQ-OAR-2002-0037-0185, at 12-65.
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Docket ID No. EPA-HQ-OAR-2002-0037 Vinyl J11s1i1111e Pe1itio11/or Reco11sideratio11 and Request to Stay the Rule Pending Reconsidera1io11
B. The Applicable Scope ofthe Combined Process Vent Provision Merits Reconsideration Based on the Conflict Between the Preamble Explanation and the Language ofthe Final Rule
As the D.C. Circuit noted in Portland Cernent Association v. EPA,Jfil the Agency has an obligation to "acknowledge and account for a changed regulatory posture the agency createsespecially when the change impacts a contemporaneous and closely related nilemaking." 108 Notwithstanding the clear basis for mandatory reconsideration of the combined process vent emissions limitations, the Working Group's concern here is focused on the applicability of the combined process vent limitation to fac ilities outside the PVC source category. Spcci fica lly, Section 63.11865 of the rule expressly states that the PVC MACT does not apply to chemical manufacturing process units that produce VCM or other raw materials used to produce PVC. In contrast, the preamble to the final PVC MACT indicates that facilities in a different source category handling vent streams from multiple faci lities must comply with al l rules applicable to their common control device, whether it is the HON, the PVC MACT, or another rule. According to the Agency:
Ifan emission point is subject to both the PVC NESHAP and other NESHA P because emissionsfrom two source categories are vented to the same control device, both standards applv. Multiple standards applicable to one emission point for the same pollutant are not necessarily ''c011flicting" or "inconsistent. " In some standards, the EPA has allowed compliance with another overlapping standard where that other overlapping standard was determined to be at least as
stringent ...lfthe EPA were to allow sources to meet the requirements from
overlapping, but potentially less stringent rules in lieu ofthe PVC standards. there is the possibility that PVCfacilities would not meet the MACTfloor based standards in this rule. Although we recognize thatfacilities may be subject to different NESHAP regulations. sources are respons ible for e11s11ri11g that they comply with all applicable regulations. Many NESHAP regulations provide a wide variety ofcompliance options, and. as such, it would be a difficult task to identify i11 advance which is the most stringent requirement in each case.!Q2
When Working Group members met with EPA on April 18, 2012, to discuss the final rule, one critical question raised was the impact of the combined process vent limit on EDCNCM and other HON or MON units that may share a control device with a PVC unit. The staIT repeatedly stressed that the most stringent limit would apply, but it was not clear whether the stafrs focus was only on the PVC s ide of the equation or whether they intended also for the HON/MON units to comply with the new PVC MACT limits. This is a critical issue as HON/MON units currently are not subject to some o f the more stringent limits in the PVC MACT and HON/MON unit operators were not afforded the opportunity to comment on whether their control devices could meet the process vent and related operating requirements finalized in the PVC MACT for combined flow.
ill Portland Ceme111 Ass '11, 665 F.3d at 187 (D.C. Cir. 2011 ).
.l!l.8. /d.
.1.22 77 Fed. Reg. 22,869.
41
Docket ID No. EPA-HQ-OAR-2002-0037 Vinyl illsti1111e Petition/or Reconsideration and Request to Stay the Rule Pending Reconsideration
It is not a s imple matter to parse out "the most stringent" operating requirements between different units with d ifferent operating conditions and different rule requirements. Two examples illustrate how a shared MACT-affected control device is now subject to new requirements for which the affected sources with "process vents originating from another source category" did not have an opportunity to review, comment, and resolve the discrepancies and conflicts:
1. At 40 C.F.R. 63. I I940(c)(2), the final PVC MACT requires that the fo llowing be installed on required HC I scrubbers: pressure gauges; a temperature monitoring device at the scrubber gas stream exit; or a specific gravity device. HON does not require any other monitori ng devices (see 40 C.F.R. 63. I 14(a)(4)), nor is it clear that this equipment would be appropriate for control devices generally regulated under the HON or MON.
2. Taking PVC MACT's Table 1 and 2 emission limits for Dioxin/Furans ("D/ F") as an example, Sec tion 63. I I 925(c)(2) for the final PVC MACT requires affected sources to establish an operating limit as per Section 63. I I 880(b). PVC-combined process vent affected sources must now determine how to comply with this requirement for the affected source's PVC operations, along with the process vents from the other source category (e.g., HON or MON), which do not have D/ F limits.
If EPA intended for the HON/ MON units to comply with the new PVC MACT limits, then EPA has erred and violated the admonishment of the Portland Cement court that " it would certainly be arbitrary, as well as a violation of the CAA itself, for EPA to set o ne standard based on data already placed in another source category in light o f the mutual exclusivity of the standards themselves,".ll.Q particularly as none of the facilities in the EDCNCM source category have had an opportunity to comment on these limits and the new potentially applicable operating requirements. Even if the Agency's approach is permissible, the mle is silent, and the sta1T has not addressed to what extent, if any, the most sllingent s tandard extends back to all source operations (e.g. , emission profiles at the process equipment) up to and including operating parameters for the contro l device as well as emission limits for the vent discharging to the atmosphere. Nor has EPA resolved any conflicting provis ions.
For these reasons, the final rule should be amended or clarified consistent with the express language in Section 63. 11 865.
X. The New Requirements for Emission Profiles are Overbroad and Must be Recons id e red
Pursuant to Section 63. I l 925(g) of the fi nal mle, which was not in the proposed rule, PVC facilities must now "characterize each process vent by developing an emissions profile for each contributing continuous process vent, miscellaneous vent and batch process vent," as part of their initial and continuous compliance demonstrations.ill The emission pro fil e is intended to
1.lQ Portland Cement Ass 11, 665 F.3d at 186. ill 77 Fed. Reg. 22,915 (codficd at 40 C.F.R. ~ 63. I I925(g)).
42
Docket ID No. EPA-HQ-OAR-2002-0037 Vinyl lnstitwe Petition for Reconsideration and Request to Stay the Rule Pe11di11g Reconsideration
describe the characteristics of the process vent stream under either absolute or hypothetical worst-case conditions so faci lities can demonstrate that "process vent streams are serving a valid process purpose and are not being diluted prior to control."ill This new requirement is in addition to the requirement at Section 63.11945 that an emission profile must be used to demonstrate that the maximum load is sent to the control device for initial and periodic compliance testing.
The Agency's changes to the definitions of process vent, batch p rocess vent, and continuous process vent, as well as the addition of a new m iscellaneous vent category after the close of the comment period, expanded the emission profi le requirement to cover vents not addressed by the proposed rule. The emission profile requirement under the proposed rule applied only to batch process vents and was limited to establishing stack testing "worst case conditions."ill The final rule not only expands the emission profile requirement, but does so in a manner that is unnecessary and overly burdensome to the PVC indust1y.
In other words, the proposed rule would have required only one emission profile at the inlet of a control device, whereas the final rule requires the development of hundreds of emission profiles from a PVCPU. The industry did not have an opportunity to comment on the unworkable new pro file requirements. Accordingly, EPA must reconsider the emission profile requirement for process vents.
A. It was Not Feasible to Comment on the Agency's New, Much Broader Approach in the Final Rule to Emission Profiles
EPA initially sought to require em ission profiles "for the vent to the control device that describes the characteristics of the vent stream at the inlet to the control device under worst-case conditions."ill The fina l rule, however, requires PVC facilities to develop emissio n profiles fo r "each contributing continuous process vent, miscellaneous vent and batch process vent."ill
In addition, the final rule eliminated, w ithout notice, long-stand ing exclusions from the batch process vent and continuous process vent definitions, certain streams the Agency had determined were de minimis (e.g., analyzer vents, sample emissions) or covered under the LOAR program or work practice standards and incorporated into the MON upon its reconsideration. For example, pieces of equipment that are subject to emission limits and work practices for equipment leaks (e.g., valves, sample connection system) are no longer exempt from the batch process vent definition. As such, emissions profi les must be developed for such valves and sampling connections systems under the new characterization requirements of Section 63. I l 925(g)( I), which apply to batch process vents. T hus, as an initial matter, the Agency's compliance focus changed from consideration of the stream at the inlet to the control equipment,
ill 77 Fed. Reg. 22,855.
* ill 76 Fed. Reg. 29,577 (to be codified at 40 C.F.R. 63.1 I945(b)(3).
ill. 77 Fed. Reg. 22,922 (codified at* 63. l I945(c)(3)) (emphasis added). ill 77 Fed. Reg. 22,915 (codified at 63. l l 925(g)) (emphasis added).
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Docket ID No. EPA-IIQ-OAR-2002-0037 Viny l Institute Petition for Reconsideration and Request to Stay the Rule Pending Reconsideration
to consideration of data describing the vent stream HAP composition and flow from each o f very many process components and em1ss1 on pomts.-116
EPA gave no indication in the proposed rule that it intended such an expansive change to the process vent structure of the PVC MACT, or to terminate the long-standing exclusions for otherwise regulated streams. Thus, the Working Group had no notice o f, or opportunity to comment on, this new process vent approach, which came as quite a surprise to the PVC industry.
B. EPA 's Burden Assessment of the Expanded Profile Requirements was Mistaken
In promulgating the fin al rule, the Agency certainly appeared to envision, incorrectly, that the emission profile requirement would impose a very limited burden on PVC facilities:
We expectfacilities to already /Jave inventories and previous test results available to develop their emissions profile. All ofthef acilities that provided infonnation in response to the August 2 1, 2009, P VC CAA section 114 survey, developed emission profiles. Additionally , we are allowing the emissions profile to be based on engineering assessment or measurement. Because ofthese reasons, 11e do not cmt1c1pate ad'u-'1flo11al hureiIenJ,rom tI11.s reqw.rement.-117
Contrary to this analysis, and contrary to the proposed rule, EPA is requiring, without opportunity for comment, that industry disregard existing emission pro files co llected from the inlet to the control device and is requiring a huge profiling effort for initial and ongoing compliance. The final regulatory text encompasses a much broader universe o f vents to be pro filed, a more comprehensive and, in some cases, impractical testing regime, and much greater repo11ing requirements than perhaps the Agency realized.
For example, as the Working Group reads 40 C.F.R. 63. I l 985(c)(2), PVC facilities must submit a batch precompliance report s ix months before the rule's compliance date fo r each and every vent, and each and every emission episode, associated w ith that batch process. The problem is that the Agency' s definition of covered vents appears to encompass apertures, connections, and other points beyond those to the control device. EPA proposed to define continuous process vents, in relevant part as " .. .the point o f discharge to the atmosphere (or the point o f entry into a control device, if any) o f a gas stream . ..,,llJi The final rule, however, defines "continuous process vent" as:
a ventf,0111 a continuous PVCPU operation through which a HAP-containing gas stream has the potential to be released to the atmosphere except that it is required by titis subpart to [be} routed to a closed vent ~ystem and control device ...
Emission profiles for batch process vents must be developed through calculations set f011h in 40 C. F.R. 63.11950. The Administrator must approve any deviations from the listed
ill Docket Document No. EPA-HQ-OAR-2002-0037-0185, at 10-55. ill 77 Fed. Reg. 22,855. ill 76 Fed. Reg. 29,596.
44
Docket ID No. EPA-HQ-OAR-2002-0037 Viny l lnstitllle Petition for Reconsideration and Request to Stay the Rule Pending Reco11sideratio11
equations. Emission profi les, now apparently including data on flow rate and individual HAP concentrations, must be detennined for continuous process vents by testing v ia methods not suited for inprocess pipes, or by engineering assessments. ln addition, emission profi les for miscellaneous vents must be detennined through an engineering assessment or testing app roved by the Administrator. No PVC facility has on hand inventories and test results to address each HAP and Clow rate information needed to develop an emission profile for the expanded list of individual process emission points covered by the final rule. Thus, as currently worded, the emission profile reporting and recordkeeping burdens arc overwhelming.
C. The Revised Definition ofCo11tinuous Process Vent is Overbroad, Carries Unintended Co11seq11e11ces, and Must be Corrected
Working Group members are concerned that by eliminating from the defin ition o f "continuous process vent" and "batch process vent" any reference to " the point o f discharge to the atmosphere (or point of entry to a control device)" or any other references to discharges to the atmosphere, that the Agency has significantly expanded the scope of the tenn. ln the absence of a regulatory definition for the tenn "vent," the general and broader meaning o f the term as "an opening fo r the passage or escape of a liquid, gas or vapor,"lli must apply. Further complicating the issue, "miscellaneous vents" are subsumed in the definition of"process vents," meaning that emissions profiles must be developed for each "gaseous emissions from samples, load ing and unloading lines, slip gauges, process wastewater treatment systems and pressure relief devices that are routed through a closed vent system to a control device and that are not equipment leaks." Minor changes in raw materials can impact process vent stream compositions so that emission profile calculations appear to be needed and reported every time a change in recipe takes place. There is an added burden for EPA as well if detailed information on the composition of raw materials and their decomposition products must be submitted to the Agency, as such in formation must be managed as Confidential Bus iness lnfonnation.
In addition, individual batch and miscellaneous vent streams from a typical PVC plant (see Figure 3) flow to a centralized recovery system (often containing a gasholder where gas stream compos itions are mixed and equalized) and then fl ow as a continuous vent stream to process condensers where the majority o f the vinyl chloride and some o f the non-VCM HAP is recovered and returned to the process for reuse. Most facilities tested the inlet stream to their control device as part of the Section 114 Request. This data will likely be sufficient with a few other engineering assumptions to detem1 ine the maximum load to the control device fo r the compliance tests. Any further calculations upstream of this point, there fore, are of minimal use with no environmental or regulatory benefit.
XI. Stay of the PVC MACT Pending Reconsideration is Warranted
T he Administrator should stay the application of the final PVC MACT rule pending recons ideration. Section 307(d)(7)(B) of the Act authorize an administrative stay during reconsideration. G iven the errors, textual ambiguities, and regulatory conflicts identified in the preceding discussions, as well as the resulting impediments to nonnal operations at PVC facilities, it would be a mani fest injustice for the Agency to proceed without staying the final
!.!2 Webster's (I New Riverside University Dictionary 1280 ( 1988).
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Docket ID No. EPA-HQ-OAR-2002-0037 Vinyl Institute Petition/or Reconsideration and Request to Swy the Rule Pc11di11g Reconsideration
rule. Accordingly, the Working Group specifically requests that EPA take all necessary and app ropriate steps to stay and defer the compliance deadlines and other provisions of the PVC MACT pending outcome of the reconsideration process. XU. Conclusion
For the forego ing reasons, the Administrator must convene a proceeding for recons ideration o f the PVC MACT Rule, stay implementation o f the Rule pending reconsideration, and extend the compliance deadlines applicable to the Rule to reflect the stay period .
46
Exhibit No. Exhibit I Exhibit II
Exhibit HI
Exhibit IV Exhibit V Exhibit VI Exhibit VII Exhibit VIII
LIST OF EXHIBITS
Description
Oxy Vinyls, LP Memorandum re PVC MACT Survey Wastewater Stripper Error, dated June 6, 20 12
E-mail and Wastewater Data from Barry Christensen, Occidental Chemical Corporation, forOxy Vinyls, LP, to Jodi Howard, EPA, dated September 15, 20 I0 Data and Calculation Spreadsheets from 13 PVC Facilities for Wastewater Stripper Discharge Non-Vinyl Chloride TOHAP Limits
Process Vent Sampling Flow Rate and Concentration Data for Docket Document No. EPA-HQ-OAR-2002-0037-0107
PolyOne Concentration Database for Vent Gas Absorbers
Generalized Procedure to Evacuate and Service a VCM Filter at a Typical PVC Facility
PVC MACT Working Group Analysis of Initial and Monthly Compl iance with Car Seal Inspection Requirements Cost-Benefit Analysis for Release indicators
EXHlBIT I
Oxy Vinyls, LP Memorandum re PVC MACT Survey Wastewater Stripper Error,
dated June 6, 2012
~
D X YV I N V L S-
~ Houston Operations
PVC Technical Group
Interoffice Memo
TO: FROM : DATE: SUBJECT: Distrib ut ion:
John West endorf, Mgr Water & Solid W aste Monica Ortega, Process Engineer 06/06/ 2012 PVC MACT Survey Wastewater Stripper Error Jonathan Witt, PVC Technical Manager; Craig Horak, Production Manager; Jadie Pryor, Environmental Engineer
This memorandum is in response to your questions concerning certain values EPA used to calculate the wastewater stripper emissions limits for major and area sources under the PVC MACT and GACT regulations issued by EPA on April 17, 2012. Specifically, you asked for information on the source of the numbers reported by OxyChem's Deer Park PVC facility in response to EPA's survey request issued in August 2009 to major sources and in September 2009 to area sources, such as the Deer Park PVC facility.
Form K-3 of the survey requested information on the facility's process wastewater streams.
Form K-3-b specifically requested HAP and voe concentration data collected in 2008 for the
process wastewater streams. On Form K-3-b, the Deer Park facility reported a sample concentration of 0.018 ppmv for Acetaldehyde in the process wastewater streams (Stream ID #s W-307, W-308 and W-310). We also reported concentrations of 0.065 ppmv for Vinyl Chloride and 0.4 ppmv for "Other" HAPs (same Stream ID #s).
I was asked by my manager in September 2009 to gather information for preparing the survey response for the Deer Park PVC facility. I was aware that the facility collected and analyzed vinyl chloride concentration data at the outlet of the wastewater stripper on a weekly basis, as part of OxyChem's process control program and to verify compliance with the Vinyl Chloride NESHAP regulations. It is the facility's practice that upon receipt of the analytical results, onsite laboratory personnel are responsible for entering the results into a computer software program.
In researching whether any additional process wastewater samples had been collected in 2008, I reviewed the facility's annual 2008 Emissions Inventory (El) report submitted to the Texas Commission on Environmental Quality in 2009. The El report included an emissions data sheet for an emission point identified as "DPS-031 Wastewater Stripper." I assumed that the reported data was for the process wastewater stripper. The data sheet reported a concentration of 18.0 ug/liter for Acetaldehyde (essentially equivalent to 0.018 ppmv). It also
reported concentrations of 64.5 ug/liter for voe and 400.5 ug/liter Total Non-VCM. I entered
Page I of2
these values onto EPA survey Form K-3-b for the facility's process wastewater streams, which was submitted to EPA on March 3, 2010. After EPA released the final PVC MACT and GACT standards earlier this year, you reviewed EPA's background documents for calculating the process wastewater emissions limits. EPA included the 0.018 Acetaldehyde value in the MACT and GACT floor calculations, but did not use the VCM or Total Non-VCM values reported by the Deer Park facility. You questioned the source of the 0.018 number and asked me review the source documents. Upon close analysis, we discovered that the data in the El report identified for the "DPS-031 Wastewater Stripper" was supposed to represent data from a groundwater remediation stripper at the Deer Park facility, not the process wastewater stripper. The groundwater stripper is located in the water treatment facility adjacent to the PVC facility and is completely unrelated to the PVC process wastewater stripper that is regulated by the PVC MACT and GACT standards. This error was not detected until you asked me to review the source numbers reported in the Deer Park facility's survey response after you reviewed EPA's final wastewater emissions limit calculations.
Page 2 of 2
EXHIBIT II
E-mail and Wastewater Data from Barry Christensen, Occidental Chemical Corporation, for Oxy Vinyls, LP, to Jodi
Howard, EPA, dated September 15, 2010
From : Howard.Jodi@epamail.epa.gov (mailto:Howard.Jodi@epamail.epa.gov] Sent: Wednesday, September 15, 2010 6:54 PM To: Christensen, Barry H. Subject: Re: Response to More questions regarding PVC test and survey data
Thanks Barry.
******************************** ..... **************************
Jodi Howard, Environmental Engineer
U.S. EPA - Office of Air Quality Planning and Standards Sector Policies and Program Divisions
Coatings and Chemicals Group Mail Code: E143-01 Research Triangle Park, NC 2771 1
Phone: 919-541-4607
Fax: 919-541-0246
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!Response to More questions regarding PVC test and survey data
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Jodi,
enclosed is a few additional data HAP points on wastewater that we took at the time of our sampling. The first sheet for our Pasadena plant encompasses
wastewater that has been steam stripped by our onsite wastewater stripper. The second sheet includes data from our Pedricktown plant that flows directly to the onsite biological wastewater treatment plant operated by PolyOne. It is separate from the process wastewater with VCM that
flows separately to the onsite PolyOne steam stripper. We can provide the back up outside laboratory reports should you need them.
Pis let me know of any questions on this data .
Barry Christensen Occidental Chemical Corp. Mgr Air Quality 972 404 3209
-----Original Message---From: Christensen, Barry H. Sent: Wednesday, August 25, 2010 3:51 PM To: 'Howard.Jodi@epamail.epa.gov' Subject: RE: Response to More questions regarding PVC test and survey data
Jodi,
in the meeting with VI you mentioned you were not able to locate our 4/21/10 submission . We are sending another copy to your attention which you should receive tomorrow.
Thanks for meeting with us yesterday. The meeting prompted some thought on a few other items we can send that may supplement some gaps in information.
(See attached file: OV Wastewater Analytical Data (with MDL values).xls)
Resin Sampling Results for Wastewater Stripper OxyVinyls, LP Pasadena, TX
Wastewater Type
Flow Diagram Equipment No. Flow Diagram wastewater Stream number
Suspension Grade
Date Sampled Date Received by Lab Lab Report Number
Compound
CAS No.
Method of Analysis
Ethylene Glycol
107-21-1
DAI by GC/MS 8260 SIM
Benzene
71-43-2
SW846 8260 B
Chloroethane
75-00-3
SW846 8260 B
Chloroform
67-66-3
SW846 8260 B
Chloromethane
74-87-3
SW846 8260 B
1,1-Dichloroethane
75-34-3
SW846 8260 B
1,2-Dichloroethane
107-06-2
SW846 8260 B
1,1-Dichloroethene
75-35-4
SW846 8260 B
lsopropylbenzene
98-82-8
SW846 8260 B
Toluene
108-88-3
SW846 8260 B
2,2,4-Trimethylpentane 540-84-1
SW846 8260 B
Vinyl Bromide
593-60-2
SW846 8260 B
Vinyl Chloride
75-01 -4
SW846 8260 B
Xylene (Total)
1330-20-7 SW846 8260 B
Phenol
108-95-2
SW846 8270 C SW846 3510C
Acetophenone
98-86-2
SW846 8270 C SW846 3510C
Hydroquinone
123-31-9
SW846 8270 C SW846 3510C
Methanol
67-56-1
SW846-8015 (DAI)
Formaldehyde
50-00-0
SW846 8315 SW846 8315
Acetaldehyde
75-07-0
SW846 8315 SW846 8315
Detected values are reported in bold font.
MDL values are reported in italic font for ND values.
Process water
Wastewater stripper (U-1202)
Discharge of the wastewater stripper (Stream W-1221) that flows to bioloaical treatment
GP, HMW, LMV*
12/22/2009 12/24/2009 JA35458
GP, HMW, GP, LMW LMW 12/29/2009 1/6/2010 12/31/2009 1/8/2010 JA35466 JA35476
GP, HMW, LMW
1/ 12/2010 1/14/2010 JA35488
GP, HMW, LMW
1/19/2010 1/21/2010 JA35502
GP, HMW, LMW
1/28/2010 1/30/2010 JA36409
ND 120 ND 1.2 ND 1.9 ND 1.2 ND 1.4 ND '1.4
2.7 J ND1 2.0 ND1 2.9 ND1 1.5 ND1 2.2 ND(0.50
40 ND(1 .3 ND(0.58
5,220 ND(5.0 656,000
25 844
ND(120 ND(1.2
2.8 J 4.3 J ND(1.4 ND(1.4 2.8 J ND(2.0 ND(2.9 ND(1.5 ND(2.2 ND(0.50
38 ND(1.3 ND(0.58
9,110 ND(5. 0 858,000 ND(6.3 10.1 J
Concentration (ug/1
ND/120) ND 120
ND(4.7! ND'12
ND(7.4) ND 19
ND(4. 7) ND 12
ND/5.8) ND 14
ND/5.7) ND 14
ND(6. 7) ND 17
ND(7.9) ND 20
ND/11! ND 29
ND(6)
ND 15
ND(B.8) ND 22
ND(2.0) ND15.0
21
36.9J
ND(5.0) ND(13
ND(0.58) NO 0.58)
4,790
9,010
ND/5.0) ND 5.0
806,000 490,000
162
NO(6.3
8,370
85
ND(120) ND(1 .2)
5.8 ND(1.2) ND(1.4) ND(1.4)
2.6 J ND(2.0) ND(2.9) ND(1.5) ND(2.2) ND(0.50)
72 ND{1.3) ND(0.64)
9,190 ND(5.6) 265,000 NO(6.3) ND(4.8)
ND(120) ND(59 ND(931 ND(59 ND(72 ND(72) ND/83) ND/99) ND(140 ND/75) ND(110 ND(25 ND(110) ND(63 ND(0.62) 9,950 NO/5.4 620 ,000 ND(6.3 2,110
* GP = General Purpose resin
HMW = High Molecular Weight resin LMW = Low Molecular Weight resin
The samples were analyzed by Accutest Laboratories.
Analytk:al SMnplln,g Ruuha for S11np, Column, C ntr1t and Sc;rubber WutewatH OxyVlnyl LP Pedrkklown. NJ
Wuieweter T......
Flow OEagr.am Enul..,,m.nt No,
Flow Oi..grm
wal w t, s,,...m
nLM'T'IMr
Sus~ne.li Grad
Oat. SamDi.d Oat Rec:elwd bv Lab Lab Re.......,. Nurnt>.r
C o m -n d Et..:-..;.;,_ Gtvaii
Benzene
Criloro&:Nnt ChlOroform
Crilorome:hane
1, t - - O i ( h b r o e t h l l n e
1 2 D1chlorneuw.ne
1,1-0lehbro.U.ne iso---....Jti.nane
T,._.,no
2 2.4--Tnmett-J- ntaM
Yri---;:;;j8t'Offldl
V11~Chlonde
X
""'"'
"'
o,no
1-fwr'lt"OQurone
Methanol
Formalda'-ie
Acataldehvie
CASNo. 101.i,.1 71-43-2 75-00-l 07-C,O..J 7 4 - 8 7- 3 IS-34-J
.....,..t07-05-2
7(,-36-4
1~ 8 8 - 3 S,0..,..1 so.~0-2 76-01-4
......, 1330-20.7
10~-2
123--31-V e1-M-1 50-00-0 75-07-0
M thod of Analvl DAI bv GC/MS 62) SIM
swe.:e 82tloe
SW84082e0 8 SW~B:2&08
SW84G82008 SW~8:260B SW8-4.& 82608 SW~B:ffl.OB SW846~08 SW84G82e08 SWB-4& 82eCJ 8
SW84G82008 SW84682eCJ8 SW84C82CIOB SW84&8270C SW84635t0C SW84C8270 C SW84& 3$10::::
SWM8 8270 C SW54C 3S10C S~15<DAll SW~ 8315 SW84-e 8315
SW~ 831~ SW8-'a 8315
0.t.cted values are rtported in bold font Val~ 111portod w!lh 4 .J' 'ndieale an stffla!Atd value
LPSumn LPSumn
Stripping CoNNnn
u-eo2 U -<102
W-<!04 tAed and
H9h Molecular
WI 11/412000 11611000 JA32100
W-<!04
Genel'III Pume.u 1/17/2000 1l17/2QOQ JA37MO
-..~....-.U-203
_,.,, E~tonl
w....
H,gh Molt~r
en
11/4/ZOOO 11/5/2000 JAl21Cle
Ni 120 W'. 023
Nr. 03 Nr 02J Nr. OZP
iii'. ON
ND 033 ND 0.40
2.3 Nnl030
...ND044 0 ,o
.,_. NnJO 25
1.270 ND ~O
003 010 1,040
Concentrat ion uni!\
NDl120
NDl120
N0023
ND1121
3.0
. . .0
N0023 NDO~
=f' 13..t
N0 .029
N()l1 l
N0031
NDlt. n
ND0 40
Nrl 030 NfJ O.._.
NDl20J
11.e
NO 1$
Nfll2ZJ
Nfl 0.10
N'YO $0
2 ),. (
N00.25
....1,7 J
N025) 1,130
.,,175
2.HO Nflif JJ
2$.3
...1 310
ND(50J
2n J
1.030
Cent.rat Cantrate Centrt Cenr,at, c,ntntt Cantrt CMtr,te CMtrat, cem,..,, Centr t c,nrr.t, c,ntrat,
U,603
u-eo,
U -<IOJ
u-eo3
u-eo,
U-C03
U-603
u-eo,
U-<!03
U-<!03
U-c103
U-cl03
MS-o<d!1.,9..,
H,gh
Molecullr Wt.
11/1~ '1/2/2()00 JA318n
S-<>20 tl..edand
H,gh Molecular
Wt 1112/200Q 11f3,7Q()Q JA3t878
S--020
Mod'"
"'"" Molecutar WI 11/3/200CI 11f4flOOQ JA.31002
,,S.-.-,0,2.0.,
H,gh Molitcu1.lr
Vil 1 11412'Cl(W 1 114/2000 JAl21Cle
S-<>20
S--020
S-<!20
S-<!20
S--020
S-<!20
S-<!20
Med nd
~-..G.ne1'111
General Puroos.
~-..Geriera1
Gener.ti
~~.
Gener1 P-H
Ger,er-.1 p , -..
H,gh Mowlar
WI.
11/W200Q 1 1/tMOOO 1111 lfl'009 11/13'2000 11113/2000 11114.'2009 12J1gl2()()g
11,W2000 111101200Q 1 1/11/2000 11/ 13r.XX)g 11/lJl'ZC()g 11/ 14'2000 1:2/2CV2000
JA324 3CI JA:32471 JA32513 JA328&C JAJ28M JA~3CX>e JAJ.5946
S-<!20
General Pumo,-e 11u,12010 111115/2010 JA37828
Nf T20' ND021 N00.3 ND02 N0029 ND020 N003J1 N 0~ N 00 N OJO ND(O 44 NDI0. 10
0.44 NO{O 25
1 5. S 1,410 NDl5 0,
010 300 f,200
N 120 N 0231 N OJ
0'3 M 0 .2" M 029
"' 033
ND 0 40
...N 05i
M OJO
M 0. 10 N0044J ND 0251
20.7 1,000
...N0(50 1,310 ,..,.
ND f20 NI 023
03)
N 023 NI 02" N 02Q Nl 033 N 040 N 05) NOOJO
04il Noo ,m ND o.cAJ ,V( 0251
2 . t, 0 1300 ND50 1,000 500 1,130
NC 120 ND023 ND ojj ND 023 ND02'9 N ONJ
N 0331 N 040l
o .5 n N 030!
N OI N O 10 NOfo .--11 ND 02$
20.2
1 . 8-40 Nfll5at
1 ?70 113 1,080
,.NDf120J
1Vni(J2J
NDIO 23 NDJO 2P NOI0. 2'1
O. iS&J NDf0.40 NDio., NDO..:JO ND/044
0 . 10 3.0 N{)IO~
,., NnlOM
-Nf')f~.0 2.000
2. 140
Conc.entHtlo.n
ND 120 Nf>I0.23
2.1
,.NDlt20
NDIO 23
NDIO 23 NDIO 2Q
1.0 NDIO 2Pl
NDIO 29 ND 0291
0 ,52 J
0.82J
N 0-10 N O<O 007 N 05
ND0.30 N OJO
N0044 N 044
ND O f 3 ,3
N 2O.,HJ.
ND025 N0(02Sl
NOO~
2.0
850
no
NDSOJ NDl50J
2.230
2,010
400
185
2,150
1.900
,.NDl120 023
ND023 NDl02'PJ NDO.~
0.e5J ND0 40 Noa, Nf. 030 N 044 Nt. OM
3.8 ND{O 25
3.1 812 NOIS t11
..,..2.320 101
,,o
N0(0231 2.1
ND O?JI N0/0201
N0029 0.81 J
N004-0 Nf, 057 M)OJO
ND0 4-4 NDO 10
3,3 ND(025
2.,
..710
,..NU<50
150 3,870
~
Sa.mole
NOl120J NDf0.231
5,3 N6ro2JI NDiOzif
NDlo-&i
0.71 J Nf. O'"""im NC 057f N7. 0301 NDOT NOD 10
11.t
...NOO:ZS 3.7
Nf')/50
2710 104 3,. . .
ND/1201 NDI() 2Jl MJjoJn NDI02.1) ND/0211 NDfONP N0/03" N0f0401 NDI05n NDOJO ND/0 441 NDIO 10 AJJ"VQ '4J
..NDIO~
,23.2
ND55
270 174
No Teat N0023
0.9J NDJO 2J =029 NDIO.~
NDJO 33 NDIO 40 rvu,0 5-1
NO 030 NCif0-14
ND010
2.0 ND02S NOOMJ
,02
"1".,,7'2.0'
2,74 0
s,,.,.,_ S c - Scrubbe, Scnbbo,
Scn,bbo, Scrubber
C-212
C-212
c.212
C-212
C.:212
C-212
W -200
...H...,g"h"'
Molteutar WI
1'12/2000 11fJJ2COV JA31873
W -200 '-'tlt!'ld
H,gh MoAoeular
WI l 1/412'0C)g
1114/2000 JA3210e
W -~
w.200 w.200
G.ner I Pu......,s.e
..~-- Geneflll
Mod ond H,gh
P\.-1olllc;ular Wt
11/W2009 11/2Q/2000 12JIQ/'2()0g
11,WOOO 1 1/2Q/2000 12/20t2000
JAJ,400 JA335JC JA3S~
w.200
GenerBI P-$e t / 15 / 2 0 10 1116'2010 JA371157C
N""0'"2"3
N OJ N 023 NDD20
~ 020 0.33 N O<O N005 N0030 N00 44 NO0 10 ND044
N ,.0.,2'
..,..2"3
, N()/5 OJ
1,490
NO 120 ND 0231 m OJ]
~,m 0.23 029) N00.10 ND 0.33 N0040 NOOO N0030 NDO NO 010 N 0 ,.
ND 025 23.0 327
ND(5.0J 32' 1,110 3<0
Co,,(tntr Uon
12 N00"' N003
,N.,,D 120 ,.,, 0"3
03
ND023
023
N 02P Nl 020
N 0.2Q NO 0.2Q
03' M 0JJ
N O<O N00.40
ND/0. N005
N()(OJO ND 0.30
NDl0 44 NDO
ND{O 10 NC o 10
1,3
ND(O.~ 3.3
110
.,.N0(5.0
7. . 2830
0.52J
,..NDiO~T
NnJO$aT
.NOOO
"3.2',7
N 120
02J N003 ND Ol:3 N 029
020
ND033
o,o
N 0$1 NOOV N00 44
ND0fO NOOc, ND 0.25
24.1 220 NOi$ ,i
.,..,,NDl341
'' N
N 023 N 037 N0023 Nl 0211 N 020 Nl 0.33 N O<O Nl 05; N OJO NOO N0010
1. NDf02.SI NOtO.st,j
09.2 ND150
308
.3,0.0
The samples were analyzed bv Aocute.s1 l.abore:orin
EXHIBIT III
Data and Calculation Spreadsheets from 13 PVC Facilities for Wastewater Stripper Discharge Non-Vinyl Chloride TOHAP
Limits
EXHIBIT Ill List of Data and Calculation Spreadsheets from 13 PVC Facilities for Wastewater Stripper Discharge Non-Vinyl Chloride TOHAP Limits
(submitted in the enclosed CD)
VI PVC MACT Wastewater Sampling Test Results 6-1 3-1 2.xlsx WW TOHAP Recalc 0606201 2.xlsx
EXHIBIT IV
Process Vent Sampling Flow Rate and Concentration Data for Docket Document No. EPA-HQ-OAR-2002-0037-0107
Exhibit IV: Process Vent Sampling Flow Rate and Concentration Data for Docket Document No. EPA-HQ-OAR-2002-0037-0107
larilil~ FPC - DE
FPC - TX
FPC - LA
Georgia GulfAberdeen Georgia GulfPlaquemine
Conlrol l>l'\ icr Thcnnal Oxidizer
Thennal Oxidizer
Process Gas Incinerator/ Caustic Scrubber
Thcnnal Oxidizer TI1cnnal Oxidizer
Flo\\ Hate (lnlrl)
I-lo\\ Hale (Outlel)
I IIC Conrentralion lk:tding,
C'II-' Conrrnlralion
01hr \ nal~ te,
l;15Ccl Spreadsheet:
- PVC MACT FPC DE
Testing-Emissions_Dam.xls Worksheet:
TestingData-lnlct ~ : Row 31, Columns C-E
Excel Spreadsheet:
- FPC TX PVC_Testing-
Emissions_ Data.xls Worksheet: - res1ingData-ln let ~ : Row3I.ColumnsC-E
Excel Spreadsheet FPC L,\ PVC_TestingEmissions_Data I.xis
Worksheet:
- TcstingData-lnlct
c~ll Nos: Row 31. Columns C-E
Excel Spreadsheet: Georgia_Gulf_Abcrdeen_PV C_Testing- Emissions_Data
Worksheet: TcstingData-lnlct
Cell Nos: Row 31. Columns C'E
Excel Spreadshcc1: Georgia Gulf Chemicals_Plaqucmine_P\IC _Testing-Emissions_Data
Worksheet: TestingData-lnlct
Cell Nos: Row 31. Columns C-E
faccl Spreadsheet:
PVC MACT FPC DE
Testing-Emissions_Dam.xis
Worksheets: TestingData-Outlet
Tcs1ingData-Outlet-jack TcstingDam(Dioxinfuran)-
Outlet Cell Nos: Row 31. Columns C-E
Excel Spreadsheet: - FPC TX PVC_Testing-
Emissions_Data.xis
WorkshCCl$:
- TcstingData-Outlct(VOST
HAi's)
- TcstingData-Outlct (M26A
& 320)
TcstingData-Outlct (SVOL)
- TcstingData(DioxinFuran)Outlet
- TcstingData(PCB)-Outlct Cell Nos: Row 31. Columns C-E
Excel Spreadsheet:
- FPC LA PVC_Tl-sting-
Emissions_Data I.xis
Worksheets:
- TestingData-Outlct
Si.i nivolat ile
- TestingData-Outlet
VolsFTLR
- TestingData(Dioxinfuran)-
Outlet
Cell Nos: Row 31 , Columns C-E
Excel Srrcadsheet
- G,-orgia_Gulf_1\bcrdecn_PV
C_Tcsting-Emissions_Data
Worksheet: TcstingData-Outlet
~
: Row 31. Columns C-E
Excel Spreadsheet:
- Georgia Gulf
Chcmicals_Plaqucmme_P\I('
_Tcsting-Emissions_Data
Worksheet:
- TcstingData-Outlct
~
: Row3 1.ColumnsC-E
Excel Spreadsheet: PVC t. lACT FPC DE Non CBI CO-THCCH{Monitoring.xls
Worksheet: CO-TIIC-CH4 Monitoring Data
Cell Nos: Colwnn D
Excel Spreadsheet:
- FPC TX Non-CBI
PVC CO-TIICCH4=Moni1oring.xls Worksheet:
- CO-TlIC-CH4 Monitoring Dam Cell Nos: Column D
Excel Spreadsheet:
- FPC LA Non CBI PVC COTI-IC-CH4_Monitoring,; Is Worksheet:
- CO-THC-CH4 Monitoring
Data Cell Nos: Column D
Excel Spn;adsheet:
- GeorgiaGulf_Abcrdecn_PVC
CO-TIIC-CH4 Abcrdccn_Monitoring_ Final Worksheet:
- CO-TIIC-CH4 t.1onitoring
Data Cell Nos: Column D Excel Spn;~clshcct:
- Georgia Gulf
Chemicals_Plaquemine_PVC _CO-Tl IC-CH4_Monitoring Worksheet CO-Tl IC-CH4 Monitoring Data (ell Nos: Column D
Excel Spreil(lshcet: PVC MACT FPC DE Testing-E111issions_Da1a.xls
Worksheet.s:
- TestingData-lnlet TestingData-Outlet TestingOam-Outlet-jack (ell Nos: Row 36. Columns C-E
Excel Spreadsheet: FPC TX PVC_Tes1ingEmissions_Data.xls
Worksheets:
- All
(ell Nos: Row 36, Columns C-E
Excel Sprcaclshcct:
- FPC LA PVC_TcstingEmissions_Data I.xis Worksheets:
All Cell Nos: Row 36, Columns C-E
Excel Spreadsheet: GeorgiaGulf_Aberdeen_PVC CO-TIIC-CH4 Aberdccn_Moni torin g_ Final
Worksheet:
- CO-TIIC-CH4 Monitoring
Data Cell Nos: Row 36, Columns C-E Excel Spreadshi.-ct:
Georgia Gulf Chemicals_Plaqucminc_PVC _CO-THC-CH4_J\.fonitoring Worksheet:
- CO-THC-C114 Monitoring Data ~ : Row 36. Columns C-E
Exec! Spreadsheet :
- PVC MACT FPC DE Testing-Emissions_ Data.xis
Worksheets - All CcJI Nos: Rows 39-End, Columns C-E
Excel Spreadsheet:
- FPC TX PVC_Testing-
Emissions_Data.xls Worksheets :
- All
~ : Rows 39-End, Columns C-E
Excel Spreadsheet: FPC LA PVC_TestingEmissions_Data I.xis
Worksheets:
- All
Cell Nos: Rows 39-End, Columns C-E
Excel Spreadsheet:
- Georgia_Gulf_Aberdccn_PV
C_Testing-Emissions_Data Worksheet:
All ~ : Rows 39-End, ColumnsC-E
Exec! Spreadsheet:
- G~-orgia Guif
C'hcmicals_Plaquemine_PVC _Tcsting-Emissions_Data Worksheet: - All Cell Nos: Rows 39-End, ColumnsC-E
I Oxy - Dcc-r Park
L.1Porte Thcnnal Oxidizer
Worksheet:
I Worksheets;
I ~ : - TestingData-lnlct Row 31, Columns C-E
TcstingData(SVOCs)-Outlct TcstingData(VOC)-Outlet
TcstingData(DioxinFuran)-
Outlet
TcstingData(PCB)-Outlct
~ : Row 31, Columns C-E
Excel Spn:~dsheet:
Ex~cl S[!rca!!{'heet:
Testing-Emissions Data
Testing-Emissions Data
NC.xis
NC.xis
Worksheet:
Worksheets:
I I ~ : Oxy - Pasadena 111cnnal Oxidizer
TcstingData-lnlct Row 31, Columns C-E
TcstingData(VOC)-Outlet TcsingData(I !CLCL.2)-Outlet
TcsingData(SVOC)-Outlet
TcstingData(DioxinFuran)-
Outlet
TcstingData(PCB)-Outlct
Cell s: Row 31. Columns C-
Excel Spn:adshce1:
xi.l S[!readsbo;;t:
PVC_Tcsting-
PVC_Testing-
I Shinteeh - Addis
I Thermal Oxidi,--er/
Scnibber
Emissions_Data.xIs
Worksheet: - TcstingData-lnlct ~ J_JJ1IQS: Row 3 I, Columns C-E
Emissions_Data.xls
\\lorkFheets: T,:.-stingDatn-Outlet TcstingData(DioxinFuran)-
Outlet
TcstingData{PCB)-Outlct
Cell Nos: Row 31. ColumnsC-E
l;xcel S11rcaclsheet:
Excel S11readshcet:
- Shintcch PVC_Tcsting-
Shintcch PVC_Testing-
ShintcchFreeport
IIncinerator/ Scrubber
I Emissions Data 022610.xls Worksheet: - TestingData-lnlct ~ : Row 3 I, Columns C-E
Emissions_Data 022610.x ls Worksheets:
TcstingData-Outlet . TcstingData(DioxinFumn)-
Outlet
TestingDaUl(PCB)-Outlet
Cell Nos: Row 3 I. Columns C-E
Excel Spn;adshee1: . PVC Testing-Emissions
Exe~! Sl!rcadshcc1: PVC Testing-Emissions
Shintcch Plaquemine
Data.xis
1 11,cnnal Oxidizer/ Scn,bbcr
j Worksheet:
- TcstingData-lnlct_PVC (ell Nos: Row 31, Columns C-E
Data.xis
Worksheet: - TcstingData-Outlet ~ : Row 3 I, Columns C-E
MonitoringNC .xis
Worksheet: . CO-THC-CIH Monitonng
Data
~
:Co!wnnD
Exe~! Sl!rcadsh~"1= . CO-THC-CH4_Monitoring
Pasadena NC.xIs Worksheet:
C'O-THC-CH4 Monitoring Data (8) ~:ColumnD
Excs;I Sl!r.1dshi.!: PVC_CO-TIICCl !4_Monitoring.xls
Worksheet: CO-THC-Cl 14 Monitoring Data
Cell Nos: Column D
Excel S1Jrcadsh'-t: Shintcch 30-Day PVC_COTHC-Cll4_Monitoring 022610.xls
Worksh~'Ct:
. CO-TMC-Cll4 Monitoring
Data !::_ell Nos: Colwnn D
Exq;I Spn;adshe~t: PVC CO-THC-C'H4 Monitoring.xis
Worksheet: CO-THC-CH4 Monitoring Data
Cell Nos: Column D
Workh~'!;!S: . All
~
: Row 36, Columns C-E
Worksheets: All
~ : Rows 39-End, ColumnsC-E
[;x~ I Sp!J:~dsheet: . Testing-Emissions Data
NC.xis Worksh~'!;t:<: . AU ~ : Row 36, Columns C-E
E~!:I Sl!!l.!dsbcct: Testing-Emissions Data
NC.xis
Worksheets: All
~ : Rows 39-End, ColumnsC-
l;xi.~I Sl!!!:il!IShcct: PVC_Testing-
Emissions_ Data.xls Worksheets:
All (ell Nos: Row 36. Columns C-E
l;;x~cl Sl!readshcer PVC_TestingEmissions_Data.x Is
Worksheets: . All ~ : Rows 39-End.
Columns C-E
Excel S11readshcct: Shintech PVC_TestingEmissions_Data 0226 I0.xls
Worksheets: . All Cell Nos: Row 36, Columns C-E
Excd Sl!rcadshl-ct: Shintech PVC_TestingEmissions_Data 022610.xls
Worksheets: . All Cell Nos: Rows 39-End, ColumnsC-E
l;x1,cl Spreadsheet: PVC Testing-Emissions Data.xis
Worksheet: . TcstingData-Outlct (ell Nos: Row 36, ColumnsC-E
r,xccl Spreadsb!.!.l: PVC Testing-Emissions Data.xis
\\lorksheet(sl: TcstingData-Outlet TcstingData(Dioxin Fumn)Outlet
~ : Rows 39-End , ColumnsC-E
mim
Control l>e,ice
Flm1 Ible (Inlet)
Flow lt:tle (Outlet)
TIIC Conernlralion lk:tdings
Cll4 Concentration
Other Anal~lt>s
Westlake Calvert C ity
I Thennal Oxidizer
Excel Spreadsheet: PVC_Testing-
Emissions_Data- Calven
I City_2-26-I0 .d s Worksheet: - TeslingData-lnlet (ell Nos: Row 31 , Columns C-E
Westlake Geismar
Primary and Oxy
1 1ncincrntors,
Incinerato r
Scrubber
I PolyOne - Henry VGA
Excel Spreadsheet: PVC_ TestingEmis s ion s _DataGeismar.xlsx
Worksheets: TestingData-lnlct (PVC WET) TestingData-lnlet (PVC DRY) TcstingData-lnlct (OXY REACTOR) TestingData-lnlct (UVS)
.. (ell Nos: Row JI. Columns C-E
Excel Sureadsheet:
. Henry-PVC_Testing-
Emissions_Datafor VI.xis
I Worksheet:
- TcstingData-lnlet Cell Nos: Row JI , Columns C -E
!;;xcel Sm:eadshcct: PVC_TestingEmissions Data- Calvcn City_2-26::-10 .xis
Worksheets; TestingData-Outlet
- TestingData(DioxinFuran)-
Outlet TcstingData(PCB)-Outlct ~ : Row3 l ,ColumnsC-E Excel S11readsheet:
- PVC_Testing-
Emissions DataGeismar.xlsx W orks heets; T e st i ng D ata -Outlet T e sting Data( Diox in Furan)Outlet Testing Data( PC B )-O utlct ~ : Row31 ,ColumnsC-E
Excel Spreadsheet:
. Henry-PVC_Testing-
Emissions_Datafor VI.xis Worksheet: . TcstingData-Outlct Cell Nos: Row 31, Columns C -E
0 C H 4_ M o n i t o r i n g - C a l v c n C ity_2-26-l0.xls Worksheet: CO-THC-C l-14 Monitoring Data (ell Nos: Column D
Excel S11readshee1: PVC_CO-THCC H4_ Monitoring- l Gcismar.xls
Worksheet: CO-TIIC-CH4 Monitoring Data
~ : C olumn D
Excel Snreadshcct: Henry- PVC CO-THCC H4_ Monit~g.xls
Worksheet: CO-THC-CH4 Monitoring Data
Cell Nos: Colwnn D
PolyOne Pcdric~'town
I VG/\
Oxy Pe<lricktown
I VGA
Excel Sureadshcct: PolyOne Pedricktown
I PVC TestingEmis~ions_Data for Kl I.xis Worksheet: TcstingOata- lnlet Cell Nos: Row 3 1, Columns C -E
Excel Spreadsheet: PolyOne Pcdricktown PVC_TestingEmissions_Data for Kl-I.xis
Worksheet: TestingData-O utlc t
Cell Nos: Row 3 1, Columns C-E
Excel Spreadsheet: . PolyOne Pcdricktown
PVC_CO-THCC H4_ Monitoring.xis
Worksheet:
- CO-THC-CH4 Monitoring
Data
(ell Nos: Column D
I Routed through PolyOne
Pcdricktown facilitv
I Routed through PolyOne
PtYlricktown faci litv
J Routed tl1rough PolyOne Pi><lricktmm facilitv
D 5- 10
I (ell Nos: Row 36, Columns C-E
no
Excel Spreadsheet: PVC_TestingEmissions_DataGeismar.xlsx
Worksheets: Testing Data-Outlct TcstingData(DioxinFurnn)Outlet TestingData(PCB)-Outlct
Cell Nos: Row 36, Columns C-E
Excel Surea dsheet: PVC_TestingEmissions_ DataGeismar.xlsx
Worksheets:
. All
~ : Rows 39-End, Columns C-E
---- ~~
--- ~ -
Excel Spreadsheet: Henry-PVC Testing-
Emissions_Datafor VI.xis
Worksheets: TestingData-lnlet
. TcstingData-Outlct
Cell Nos: Row 36, Columns C-E
Excel Spreadsheet: PolyOne Pedricktown PVC_ TestingEmissions_Data for KH.xls
Worksheets: TestingData- lnlet Tes tin g Data-Outlet
Cell Nos: Row 36, Columns C-E
Routed through PolyOne Pcdricktown facilitv
Excel Snreadsheet:
. Henry-PVC_Testing-
Emissions_Datafor VI.xis Worksheets:
TestingData- lnl e t
. TcstingData-Outlct
Cell Nos: Rows 39- End, Columns C-E
Excel Spreadsheet:
. PolyOne Pedricktown
PVC_TestingEmissions_Data for KH.xls Worksheets: TestingData-lnlct TestingData-Outlet Cell Nos: Rows 39-End. Columns C-E
Routed through PolyOne Pcclricktmm facilit
EXHIBIT V PolyOne Concentration Database for Vent Gas Absorbers
EXHIBITV List of PolyOne Concentration Databases for Vent Gas Absorbers
(submitted in the enclosed CD)
Henry- PVC_CO_CEMS_Monitoring.xls Henry- PVC_CO-THC-CH4_Monitoring.xls Henry-PVC_Testing-Emissions_Data.xls PolyOne Pedricktown PVC_CO_CEMS_Monitoring.xls PolyOne Pedricktown PVC_CO-THC-CH4_Monitoring.xls PolyOne Pedricktown PVC_Testing-Emissions_Data.xls
EXHIBIT VI
Generalized Procedure to Evacuate and Service a VCM Filter at a Typical PVC Facility
Generic Vinyls PVC-
Page 1 of 10 Production
VCM Filters
Issue Date
Rev.#
1
Rev. Date
SCOPE: This procedure describes the steps necessary to evacuate and service the VCM filters.
Removing from service Returning to service
REQUIREMENTS: The poly floor operator is responsible for performing this procedure. Maintenance must wear fresh-air when opening the filter.
Used filter elements must be placed in plastic bags and removed from the poly floor roof and disposed of in the BFI bin. RELEVANT DOCUMENTS VCM MSDS
DEFINITIONS
None
PROCESS EQUIPMENT : VCM Charge Line II VCM Charge Filter RVCM Filters, Virgin VCM Filter
MATERIALS/EQUIPMENT (36) Filter cartridges
SAFETY
Hazardous materials are materials that present a health
and/or physical hazard. Refer to the attached chemical description which lists the
hazardous material, the hazards they present and the controls used to minimize the
hazard.
QUALITY
This is a quality critical procedure. The filter elements must
be installed properly to prevent quality problems.
ENVIRONMENTAL
There are environmental regulations associated with the
opening of this equipment that must be properly followed throughout this procedure. The
filter elements must be disposed of properly to comply with environmental regulations.
Generic Vinyls PVC-
Page 2 of 10 Production
1.0 Approval
2.0 Evacuate the Filter
VCM Filters
Issue Date
Rev.#
1
Rev. Dale
PROCEDURE REMOVING FROM SERVICE
1.1 Request the use of the #1 vacuum pump.
1.2 Verify with the DCS operator which filter is to be serviced.
NOTE The servicing of the VCM charge filters must be coordinated with the DCS operator to ensure reactor charges are not delayed.
1.3 Close and lock the following valves on the filter: Inlet valve from charge pump Outlet valve to reactor Relief valve to LP header valve
1.4 Open the drain valve to the RVCM receivers.
NOTE By draining off as much liquid VCM as possible to the receivers, evacuation of the filters will be more efficient.
1.5 Close and lock the drain valve when the pressure is equalized between the filter and the RVCM receivers.
2.1 Open the upper block valve to the evacuation and purge header.
2.2 Monitor the filter to ensure the pressure is dropping.
2.3 Slowly open the drain valve on the bottom of the filter once a vacuum is established on the filter.
2.4 Close the drain valve.
2.5 Remove the plug from the drain valve at the bottom of the filter.
Generic Vinyls PVC-
Page 3 of 10 Production
VCM Filters
Issue Date
Rev.#
1
Rev. Date
WARNING Block valves can leak through causing VCM vapors to build behind plugs. Remove plugs slowly to prevent possible VCM exposure.
2.6 Insert a Chicago coupling into the drain valve.
2.7 Connect a steam hose to the drain valve.
NOTE The condensate should be blown out of the steam hose before connecting to the filter.
2.8 Slowly open the steam to the filter once a vacuum on the filter is reached.
NOTE Monitor the filter pressure on the local pressure gauges on the filter. Once the filter housing and the piping are warm, let the filter steam for 5 minutes to ensure the filter is clear of VCM.
2.9 Close the following valves: Steam to the filter at the hose station Close and lock upper and lower block valves to the evacuation and purge header
NOTE Lock sample valve to sample station.
2.10 Disconnect the steam hose from the filter.
Generic Vinyls PVC
Page 4 of 10 Production
VCM Filters
Issue Date
Rev.#
1
Rev. Date
WARNING Ensure that filter is under a vacuum after the steam hose is blocked in. This will ensure that all of the hot condensate has been removed from the hose to prevent serious burns when removing.
2.11 Notify the DCS operator that you are through with the vacuum pump.
3.0 Prepare the Filter for Opening
3.1 Have the DCS operator start up the steam jet.
3.2 Open the block valve on the filter to align the filter to the steam jet.
3.3 Open the drain valve at bottom of filter to pull air through the filter.
NOTE The steam jet should be allowed to pull air through the filter for 2-3 minutes to ensure it is cool enough for maintenance to begin work.
4.0 Open the Filter
3.4 Close and tag the block valve to the steam jet. Must be able to use valve if necessary - (ex: pressure build up from a valve leaking by, etc.)
3.5 Notify the DCS operator you are finished with the steam jet.
4.1 Have maintenance tag lock box.
4.2 Issue permit to maintenance.
WARNING Maintenance must wear all required PPE (gloves, fresh air) while removing the filter head to prevent exposure to VCM and/or burns from hot piping.
Generic Vinyls PVC
Page 5 of 10 Production
VCM Filters
Issue Date
Rev.#
1
Rev. Date
4.3 Collect an opening/loss sample with a MiniRAE meter.
4.4 Record the results on the work permit.
4.5 Allow maintenance to begin replacing elements.
4.6 Inspect the filter elements for damage and general condition.
4.7 Inform the Lead Operator of the condition of the filter elements.
NOTE Some or all of the elements may be saved to let the technical group inspect.
RETURNING TO SERVICE 1.0 Place Filter Back in
Service 1.1 Ensure there is no debris in the filter pot.
1.2 Verify the filter elements stabilizing ring is installed.
1.3 Ensure a new head gasket is installed.
1.4 Have maintenance place the head on the filter and secure.
2.0 Pressure Test the Filter 2.1 Connect an air
hose to the drain valve on the bottom of the filter.
2.2 Pressure up the filter to 80 psig with air.
2.3 Block in the air to the filter.
2.4 Soap test for leaks. If OK, have maintenance remove tags from lock box.
Generic Vinyls PVC
Page 6 of 10 Produc tion
3.0 Evacuate the Filter
VCM Filters
Issue Date
Rev.#
1
Rev. Date
WARNING The filter must be leak tight to prevent employee exposure to VCM vapors, and to prevent any leaks to atmosphere.
3.1 Block in the drain valve at the bottom of the filter. 3.2 Disconnect the air hose and install the plug. 3.3 Have the DCS operator start up the steam jet. 3.4 Open the block valve to the steam jet.
4.0 Return the Filter to Service
CAUTION Ensure the filter is pulled into a good vacuum to remove any oxygen which would affect product quality and to prevent a reaction between VCM and oxygen.
NOTE If the filter shall remain on stand-by, it is left evacuated.
4.1 Unlock and open the valve from the filter outlet to the charge header and remove the tag .
4.2 Unlock and open the filter inlet and remove the tag.
4.3 Align the sample station.
4.4 Notify the DCS operator the filter is back in service (VCM charge filters).
5.0 Perform Housekeeping 5.1 Roll up hoses and store.
5.2 Return the MiniRAE to storage and place on charger.
Generic Vinyls PVC
Page 7 of 10 Production
VCM Filters
Issue Date
Rev.#
1
Rev. Date
5.3 Ensure the plugs are in the valves.
5.4 Ensure the filter elements are disposed of properly.
SERVICING RELIEF VALVES
1.0 Prepare to Service the Relief Valve
1.1 Obtain approval from the production superintendent and/or Lead Operator.
1.2 Ensure maintenance is ready.
1.3 Isolate the filter.
1.4 Evacuate the filter.
NOTE Refer to the section "Removing From Service" in this procedure for specific instructions.
2.0 Prepare the filter for Maintenance
2.1 Unlock and close the tagged block valve to the low pressure (LP) header.
2.2 Lock and tag the LP header valve in the closed position.
2.3 Issue permits.
3.0 Inspect the Relief Valve and Rupture Disk
3.1 Compare the tag information on the one removed from service to the one being installed. Set pressure/temperature Size
3.2 Ensure the relief valve/rupture disk is installed properly: Proper type bolts/studs (no all-thread rods) Bolts tightened evenly Proper type, size, and number of gaskets
4.0 Service the Filter
NOTE The filter is serviced each time it is evacuated/steamed.
Generic Vinyls PVC
Page 8 of 10 Production
5.0 Pressure
VCM Filters
Issue Date
Rev.#
1
Rev. Date
5.1 Connect an air hose to the drain valve on the bottom of 5.2 the filter.
Pressure up the filter to 80 psig with air.
5.3 Soap test for leaks.
WARNING The filter and relief valve assembly must be leak tight to prevent employee exposure to VCM vapors and any leads to the atmosphere. If any leaks are found, vent the pressure and repair the leak(s). Pressure up again and check for leaks.
5.4 Block, bleed, and disconnect the air hose. 5.5 Vent the pressure to the atmosphere.
6.0 Align the Relief Valve
5.6 Close the drain valve and install plug. 6.1 Unlock and open the valve to the LP header.
6.2 Lock and tag the valve in the open position.
7.0 Temporary Operation
Temporary Operation
7.1 When temporary operations are required , the Production Superintendent will develop procedures before they begin. An MOC (Management of Change) will be generated. Training will be conducted and documented.
Emergency Operation
8.0 Emergency Operation
8.1 When emergency operations are required, the Production Superintendent will coordinate with the Lead Operator on duty. Training will be conducted and documented at the time of the emergency.
Generic Vinyls
PVC Page 9 of 10 Production
VCM Filters
Issue Date
Rev.#
1
Rev. Date
Emergency Shutdown
9.0 Emergency Shutdown 9.1 Block in inlet, outlet, and all bleed valves.
CONSEQUENCES OF DEVIATION AND STEPS TO RECOVER
Procedure Step 2.10
2.4, 5.3
Problem Description
Failure to ensure filter is under a vacuum after steam hose blocked in Failure to soap test for leaks
Consequence of Deviation
Operator could be potentially sprayed with hot condensate resulting in burns
Potential employee exposure to leaking VCM vapors, potential reportable release
System Response None
Tag Number NIA
Area GC monitors, LEL NIA detection system
Steps to Recover
Repeat training, monitor vacuum before disconnecting steam hose
Tighten bolts if leaking gasket, or shutdown, evacuate, and make repairs
Rev.#
Change
0
Initial issue.
1 Added third bullet to step 1.3. Replaced the word tag with lock. Added note after step 2.9. Revised step 3.4. Added steps 7.0, 8.0 & 9.0.
REVISIONS/TRAINING
TABLE
Training Required Yes/No
Yes Yes
Generic Vinyls PVC-
Page 10 of 10 Production
VCM Filters
Issue Date
Rev.#
1
Rev. Date
PROPERTIES: SYMPTOMS:
VINYL CHLORIDE MONOMER (VCM)
DESCRIPTION:
A colorless, sweet smelling gas
at atmospheric pressure and room temperature.
Flammable and toxic. Cancer suspect agent.
HAZARDS: Harmful if inhaled. Causes thermal burns. Rapid evaporation of the liquid causes frostbite to skin and eyes.
Loss of sensation, state of stupor, and loss of
consciousness. PPE:
Refer to PPE Sampling Matrix for specific PPE, required when sampling. Airline
respirator, chem-proof gloves and rubber boots. Splash suit if possible danger of
splash.
CONTROL:
In the event of a leak, eliminate ignition sources, notify the
supervisor, and stop or control the leak if it can be achieved without undue risk. Use water
spray to disperse vapors and protect personnel.
FIRST AID:
Eyes:
Immediately flush eyes with water for 15 minutes. Forcibly hold eyelids apart to ensure irrigation of all eye and lid tissue. Seek medical attention.
Skin:
If direct liquid contact
occurs, flush with water. If frostbite or
burn occurs, do not rub the area. Get
immediate medical attention.
Inhalation: Move victim to fresh air. Apply appropriate first aid treatment as necessary. Get immediate medical attention.
Ingestion: N/A
REFER TO THE MSDS FOR ADDITIONAL INFORMATION
EXHIBIT VII
PVC MACT Working Group Analysis of Initial and Monthly Compliance with Car Seal Inspection Requirements
Operational Actions to Comply with EPA 's PVC MACT Bypass Provisions
06.07.2012
Operational Actions to Comply with EPA's PVC MACT Bypass Provisions
Notes:
1. Since there are no bypass exemptions, any component within the closed vent system (CVS) that could cause a HAP-containing gas stream to be diverted away from the control device and then be discharged to the atmosphere must have a bypass indicator (i.e.. flow indicator & alarm; or, a car-seal/lock & key mechanism), including any of the following no matter what size (e.g., in valve on a drain): a. Low leg drains; b. High point bleeds; c. Valves on open ended lines; d. Pressure relief devices; and, e. Analyzer vents.
2. Since there is no clear exemption for equipment that has met the PVC MACT equipment opening requirements; any HAP release event must be considered, including: a. Any remaining fugitive HAP gases after the equipment opening emission standard at 40 CFR 63.11955 has been met; and, b. Vapor collection systems from miscellaneous vents (e.g.. loading lines) c. Exhaust gas from analyzer vents, such as a ambient air monitoring system required by 40 CFR 63.11956
3. In addition, consideration must be made to any bypass that could cause air intrusion into the control device" (40 CFR 63.11930(gX1 )); for example: a. Manway hatch on a CVS Knockout pot
4. Burden to comply with the Bypass provisions is considered an independent burden from the CVS Inspection and Monitoring requirements (e.g., initial inspection using EPA Method 21 monitoring procedures; and. annual audio, visual, olfactory (AVO) inspection thereafter).
Summary of Actions Required in Order to Comply:
Action # 1: Identifying affected Closed Vent System (CVS) equipment and potential bypasses prior to installing Bypass indicators
Action #2: Develop and implement procedures to prevenUminimize bypass "violations" and certify compliance including:
1. Ensuring bypass indicter changes are tracked (e.g., flow indictors alarms, car seal is broken); 2. Required actions are performed (e.g., if alarm is triggered; identify the cause); and, 3. Required records and reports are maintained and retained; including potential release events.
Action #3: Develop and implement Added/ Removed Car-Seal Tracking Procedures and other data Quality Assurance/Quality Control (QA/QC) checks
Action #4: Conduct Bypass Training
Specific Details Follow Below
1
06.07.2012
Action #1: Identifying affected Closed Vent System (CVS) equipment prior to bypass indicator installation, which includes the following steps:
Step 1.1: Determining Regulatory Applicability: Determine if there are any other regulatory overlaps with the PVC MACT (e.g., CVS is shared with HON regulated Unit: State-required CVS special conditions)
Step 1.2: P&IO Review and Speciation The Operations Department and the Environmental Department review P&IDs to determine which CVS
Bypass components are "in HAP service," and which are reasonably expected not to be exceed 5% wt.
HAPs.
Step 1.3: Field Verify The Operations Department, combined with the efforts of the Environmental Department, will field verify the location of the CVS Bypass equipment and confirm existing speciation of chemicals that could be diverted through the bypass component.
Step 1.4: Install Bypass flow indicator or hang Car-seal The Operations Department will install the bypass indicator equipment, which may entail the need to rent a lift to raise personnel up to a bypass valve; shut down of equipment that is unsafe to work on (e.g., too hot; under construction scaffolding): obtain safety permits, etc.
Step 1.5: Establish database/log sheet of affected bypass equipment Data elements necessary for finding and inspecting regulated components include some of the following , using a car-seal example:
Unit Process Area Equipment Car Seal Number Component Type (e.g. valve, pressure relief device, etc.) Size Service Type Applicable Rule (if overlap; determine which supersedes) Location Description Accessibility (difficult to monitor?, unsafe to monitor?) Process Stream Identification Process and Identification Drawing (P&ID) Number Safety equipment necessary to perform inspections
Action #2: Develop and implement procedures for:
1. Ensuring bypass indictor changes are tracked (e.g. flow indictors alarms, car seal is broken); 2. Required actions are performed (e.g., if alarm is triggered; identify the cause): and. 3. Required records and reports maintained and retained; including potential release events and CVS leak
repairs.
ASSUME CAR-SEALS ARE INSTALLED:
Step 2.1 : Visually inspect car seal monthly: Develop and implement inspection route & inspection forms
Complete inspection to determine if car seal is still in place (e.g., did not fall off due to deterioration) or broken due to discharge through the valve; and/or, replaced with new Car-Seal mechanism/ID number.
2
06.07.2012
Record: Date,
Car Seal number Inspection results, including bypass valve position.
Step 2.2 : If opening a car-sealed bypass for any reason: Complete Car seal tracking form: Record date, lime, Car seal number and if emissions occurred. If emissions occurred: Record the following information: Date and time the bypass was opened/closed;
The duration of the flow in the bypass; Records of the limes of all periods when the vent stream is diverted from the control device or the
flow indicator is not operating; Complete emission estimations; and, Because Event is considered a violation: Follow PVC MACT "Affirmative Defense" provisions, with a preponderance of evidence to support valve change is not a "violation (see 63.11930(c)(2)(ii) and 63.11895).
Step 2.3: Records & Reporting
Report: Semi-annually within PVC MACT Report: Each instance for which a bypass valve is changed to the
diverting position. Other Repotting mechanisms (e.g., Semi-Annual TiUe V Deviations Report; annual Emissions
Inventory, etc.)
Action #3: Develop and implement Added/ Removed Car-Seal Tracking Procedures needed to ensure tha t covered equipment added to/ removed from the Unit for any reason is integrated into the Car-Seal inspection and reporting program
Step 3.1: Rectify Car Seal Numbers Car seal numbers on the monthly inspection sheet need to match up with the car seal numbers in the field. During a turnaround or complex maintenance event; numerous maintenance-type valves, like low-leg drains, will be opened. As such, new car seals are Installed; the old car seal number needs to be retired from the inspection sheets and a new car seal number inserted. Rectifying car seal numbers may take considerable effort if 100-200 maintenance-type bypass valves are open during a major turnaround.
Action #4: Bypass Training - Procedures and training protocols are needed to describe actions to be taken if a bypass release occurs; what to look for during car-seal inspections, etc.
Step 4 .1 By Pass Training: Since monthly inspections are needed; car seals number tracked; broken car
3
06.07.2012
seals replace. compliance certifications required, etc. in order to prevent "violations," training on the issue needs to be provided to the following personnel:
Operations Department: Maintenance Department; Instrumentation Department; Contractors: and, Environmental Department. Step 4.2: Compliance certifications: Due to the specific PVC MACT requirements to certify compliance (e.g., 40 CFR 63.11985(aX9)), the following types of personnel also need to be trained on the requirements: The Responsible Official; Site Managers; and/or Vice Presidents/ General Managers
4
Bypass Burden Cost Estimate: PVC MA CT
6.7.12
By Pass Labor Burden Cost Estimate: PVC MACT
Actions Step 1.1 Determine Regulatory Aoolicabllity
Initial
Annual
Assume: 2 EnQ. 4 hrs $ 664.08
Step 1.2: P&ID Review and Speciation
Assume: 2 Eoo for 24 hr $ 3.984.48
Step 1.3: Field Verify
s Assume: 2 EnQ for 24 hr & 1 Op. for 24 hr 5.129.52
Stec 1.4: Install Bypass flow Indicator or hang Car-seal Assume: 2 Op. for 20 min/bypass S 11,132.33
Step 1.5: Establish database/l oQ sheet of affected bypass equipment
s Assum-e 1 Ena for 40 hr
Step 2.1: Vlsuallv Inspect car seal monthly : Assume Palvolefins lnsnH.tion Rate by Op.: 7 min/bvoass
3,320.40
I
$
23.377.90
Step 2.2: Actions If opening a car-sealed bypass (Violatlon; must investiqatc & develoo corrective actions):
Assume 1 OP. 1 EnQ & 1 Mgr 1 hr/event
$ 733,265.92
Step 2.3: Records & Reporting
Assume 1 Eng & 1 MQr 2 hr/month
$
4,905.36
1 Step 3.1: Rectify Car Seal Numbers
Assume 1 Eng for 2 hr/month
1
Step 4.1 Bv Pass Training:
s All Operations & Env. Employees (assume 50) 2 hr initial s Resoonsible Official/Site Managers. (assume 3) for 30 min initial
$
'
4,771 .00 182.07
'
f
1,992.24
'
nvuY. "<Ht:::> \IIUIJI t=r-1'\ ~ 1",H r-011. VUHlfOI \..OSl manua1J;
Operator/Suoervisor
$
Process/Env. Enolneer/Tech
$
Management
s
47.71 83.01 121.38
Number of Car Scaled bvnasses
Examole PVC Unit: 350
Number of Car Seals broken in a voar 1. Reactor Openino (assume 4 Reactors) Four Bypass valves open dailv/ Reactor 2. Maintenance Valves In non TIA Year
5840 200
Total :
604Q
voe tpv release
TPY voe
Small Eauioment Larae Eauipment
Total per Unit:
Total MSS all 17 PVC Units:
'MSS Cale far a susoenslon PVC Unit assume residual emitted from bypass is 10% of total emitted
Total Fualtivc HAPs Emitted from Maintenance Bvoasses bv all PVC Units
2 1.4 3.4 57.8
5.78
s s Total per PVC Unit:
29, 184
s Total all 15 major & 2 area PVC Units
496,126 $
763,541 12,980,204
Annual Cost Per Bypass
$
2 ,182
Cost Effectiveness (Slton VOCI
s
PotenUal Penaltv/ Violation
TIA= Turnaround MSS = Maintenance. Startup. Shutdown emissions
2.245,710 $37, 500
EXHIBIT VIII Cost-Benefit Analysis for Release Indicators
EXHIBIT VIiia Westlake Cost Estimates from Honeywell
AWC
Honeywell
Page: 1 of 3
Customer Details
Name:
Allen Bodron
Company: Westlake Chemical
Address :
Quotation Quotation Date : 03/15/2012
Quote From: Randy Hamilton
Tel: Fax :
Reference:
Subject: XYR6000 (Pressure Transmitter Option)
Dear Allen,
This is budgetary quote per your request. This proposal at this time does not reflect project pricing or bundling of items in starter kit fashion to save cost. Two WDM and two FOAT are quoted to reflect redundancy aspect you are trying to achieve. Release 210 will have redundancy already integrated and this will be released end of this year. The fastest scan time available with this solution is 1 sec with this wireless technology. If you have any questions pleas feel free to call.
Regards,
Randy Hamilton Account Manager
Honeywell
Page: 2 of 3
Pos Qty
Description
1 2 WDMS-00-KD-000-00
OneWireless
Device Manager
OneWireless Network R200 Documentation Kit
2 2 FDAP2-F6SA00-F6SA00-WM-DD-0000 OneWireless Field Device Access Point with Class 1 Div 2 certification DSSS Ant. 1Opt.: 6 dBi Integral Omni DSSS Ant. 1Opt.:with Integral Lightning Surge Arrestor DSSS Ant. 1Opt.:No Cable DSSS Ant. 2 Opt.: 6 dBi Integral Omni DSSS Ant. 2 Opt.:with Integral Lightning Surge Arrestor DSSS Ant. 2 Opt.:No Cable Wall mount kit OneWireless Network R200 Electronic Documentation on CD
3 50 STGW94L-E1A-00000-R0000-XF,BA,1C-NA0O XYR 6000 Wireless Transmitter In-Line Gage & Absolute Pressure Series 900 Gage pressure : 0-20 to 0-500 psig/0-1.4 to 035 bar 316 SS wetted process head, 316L SS barrier diaphragms Silicone fill fluid Process connection configuration : 9/16" - 18 Aminco Integral Right-angle, vertical 4 dBi None None 2.4 GHz Frequency Hopping Spread Spectrum (FHSS) Battery FM IS, Explosion proof, non incendive, non sparking North America,Canada
4 1 Dolphin Handheld for Downloading Keys
Unit Price
Total
$4,298.00 $ 8596.00
1t~
$3,444.00
.
$ 6888.00
~1- . ' [; ~
$3,164.00 $158200.00
fr
$ 1700.00 $ 1700.00
AWC
Honeywell
Page: 1 of 3
Customer Details
Name:
Allen Bodron
Company: Westlake Chemical
Address:
Tel: Fax :
Quotation Quotation Date : 03/15/2012
Quote From : Randy Hamilton
Reference :
Subject: XYR6000 (Digital Input Option) Dear Allen,
This is budgetary quote per your request. This proposal at this time does not reflect project pricing or bundling of items in starter kit fashion to save cost. Two WDM and two FOAT are quoted to reflect redundancy aspect you are trying to achieve. Release 210 will have redundancy already integrated and this will be released end of this year. The fastest scan time available with this solution is 1 sec with this wireless technology. If you have any questions pleas feel free to call.
Regards,
Randy Hamilton Account Manager
Pos Q 1 2
Descri tion WDMS-00-KD-000-00 OneWireless Device Manager OneWireless Network R200 Documentation Kit
Honeywell
Page: 2 of 3
Unit Price $4,298.0
Total $ 8596.0
2 2 FDAP2-F6SA0O-F6SA0O-WM-DD-0000 OneWireless Field Device Access Point with Class 1 Div 2 certification DSSS Ant. 1Opt.: 6 dBi Integral Omni DSSS Ant. 1Opt.:with Integral Lightning Surge Arrestor DSSS Ant. 1Opt.:No Cable DSSS Ant. 2 Opt.: 6 dBi Integral Omni DSSS Ant. 2 Opt.:with Integral Lightning Surge Arrestor DSSS Ant. 2 Opt.:No Cable Wall mount kit OneWireless Network R200 Electronic Documentation on CD
3 50 STXW500-000-0000-R00O0-XF, BA,TG,SB,1CEU00 XYR 6000 Wireless Multi Discrete Input Transmitter Series 500 Wireless Transmitter with Three Discrete Inputs Integral Right-angle, vertical, 4dBi 2.4 GHz Frequency Hopping Spread Spectrum (FHSS) Battery Stainless Steel Customer Wired-On Tag Mounting Bracket - 304 SS FM,IS ,Explosion-proof,Nonincendive,NonSparking For use in European Union
4 50 Fike BDI (Burst Disk Indicator)
$3,444.0 $ 6888.0 $2,600.0 $130,000.0
$ 250.0 $12,500.0
5 1 Doi hin Handheld for Downloadin Ke s
$ 1700.00 $ 1700.00
EXHIBIT Vlllb Westlake Cost Estimates from Champion Technology Services
From : To: Sent: Subject: Allen,
"Mehrdad Ghorashi" <Mehrdad.Ghorashi@champtechnology.com> "Bodron, Allen" <abodron@westlake.com> Monday, March 26, 2012 10:28 AM
EPA OPC Data Integration to Honeywell
Per our discussion, I have the following scope captured:
1) Establish OPC Connectivity to Data Server 2) Build of 50 OPC Points to the Honeywell $CADA 3) One (1) tabular graphic showing all data points
If the OPC server is remote to your Honeywell servers, I recommend purchasing and installing Honeywell's OPC tunneller (~$2,400) to make the connection to the remote OPC server so you don't have to compromise the security settings of the Honeywell servers..
Here is the cost breakdown:
1) Services - $4,400 (T&M @$110/hr) a. Install necessary software b. Build Channel and Controller for OPC data c. Build 50 EPA Quickbuilder points d. Develop 1 graphic displaying data points
2) Software - OPC Tunneller - $2,400
Total cost= $6,800
Feel free to call me with any questions or comments. Thanks,
Mehrdad Ghorashi
Business Manager
Champion Technology Services, Inc.
17991 Old Perkins Rd. East, Suite E Baton Rouge, LA 70809
**Please note new office address and phone number**
Office: 225-615-8120
Cell: 225-802-2179
Fax: 225-612-6394
email: Mehrdad.ghorashi@champtechnoloqy.com
www.champtechnology.com
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EXHIBIT Ville
Dow Chemical Corporation Cost Estimates for Wired PSV System
Dow Chemical Corporation Cost Estimate for Wired PSV System With Installation of an Additional Junction Box
Global Project Controls
Project Cost Estimate Summary Report
Rev. 1.30
Dow Site
iLouisiana Operations
Date
February 29, 2012
Project Name
iPSV Switch Installation
Project No./Auth.No. !
Cost Eng.
Proj.Mngr.
M. Dugas Don Eure
Auth. Date
!April 1, 2012
Proj.Eng.
RTO Date
!May 1, 2012
Plant
Dow Furnished Materia-l ----------------------------- -
3000 Civil/Steel
---------
Contracts
4000 Pjping_ Materials-------------------------------------------------------------+--- -- - - - --!
6000 Instruments
------------------- ------------------+-- - - ----'$--4.'1-4~2
,-4-----------1 7000
8000
ELoleccatrl iOcardl ers__-_-_-_-_-_-_- -_-_-__-_-_- -_-_-__.- ,Oc:..:.- Oc.:.%-:...o:::f- -=Dc:.F.c.-M_:.... _______
9000 Major Equipment _______________o._0%_in_c_luded for spare parts________
D-F-M-to-ta-l ------------------
~ $4,142
M-aj_o-r Eq-_ui-pm-en-t _-_-_-_-_-_-_-_-------'M-a-n-hr-s'-.--- Labor
Material
_<;fy.:.,il_______________________________________________+ - - -- - - - - ---1
.FS:t!eee!'}lJ-l _--_-_--_--_-_--_-_--_-_--_--_-_--_-_-------------
Instrumentation __________________37_____ $2.062 _________ S2.~5-'-3+--- ------'-S=-2cc3-'-15'-'
Electrical _________________
_______123________ $7,244 __________$1_,,_3o..1..c5+-------- ..:.S.;;;8c:.5=-59'-'
Insulation ---------------------------------------- ----------+--- - - - - ---1
.f:!J!':.t:._ _ __ _ - - - - - - - -- -----------------
E!!.f!..o_l_cl_i_!29_
___________
$900
$900
Demolition _________
E9uipment Rental---------------------
_ _ _ _ _ _2.048
$2,048
Overtime Premium----------.Winter Work {Labor Only) _____
---- - - - - - - - - ______________
_-_------
----
-
---
-
---
-
---
-
---
--+
---
-
---
-
---
4
----------------------------------------------
---
-----------------------------+- - - - --
----------------------------1--- -- -
- ---I
- --~
Indirects
1000 Contracts total ----------- ----------1-6-0-------------- - -
2100
-----------
Proj!Ct Manaflement
-
-
-
-
-
-__-_-__-_-__-_-__-_-__-_%_-__o-_f-_e2-s.t-5i'm-%-'-'a--te--------~---------- -
2200 Process E'!!l!!!.eerin
