Document 8V8Rk830mq1L29OGkepraqv7o

is COOLING TOWER FUGITIVE EMISSIONS CONTROL PLAN The Vista VCM Plant Cooling Tower Fugitive Emissions Control Plan is designed to provide a formalized procedure for detecting and controlling emissions from exchangers in VOC (Volatile Organic Compound) service into the cooling water return to the main plant cooling tower. This plan will be reviewed periodically to determine if the plan meets the original purpose, I. Cooling__Water Sampling The daily sampling of the cooling water return to the main plant cooling tower and analysis for VCM, EDC, and Ethylene (the major constituents of the plant process streams which could get into the cooling water) will be used as a check for emissions from exchangers in VOC service. B. Definition of an Action Level A cooling water return sample which indicates a level of 1 ppm or more (of EDC plus VCM plus Ethylene) requires that a second sample be taken and analyzed. If the second sample also indicates a level of 1 ppm, then an Action Level is detected and the Action Plan will be implemented. C. Definition of a.Release A cooling water return sample which indicates a level of 2 ppm or more (of EDC plus VCM plus Ethylene) for two consecutive samples indicates that a release has occurred, and the Louisiana Department of Environmental Quality must be notified. D. Description of Analytical^Equipment A Perkin Elmer Sigma 2000 Gas Chromotograph with an HS-100 Headspace sampler, or equivalent instrumentation, will be used to analyze the cooling water samples. E. Calibration and Maintenance The analytical equipment will be calibrated periodically and maintained as necessary to insure reliable analyses. A standard sample is run with each batch of samples. vvv 0000028^ The analytical results for this standard sample are compared against a range of acceptable values to check the calibration of the analytical equipment. F. Sample Point Location and Sampling Procedure A four ounce sample of the cooling water return is caught from a sample line located at the southeast corner of the Main Plant Cooling Tower. The sample line continuously drains a slipstream of water from the cooling water return header to the cooling tower basin. Action Plan For Response To An Action Level If the cooling water return analysis indicates that two consecutive samples exceed 1 ppm (total of EDO, VCM, and Ethylene), a search, identification, and elimination program shall be initiated. The action plan will consist of the following steps: 1. Additional samples will be taken of the main headers and the effluents of the individual exchangers in order to pinpoint the source of the increased emissions. Sampling will be prioritized based on the specific component or components (EDO, VCM, and/or Ethylene) which had increased in the cooling water return. 2. Immediate action will be taken, if possible, to control the increased emissions. 3. If the increased emissions are not controlled, the Operations Superintendent will be notified. The Operations Superintendent will take one of the following actions: a. Act to control the increased emissions, if practical, or b. Notify the Maintenance Department to take corrective action to control the increased emissions. 4. All increased emissions will be controlled and/or repaired as soon as is practical. If a delay of repair is justified, the justification shall be documented by the Operations Superintendent or his designee. VVV 000002695 APPENDIX 2 CALCULATIONS FOR EIQ MODIFICATIONS TO PERMIT 16Q3T-M1 Point Source IIA IIB IID HE IV--A IVC V-A V-B Cracking Furnace Stack Cracking Furnace Stack Cracking Furnace Decoking Scrubber Stack Cracking Furnace Decoking Scrubber Stack C-500 Vent Stack Propylene Vent Stack Vent Incinerator Cooling Tower Fugitive Emissions Page A--1 A-3 A-4 A-9 A-10 A-12 A-14 A-16 VVV 000002396 IIA. Cracking Furnace Stack This point source is currently included in the EIQ. The --emissions reported in the EIQ are being revised to reflect the emission differences between firing Refinery Fuel Gas and our current fuelf Natural Gas# and to update the permit to reflect current AP-42 emission factors. A. Basis for calculations. 1. The maximum continuous capacity of the furnace is 59.4 million BTU's (lower heating value) per hour, the same as in the existing permit. 2. The lower heating value of natural gas burned in the furnace is 935 BTU's per standard cubic foot (SCF) based on information from our natural gas suppliers. The lower heating value for Refinery Fuel Gas used to be about 1200 BTU/SCF; however, the Refinery has changed their process and the lower heating value can be approximated by that of natural gas. 3. The furnace is assumed to operate 8568 hours per year. 4. The maximum instantaneous emissions rate is calculated to be 1.30 times the maximum continuous emissions rate based on the maximum capacity of all the burners at maximum fuel gas supply pressure. 5. The emissions for each pollutant except S02 are based on AP-42 factors for natural gas (based on Table 1.4-1 of the Fourth Edition of AP-42 dated September 1985). The S02 emissions factor of 30 pounds per million SCF is based on the back-up fuel of Refinery Fuel Gas. Pollutant Pounds per million SCF Particulates NOx Hydrocarbons Carbon Monoxide 5 140 5.8 35 B. Calculations 1. The annual emissions are based on the annual natural gas fuel usage of 59.4 million BTU/hour * SCF/935 BTU * 8568 hour/year = 544.3 million SCF per year. -- A--1 WV 000002897 Pollutant Lbs/MMSCF Lbs/year Tons/year Particulates S02 NOx Hydrocarbons Carbon monoxide 5 30 140 5,8 35 2721.5 16329 76202 3156.9 19050.5 1.361 8.165 38.101 1.578 9.525 2. The average emission rates are calculated by dividing the pounds emitted annually for each pollutant by 8760 hours per year. The maximum emission rates are calculated by dividing the pounds emitted annually for each pollutant by 8568 hours per year and multiplying by 1.30 Pollutant Average lbs/hour Maximum lbs/hour Particulates S02 NOx Hydrocarbons Carbon monoxide 0.311 1.864 8.699 0.360 2.175 0.413 2.478 11.562 0.479 2.890 C. Summary of Results The emissions for the EIQ are as follows: Pollutant Tons/year Average lbs/hr Maximum lbs/hr Particulates S02 NOx Hydrocarbons Carbon monoxide 1.361 8.165 38.101 1.578 9.525 0.311 1.864 8.699 0.360 2.175 0.413 2.478 11.562 0.479 2.890 -- A-2 -- VVV 000002898 IIB. Cracking Furnace Stack This point source is currently included in the EIQ. The --emissions reported in the EIQ are being revised to reflect the emission differences between firing Refinery Fuel Gas and our current fuel, Natural Gas, and to update the permit to reflect current AP-42 emission factors. The calculations for this point source are identical to those for point source IIA, Cracking Furnace Stack. Summary of Results The emissions for the EXQ are as follows Pollutant Eons/.year. Average lbs/hr Maximum ibs/hr Particulates S02 NOx Hydrocarbons Carbon monoxide 1.361 8.165 38.101 1.578 9.525 0.311 1.864 8.699 0.360 2.175 0.413 2.478 11.562 0.479 2.890 -- A-3 VVV 000002899 IID. Cracking Furnace Decoking Scrubber Stack This point source is a grandfather source which is being .5,--added to make a complete accounting of all emissions sources. The basis for the emissions listed in the EIQ are as given below. A. Basis for Calculations 1. The initial coke volume prior to decoking is assumed to increase from 0 inches thickness to 0.5 inches thickness over the length of the last sixteen passes of each of the two coils in each furnace. The last sixteen passes are the only tubes in the radiant section and are therefore subject to the highest tube metal wall temperatures. The coke volume has been observed to be approximately 0.5 inches thick at the outlet. The steadily increasing thickness is based on the fact that the process temperature steadily increases over the sixteen tube passes in the radiant section. The furnace tubes are 62 feet long each and have an inside diameter of 7 inches. Therefore, the total amount of coke in the furnace at decoke is: ((7**2)-(6.5**2))*pi/4 in2 * ft2/144 in2 * 62 ft/pass * 16 pass/coil * 2 coils/furnace 73.0 ft3 2. Approximately 15 cubic feet of coke is collected from the decoking scrubber in the collection box and scrubber water filter after each decoke. This volume is based on the dimensions of the box and the coke level in the box after decoking. 3. Essentially all the other coke is converted to carbon dioxide (C02) or carbon monoxide (CO). Based on a laboratory analysis, the composition of the stack gas has approximately equal quantities of C02 and CO on a molar (or volume) basis. 4. Nine decokes per year per furnace are based on actual furnace operation. 5. The density of coke is assumed to be 102 lb/ft3. This density is based on the specific gravity of 1.63 given for petroleum coke in Table 8-3 of The_5th Edition of Perry and Chilton1s Chemical Engineers1 Handbook. 6. The particle size distribution of the coke is assumed to be similar to that of pulverized coal (see Figure 20-92 of The 5th Edition of Perrv and Chilton.1 s Chemical Engineers1 Handbook) . The distribution shown is between 3 microns and 400 microns in diameter. The actual weight percentage for each particle size is assumed to be normally distributed about the average with the entire range consisting of six standard deviations about the mean. The parameters for the distribution are, therefore: -- A-4 -- VVV 0000029 Average diameter (3 + 400)/2 microns * 201.5 microns Standard deviation = (400 - 3)/6 microns = 66.17 microns --This model is believed to be conservative because it predicts more very fine particles (the most difficult to remove from stack gases) and fewer large particles than are actually observed. Therefore, particulate emissions are likely to be overstated by using this model. 7. The removal efficiency for the cyclone scrubber is based on the removal efficiency shown for medium efficiency scrubbers in Figure 3-5 Comparison of PM Control Device Fractional Efficiencies in Louisiana New Source Review Manual. Volume 1 dated August 15, 1986. A copy of the figure extrapolated for particles larger than 10 microns is included on the next page. The values read from the graph for various particle size ranges is: Size range in microns % removal efficiency 50 to 400 30 to 50 ID to 30 0 to 10 100.00 99.99 99.00 20.00 8. The coke is assumed to be essentially all carbon for purposes of determining CO emissions. 9. The emissions are assumed to decrease over the course of an 18 hour decoke. The maximum rate for CO emissions is based on the maximum air rate used in decoking, about 12,000 pounds per hour. The maximum rate for particulate emissions is assumed to be equal to the average particulate emissions rate multiplied by the ratio of the maximum CO emissions rate divided by the average CO emissions rate. B. Calculations 1. The weight percentage of coke for the particle size ranges based on the normal distribution and the percent emitted for each size range are given below: Si*e ranae Zmin Zjmax Area(*) % Emitted Fraction Emitted 50 plus 30 to 50 10 to 30 0 to 10 -2.29 -2.59 -2.89 -inf. inf. -2.29 -2.59 -2.89 0.9890 0.0062 0.0029 0.0019 0.00 0.01 1.00 80.00 0.000000 0.000001 0.000029 0.001520 TOTALS 1.0000 0.001550 * - Based on area under a normal (gaussian) curve between the values of z given. -- A-5 -- 000002901 2. The total amount of coke emitted is equal to the fraction emitted multiplied by the amount of uncombusted coke per decoke multiplied by the number of decokes per year, or 0.001550 * 15 ft3/decoke * 102 lb/ft3 * 9 decokes/year 21.3 lbs of particulate matter emissions per year, or 21.3 lbs/year / 2000 lbs/ton " 0.011 tons per year 3. The combusted coke equals the total coke less the collected coke and the coke particulate matter emitted, or 73.0 ft3 - 15 ft3 - (21.3 lbs / 102 lbs/ft3) = 57.8 ft3 or, 57.8 ft3 * 102 lbs/ft3 = 5895 lbs per decoke. 4. The CO emissions are formed from half the combusted coke, or 5895 lbs * 0.5 * 28 lbs CO / 12 lbs carbon = 6878 lbs CO or, 6878 lbs / 2000 lbs/ton = 3.44 tons CO per decoke 5. The annual CO emissions are, for nine decokes, 3.44 tons/decoke * 9 decokes/year = 30.96 tons per year 6. The average emissions for each pollutant is: Particulate Hatter. 0.011 tons/year * 2000 lbs/ton / 8760 hours/year = 0.0025 lbs/hour CO. 30.96 tons/year * 2000 lbs/ton / 8760 hours/year = 7.07 lbs/hour 7. The maximum emission rate for CO is based on the equal mole split of the combusted coke to CO and C02 and the maximum air rate used in decoking. Max air rate = 12000 lbs air/hour * 379 ft3/28.964 lbs air * .21 (fraction 02 in air) * 32 lbs 02/379 ft3 = 2784 lbs 02/hour -- A-7 WV 000002902 Two-thirds of the 02 reacts to form C02, one-third forms CO Max CO rate = 2784 lbs 02/hour / 3 * 28 lbs CO/ 16 lbs 02 = 1624 lbs CO/hour 8. The maximum emission rate for particulate matter (PM) is based on the same ratio of the maximum rate to the average rate for CO: .011 tons PM/year * (1624 lbs CO/hour / 30.96 tons CO/year) = 0.58 lbs of PM/hour C. Summary of Results The emissions for the EIQ are as follows: Pollutant Tons/year Average lbs/hr Maximum lbs/hr CO Particulate Matter 30.96 0.011 7.07 0.0025 1624 0.58 -- A-8 VVV 000002903 IIE. Cracking Furnace Decoking Scrubber Stack This point source is a grandfather source which is being "added to make a complete accounting of all emissions sources- The basis for the emissions listed in the EIQ are as given below. The calculations for this point source are identical to those for point source IID, Cracking Furnace Decoking Scrubber Stack. Summary of Results The emissions for the EIQ are as follows: Pollutant Tons/year CO Particulate Matter 30.96 0.011 Average Ibs/hr 7.07 0.0025 Maximum lbs/hr 1624 0.58 -- A-9 -- VVV 000002904 IV--A* c-500 Vent Stack This point source is currently included in the EIQ. The -----emissions reported in the EIQ are being revised to reflect actual operating data for the composition of the material released through C-500 during Oxychlorination Unit shutdowns. A. Basis for Calculations 1. The basis for the calculations is identical to the basis used in the existing EIQ with one exception: The existing EIQ was prepared based on design material balances because the pure oxygen-based Oxychlorination Unit had not been operating for any significant length of time at the time of the EIQ submittal. The pure oxygen-based Oxychlorination Unit has now operated for about five years, and the emissions reported in the Oxy Unit Semi-Annual Shutdown Report are based on analysis of the actual compositions in the equipment purged during the shutdown. 2. The actual emissions are based on a complicated computer program which takes into account the volume purged during typical shutdowns. The compositions used were based on the compositions in the equipment during the actual oxychlorination unit shutdowns from 1984 through 1987. These emissions have been submitted in the annual EIS/PS report for each of the years from 1984 to 1987. 3. The average emissions are given as zero since the emissions from Oxychlorination Unit shutdowns occur only during emergencies. B. Calculations 1. The calculations are not attached* but the change is relatively minor as shown by this comparison: Bo11 atant Tons/year. existing EIQ Tons/yeaC-i this EIQ HC1 Total Hydrocarbons Carbon monoxide 12.41 3.54 0.8 12.41 3.57 0.03 Individual Hydrocarbons Methane 0.08 Ethane 0.01 VCM 0.01 EDC 1.06 (1) 0.09 (2) 2.28 0.06 0.04 0.02 0.89 0.08 2.48 (1) Miscellaneous chlorinated hydrocarbons. (2) Miscellaneous hydrocarbons.000002 -- A-10 -- 000002 905 C. Summary of Results The emissions for the EIQ are as follows: Pollutant Tons/year Averaae Ihs/hr HC1 Total Hydrocarbons Carbon monoxide 12.41 3.57 0.03 0 0 0 Individual Hydrocarbons Methane 0.06 Ethane 0.04 VCM 0.02 EDC 0.89 (1) 0.08 (2) 2.48 0 0 0 0 0 0 (1) Miscellaneous chlorinated hydrocarbons. (2) Miscellaneous hydrocarbons. Maximum lbs/hr 2500 713.23 6.23 10.82 7.61 3.80 176.87 16.13 550.48 -- A-ll VVV 000002906 IV-C. Propylene Vent Stack This point source is a grandfather source which is being ^--added to make a complete accounting of all emissions sources- The basis for the emissions listed in the EIQ are as given below. A. Basis for calculations. 1. This point source emits approximately once per year: twice every two years during a maintenance outage for turnaround (once to clear equipment for entry and once to purge nitrogen used in drying equipment after turnaround) and as much as twice every other year between turnarounds for shorter maintenance outages. The emissions occur when the propylene system is vented to atmosphere after the pressure has been drawn down as much as possible by compressing and condensing the propylene. 2. The approximate volume of the system is based on the volume of the equipment in the system. Equipment Volume. ft3 T-503 T-504 T-506 H-501 (shell side) H-502 (both sides) H-306 (shell side) H-204 (tubes and top head) BL-501 Piping 314 314 96 96 146 250 242 200 379 Total 2037 2100 ft3 will be used in the calculations. 3. The density is based on a pressure of 25 psia and the saturation temperature of propylene at this pressure, -32 F or 428 Rankine. The density is 25 psia * 42 lbs/lbmole / 428 R / (10.73) = 0.23 lbs/ft3 where 10.73 is the universal gas constant in the appropriate units. 4. The maximum emissions rate is based on the initial purge from 25 psia to 14.7 psia and 68 F (atmospheric pressure and ambient temperature) taking five hours and the emissions occurring at a constant rate over these five hours. The remainder of the propylene is purged out with nitrogen at a slower rate. -- A-12 VVV 000002907 5. Calculations 1- The annual emissions are 2100 ft3 * 0.23 lbs/ft3 * 2/year = 966 lbs per year 966 Ibs/year / 2000 Ibs/ton = 0.48 tons 2. The average rate is 966 Ibs/year / 8760 hours/year = 0.110 lbs/hour 3. The maximum rate is calculated as Temperature in Rankine after initial purge = 460 + 68 F = 528 R Density after initial purge 14.7 psia * 42 lbs/lb-mole / 528 R / (10.73) = .11 lbs/ft3 Quantity purged in the first five hours = 2100 ft3 * (0.23 - 0.11) Ibs/ft3 = 252 lbs Maximum rate = 252 lbs / 5 hours = 50.4 lbs/hour C. Summary of Results The emissions for the EIQ are as follows: Eollutant lons/year Average lbs/hr Maximum lbs/hr Propylene 0.48 0.11 50.4 -- A-13 -- VVV 000002908 V-A. Vent Incinerator This point source is currently included in the EIQ. The --emissions reported in the EIQ are being revised to reflect emissions for two components that are expected in flue gas from the vent incinerators and were not previously reported. The two components are HC1 and Chlorine. The NOx emissions are also being corrected for two numbers that were transcribed. A. Basis for Calculations 1. The chlorine emissions are based on the permit basis flue gas rate of 1,536,900 dry SCF per hour and a maximum concentration (design basis) of 20 ppm chlorine (volume basis) in the flue gas. The chlorine is formed in the incinerator firebox by the reaction (2)HC1 + (1/2)02 --> (1)H20 + (1)C12 The chlorine is removed by countercurrent scrubbing first with water and then with a caustic (NaOH) solution. The caustic removes the chlorine by the reaction (1)C12 + (2)NaOH --> (l)NaOCl + (l)NaCl + (1)H20 The scrubber removal efficiency for chlorine is conservatively estimated to be 80 percent. 2. The HC1 emissions are based on the permit basis flue gas rate of 1,536,900 dry SCF per hour and an average concentration of 15.90 lbs of HC1 per million dry SCF determined in the performance test (Report 79-15189 from Kemron Environmental Services on Emission Testing for Conoco) of the vent incinerators. 3. The lbs of HC1 per hour fed to the flue gas scrubbers at the incinerator unit is 6781 based on the feed composition and combustion calculations for the permit basis flue gas rate. 4. The NOx emissions were mistakenly reported as 27.81 pounds per hour rather than 28.71 pounds per hour, due to transcribed numbers. The incorrect number was used to calculate the tons per year of NOx emissions, also. The correct number is 125.40 tons per year. B. Calculations 1. The annual emissions for C12 are 1536900 SCF/hour * 8760 hour/year * 20 SCF C12/ 1000000 SCF of flue gas * 70.91 lbs C12/379 SCF C12 = 50300 lbs/year -- A-14 -- VVV 000002909 50300 lbs/year / 2000 lbs/ton = 25.15 tons per year The average emissions equal the maximum emissions and are 50300 lbs/year / 8760 hours/year = 5.74 lbs/hour 2. The annual emissions for HC1 are 1536900 SCF/hour * 8760 hours/year * 15.90 lbs HC1 per million SCF = 214100 lbs per year 214100 lbs/year / 2000 pounds/ton = 107.05 tons/year The average emissions equal the maximum emissions and are 214100 lbs/year / 8760 hours/year 24.44 lbs/hour The pounds of HC1 fed to the flue gas scrubbers (per million dry SCF of flue gas) is: (6781 lbs/hour) * (hour/1.5369 million dry SCF) = 4412 lbs HC1 per million dry SCF of flue gas This equates to a removal efficiency of (4412 -15.90)lbs HC1 removed / 4412 lbs HC1 feed * 100% = 99.6 % removal efficiency C. Summary of Results The emissions for the EIQ are as follows Eollutant Tons/vear Average lbs/hr Maximum lbs/hr Chlorine HC1 NOx 25.15 107.05 125.40 5.74 24.44 28.71 5.74 24.44 28.71 A-15 VVV 000002910 V-B. Cooling Tower Fugitive Emissions This point source is a grandfather source which is being --added to make a complete accounting of all emissions sources. basis for the emissions listed in the EIQ are as given below. The A. Basis for calculations. 1. Emissions from this point source occur as a result of fugitive emissions from process heat exchangers that use cooling water as a cooling medium. 2. Emissions are determined by multiplying the cooling water circulation rate (typically 500 million pounds of water per day) by the concentration of hydrocarbons in the cooling water return. It is assumed that all the hydrocarbons are air stripped from the' cooling water returned to the cooling tower? in other words, the concentration of hydrocarbons in the cooling water supply to the process heat exchangers is zero. 3. Only three hydrocarbons are analyzed for (VCM, EDC, and ethylene) because they make up more than 99 percent of the constituents in the process streams which are cooled by cooling water in process heat exchangers. Any other hydrocarbons are assumed to be negligible when compared to these three components, hence the total emissions for all hydrocarbons from the cooling tower are assumed to be equal to those calculated for these three components 4. The fugitive emissions are based on the average concentration of EDC, VCM, and ethylene measured in the cooling water return for the years 1985, 1986, and 1987 excluding major releases from the cooling tower as a result of exchanger leaks. The average concentration for EDC, VCM, and ethylene combined in the cooling water return, excluding the releases, was 0.4 ppm (parts per million). 5. The maximum emissions rate is based on a maximum concentration of 2 ppm total for these three components in the cooling water return. This concentration is consistent with the Cooling Tower Fugitive Emissions Control Plan which is included in the permit application. B. Calculations 1. The annual emissions are 0.4 ppm * 500 million pound/day * 365 days/year = 73000 Ibs/year, or 73000 Ibs/year / 2000 lbs/ton = 36.5 tons per year -- A-16 -- VVV 000002911 2. The average emissions rate is 73000 Ibs/year / 8760 hours/year = 8.33 T; The maximum emissions rate is 2 ppm * 500 million lbs/day * day/24 hours C. Summary of Results The emissions for the EIQ are as follows: Pollutant Tons/year Average lbs/hr Hydrocarbons 36.5 8.33 41.67 Ibs/hour Maximum lbs/hr 41.67 -- A-17 -- Wv 000002912 AIR QUALITY DIVISION P.O. Gox <1*1096, Baton ilougc, LA. Telephone: (504) 342-1206 703Q4 ^-EMISSION INVENTORY QUESTIONNAIRE (Revision of U/7M Paee 1 of 9 CHECK ONE OF THE BLOCKS BELOW: VISTA. CHEMICAL COMPANY (name of company) (parent company; if above is a division) Submitted bv company on April 15, 1988 0This inventory includes only presently existing emissions. This inventory includes both those old emissions(expected to be still existing!and those pro posed additional emissions in cluded in our permit request for (date) (type of new facility/modification Please file a separate report for each of your plants physically located.in Louisiana. This Inventory covers the following plant location: which was submitted to the com mission on (date) and which new emissions are to be existing bv (date). VISTA VCM PLANT (plant's name, if any) WESTLAKE . (nearest town) CALCASIEU (parish of plant site)_ ....... .......... .. INSTRUCTIONS: Keep the original.of this form; return a photocopy to this agency, ifo not write information in the top on. left side margins of this form, as file fold er. bindings my coven, the information, We have tried to ask only for the information toe need, please do your best to answer each question* Our authority to ask for this information is contained in R.S. 40:2201 et sec. Copies of, this taw are available upon request, Ain. pollutant emission data provided on this form shall be available to the general public, without exception, All other data and information provided on this form and attachments shall also be available to the public, except that upon a showing satisfactory to the Technical Secretary that such other data and in formation, if made public, would divulge methods or processes entitled to protection as trade secrets, the data will be kept from all persons other than employees, or other agents, of the Louisiana and federal air pollution agencies, r~i Confldencialicy of all information, except the air pollutant emission rates, la requested, and our justification for this request is attached to the back of this form. (Check the bloc* it thia^Ta the" case.) If certain questions are not applicable, indicate "none" or "not applicable" (W.A.). Terms suck as "not significant", "nil", "trace", "negligible", etc. are not accept able, Please attack additional sheets if more space, is needed. An updated report should be submitted in the future when the annual emission rate of any pollutant from any stack changes more than 10Z from reported values.____________________ ITEM 1 . . . ORGANIZATION ACTIVITIES A. Circle any days of the week normally not operating: M Tu W Th F Sat Sun B. This facility, as a whole, typically operates _ 365 _days per year. C. The peak production season is NA _-- D. The facility normally operates 1 02 X3 3 eight hour shifts per day, or specify the hours normally worked per day. _ _ B. Approximate number of employees at this location is 113 . VVV C00002913 EMISSION' IN*VENTC?/f OUZSTIO>ft!AIRS (Revised U/74' Paee 2 of 9 F. If Che facility, as a whole, operates intermittently, give details on the lines below: G. Ownership of facility. Please check one of Che following *.e orporation. partnership, or sole proprietorship city government state government Q ocher, specify__________________________ "regulated utility federal government H. Please check off, or write below, the descriptive name which applies to your operation: lumber Indus try* asphaltic concrete E chemical industry pulp &-paper fertilizer P natural gas industry Qcement industry metals industry petroleum industry D particleboard fish meal Q sugar cane industry Q plywood brick making other, specify ______ I. Please give a very brief description of your operations, with emphasis on any possible sources of air pollution. REFER TO PROCESS DESCRIPTION IN ATTACHMENT 1. ITEM 2 . . . FUEL USE 3Y FACILITY AS A WHOLE Check one of tha blocks below, ana supply information as requested: 52 1$ this 4.a*j*rvt&iy is &ox "pAC&znZty existing" coi^ditions [as che.ck.zd &ca page. 1J, ptease give the in^o/eration Acquitted betouj {an the latest 12 month pzxiod &oA which, ycu. hc.'jz data. Vats f-o/t the. 12 month* ending Months DECEMBER Veexs 1987- HULL -in) has been given. 1$ d'.tcAi txsz is ex.pccx.zd-to be maxexuUZy~aZ^eAeyit [ozhex than as ouitLcied in a cuAfi&it pzJir.it AeqtLZSt) givz details on a separate sheet. Ii5 this ZaventoAtj is being submitted in conjunction taitk a peAr.it Acquest [as checked on page 1), plxasz gXva the anjtuai consuJnp-tion nates expected $oa the total plant &qa the 11 months AoZloicijig the date the new facility ex modedication becomes opzActiorai. This date Is listen on page J. Type of fuel Natural res Process *vs No. 1 i* fuel oil No, 5 or rj f up l oil Bark/ yooa enfes Coal (specify asn '4 & anthrjcitf>/bltucinou3*J Other Other Annual Consumption (ii = r.hcusnndO 1 .200 million cubic million rurX r. M (?-1 ' OP.*! M ",i lions rns font foc Sulfur 7. Heating value * i 1 nnin /MtrtC 935 KM BTU/ srM frJ in ^-.io/inri cr^O^. BTU/ KM ft-3 MM BTU/m ,i 1 MM BTU/ .'1 -al MM R7U7 ton tons MM BTU/ con 1 KM BTU/ 1 KM DTLV * - NET HEATING VALUE VVV 000002914 EMISSION INVENTORY QUESTIONNAIRE (Revised lt/76) P.nee 3 of Q ITEM 3 . . . MATERIALS USED, PRODUCED, STORED, OR TRANSPORTED BY TOTAL TLANT Raw materials or materials being trans ported Name of material Ethylene Chlorine Oxvaen Hvdroaen Chloride Cuontitv used or transported Annual Hourly Hourly average average maximum MM Lbs. 378 475 112.2 88 Ib/hr 43,0$6 54.224 12,311 10 046 lb/hr 45,333 57.308 13,?76 19,200 How scored How moved (Be specific - (Pipeline, floating roof tanktruck, tank, fixed etc.) roof, etc.) not stored Pipeline Pressure tank Pipeline/railc. i not stored Pipeline not stored Pipeline B. Products or byproducts Intermediate Products 1 1. Hvdroaen Chloride | 4fe(J.I 2. l,2,Dichloroethane Vinyl Product: 1. Vinyl Chloride 11,292.9 \ I 800 Byproducts: 1 MnriaHr Rr-id 2. Light Ends 1 i 4.337 | 1.452 52,Ofay i 54, / / 2 Pressure TanK j Pipeline "147,589 j155,249 Nitroqen padded dhip, railcar II fixed roof tanks i yi, 524 j 10 5 , uuu Pressure spheres ship,railcar,p: (1 1 495.1 1550 J 165.7 | 174. J 1 lFixed Roof 1 ank truck (Fixed Poof Tanks Railcar ITEM 4 . . . EMISSION INFORMATION ON THE ENTIRE PLANT AS A WHOLE The AOte& gtven ihctild coxne&pand, tn matt cn.sej, f to the. 4tun the. tncU.vtdu.iit avennye fiatej> the *point 4ouAce4 tinted tn the. Itern 5 pageA &o\ each type o& atn pottiLtant. A. PARTICULATE SOLIDS OR'LIQUIDS soot from combustion mineral dust other, specify: other, soeclfv: other, soeclfv: 1 Material name Emission rate (if must specify) lbs/hr 17.887 Emission rate tons/vr 78.33 B. ORGANIC GASES OR VAPORS alkanes/ paraffins methane and ethane alkenes/ olefins, specify: miscellaJ leous hydrocarbons alkvnes/ acetylenes aromatics, soeclfv: alcohols. soeclfv: other, specify: 1,2 Dichloroethane other, specify: Vinyl Chloride other, soeclfyjmisc. haloaenated by irocartons 0 9.60 0 2.54 0 0.10 '44.606 0.89 11110 0.08 C. INORGANIC CASES OR VAPORS sulfur dioxide hydroeen sulfide carbon monoxide nltroeen oxides ammonia halosens. specify: organic sulfides (except HoS) other, soeclfv: * SEE PAGE 6 (SUBPAGE 7 OF 9 ). SO? no >300 HC1 & cl2 4.188 19.02 46.108 30.18 18.35 83.43 201.3TJ3 144.61 VVV 000002915 EMISSION INVENTORY QUESTIONNAIRE (Revised 11/70 Papie 4 of 9 NOTES TO ITEM 5 Please read all notes before attempting to fill out page(s) 6. 1* Use any number you wish, but please be consistent in identifying this point by the same number on calculations, maps, future correspondence, computer printouts, etc. 2. If the emission point is not a vertically discharging.stack, or if there is no clear-cut point of emission (e.g., dust from moving equipment, multiple leaking valves, evaporation from storage tanks, etc.), put a zero in this column. 3. Give the inside diameter at the top. For non-round exits, use the equivalent di ameter, equal to 1.128 times the square root of Che cross-sectional area at the point of discharge. Diameter, volume flow rata., and exit velocity must be consistent! 4. A "boiler", for purposes of this form, is to be understood to be any combustion device which heats a fluid and is separated from such fluid by a partition. TheAe- &OKZ oil heatZXA, Vouithe/'jn heoteAA, etc. OAC included. Internal combustion engines and incinerators are not included. Direct fired kilns are not included. 5. Enter the proper code number, taken from the list below: 000 No control equipment 010 Electrostatic Precip. 040 Alkalized aluminia 001 Wet scrubber, above 95% efficiency 041 Dry llmestuQe injection above 95% efficiency 011 Electrostatic Precip. 042 Wet limestooe injection 002 Wet scrubber, 8p% - 957. efficient 043 Sulfuric acid plant, 807. - 957. efficient 012 Electrostatic Precip. contact process 003 Wet scrubber, below 80% efficient 044 Sulfuric acid plant, double below 807. efficiency 013 Gas scrubber, general contact process. 004 Gravity collector, 014 Mist eliminator 045 Sulfur recovery plant use above 95% efficiency 017 Fabric filter 046 Reduced emissions by 005 Gravity collector, 019 Catalytic afterburner changing process 807. - 957. efficient 020 Catalytic afterburner, 047 Vapor recovery system 006 Gravity collector, with heat exchanger 048 Activated carbon adsorp below 80% efficiency 021 Direct flame after tion 007 Centrifugal collector burner 050 Gas absorption column, above 95% efficiency 022 Direct flame after packed. 008 Centrifugal collector burner with exchanger 052 Spray tower for gases 80% - 95% efficient 023 Flaring 053 Venturi scrubber for gases 009 Centrifugal collector 039 Catalytic oxidation - 049 Liquid filtration system below 80% efficiency flue gas desulfuriza 051 Gas absorption column, tion tray-type 6. Give the percent by weight of uncontrolled emission removed. If unknown, leave blank; if there is no effective removal, enter a zero in the column. 7. Enter the number of the method used, as follows: (1) By actual stack test ..... ..... (2) By material balance, provided that _this method is applicable. (t. e., tfuA method obviously cannot be tibed wkzfiz the inaceuxacie& in mecuoAement OAe equal to ox gxeatex than the. absolute magnitude o& the lo&iei. An example p'topeA tue ujcutd be wh&ni solvent mi*6ion6 axe not dixeetty meeuuxzd, bat alt solvent puxdvued ib eventually lobt to the erfmotphexe, and thexe^oxe matexial bought divided by opeaating houxb equate lo&6 Kate.) (3) By the use of E.P.A. emission factors. (See the "Compilation of Air Pollution Emission Factors", E.P.A. publication AP-42) (4) By making a conservative estimate. (5) By the use of emission factors other than those supplied by Che E.P.A. VVV 000002916 EMISSION INVENTORY QUESTIONNAIRE (Revised 11/70 Page 5 of 9 NOTES TO ITEM 5, CONTINUED (-continuing with note 7:) (6) Use this number if and only if you are submitting this form in connection with a permit request, and the emissions referred to have no present existence, but are simply the result of design calculations. (7) Sources ceasing emissions must be reported on one inventory document after they cease operation (see note 8). Emissions will be zero, and a number 7 should be placed in the "emission estimation method" column. 3. If this particular pollutant, from this particular stack (point source), was not included in the stack or point source information submitted on your last Emissions Inventory Questionnaire, or if this is the first Emissions Inventory Questionnaire you are submitting, write "add" in this column. If this particular pollutant, from this- particular point, was Included on the last Emissions Inventory Questionnaire (EIQ) submitted, but the amount has been in creased or decreased (to other than zero), write "change" in this column. If a point source has ceased operation since your last EIQ, the pollutants from chat point should be reported as having zero emission rates on next submitted EIQ, and you should write "delete" in this_column. AFTER A VELET10N HAS BEEN ONCE RE PORTED, VO NOT REPORT THE POINT AT ALL ON ANY FUTURE Elfc'S AND VO NOT USE THAT POINT'S IDENTIFICATION (ID) NUMBER IN THE FUTURE FOR ANY OTHER POINT. 9. Report the concentration of particulate matter only for Incinerator flue gases, in grains per standard cubic foot of dry flue gas. (See Regulation 20.6.1). If this point is not an incinerator flue, write "N,A." in the column. Report SO2 concentra tions for any stack in which it is found, in PPM by volume at standard conditions. .Stack exit concentrations need not be reported for other pollutants* 10. If the hydrocarbons being emitted are of unknown type or have been obtained from emission factors which do not indicate, the hydrocarbon type, simply report the data requested on the line marked "hydrocarbons" If, however, you know more about the specific hydrocarbons being emitted (for example -- that they are non-raethane hydro carbons , or that they are paraffinic hydrocarbons, or that they are, say, 20 weight 2 alkenes with remainder paraffins, or if you know the specific name of the hydro-carbon being emitted, say, benzene or methanol or methylethylketone or whatever) please leave the line marked hydrocarbons blank, write in the name or partial iden tification of your specific hydrocarbons in one of the blank lines below, and give the data requested on that line* 11* Report the fuel charging rate, if any, in units of KM ft^ (million cubic feet) for gases, M gal fox fuel oil, and tons for coal, bagasse, sawdust, etc. Report the process materials charging rate, if any, in units such as M Bbl. (thousand barrels), tons (of material processed or produced), tons (air dried unbleached pulp), M gal (storage capacity of tanks; breathing losses), etc. Please telephone us and ask if unsure of what units to use. Do not list air or water as "process materials". In determining rates, do not Include any recycle amount unless asked to do so, in general the races should be determined on a "fresh feed" basis. For storage tanks, list separately under "Name of fuel/ process material" the two categories of breathing losses and working losses. The "rate" of the breathing loss determinant la M gal (storage capacity) and,of the working loss, is also M gal (throughput). If any one pollutant type (l.e., SOj, particulate matter, etc.) is emitted from more than one stack (or ocher emission point) serving the same piece of equip ment, please explain briefly on the reverse side of the page 6 subsheet, and write "See reverse side" prominently at the bottom of the form side. VVV 000002917 ITEM NO. 5 EMISSION INVENTORY QUESTIONNAIRE (Revised 11/74) Page 6 of 9 (SUBPACE NO. 1 OF 9 ) This page is to be used to record the data from one stack (or other emission point) only. Photocopy this page as many times as there are individual emission points, and use one page for each point. Note that the subscripted numbers indicate explanatory notes on pages 4 and 5. Point source ID number} IIA Descriptive name of the equipment served by this stack CRACKING FURNACE STACK Height of stack above grade2 119.97 ft Stack diameter^ 4.50 ft Stack gas exit temperature 824 oF Stack gas flow rate at process conditions, not at standard 39,000 ft^/mln Stack gas exit velocity 43- ft/sec If this stack serves a "boiler'^, give the type(s) of fuel used and the heat input (l.e., fuel rate x heating value) NATURAL GAS type(s) of fuel 59.4 x (2) T3T 10 BTU/hr 1st fuel 1q6 BTU/hr 2nd fuel, if any BACK-UP FUEL % of annual throughput of pollutants through this emis' 9ion point (totals 100%.) Dec- Mar- June- Sept- Feb May 25 X 25% Aug 25 % Nov 25% Normal operat ing time of hrs davs wks day week yr 24 7 51 Name of pollutant particulate matter sulfur dioxide nitrogen dioxide hydrocarbons in carbon monoxide Pollution Control Average Maximum Annual control equipment emission emission emission equipment efficiency rate rate rate code * 660 fi Ibs/kr lbs/hr tons/yr 0 6.311 0.413 1.361 --m-- 0 1.864 "2.4?8 8.165 000 0 8.699 11.562 38.101 000 0 0.360 __).479 , 1.578 000 0 2.165 2.890. 9.525 Emission estimation method y 3 2 3 3 3 Add, change or delete code g chanqe chancre chancre chancre chanqe Concentration in gases exiting the stack g NA. er/std ft^ NA PPM (VOL) Fill in this column only as required by note 9. WV 000002918 If this stack is from equipment which burns fuel, Give below the fuel or process materials charging race to give the % of the total fuel used by the equipment the unit served by this stack.}} which is used, either directly or indirectly, for Annual Maximum space heating (or cooling) at the plant, (i.e., j Name of fuel/ process material rate hourly rate to heat or cool the air in a room) If this stack NATURAL GAS 544.3 MM SCF/yr is not from a fuel burning equipment, or if fuel hr /hr is burned but none of the heat is intended to heat hr /hr or cool air in a room, enter a zero below: /vr /hr 0 X "apace heat" hr /hr 111 /hr ITEM NO. 5 EMISSION INVENTORY QUESTIONNAIRE (Revised 11/74) Page 6 of 9 (SUBPACE 2 OF 9 ) This page is Co be used to record the data from one stack (or other emission point) only. Photocopy this page as many dotes as there are individual emission points, and use one page for each point. Note that the subscripted numbers Indicate explanatory notes on pages 4 and 5. Point source ID numberi IIB Descriptive name of the equipment served by this stack CRACKING FURNACE STACK Height of stack above grade2 119.97 ft Stack diameter^ 4.50 ft Stack gas exit temperature 824 oF Stack gas flow rate at process conditions, not at standard 39,000 ft3/mln Stack gas exit velocity 41 ft/sec If this stack serves a "boiler14, give the type(s) of fuel used and the heat input (l.e., fuel rate x heating value) NATURAL GAS type(s) of fuel 59.4 xlpfe BTU/hiT1st fuel 106 BTU/hr 2nd fuel, if any FUEL GAS IS BACK-UP . FUEL IS BACK-t^5 vrm- ~ % of annual throughput of pollutants through this erais- slon point (totals 1002.) Dec- Mar- June- Sept- Feb May 25 7. 25% Aug 25% Nov 25% Normal operat ing time of this point hrs days wks day week yr 24 7 51 Name of pollutant particulate matter sulfur dioxide nitrogen dioxide hydrocarbons ia carbon monoxide Pollution Control Average Maximum Annual control equipment emission emission emission equipment efficiency rate rate rate code c -- --000-- A lbs/hr lbs/hr tons/vr 0 0.311 . 0.413 1.361 0 054* 2.478 8.165 000 0 8.699 11.562 38.101 000 0 0.360 0.479 1.578 000 0 2.165 2.890 9.525 Emission estimation method 7 3 2 3 3 3 Add, change or delete code g chanae chancre rhanrfp chanae chanae Concentration In gases exiting the stack 9 N& er/std NA PPM (VOL) Fill In this column only as required by note 9. 61620OOGO AAA If this stack is from equipment which burns fuel, Give below the fuel or process materials charging rate to give the % of the total fuel used by the equipment the unit served by thl9 stack. which is used, either directly or Indirectly, for Annual Maximum space heating (or cooling) at Che plant, (l.e., ] Name of fuel/ process material to heat or cool the air in a room) If this stack NATURAL GAS 54 rate hourly rate 82.6M SCF /hr Is not from a fuel burning equipment, or if fuel /yr /hr .8 burned but none of the heat is intended to heat /yr /hr or cool air In a room, enter a zero below: /yr /hr /yr ... /hr 0 X "space heat" bx /hr ITEM HO. 5EMISSION INVENTORY QUESTIONNAIRE (Revised 11/74)_________________ Page 6 of 9 (SUBPACE iJb- 3 OF 9 ) This page is to be used to record the data from one stack (or other emission point) only. Photocopy this page as many times as there are individual emission points, and use one page for each point. Note that the subscripted numbers indicate explanatory notes on pages 4 and 5. Point source ID number^ IID Descriptive name of the equipment served by this stack CRACKING FURNACE DECOKING SCRUBBER STACK Height of stack above grade2 37 h__________ft Stack diamete^ ft Stack gas exit temperature 212 P Stack gas flow rate at process conditions, not at standard Stack gas exit velocity 3,632 ft^/mln 77 ft/sec If this stack serves a "boiler"^, give the type(s) of fuel used and the heat i x heating value) NA type(s) of fuel 1st fuel 2nd fuel, if any % of annual throughput of pollutants through this emis- a ion point (totals 100%) Dec- Mar- June- Sept- Feb May Aug Nov 25% 25% 25 % 25 % Normal operat ing time of this point hrs days wks day week yc 18 6 Name of pollutant particulate matter sulfur dioxide nltroRen dioxide hydrocarbons carbon monoxide Pollution Control Average Maximum Annual control equipment emission emission emission equipment efficiency rate rate rate code * A lbs/lir Ibs/hr tons/vr 001 99.8 0.0025 0.58 0.011 000 7.07 1624 30.96 Emission estimation method i 4 4 Add, change or delete code g add add Concentration in gases exiting the stack g NA cr/std fc^ PPM (VOL) Fill in this column only as required by note 9. VVV 0 0 0 0 0 2 9 2 0 If this stack Is from equipment which burns fuel, give the % of the total fuel used by the equipment which Is used, either directly or indirectly, for space heating (or cooling) at the plant, (i.e., to heat or cool the air in a room) If this stack la not from a fuel burning equipment, or if fuel is burned but none of the heat la Intended to heat or cool air in a room, enter a zero below: 0 X "space heat" Give below the fuel or process materials charging rate to the unit served by this stack.^ Annual Maximum Name of fuel/ process material rate FURNACE COKE 33.5 tons/v hourly rate 0.2 tons /hr /vr /hr ht /hr /vr _ /hr /vr /hr ill /hr ITEM NO. 5 EMISSION INVENTORY QUESTIONNAIRE (Revised 11/74) Page 6 of 9 (SUBPACE NO. 4 OF9 ) This page is to be used to record the data from one stack (or other emission point) only. Photocopy this page as many times as there are individual emission points, and use one page for each point. Note that the subscripted numbers Indicate explanatory notes on pages 4 and 5. Point source ID numberi HE Descriptive name of the equipment served by this stack CRACKING FURNACE DECOKING SfTRITRRFR crvArv Height of stack above grade2 37 ft Stack diameter^ 1 ft Stack gas exit temperature 212 P Stack gas flow rate at process conditions, not at standard 3-632 ft3/mln Stack gas exit velocity 77 - If this stack serves a "boiler"^, give % of annual throughput of the type(s) of fuel used and the heat pollutants through this eraia- Input (l.e, fuel rate x heating value) sion point (totals 100Z) NA type(s) of fuel Dec- Mar- June- Sept- lQfa BTU/hr~1st fuel Feb May 10* BTU/hr 2nd fuel, if any 25 % 257. Aug 25 X Nov 25 Z Normal operat- this pof rt hrs days yks day week yr 18 x 6 Name of pollutant particulate matter sulfur dioxide nitrogen dioxide hydrocarbons carbon monoxide Pollution Control Average Maximum Annual control equipment emission emission emission equipment efficiency rate rate rate code * lbs/br lbs/hr tons/vr 001 99.8 0.0025 0.58 0.011 Emission estimation method 7 4 000 7.07 1624 30.96 4 Add, change or delete code g add add Concentration in gases exiting the stack g NA er/std PPM (VOL) Fill In this column only as required by note 9. VVV 0 0 0 0 0 2 9 2 1 If this stack is from equipment which burns fuel, give the Z of the total fuel used by the equipment which is used, either directly or Indirectly, for space heating (or cooling) at the plant, (i.e., to heat or cool the air in a room) If this 6tack is not from a fuel burning equipment, or if fuel a burned but none of the heat is Intended to heat or cool air in a room, enter a zero below: 0 X "apace heat" Give below the fuel or process materials charging rate to the unit served by this stack.^ Annual Maximum Name of fuel/ process material rate FURNACE COKE 33.5 tontfv hourly rate 0.2 tons i\ /vr /hr /vr /hr /vr /hr /yr /hr bs. /hr ITEM NO. 5 EMISSION INVENTORY QUESTIONNAIRE (Revised 11/74) Page 6 of 9 (SUBPACE NO. 6 OF 9 ) This page Is Co be used to record the data from one stack (or other emission point) only. Photocopy this page as many tlaies as there are individual emission points, and use one page for each point. Note that the subscripted numbers indicate explanatory notes on pages 4 and 5. Point source ID number^ IV-A Descriptive name of the equipment served by this stack C-500 (MAIN PLANT VENT STACK) Height of stack above grade2 148 ft Stack diameter^ 3.0 ft Stack gas exit temperature Ambient op Stack gas flow rate at process conditions, not at standard Stack gas exit velocity If this stack serves a "boiler "a* give the type(s) of fuel used and the heat input (l.e., fuel rate x heating value) NA tvoe(s) of fuel X of annual throughput of pollutants through this emie- sion point (totals 100X) Dec- Mar- June- Sept- Normal operating time of this point hrs days wks 106 BTU/hr 1st fuel ^ ft^/min ^ ft/sec 106 fiTU/hr 2nd fuel , if any (1) THERE WILL BE NO FLOW EXCEPT DURING OXY SHUTDOWNS. 1 Feb 25 X May 25 % Aug 25 % Nov day week yr 25 X a) (1) (1) Name of Pollution Control Average Maximum Annual Emission Add, change Concentration in pollutant control equipment emission emission emission estimation or delete equipment efficiency rate rate rate method i code g gases exiting the stack 9 particulate matter sulfur dioxide code k ft lbs/hr lbs/hr tons/vr er/std ft^ PPM (VOL) nitrogen dioxide hydrocarbons ia carbon monoxide tltit: A CTACHMENT , i Pill in this column only as required by note 9. VVV 0 C 0 0 0 2 9 2 2 If this stack Is from equipment which burns fuel, give the Z of the total fuel used by the equipment which Is used, either directly or indirectly, for space heating (or cooling) at the plant, (i.e., to heat or cool the air in a room) If this stack s not from a fuel burning equipment, or if fuel s burned but none of the heat is Intended to heat or cool air In a room, enter a zero below: 0 X "space heat" Give below the fuel or process materials charging rate to the unit served by this stack. Annual Maximum Name of fuel/ process material NA rate /vr hourly rate t\ /vr /hr /yr /hr /vr /hr /vr /hr Ixi /hr SUBPAGE 7 OF 9 ) ATTACHMENT A C-500 VENT STACK {IV-A) INTERMITTENT EMISSIONS DUE TO OXY SHUTDOWNS Name of Pollutant Pollution Control Equipment Code 5 Carbon Monoxide HC1 Total Hydrocarbons Methane Ethane VCM EDC Misc. Chlorinated HC Misc. HC 000 002 000 000 000 000 000 000 000 Control Equipment Efficiency e 80% Average Emission Rate Lbs./Hr. 0 0 0 0 0 0 0 0 0 Maximum Emission Rate Lb./Hr. 6.23 2500 713.23 10.82 7.61 3.80 176.87 16.13 550.48 Annual Emission Rate Tons/Yr. 0.03 12.41 3.57 0.06 0.04 0.02 0.89 0.08 2.48 Emission Estimation Method 7 Add,Chang or Delete Code 8 (2) change (2) change (2) change (2) change (2) change (2) change (2) change (2) change (2) change c < < o o o o !o\> fNJ U> ITEM HO. 5EMISSION INVENTORY QUESTIONNAIRE (Revised 11/74)Page 6 of 9 (SUBPAOE NO. 5 OF 9 ) This page is to be used to record the data from one stack (or other emission point) only! Photocopy this page as many times as there are Individual emission points, and use one page for each point. Note that the subscripted numbers indicate explanatory notes on pages 4 and 5. Point source 10 number^ IV-C Descriptive name of the equipment served by this stack PROPYLENE VENT (BL-501) Height of stack above grade? 148 ft Stack diameter^ 0.666 f Stack gas exit temperature AMBIENT op Stack gas flow rate at process conditions, not at standard Stack gas exit velocity 7.6 ft^/mln 0.36ft/sec If this stack serves a "boiler"^, give % of annual throughput of the type(s) of fuel used and the heat pollutants through this emie- Input (l.e., fuel rate x heating value) type(s) of fuel Dec- Mar- June- Sept- X0b BTU/hr 1st fuel Peb 1q6 BTU/hr 2nd fuel, if any * X May *% Aug *% Nov *X Normal operat ing tioic of hrs days wks day week yr * ** Name of pollutant particulate matter sulfur dioxide nitrogen dioxide hydrocarbons in * carbon monoxide Pollution Control Average Maximum Annual control equipment emission emission emission equipment efficiency rate rate rate code k fi Ibs/br lbs/hr tons/vr 000 0.11 50.40 0.48 Emission estimation method y (4) Add, change or delete code g add Concentration in gases exiting the stack g NA NA er/std ft^ PPM (VOL) Pill In this column only as required by note 9. VVV 0 0 0 0 0 2 9 2 4 If this stack is from equipment which burns fuel, give the Z of the total fuel used by the equipment which is used, either directly or Indirectly, for space heating (or cooling) at the plant* (l.e., to heat or cool the sir In a room) If this stack s not from a fuel burning equipment, or if fuel .s burned but none of the heat is intended to heat or cool air In a room, enter a zero below: _________ X "apace heat" Give below the fuel or process materials charging rate to the unit served by this stack.u Annual Maximum Name of fuel/ process material PROPYLENE rate hourly rate 50.40 lbs. /I /yr /hr /vr /hr /vr /hr hr /hr 111 /hr * PROPYLENE UNIT VENTS ONLY DURING TURNAROUNDS AND MAINTENANCE OUTAGES WHERE THE PROPYLENE SYSTEM MUST BE CLEARED. ITEM NO. 5 EMISSION INVENTORY QUESTIONNAIRE (Revised 11/74) Page 6 of 9 (SUBPAGE 8 0Fy ) This page Is to be used to record the data from one stack (or other emission point) only. Photocopy this page as many times as there are Individual emission points, and use one page for each point. Note that the subscripted numbers Indicate explanatory notes on pages 4 and 5. Point source 10 numberi V-A Descriptive name of the equipment served by this stack VENT INCINERATOR Height of stack above grade2 145 ft Stack diameter^ 3.0 ft Stock gas exit temperature 125 op gaa . .wn rate at process conditions, not at standard Stack gas exit velocity 28,817 f t^/mln 67%t/sec If this stack serves a "boiler"^, give the type(s) of fuel used and the heat input (i.e., fuel rate x heating value) NA type(s) of fuel 1Q6 BTU/hr"1st fuel 106 BTU/hr 2nd fuel, If any X of annual throughput of pollutants through this emle point (totals 100*4) Dec- Mar- June- Sept- Feb May 25-4 25 % Aug 25% Nov 25_% Normal operat- this poi nt hrs Amis. wks day week yr 24 7 52 Name of Pollution Control pollutant control equipment equipment efficiency code c fi particulate matter sulfur dioxide 022 022 nitrogen dioxide 022 hydrocarbons m 022 carbon monoxide vinyl chloride 022 WF1 hydroqen chlorid e 001 99.6% chlorine 003 80% Average Maximum Annual emission emission emission rate rate rate lbs/br lbs/hr tons/vr 17.26 0.16 17.26 75.586 "(5715 5.02 28.71 2.98 28.71 125.40 2.98 13.07 0.55 2.54 0.55 2.43 2.54 11768 24.44 24.44 107.05 5.74 5.74 25.15 Emls sion esti mation me th od y 4) 4j (4) (4) 4) . (4) (4) (4) Add, change or delete code g Concentration In gases exiting the stack g u.u /y er/std ft^ 1.78 ppm (VOL) Fill in this column only as required by note 9. VVV 0 0 0 0 0 2 9 2 5 If this stack is from equipment which burns fuel, give the X of the total fuel used by the equipment which Is used, either directly or indirectly, for space heating (or cooling) at the plant. (I.e., to heat or cool the air In a room) If this stack la not from a fuel burning equipment, or if fuel is burned but none of the heat is intended to heat or cool air In a room, enter a zero below: 0 X "apace heat1 Give below the fuel or process materials charging rate to the unit served by this stack.^ Annual Maximum Name of fuel/ process material rate hourly rate La . hr hr hr hr /hr /hr /hr /hr La /hr ITEM NO. 5 EMISSION INVENTORY QUESTIONNAIRE (Revised 11/74) Page 6 of 9 (SUBPAGE OF * ) This page is to be used to record the data from one stack (or other emission point) only. Photocopy this page as many times as there are individual emission points, and use one page for each point. Note that the subscripted numbers indicate explanatory notes on pages 4 and 5. Point source ID number^ V-B Descriptive name of the equipment served by this stack VCM PLANT COOLING TOWER Haight of stack above grade2 56 ft Stack diameter** 48 ft Stack gas exit temperature 90 op Stack gaa flow rate at process conditions, not at standard 3.8MM ft3/min Stack gas exit velocity 36ft/sec If this stack serves a "boiler"^, give % of annual throughput of the type(s) of fuel used and the heat pollutants through this emis input (i.e., fuel rate x heating value) sion point (totals 100%) NA type(s) of fuel Dec- Mar- June- Sept* ~ 10* BTU/hr 1st fuel Feb 10* BTU/hr 2nd fuel, if any .25* May 25* Z Nov 25 X Normal operat ing time of this point hrs days whs week 7 5 Name of pollutant particulate matter sulfur dioxide nitrogen dioxide hydrocarbons m carbon monoxide * Pollution Control control equipment equipment efficiency code * A Average Maximum Annual emission emission emission rate rate rate lbs/hr lbs/hr tons/vr oon 8.33 41.67 36'.5 Emission estimation method 7 (2) Add, change or delete code g add Concentration in gases exiting the stack 9 NA er/std fcJ NA PPM (VOL) Fill in this column only as required by note 9. w v 000002926 If this stack is from equipment which burns fuel, give the Z of the total fuel used by the equipment whleh la used, either directly or indirectly, for space heating (or cooling) at the plant. (I.e., to heat or cool the air in a room) If this stack s not from a fuel burning equipment, or if fuel s burned but none of the heat is Intended to heat or cool air in a room, enter a zero below: 0 X "apace heat" Give below the fuel or process materials charging rate to the unit served by this stack.^ Annual Maximum Name of fuel/ process material NA rate /yr hourly rate /hr /vr /hr /vr /hr /vr /hr * /vr /hr /vr /hr EMISSION INVENTORY QUESTIONNAIRE (Revtr.nH 11/76) ITEM 6 PLANT LOCATION FOR AIR POLLUTION DISPERSION MODELING Page 7 of 9 Clve below the Universal Transverse Mercator zone number and Universal Transverse Mercator (UTM) coordinates, to the nearest one-tenth kilometer, of your facility. We must have this Information since we are required to report it to the U. S. Environ mental Protection Agency for wide area dispersion modeling purposes. The coordinates can be obtained from most U. S, Geological Survey maps, scale 1:24,000 or 1:62,000 for your particular area. These maps, if not already in your possession, may be found in your local library, or can be purchased from the U. S. Geological Survey (USGS) at the address shown below for 75C each (1974 price). An Index of all Che maps available for Louisiana, together with prices and detailed instructions for ordering, may be obtained free by addressing a request to: U. S. Geological Survey, Distribution Center, Denver Federal Center, Bldg. 41 Denver, Colorado 80223 If the map has the Universal Transverse Mercator (UTM) coordinates listed, it will have the UTM zone number mentioned among the writing along-the bottom of the map. This zone number will be either 15 or 16 for Louisiana. Plec&z note, that latitude and longitude czz not what we need, and that the USGS maps do not show UTM grid lines as they do latitude and longitude; however, tick marks along the edges of the maps do Indicate the UTM grid locations. A straight edge must be used to connect tick marks at the opposite sides of USGS maps when interpolating between UTM tick marks because the map grid is drawn on the latitudelongitude system and, therefore, the UTM grid may appear quite skewed. For the scales mentioned, tick marks appear for every 1000 meters (1 kilometer), with every fifth tick mark and the tick marks nearest the southeast and northwest corners of the map giving the value in meters. The 1:24,000 scale is preferred to accurately locate the facility, but the 1:62,000 scale may be used if the 1:24,000 scale map is un available for your area. For example: The state capltol building in Baton Rouge would be: UTM zone No. .1 J5. horizontal coordinate: ,6 1_ 4..1 Km. E vertical coordinate: 3^ ,3 J. .. Km* N Your facility: UTM zone No. 1 horizontal coordinate: ^7 2Km. E vertical coordinate: 3 3 4 J5.5 Km. N ITEM 7 . . . COMPLIANCE STATUS Check one oi the. block* below, zeganding youn. facility* * "Compliance Schedule": 0 Such a document has not been requested of us, so far as we know. Such a document was requested, or submitted, but we haven't yet received noti fication that It was accepted at a public hearing by the Commission. We were notified chat the document was accepted at a public hearing; no schedule of actions to achieve compliance was necessary. DWe were notified that the document was accepted at a public hearing; our sched ule of actions to achieve compliance by _ _ (month), 197 _ (year) was approved. The most recent "Increment of progress" date in our schedule of actions was achieved on ____(month) _ (day) 7 _ (year). pfOU MUST FILL IN THE DATE BLANKS IF YOU HAVE CHECKED THIS"PARAGRAPH^ WV 000002927 EMISSION INVENTORY nm>:STTnMNAT3K (Uevlf^d I } / 74 ) ITEM 8 . . . REFUSE %~OLLECTICH AMD DISPOSAL Page ft of 9 Amount of combustible refuse disposed of per year: 5915 Tons (give the applicable units) Description of recuse; check off applicable categories*. 20 Paper scrap Rubber scrap XX Wood scraps & sawdust G Wet garbage or animal*wastes jS Other, specify: Rubbish__________________________________________________ , _ C. Method of refuse disposal; check off applicable catagories: City pickup G On-site dump Q On-site incineration XXContractor pickup Cn-site outdoor burning D On-site landfill POther, specify: ___________;______________________ D. If disposal is by contractor pickup, .give the name and.address of the contractor: Browninq-Ferris Industries of Louisiana Inc. SoTia waste Division-Cities Service Highway - Sulphur, LA 7TT65X E. The on-site lncineracor, if any, has tha following design features: No on-site incinerator C Aftarbumars Water scrubber installed Single chamber C Primary <* secondary G Waste material disposed of Multiple chamber burners installed by burning in a boiler F* Incinerator equipment data -(-if applicable): Manufacturer: NA Model: ' Capacity: Installation date: Auxiliary fuel used: (type, how used, rate of use) ITEM 9 . . . SUPPLEMENTARY INFORMATION A. Please supply a unit plot plan on map which shovti the location* orf stacks (on othen *ounce*), togethen with the aoua.cs -identification numbens ftnom Item 5. the plant boundaries, a distance scale, and the dOiectlon Month. Please also show, on a sepanate diagnam l& necc&sany, the location ofi the plant in notation to nearest highways, nesidential areas, and torxns. Attack the maps to the back oi this oajh. B. Approximately how much money have you spent on air pollution control equipment and operation in the past 12 years? Equipment $23,223,000 Operation $4,16i;000 ITEM 10 . . . TOXIC CASES & HAZARDOUS MATERIALS A. Are there any substances used or produced in your facility whi:h could cause im mediate injury to life or property, JJf they were emitted to the atmosphere, which are not already listed in this form as one which is presently being emitted to the atmosphere? (e.g., chlorine for water treatment, toxic gases, gases used as cata lysts, etc., which ordinarily do not escape) Please list such substances below. If none, please so state. No B, Does your facility use or produce asbestos, mercury (other than laboratory use), or beryllium in any amount whatsoever? If answer is yes, give detalln r- -.* separate sheet. If answer is no, please write "no" below: Yes, asbestos is present in sore of the plants older insiilatiioru WV 000002923 EMISSION INVENTORY QUESTIONNAIRE (Revised 11/74) ITEM n . . . PERSONNEL fit CERTIFICATION p.iftc q of 9 The malinger of the facility, on location at the plant site. is as fallows: Name: Title: Name of Company: Business street address/ P. 0. Box: City or town, parish, Zip code: Business area code/ telephone No.: Richard A. Conrad__________ Plant Manager - VCM Plant Vista Chemical Co.__________ P. O. Box 605________________ Westlake. LA 70669________ (318) 494-5063_______________ B. Person to cantact at the site of the facility about air pollution control, if different from the above: ' Name: Title: Business telephone No./ extension: Ed Taylor Environmental uooramator (318) 494--5031 C. If the company's air pollution control correspondence and documents are prepared at a headquarters office, at a different site, give the Information on the person to be contacted below: Name: Mike Haves*; Title: Director of Environmental Control Name of company; or parent company: Vista Chemical Co-. Business street address/ P. 0. Box: P. O. Box 727 City, state, Zip code: Westlake. LA 70669 Business srea code; telephone No.: (318) 494-5437 D. Person who prepared this report: Name: Title: 'J'lrm: (if prepared by a consultant) Company: (If prepared in-house) Street address/ P. 0. Box: City, state, Zip code: Area code, telephone extension: (I one o the. above, juzt check appropriate block:) a a. a b. a c. William P. Swan Sr. Process Engineer Vista Chemical Canpany p O Box 605 Westlake. IA 70669 (31B1 494-5058 E. CERTIFICATION. j ceAtiiy, under. the. provision* in Louisiana and United StateA taut which provide. c/Uminat penalties ion. &aZ&e statements f that this Emission Inventory Questionnaire, including oJJL attachments thereto, contain* in^onmation which is true and coAJie.cZ to the best oi muJ*fOwled$e and. belief. (signature of manager, or other company agent) R.A. Conrad, Plant Manager - VCM Plant (printed or typed name & title of person above) ^/'t AnT____________________________ (date signed) VVV 000002929 ATTACHMENT 1 Brief Process Description Gaseous chlorine (supplied by pipeline from PPG Industries) and gaseous ethylene (supplied across the fence by a Vista ethylene plant) is reacted to form crude 1, 2 dichloroethane (EDC). The crude EDO is purified by two stages of distillation to produce a relatively pure EDC. Pure EDC is thermally cracked in a gas-fired furnace at about 500C and cracks into vinyl chloride (VCM) and anhydrous HC1. This mixture is purified by two stages of distillation to separate the heavy tars and the HC1 from the VCM. The VCM is then redistilled to separate uncracked EDC (which is recycled back to the process) and the pure VCM is dried, neutralized and stored in pressure spheres at about 80 psig. The HC1 separated in the above process is reacted in a multi-stage catalytic reactor with oxygen and ethylene to form additional EDC. This extra EDC is fed into the two stage EDC distillation process and blends with the EDC produced by the chlorine/ethylene reactor. The tail gas from this reactor is fed to the chlorine/ethylene reactor. An incinerator burns vent streams from process equipment and loading operations, and neutralizes the exhaust gases before discharging them to atmosphere, and produces Muriatic Acid for sale. Storage is provided in the plant for several grades of EDC, VCM product and two liquid organic by-products. Essentially all of the VCM product is shipped out by ship or railcars. A small amount of EDC is also sold in ships or railcars. Design capacity of the plant is 800,000,000 lbs/yr. of VCM VVV 000002930