Document 9JMj8M5EGXR4q6KGJKZ5yLD9p

Interoffice Communication To From Date subject J. c. Ledvina - Houston V. M. Fisher November 19, 1981 VOC Regulation Impact on VCM Plant's Modernization Effort Attached are the new Tables I & II which were issued in the previous letters, "VOC Regulation Impact on VCM Plant's Oxychlorination Revamp Project," Spet. 22, 1981 and its revision issued October 9, 1981. Since the issuance of both letters more definitive information has become available concerning the existing equipment in VOC service which can be successfully modified, in accordance with the EPA standards. Based on this information the scope varies moderately, however, the bottom line does not. As it stands now the offsets obtained through existing equipment modifications, Table I, total 44.107 lbs./hr. This means that the available offsets will compensate the plant modernization but will not compensate the entire plant expansion. However, not included in this offset sum are the open-ended valves on process lines being plugged. This work is currently being done by the plant. Offsets from these will be tabulated and added to this offset sum at a later date, although its estimated that 26 plugged valves could make up the 0.230 lb./hr. difference. The likelyhood of attaining this number of valves is promising. Total available fugitive emission offsets Lbs,/Hr. Voc 44.107 Total increased fugitive emissions from entire plant expansion - Case I 44.337 Total increased fugitive emissions from plant modernization - Case II 16.622 As the scope of the modification to existing equipment becomes more define the total available fugitive emission offsets will possibly be revised. In addition, the following items need clarification. 1) It is being assumed that equipment modifications previously completed or presently being accomplished are "claimable" as offsets. Does the EPA have a retroactive date to determine which modifications are claimable ? If so what is this date ? 2) Can open-ended valves in vinyl service that are to be plugged be claimed as offsets ? CCR 0000X7718 A response to the questions above is requested as soon as possible Please contact me concerning any questions or comments you have regarding this letter. CC ! JAD-JWW-GLF-MLA-DLD-JGC-JJH-MGH-GCB-BIR-GJF CCR 000017719 nr> 30 o o oo H* TABLE I rsj NEU VOC FUGITIVE EMISSIONS FOR OXY REVAKP o Fugitive Fmission Source 2 Ni-w Pumps (Control 1 ed) New Relief Valves (Controlled)2 2 Ni-w Ni.n-Vinyl Compressors (Controlled) New Valves Cast 1: ^ I'rv. Valves in la; or Service l'i in ss Vd 1 ves in l ii)u)d Service Ini t r'ui i*nt Valves in Vapor Service 1 ns tr ui..ent Val ves in l ifpjid Service Total Case 2:(2} Process Valves in Vapor Service Process Valves in Liquid Service Instrument Valves in Vapor Service Instrument Valves in Liquid Service Total Number of Sources 2 6 3 241 500 298 381 1,420 107 98 185 43 433 Uncontrolled Emission Factor lb/hr 0.0463 0.022 0.0463 0.022 0.0463 0.022 0.0463 0.022 Total Uncontrolled Emissions lb/hr 11.158 11.000 13.797 8.382 44.337 4.954 2.156 8.566 0.946 16,622 Controlled Emission Factor 0.00 0.00 0.00 Total Controlled Emissions lb/hr 0.00 0.00 0.00 (Table I) Notes: 1) A definitive estimate of the entire expansion from PED. 2) A preliminary estimate of the oxychlorination modernization from PED. 3) Estimated valve split for the entire expansion is 40% in vapor service and 60% in liquid service. Estimated valve split for the o>ychlorination modernization is 70% in vapor service and 30% in liquid service. CCR 00001T721 CCR 0 0 0 0 1 7 7 2 2 Fugitive Emission Source Existing Pumps Existing Safety Relief Valves Existing Sampling Connections Existing Compressors TABLE II AVAILABLE OFFSETS FROM EXISTING VOC FUGITIVE EMISSION SOURCES Number of Sources 44 73 26 6 Uncontrolled Emission Factor lb/hr 0.265 0.353 . 0.033 0.97 "otal Emissions Ib/br 11.660 25.769 0.858 5.820 Controlled Emission factor 0.00 0.00 0.00 0.00 Total Available Offsets 1 b/hr 11.660 25.769 0.858 5.820 44.107