Document B89eejy5EXvKVbdMzY6Z82v7J

Interoffice Communication To From Date Subject J. J. Hall - Holston W. V. Henry July 9, 1979 Daily Log of Persons Entering Regulated Areas RECEIVED JUL 1 ? W/9 After receiving your 1 ;ttdr of June 12, 1979 informing us that OSHA has revoked the requiremen that a daily roster be made of persons who enter a regulated area, the /CM Plant, effective July 16, 1979 will no longer require personnel to sfi gn in before entering a regulated area. We will still require that access to regulated areas be limited to "authorized persons". This decision was made after careful consideration and we determined that this particular requirfemeri t is of a limited benefit in achieving the intended purpose, and the ihefore add unnecessary detail and do not sub stantially contribute [to employee safety and health. ^ iC W. V. Henry Safety Director br cc: JAD-RDG-DAK VVC 000012550 VCM Plant CERTIFIED MAIL 731561b RETURN RECEIPT REQUESTED July 5, 1979 Conoco Chemicals Coritiocntai Oil Company P.O. Elox 605 Westlake. Louisiana 70669 <318) 491-521 1 Ml -"'"T Mr. James F. Coerver Technical Secretary Louisiana Air Contro ] Commission P. 0. Box 60630 New Orleans, LA 70160 Dear Mr. Ccerver: The CONOCO Chemicals VCM Plant in Westlake, Louisiana hereby requests a one year variance from LAC 14-11:22.8 for the vent from our direct chlorination reactor he referenced regulation requires the incineration of waste gases conta lm ng halogenated hydrocarbons which have sufficient heating value to suppoort combustion. The direct chlorination reactor vent falIs under this reg j! a in cn and is currently being incinerated. We feel, however, that there is significant safety risk in continuing to incinerate this vent. On January 2, 1979 tie YCM Plant experienced an explosion in the direct chlorination vent knb ckout drum, S-500. Although it has been impossible to unequivocally ex plain the cause of the detonation, the most likely cause was a flash back froin the vent gas incinerator which was propogated through a flammable mixture in the vent header. Damage from the explosion was not severe, however, th re v/as some damage at the incinerator end of the header and at the direct chU orination reactor end of the header in addition to the knockout drum. Therfifore, it is our evaluation that there was the potential for severe damage to thi operating units as well as the entire vent header. Currently, natural gas is charged to the direct chlorination reactor to prevent formation of fl c.mmahle gas mixtures. The natural gas addition rate is set to maintain tie System on the fuel rich side of the flammability envelope calculated for the system. In addition, in line flame arrestors at the incinerator are used to prevent flame flash back should a flammable mixture occur during a system u bset. The recent explosion in S-500 has prompted concern over the safety of this system. Specific concerns are in the following areas: a) The chlorine eed to the direct chlorination reactor is supplied by PPG Indjsti res. PPG frequently experiences upsets in their chlorine cblli. Historically, elevated levels of air (oxyg jn VVC 000012551 James F. Coerver Page 2 July 5, 1979 and nitrog in) have appeared in the chlorine feed supplied by PPG during these upsets. During these upsets the oxygen concentration in the direct chlorination reactor rapidly increases Tremendous amounts of natural gas are required during upset conditions to maintain the gas mixtures in the system in a nonflammable egion. The present natural gas addition system cannot supply the recuired amounts of natural gas. Also, the system itself 1i mi ts the amount of natural gas which can be added. Therefore, Flammable gas mixtures are present in the direct chlorinati On System during PPG chlorine cell upsets. b) Questions lave recently been raised concerning the accuracy of the calcul stec flammability envelope currently used to set the natural ga a ddition rates. The present envelope applies for atmospheri pr essure conditions. The direct chlorination system, hojv eve is operated at pressures substantially greater than atmosa her ic. Data for calculating flammable compositions at pressur es greater than atmospheric is unavailable at this time. c) Recent, irv sstlgatiohs have yielded concern over the present flame arre stors used on the direct chlorination vent. Contacts with compa[i ies and agencies which have tested flame arrestors similar to ours in pipeline service have indicated that the arrestors provi de protection only within a limited range of gas mixtures Our conclu sion after these contacts is that our arrestors are not adequate f o r the service. Granting a one year var ance for the direct chlorination reactor vent would allow us to re rou e the vent to the oxychlorination vent stack, C-500. This would allow us to sol ate the vent from the flame source. Natural gas addition would b co ntinued to prevent flash back from any other ignition sources such as 1igh ti ng , static electricity, etc. Recycle EDC from the EDC recycle chlorinator wi 1 be by-passed around the direct chlorination system, This will reduce the vi lyl concentration in the direct chlorination system to less than 10 ppm. T lerefore, the VCM Plant will continue to comply with all federal vinyl c hi or de standards even though the vent will not be incinerated. Rerouting the direct ch orination vent to C-500 will add 6.9% to the hydrocarbon emission 1is ted n the present Emission Inventory Questionnaire (EI0) Since this is less than a 10% increase, a revised EIQ is not being submitted at this time. A table f the present EIQ values as well as the increase associated with the rero uting of this vent is attached. vve 000012552 EMISSION INVENTORY - C-500 STACK VERAGE EMISSIONS IN TONS/YR Components Present C-500 Vent as Defined in 1977 EIQ. Carbon Monoxide HC1 Cl2 Methane Ethane Total Non-Photcchemicall;' Reactive Components 1 ,776 ` 245 29.9 172 20 2242.9 Direct Chlorination Vent 71 668 23 762 VCM c2h4 Ethyl Chloride EDC Others Total Photochemically Reactive Hydrocarbons 55.8 479 2,001 1,694 188 4,417.8 1.9 196 .5 106 1.0 305.4 VVC 000012553 James F. Coerver Pago 3 July 5, '1979 i ' j . '% This situation is ten porary. Jnvest'igations into solvent adsorption and carbon adsorption wh c11 would remove the EDC and other chlorinated hydrocarbons from the vent are cu rently underway. Also, studies are being conducted to determine the feasib lit.y of a pure oxygen based oxychlorinat'ion system. A pure oxygen oxy woul i allow the direct chlorination vent to be rerouted directly to oxy, thus eliwina ting the v.ent. In the meantime, development of better flammability data ai i 'i investigation into adequate flame arrestors for the direct chlorination vent ar ? continuing. In view of the above information, we request a variance for this vent. If you have any questions, jleasc contact 0. L. Foshee, Chief Process Engineer at (318) 491-5062. Sincerely, J. A. DeBernardi Plant Manager is BCC: REL-DAK-CRH-HJN-MAF GLF-PLF-JOG-JWW VVC 00001255** CERTIFIED MAIL 431564 3 RETURN RECEIPT REQUE $TEQ June 22, 1979 Conoco Chemicals Continental Oil Company P.O. Dox 605 Westlake. Louisiana 706S9 {3181 491-521 1 Mrs. Linda Hunter Environmental Protect ion Agency Permits Branch (6AEPA P) Region VI First International Building 1201 Elm Street Dallas, TX 75270 Dear Mrs. Hunter: This letter is in redpon e to your Public Notice dated May 26, 1979 (A.O. f';'9T-il33NALX) cone rning CONOCO Chemicals Company VCH Plant's NPDES Permit No. LA00034/6. S everal errors have been noted in the fact sheet and in the proposed permit. The following changes need to be made on the fact sheet: 1) In Sections l.|e.{l), l.e.(2), and l.e.(3), the outfall number shoi Id be changed from 001 to 201. Outfall 001 is the combine, tion of the secondary waste treatment effluent (designatec. outfall 201) and the neutralization system effluent (c. esignated outfall 101). In general , the combined effluent at 001 would be essentially the same as outfall 201 However, t! e effluent characteristics listed in Sections (1) and (3) are not monitored at 001. The permit should be referenced for specific monitoring location for each pollutant. 2) In Section I.e.(3), the daily average COD concentration (mg/1) should be dhanged from 22.4 to 224. ,3) In Section 2 Item Number (2) Modification request submitted January 4, 1 973 should have the date changed to January 4, 1979 The order of t e references should then be: 1) NPDES Standard Form C date d A 3ri 1 14, 1978; 2) Existing NPDES Permit effective December IE , 1 578; 3) Modification request submitted January 4, 1979. 4) In Section 3,a., the proposed daily maximum limit on BOD in outfall Nun- ber 201 should be changed from 1375 lbs./day to 1350 Ibs./d ay- VVC 000012555 Mrs. Linda Hunter Page 7. June 22, 1979 The following change should be made on Page 4 (Section A-3) of the proposed permit. 1) In the 1ast Stc itement on this page, the samples should be taken at thi combined effluent box instead of the weir. There is no weir ct this particular point. Under Applicant Number 2 in the Public Notice, the applicant's mailing address should be change d to: Conoc o Chemicals Company - VCM Plant vi s ion of Conoco, Inc. 0. Box 605 West ake, LA 70669 All addresses in the Permit and Fact Sheet should be changed accordingly since Continental Oi edmpany will officially change its title to Conoco, Inc. on July 1, 1979 If there are any gnostic ns concerning these comments, please contact 6. L. Foshee, Chief 5roc css Engineer at (318) 491-5062. Sincerely, J. A. DeBernardi is CC: Diana Dutton - tPA R. A. LaFleur -1 LSCjC BCC: rel-dak-crh-hjn-maf-fIlh GLF-PLF-JOG-JWW-HDG-EAP VVC 000012556 VCM Plent/ "tElfflFIED #315644 Conoco Chomicols Continental Oil Company P.O, Box 605 Westlake. Louisiana 70669 (318)491-5211 June 21, 1979 received High E. Wise, Jr. Project Officer Organic Chemicals Branch Effluent Guidelines Divi ;ion (WH-552) United States Environmental Protection Agency Washington, DC 20460 JUN 2 8 1979 Dear Mr. Wise: After receipt of your letter of June 7, 1979, we reviewed our files and found no record of tjie December, 1977 request for BAT Data as referenced in your letter. Mr. Pail Casidy of your office confirmed in a phone conversation that no da :a was requested in 1977. However, he stated that the data request of January 14, 1979 was also made under the authority of Section 30S of P.L. 925d0; and our response would also be released to Catalytic, Inc. as part of the EPA contracts. As was noted on our response to the January 14, 1979 request, CONOCO Chemicals Company considers th 2 information supplied in the questionnaire confidential and requests that it be treated as such. We view the confidentiality agreement between the EPA and Catalytic, Inc. as binding between CONOCO and Catalytic, Inc., and feel that it lives CONOCO adequate protection. Therefore-, we agree to the release of this nformation under these conditions. Sincerely, A. DeBernardi sj BCC REL - DAK - CRH - HJtlj MAF - GLF - PLF - JOG JWW - HPG \f\fC 000012557