Document Ed50jev2GRmnRD7B20aygy6Ob

-a V / ___________ CERTIFIED--RETURN RECEIPT REQUESTED Conoco Chemicals Company A Di vision of Conoco Inc. P.O. Bo* 727 Westlake. Louisiana 70333 (318) 491-5211 February 26, 1980 i C E; V E 0 Mr. Randall E. Brown Environmental Protection Agency 6 AAHAT Technical Support Section First International Building 1201 Elm Street Dallas, Texas 75270 Jjjj_ 2 ' *fwdu Dear Mr. Brown: By this letter, we are advising you of our withdrawal from consideration the Prevention of Significant Deterioration ("PSD") Application (LA-291) submitted by Conoco Inc. on November 20, 1979. The application pertained to the construction of a new Linear Alkylbenzene Plant in Lake Charles, Louisiana. This action is being taken pursuant to the Administrative Order entered on January 30, 1980, by the Administrator of the Environmental Protection Agency in conjunction with the litigation in Alabama Power Co. v. Costle, No. 78-1006 (D.C. Cir. December 14, 1979). The proposed construction will have a controlled emissions of less than 100 tons per year of all pollutants regulated under the PSD regulations proposed on September 5, 1979, and hence will not be a major source subject to PSD review for any of these pollutants. The plant is to be located in an Air Quality Control Region which does not meet the National Ambient Air Quality Standard for ozone and, therefore, is classified as a "non-attainment" area. Due to this "non-attainment" status, PSD does not apply. However, the State of Louisiana has granted a State construction permit, which is included on Paga 13 of the Appendix, demonstrating total compliance with the State Implementation Plan and all other applicable air regulations. A basic information package is attached which follows an outline for PSD applications obtained from EPA. Included in this information is emission calculations which demonstrate Conoco's position on PSD. If any clarification is required, please do not hesitate to contact Jack Neeld at (318) 491-5437. Sincerely, CONOCO CHEMICALS COMPANY Manager, Lake Charles Operations HJN/mbr Enclosure hn- .in nr?) rdn HS 000100043 TOTAL LINEAR ALKYL PLANT INFORMATION PACKAGE 1. Applicant: Conoco Chemicals Company, A Division of Conoco Inc. Address: Phone: P. 0. Box 727, Westlake, LA 70669 (318) 491-5437 Contact: Harvey J. Nesld, Director of Environmental Control 2. Facility Name: Lake Charles Linear Alkyl Benzene Plant Location: Westlake, Louisiana Type of Operation: Organic Chemicals Manufacturing 3. Benin Construction: August 1, 1980 Beain Ooeration: April 1, 1982 4. Site Information: The plant will be located within the S.W. quadrant of the. N.U. quadrant of Section 27, Township 9 South, Range 9 West. This location is within the city limits of Westlake, Calcasieu Parish, Louisiana. Cascio subdivision is the nearest residential section to the plant which is approximately 1,750 feet to the north. Source Plans, Description, and Design: A plot plan is attached (Figure IV) indicating the various sections of the plant including emission point sources. For descriptive purpose, three figures are attached. Figure I presents a block process flow drawing of the process for a 150 million pound per year linear alkyl benzene production. Figures II and III show more detailed process information, including the major operating equipment involved and major emission points. - Paraffins (primarily Cn to C^) are transferred from storage, mixed with recycle paraffins and recycle hydrogen, vaporized in the feed-effluent exchangers, and heated in the PAC0L charge heater, a direct-fired process heater. They then flow through one of two reactors where the paraffins are converted to olefins at 10 to 14% conversion. The vapors flow through the feed-effluent exchanger to an air cooler and then to a separator drum. Vapor from the separator drum (primarily hydrogen) is compressed and re cycled to unit feed. Excess hydrogen resulting from the reaction is used as fuel. Liquid from the separator flows to the PACOL stripper. The overhead product consists of liquids and vapors which are again used as fuel. The HS 000100044 Page 5 BENZENE ALKY & PROD. PtlRIR UNITS LINEAR ALKYL BENZENE PRODUCTION UNIT UNIT LOCATION KEY 1. Paraffin Fractionation 2. Hydrogen Fuel System 3. Bottoms Fractionation 4. Alkylate Treating (Space Only) 5. Plant and Instrument Air 6. Cooling Water System 7. Paraffin Tankage 8. Flare System 9. Waste Water Systems 10. Fuel System Knockout Drum 11. Well Water Systems 12. Warehouse 13. Railspur and Loading 14. Control Room 15. Hot Oil Heater LH-3 16. Charge Heater LH-1 17. Startup Heater LH2 18. Benzene Waste Water Tank 100 19. Vacuum System (LV-1) FIGURE IV / . r- ( soo Paoe 6 \ \ HS 00010004V Page 7 5. The following table is a compilation of estimated controlled emissions in tons per year for the proposed facility. TSP (T/YR) CONTROLLED S02 (T/YR) CONTROLLED N0X (T/YR) CONTROLLED HC (T/YR) CONTROLLED CO (T/YR) CONTROLLED 14.4 16.3 83.6 8.0 17.3 The sources of- emissions are itemized in Tables I through V (Pages 16 through 20 of the appendix). Sample calculations, emission factors, and other technical information are provided on pages 21 through 36 of the appendix to allow verification of the estimated emissions. It is important to note that all equipment has assumed a 365-day/year operation when in fact it will be only approximately 330 days or less. 6. Figure V is a copy of a portion of a United States Geological Service map (NE/4 Sulphur 15` Quadrangle) showing the location of the facility and the nature of the surrounding topography. Figure IV indicates the various structures and equipment within the fence .line, of the plant. The highest structure close to the process heaters is the paraffin column approximately 200 feet away which has preliminary design dimensions of 140 feet high and 18.5 feet wide. 7. The major fuel source for the plant will be a purchased fuel gas. The fuel gas has the following composition: `` COMPONENT % MOL. 2 CiH4 C2H4 C2H6 C3H6 C3H8 C4H8 iC4H10 nC4H]o C5H10 1C5H12 nC5H]2 C6H14 n2 <0 & <? 12.3 33.3 9.8 19.5 . 5.7 8.0 2.3 2.5 0.2 0.1 0.2 0.1 0.1 5.9 Page 9 The maximum sulfur content of the fuel aas is ten grains H2$ per 100 standard cubic feet of gas consumed. Internally produced waste gas and HF bottoms will be supplemental fuel for the hot oil heater. (See Pages 27 through 32 for more detail). The startup heater and the plant flare will utilize natural gas for fuel. Natural gas will also be used to fire the hot oil heater and/or charge heater in the event of an inter ruption of purchased fuel gas. 8. Emission control equipment to be used in the LAB facility are as follows: A. Conoco Chemicals operates under a self-imposed personnel exposure standard of 1 ppm benzene on an eight hour time weighted average.. As a result, many control technologies are/utilized which are otherwise not required by State or Federal criteria.- The following list details the control technologies to be used: 1. A benzene steam stripper is designed to remove benzene from the wastewater. All sources of benzene wastewater (i.e., water draw from benzene tanks, benzene process water discharges, etc.) are collected in a closed segregated sewer system and treated through the stripper to a designed discharge concentration of 1 ppm . benzene. The effluent from the stripper is then biologically treated before discharge. 2. A closed segregated underground benzene sewer will be used to ensure minimal benzene release. 3. All tanks which are in benzene service will utilize one of two emission control methods; fixed roof tanks with a double sealed internal floating roof which is nitrogen blanketed and pressure tanks which vent to the flare system. 4. Double mechanical seals on all pumps in benzene service. 5. A closed aromatic sampling system. 6. Benzene monitoring system and combustible analyzer. B. The facility utilizes hydrofluoric acid (HF) as a feedstock. Great care has been taken to minimize HF emissions as the following indicates: 1. Closed segregated HF drains and sewers. The HF neutralization pit is covered, sealed, and vented after passing through a water scrubber to .remove residual HF. 2. Double mechanical seals on all pumps in HF service. 3. Closed HF sampling system. HS 00010005 MCI) 0 0 0 0 0 8 8 4 7 Page 10 C. NOx emissions will be minimized by use of staged combustion Lo NOx burners specified by John Zink Co. and controlled excess combustion air according to continuous flue gas oxygen analyzers. D. All process tower vents will be sent to the flare system. E. The flare system will utilize steam addition for smokeless operation. F. The vacuum ejector system for the fractionation section is equipped with surface condensors to reduce hydrocarbon emissions. (Emission ID Mo. LV-1). 9. As noted in the November 3, 1977, Federal-Register, the Breton Sound area is a national wilderness greater than 5,000 acres and is, therefore, con sidered a Class I area. Since this area is located approximately 375 kilometers from the described facility, it is concluded that compliance with the provisions of 40 CFR 52.21 (c) (2) (ii) is shown. 10. A copy of the State construction permit is provided in the Appendix (Page 13). The State permit was issued based upon significantly higher emissions than are discussed in this submittal. The State permit appli cation was approved based on firing No. 6 fuel oil as the primary fuel with off-gas and natural gas as alternates. Following a fuel source evaluation by Conoco, we have revised our emission calculations to reflect our intention to utilize off-gas as the primary fuel. At the appropriate time, we will amend the State permit to reflect emissions based on firing of off-gas. 17e expect no difficulty in obtaining State concurrence as the estimated emissions utilizing off-gas are less than the previously approved No. 6 fuel oil case. All State opacity and applicable emission standards will be met. o 2 000008848 S^B 12-75 r M E Kiefer Conoco Inc Westlake, La AFE--7090 C F BRAUN & CO CHROMATOGRAPH SYSTEM LAB PLANT LAKE CHARLES CHEMICAL COMPLEX Page 11 Specification 5669-100-212-1 June 16, 1980 ,T 18.1 ambient' air" analyzers The analyzers shall measure benzene in ambient plant air with maximum analysis time of ninety seconds. The analyzers shall a sensitivity of at least one part per million full scale and be autoranging. a have shall Hydrocarbons processed in the benzene area of the plant are benzene, C4 through Cg parafins, C^2 through C^4 olefins and C1Q-C14 aromatics. The atmospheric concentration of these hydrocarbons should be very low. Light hydrocarbons (C^-Cj) in low concentrations may drift in from adjacent units. Naturally occuring terpenes may also be present. Each analyzer shall include an integral air purification system which allows instrument air to be used in the flame ionization detector. Each analyzer shall include pressure sensors for both instrument air and hydrogen. A temperature sensor shall monitor the flame in the detector. Whenever there is a loss of pressure or a flame-out all power shall be removed from the analyzer and a normally closed solenoid valve in the hydrogen supply line shall be deenergized. The hydrogen solenoid valve will be supplied with the analyzer shelter and located at the cylinders. A spring loaded switch or pushbutton shall allow manual energizing of the solenoid valve for start up. The controller shall provide a continuous isolated 4-20 mADC trend output proportional to the last benzene concentration measured at each sample point - a total of twenty trend outputs. The controller shall also compute eight hour, twenty-four, and thirty day running averages for each sample point. The operator shall be able to initiate a printout of any average at anytime from the teleprinter keyboard. The appropriate averages shall automatically print at the end of each shift, day, and month. The eight hour averages shall be printed in the following format. The printout shall include the heading. V32J B9 S7B 12-75 M E Kiefer Conoco Inc Westlake, La AFE-7090 C F BRAUN & CO CHROMATOGRAPH SYSTEM LAB PLANT LAKE CHARLES CHEMICAL COMPLEX Page 12 Specification 5669-100-212-1 June 16, 1980 18.1 AMBIENT AIR ANALYZERS Continued BENZENE Eight Hour Report Time Date STREAM AVE CONC LAST READ MAX CONC TMAX 0.5 1.0 1.5 R1 R2 r3 r4 803-1 803-2 803-3 803-4 803-5 803-6 302-7 803-8 803-9 803-10 0.00 0.00 401-1 401-2 401-3 401-4 401-5 401-6 401-7 401-8 401-9 401-10 0.00 The columns are: 0.00 0.00 00:00 00 00 00 00 0.00 0.00 00:00 00 00 00 00 ' 0.00 0.00 00:00 00 00 00 00 STREAM Sample point identification number. AVG CONC Time weighted average of benzene concentration at sample point over last eight hours. LAST READ Last measured benzene concentration at sample point. MAX CONC Maximum benzene concentration measured at sample point in last eight hours. MCD 0 0 0 0 0 8 8 5 0 V32J B10 S7B 12-78 M E Kiefer Conoco Inc Westlake, La AFE-7090 C F BRAUN & CO CHROMATOGRAPH SYSTEM LAB PLANT LAKE CHARLES CHEMICAL COMPLEXQ 18.1 AMBIENT AIR ANALYZERS Continued Page 13 Specification 5669-100-212-1 June 16, 1980 ^ i TMAX Time of maximum benzene concentration measured in last eight hours. R]_ - R4 Number of measurements falling in the concentration ranges indicated by the superscripts. The daily averages shall be printed in a similar format. The monthly report need only show sample points and average concentrations. Alarm conditions and their time of occur sice shall be printed on the teleprinter as they occur. The following conditions must be reported. Automatic analyzer shutdown Low carrier gas pressure Low sample flow Low bypass flow Analyzer removed from service Analyzer returned to service High benzene concentration (sample point shall be identified) High average benzene concentration over last eight hours (sample pdint shall be identified) The controller shall contain a relay with unpowered normally open contacts. The relay contacts shall be connected to a terminal strip. During normal operation the relay shall be energized. If the benzene concentration at any sample point exceeds five ppm the relay shall deenergize and remain deenergized until the condition has cleared. The alarm point shall be adjustable from the teleprinter keyboard. All concentrations shall be printed in parts per million to the nearest hundredth of a part per million. '`The measurements shall be accurate to within three percent of the measured value except that measurements of low concentrations need only be accurate within 0.025 parts per million. MCD 0 0 0 0 0 8 8 5 1 V32J Bll 578 12-75 -M_E Kief el Conoco Inc Westlake, La AFE-7090 C F BRAUN fit CO CHROMATOGRAPH SYSTEM LAB PLANT LAKE CHARLES CHEMICAL COMPLEX Page 14 Specification 5669-100-212-1 June 16, 1980 18.1 AMBIENT AIR ANALYZERS Continued Tag numbers for the benzene monitoring system are as follows. End of Line Filters AE-803-1 through AE-803-10 AE-401-1 through AE-401-10 Analyzers AT-401 and AT-803 Controller and Teleprinter AI-401 & AI-803 18.2 RECYCLE HYDROGEN ANALYZER A A single analyzer shall measure water vapor and hydrogen sulfide in the recycle hydrogen with a maximum analysis time of six minutes The analyzer shall include a pressure sensor for instrument air. Whenever there is a loss of air pressure all power shall be removed from the analyzer. Provisions shall also be made to protect the detector filaments whenever there is a loss of carrier gas. A The controller shall provide a continuous isolated 4-20 mADC trend ouput proportional to the last water and hydrogen sulfide concentration measured, a total of two trend outputs. The outputs of this analyzer shall not be printed on the teletype. A Service Analyzer Tag Number Analyzer Location Sample Temperature Sample Pressure Sample Return Sample Line Length Interconnecting Cable Length Detector Accuracy Alarms P&ID Number Recycle Hydrogen AT--211 Analyzer Shelter Number 90--105 F 50-60 psig 8-15 psig 100 ft 800 ft Thermal Conductivity + 3% of full scale None 5669-100-KE-9 1 MCD 0 0 0 0 0 8 8 5 2 V32J B12