Document Exz1v1y6JNmXZvMKnao7MVO4

" ::ived ^ 5 2 1973] UQAL o:pr. C.H.S.J. FEB 1 4 1973 February 6, 1973 3TCD vRi - Mr. John E. Trygg Technical Secretary Louisiana Air Control Commission P. 0. Box 60030 New Orleans, Louisiana 70160 TDK. Dear Mr. Trygg: The attached is a rev^edCompLlanceSchedule requested by the Commission covering the deficient areas referred to in your letter of November 9, 1972. Very truly yours. FPT/RMT:ef Attach. P. B. Cornell, Manager Baton Rouge North Works bcc: Mr. A. J. von Frank Mr. T. D. Kent Mr. J. E. Bowler Mr. E. E. James Mr. R. S. Christian^ Attn. Mr. C. R. Walbridge ASI-PR 0004153 BATON ROUGE NORTH WORKS INDUSTRIAL CHEMICALS DIVISION ALLIED CHEMICAL CORPORATION REVISED AIR COMPLIANCE SCHEDULE I. GENERAL One of the principle products at this location is soda ash (sodium carbonate). The production of this product involves the following operations: calcining, conveying, grinding, screening, packing and loading* The effect from these operations creates a fugitive particulate (dust) condition, and our compliance schedule for abatement puts heavy emphasis on dust collection systems. The Works' testing program has been primarily for dust fallout within its battery limits. The reason for this measurement is due to the relatively large and dense particles which agglomerate in a humid atmosphere and fall as fugitive dust within the perimeter of the Works. Relative to State ambient standards, it is believed that fu^itfofe particulate (dust) falls out much nearer the source than can beCpredicated)bv dispersion , calculations. There is also a question on the value 6~dispersion calcula tions considering the multiple sources involved in an industrial complex. The dispersion calculations should incorporate valid point source data, accountability for all variables (meteorology) and computer programs appli cable to the problem. The above technique and expertise were not available at this location so that no dispersion calculations were made. Dust fallout data over the last year indicate the soda ash fugitive dusts settle out and meet the State ambient standard in a distance of less than a quarter of a mile from the source and, in general, within the boundaries of our plant. Limestone dust settles at a much faster rate. (Limestone is a major raw material used in the soda ash process). Attached for reference to this revised compliance schedule is the schedule submitted on August 23, 1972. II. EMISSION STANDARDS Section 18.0 - Smoke Control 1) General burning of natural gas as fuel for power generation, calcining soda ash and cracking is in compliance. These operations use natural gas which rarely produces smoke. 2) Emission of smoke from vertical kilns during intermittent charging operations is in compliance. Charging of each kiln with limestone and coke seldom exceeds Ringelmann 1. ASI-PR 0004154 2- - 3) Smoke generated in decoking of furnace tubes in the vinyl chloride monomer operation is not in compliance. a. The furnace tubes are heated and blown with air and steam twice per month for 18 hours each time. During the initial stage of this operation Ringelmann 1 is exceeded for a period of 15-20 minutes. After the initial period during intermittent spalling with air, the smoke does not exceed. Ringelmann 1 for more than four minutes in sixty consecutive minutes. b. The decoking procedure is a shutdown and start-up operation and on this basis we are asking the commission to approve compliance status under exemption 18.4 and/or 18.6.2 based on the limited amount of smoke being emitted in an unpopulated area of the plant. 4) Flaring of Ethane and Ethylene from brine well storage system near Plaquemine, Louisiana is in compliance. a. Pressure release venting for repair of lines, etc., does not cause smoke to exceed Ringelmann 1 more than an aggregate time of six hours in any ten consecutive days. The location for this operation is in an unpopulated area. 5) Smoke emission from Test Burning of Standby Fuel Oil for power generation is in compliance. a. The standby fuel oil facilities are tested periodically for readiness in event of a natural gas outage. The smoke emitted during the changeover from gas to oil will be controlled within the limit of four minutes in any sixty consecutive minutes. 6) Flaring of gases from the Dichloroethane (EDC) and vinyl chloride operation is in compliance. a. Smoke emission from flaring during this operation does not exceed Ringelmann 1 more than an aggregate time of six hours in any ten consecutive days. 7) Smoke emissions from Lead Melting Furnace is in compliance. a. The lead recovery process used for rebuilding diaphragm cells involves some organic matter which burns off in the lead melting furnace. The smoke generated during this operation will be controlled so that a Ringelmann 1 will not be exceeded for more than four minutes in sixty consecutive minutes. ASI-PR 0004155 3- - Section 19.0 - Particulate Control 1) Soda ash loading operations into ships and barges. Fugitive dusts from these operations are considered to be in compliance on the basis of our fallout sampling over the past year. Light Ash Loading - Process weight 175 tons/hr. Dnissions allowable 56 lbs/hr. Dense Ash Loading - Process weight 250 tons/hr. Emissions allowable 60 lbs/hr. The loading operation is located in a remote area on the east bank of the Mississippi River. The shipping area is dusty during the loading operation, however, the dust fallout is within State ambient standards at our North and South property lines. Data show 13.8 tons/square mile/30 days at the South property line station and 5.8 tons/square mile/30 days soda ash at the North property line station. Ambient State standard is 20 tons/square mile/30 days. 2) Salt drying, conveying and loading operations are in compliance. Process weight Emission allowed Stack tests on wet scrubber 25,000 lbs/hr. 22 lbs/hr. 18 lbs/hr. 3) Decoking of furnace tubes in the vinyl chloride monomer operation are in compliance. Process weight Emission allowed Calculated emissions 20,000 lbs/hr. 19 lbs/hr. 6 lbs/hr. The furnace tubes are heated twice per month for 18 hours. During this time the tubes are blown with air and steam for one to two minutes every thirty minutes. Estimate 200 lbs. carbon is half burned and blown out during each 18-hour period. 4) Lime slakers producing milk of lime are in compliance. Process weight Particulate emissions allowed Estimated emissions 1,650 tons dry lime + S500 tons water per day 62 lbs/hr. None visible (steam) 5) Vertical lime kilns during charging operations are believed to be in compliance. Process weight Particulate emissions allowed 2,640 tons limestone and 210 tons coke per day 52 lbs/hr. ASI-PR 0004156 4- - These emissions, mostly fugitive, are believed to be in compliance as estimated by visual observations and evaluation of fallout data taken over the last year. Data shows less than the 20 tons/square mile/30 days (state requirement) at the Work's battery limits. 6) Other sources of particulate fugitive dust and their respective compliance schedules were designated as Plans 1-4 and were submitted to the Air Control Commission on August 23, 1972 (see attached). Following is a review of emission data in these plans. Plan 1 - Design and install new dust collecting systems on lime kilns discharges and conveyors. Process weight Particulate emissions allowed Estimated emissions 1650 tons/day 47 lbs/hour 260 lbs/hour Expected emissions after installation of planned equipment - 30 lbs/hour Plan 2 - Purchase and install three improved bag dust collector systems to replace present ones in Nos. 1, 3 and 4 elevator towers in soda ash section. Process weight Particulate emissions allowed Estimated emissions 6600 tons/day 61 lbs/hour 600 lbs/hour Expected emissions after installation of planned equipment - 55 lbs/hour Plan 3 - Purchase and replace four bag dust systems in dense ash operating systems. Process weight Particulate emission allowed Estimated emissions 1800 tons/day 48 lbs/hour 300 lbs/hour Expected emissions after installation of planned equipment - 30 lbs/hour Plan 4 - Design and install dust collecting systems on soda ash loadings into trucks and rail cars. Process weight (Light Ash) loading 35 tons/hour Particulate emissions allowed 42 lbs/hour Estimated emissions 175 lbs/hour Design criteria to be satisfied 30 lbs/hour ASI-PR 0004157 5- - Process weight (Dense Ash) loading Particulate emissions allowed Estimated emissions Design criteria to be satisfied 70 tons/hour 47 lbs/hour 88 lbs/hour 35 lbs/hour Section 20.0 - Incinerator Standards Question 1 through 4 under incinerator compliance schedule guidelines are not applicable as refuse is used for land fill. Section 21.0 - Fuel Burning Equipment Standards This item is not applicable as natural gas is used for steam and power generation. Section 22.0 - Volatile Organic Compound Control A supplemental schedule will be submitted based on federal approval of state regulations, as per guideline instructions. Section 24.0 - Sulfur Dioxide Control ,, Sulfur dioxide from combustion of natural gas at Baton Rouge North Works and ethane gas at our brine wells near Plaquemine, Louisiana are in compliance. Both natural gas and ethane contain less rhan 1 ppm sulfur. The resulting combustion products are within state standards at the property lines. Section 25.0 - Carbon Monoxide Control Carbon monoxide from vertical kiln operations. In compliance based on being an existing operation and classified as a priority III region. Section 26.0 - Nitric Acid Industry Standards Not applicable industry. III. AMBIENT AIR STANDARDS Section 9.0 - Suspended Particulate Level Control and Section 10. 0 - Dustfall Level Control In reference to both of the above sections, as previously indicated, our problem area is fugitive dust. These fugitive dusts, soda ash and limestone, are relatively large, heavy particulate which settle rapidly after becoming airborne. Except for areas adjacent to the specific ASI-pr 0004158 -6 operation our dust fallout data indicates compliance. However, in areas where compliance is not met, our original submitted compliance schedule should result in a reduction of particulate to meet state ambient standards. Section 11.0 - Outdoor Burning Standards Section 12,0 - Sulfur Dioxide Level Control Section 13.0 - Carbon Monoxide Level Control Section 16.0 - Nitrogen Oxide Level Control These above parameters (Sections 11.0, 12.0, 13.0 and 16.0) are in compliance or are not applicable as reported in the emission standards section. Section 14.0 - Hydrocarbon Level Control Section 15.0 - Oxidant Level Control A supplemental schedule covering Sections 14.0 and 1S.0 will be submitted based on Federal approval of state regulations, as per guideline instructions. IV. INCREMENTS OF PROGRESS Increments of progress are given in the attachment of the original compliance schedule submitted. Periodic progress reports will be made to the Technical Secretary on the status of BRNW compliance schedule at six month intervals. ASI-PR 0004159