Document JrnLoJ6N4Xb5Y2wEBBKDMZ9NZ

-1 12CHEMICALS INDUSTRIES ^4 AJ Eb rffi P /?,<po ' + 1 S AWr AHck> & i 3> INTEROFFICE / LAKE CHARLES TO R. J. Samel son FROM a. P. Plauche' 'VP DATE . February 18, 1983 SUBJECT EPA Request for Hg Emissions Information Enclosed is the completed EPA questionnaire on Hg emissions standards which you requested that Lake Charles complete. If you have any questions or need more information, please call me at 4814. /ap SL 025789 // '41 2 .2 Please provide copies of emission test results and all supporting reports of emission tests performed since promulgation of the mercury standard. Include a description of test methods, process conditions during the tests, problems encountered during the tests, and any steps taken to resolve the problems. See Attachment II 3. Please provide a basic process flow diagram for each facility identifying major processes, technology, and emission control systems. See Attachments III/V What is the annual production capacity of the mercury cells for each facility? Facility Capacity (t/day chlorine) Uke_Charles. La.. New Martinsville, W.V. TOO; 208 C. Process and Control Technology Information Please provide information or answer the questions in this section for the Lake Charles, La. facility only. 1. What is the strength (percent by weight) of caustic produced at this facility? To what extent is evaporation used to concen trate the caustic? The strength of the caustic produced at this facility is 50%. No evaporation is utilized to achieve this concen2. What are the end uses of the hydrogen gas at this facility? trat,*on The Hg gas produced .is sold for use as a boiler fuel to a PPG powerhouse and to a neighboring anwonia plant as a raw material. * 3. Please briefly describe the treatment of the chlorine gas stream after it leaves the cell. How is the chlorine stored and shipped? See Attachment IV 4. Please provide a basic diagram showing the emission control systems for the end-box ventilation and hydrogen stream with main components described by type, manufacturer, date of installation, design mercury removal efficiency, and typical operating conditions. Please include under operating conditions the following types of information for each control system. See Attachment V SL 025790 / + 3 Cooling and mist elimination: Temperatures Cooling medium Chemical scrubbing: Inlet gas temperature and flow rate Scrubbing medium Liquid flow rate Pressure drop Activated carbon adsorption: Inlet gas temperature and flow rate. Type of carbon impregnation Bed depth Typical bed life Method of recovery of mercury from bed or disposal of spent carbon Molecular sieve adsorption: Inlet gas temperature ;and flow rate Typical bed life Recycle-regeneration system 5. Please provide flow rates for the following ventilation systems. a. Cell room (scfm) Design: 1,500.000 HFM & 20-97 F Maximum: Not available Typical: Not available b. End-box (scfm) Design: 3000 SCFM. Maximum: liOOd SCFM TyPical: ^lSQiLSCEM c. Hydrogen by-product stream (scfm) Design: Maximum: Typical: 5350 SCFM 53b0 5cFM 5200 SCFM 6. Please specify the type of ventilation system used in the cell room. Convection type contouramic air mover 7. Please provide a list of cell room housekeeping practices if your practices differ from those recommended by the Environmental Protection Agency. PPG's housekeeping practices include all those ,, recommended by the EPA. 8. What method and frequency of monitoring is used to measure the concentration of mercury in the air in cell rooms? An ultra-violet absorption Hg vapor monitor Is used to monitor the air in our cell roans twice/week at 36 locations each time. How are monitoring results used to locate mercury leaks in the cell room? All above-standard readings are imnediately traced to their source and reported to the Operations Supervisor. The cause of the over-standard is eliminated that day. Follow-up monitoring is performed to insure that the problem was corrected. SL 025791 / & 4 What concentrations have been measured? (Please indicate time period for which measurements are, provided.) Results shown cover all measurements made during 1980-81 (1982 numbers not yet summarized)----Maximum, mg/m3: 1.1 ' Average, mg/m3: 0.21 _____________ ____________________________ _ Range: <0.01 mq/m3 to 1.1 mg/nv* 9. Please briefly describe the waste water treatment system used at this facility. Include a list of the sources of mercury- contaminated wastewater. See Attachment VI 10. Please briefly describe the solid waste disposal methods used at this facility. Include a list of the sources of mercurycontaminated solid wastes. The sources of Hq-contaminat-prl cnlirl waste are: 1) mercury sulfide filter: 2) cell renewal: 3) mercury NaOH filter; 4) mi sc. solids contaminated with Ho (lumber, pipe. JMUfirJLea^es. etc.)._ All mercury contaminated solid waste is _ placed into 30 vd^ closed too bulk boxes (designed to transport hazardous waste solids) and transported to an off-site EPA approved hazardous waste disposal facility by EPA-approved transporters. Is mercury recovery of solid wastes practiced? a No Yes If yes, please briefly describe the process and provide mercury emission rates, if available. 0. Cost of Compliance With the Mercury Emission Standard 1. Please provide the following data related to the cost of compliance for those control systems described in Section C. If cost break downs are not available, please Drovide total costs as indicated. FUME 'A' MIST *8' MOL. 'C* Control system identification SYSTEM ELIMIH. STFVE AHSOR. CARRON ADS0RP. Year installed 1967 1971___ 1974 1976 SL 025792 IS B-2. Copies of emissions test results and supporting reports for the initial determination of compliance in 1974-75 are given in Attachment II-A. Since the middle of 1976, however, the H2 stream has changed from an "emissions source" to a "product stream" being sold to an adjacent company for use in manufacturing amnonia,or alternatively, being used as a fuel for our powerhouse boiler. The hydrogen stream is vented to the atmosphere only during infrequent shutdown situations. PPG has performed additional tests since 1975 to insure the continuing effective operation of control equipment for both product quality control reasons and to assure ourselves that we will remain in compliance when the need to vent H2 arises. The method used for these "in-house" tests is not the method specified for official "compliance tests", but is a method which PPG feels gives substantially accurate results (a description of the method used is given in Attachment II-B). Because PPG's housekeeping practices include all those practices recommended by the EPA, we are making the assumption (per EPA regulations) that emissions from the Cell Room total 1300 grams Hg/day. This leaves 1000 grams Hg/day of allowable emissions from our End Box Fume System and the H2 system combined. The attached laboratory analysis (Attachment II-C) report and calculations dated 3/14/78 for the "Mercury Cell End Box Vent System for Mercury" Indicate that an assumption of 50 grams Hg/day for this system is reasonable. This leaves 950 grams Hg/day of allowable emissions from our H2 system alone. Results of tests performed on the inlet and exit of the Pura-Siv unit in 1980*given in Attachment II-D. [In the event hydrogen must be vented to the atmosphere upstream of the Pura-Siv unit (2408 grams Hg/day rate). Mercury Cell operating procedures require shutdown of the plant before the allowable mercury emission limit is exceeded.] Additionally, analysis of the H2 product after the HGR carbon bed is performed routinely five days per week for product quality control. These analyses verify that the 950 grams Hg/day emission, limit would not be exceeded should the H2 need to be vented1 at this location. The analysis results of this stream for the time period of 12/25/82 to 1/4/83 show a range of <0.4 grams Hg/day to 0.7 grams Hg/day Hg in hydrogen. SL 025793