Document NGqDd6XR5e6LmRQYm3mxoqNRQ

UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS P. O. SOX 471, TEXAS CITY, TEXAS 77590 February 25, 1977 F/l. Mr. Gary Bernath Air Compliance Branch U. S, Environmental Protection Agency First International Bank Building 1201 Elm Street Dallas, TX 75270 Dear Mr, Bernath: Subject: VCM Standard. Destruction of VCM Vapors in a Flare At the conference on the VCM Standard conducted at your location last November 19th, we brought up the question of the use of a flare to incinerate vapor streams of VCM under certain temporary or emergency situations. Our notes indicate that your major concern would be whether or not the flare could actually burn all the VCM adequately to meet a 10 ppm emission limit. The burden of proof would be on those of us who might petition for an equivalency to use this method, if we could dem nstrate that sufficiently complete combustion could occur in a particular flare system. Since residence time and temperature are among the major variables in flare flame effectiveness, we had inquired whether pilot data on a test stand flare (which could be properly monitored) would be c asi de red in preparing such an equivalency request* We recall that Mr. Farenthold bad indicated a willingness to consider such a presentati n, since he was aware of the problems of monitoring emissions from an operating flare in die field. The major purpose for our desire to use a flare for burning VCM-containing gas streams is to provide a way to prevent the overloading and upsetting of process systems, boilers, furnaces or incinerators when diverting normally abated streams into them shquld be a disturbance occur in a primary abate ment device. For example, when a boiler or furnace is the primary abatement device for a VCM-containing stream and it incurs a process upset which results in a shutdown, an alternate boiler or furnace is generally available for picking up this stream. However, the new furnace normally requires a manual cut-back before the new stream can be added in, to avoid over-ranging the controls and possibly knocking the new boiler off the line. The time period ucc 052328 Mr. Gary Bernath February 25, 1977 Page 2 .1 between the loss of the first boiler and the pick-up by the second is wh r a flare can be used at great advantage to burn the emissions until the new boiler can be lined out at the new condition. The nature of a flare is to accommodate variable flows of gases for rela tively short periods of time and without prior notice or adjustment, until the processes causing the VCM stream change can be better stabiliz d without direct air emissions on an emergency basis. This "elasticity" provided by a flare improves the options in maintaining safe, low emission operation, thus preventing larger VCM losses to the air that might result if there were no flare to go to. Because of the versatility and improved emission control that we believe could be achieved if a flare were permissable under certain conditions, we have arranged through our Engineering, RfcD and Operations Departments to conduct a series of tests with a company of demonstrated flare expertise to determine, if possible, the effectiveness of a flare for this purpos . If these tests are favorable, we will consult with your staff on the submission of a request for equivalency to cover operations at this location, using the test work as a basis for our request. \S, F. Erdmann\/ Environmental Protection Coordinator bcc: * Mr. W. D. Bradbury - 511 Mr. H. P. Brady Mr. W. E. Burndrett - 519 Mr. S. W. Clark - 511 Mr. M. E. Eisenhour Mr. R. L. Frantz Mr. W. T. Gray, Jr. Mr. R. A. Herrington Mr. J. B. Leverton/R. E. O'Bryan Mr. D, C. Macauley - 511 Mr. W. R. Manning - 511 Mr. W. A. Mazzolini Mr. R". P. Melton Mr, F. S. Provenzano Mr. G. F. Tacquard Mr. R. N. Wheeler - 514 ftj y j 7$fa* . ! ucc 052329 VO UNION CARBIDE INTERNAL C RRESfONDINCC .r \ ,, i .s* , CHEMICALS AND PLASTICS p. o. box, 83i, south Charleston, west Virginia 25303 To (Nomo) Division location ' & Texas City copy io Mr. W. 0. Bradbury Mr. W. E. Burndrett Mr. S. W. Clark Mr. M. E. Elsenhour\ Mr. W. T. Gray, Jr. x Mr. D. C. Macauley ' Dim Originating Dtpt. Subnet February 11, 1977 Eng IneerIng Vinyl Chloride Flare Testing Dear Hal: I ' I have discussed..with Bill Bradbury and Stan Clark your proposal for flare testing at National Air Oil for disposal of vinyl chloride vent streams. We have agreed to accept the charges, up to a maximum of $10,000, on our Engineering Managerls budgets. Please charge each of the following engine ring order numbers with one-third of the charges: 938XX - 2301 - Solvent Vinyl Resins 938XX - 230A - Suspension Vinyl Resins 938XX - 2525 - Ethyleneamines Thanks. Sincerely, ucc 052330