Document Ne2vzqy5LnZ8G1EeR13vprE7Q

* /s / . / ZERO DISCHARGE ENVIRONMENTAL STUDY - CHEMICALS LAKE CHARLES 1. Decision was made in 1983 to launch Phase I Engineering study of ZD at Lake Charles. 2. Definition was made for BPT and BAT projects and what regulatory problems these would address/solve leaving only the ZD and SPCC portions. Post BAT water needing reduced to zero was 6,000 GPM. 3. ZD Project was split into 25 tasks and full time process engineers and estimators were assigned. 4. By September, 1985, Phase I Engineering progress was at 80.5% average completed. All estimates were completed for 8 of the 25 tasks. ALL ZD PROJECT WORK WAS SUSPENDED AND PUT ON THE SHELF DUE TO ECONOMIC FACTORS CONFRONTING CHEMICALS. 5. Twenty-four thousand two-hundred (24,200) man hours had been expended at that point or $225M for Process Team Members only working at Lake Charles. 6. Total engineering expenditures were around $1,500,000. The capital costs estimated in 1985 dollars for the 8 tasks completed was $83MM. This was beyond BAT and NPDES. The Total Task for ZD alone was probably $200MM. 7. The SPCC portion of the study was scoped and estimated completely. Three packages were assembled for Plants A, B, C. The 1984 dollar costs were approximately $14MM. Mean while Louisiana passed a Spill Control Act and Lake Charles began to implement all of those portions of SPCC that were required by law or that were Best Management Judgment (dik ing, etc.). 8. NO FURTHER WORK DONE TOWARDS COMPLETION. There was not a firm technology base in all cases of ZD process design. Some of the ZD processes involved exotic, unproven technolo gy yet to be proven, i.e., reverse osmosis, etc. SL 106259 ZERO DISCHARGE ENGINEERING STUDY - CHEMICALS NATRIUM 1. Conceived by V. A. Sarni in 1978 in response to a blue-sky "goal" (not regulation) of the San Muskie's Clean Water Act of eliminating process pollutants from water discharges. In fact the permits issued are NPDES (National Pollution Dis charge Elimination System). 2. Decided to see what this meant to one of our totally inte grated Chlor-Alkali plants with power producing capabili ties. Natrium chosen. 3. On March 27, 1979, ZD Engineering project was organized in Central Engineering as high priority item with full time process, mechanical, and cost estimating people assigned. 4. ZD goal defined to reduce polluted water discharges to zero. Any water coming in contact with the process would be treated/recycled/revised and to spend the money for other projects only once. (See definitions attached) 5. Phase I - $6Q0M - Conceptualization Engineering Phase II - $1,108M - Scope Engineering - 8 projects 6. Would include BMP, BPT, BAT, ZD, SPCC and regulatory dead lines--ten Task Groups. 7. Total cost for Natrium ZD estimated at $57.5MM in 1981 dollars (would now be near $100MM). This includes all regulatory areas previous to ZD attainment leaving $28MM as pure ZD costs to go the final step. Estimates were ACT grade. 8. As a matter of fact, some "Immediate Action and Maintenance" and SPCC items have been completed. We are just now doing some of the BAT items, since the Organic Guidelines have been eleven years in the making at EPA, i.e., we still do not have a steam stripper for chlorobenzene removal from discharge waters. 9. ZD program presented to Business Managers, Operations, Environmental Affairs and Central Engineering February 18, 1982 . Conclusion: All future ACTS after 11/1/83 would include an assessment of practicality of going to ZD and must state how the equipment installed now impacts and is directed towards ZD. Only those items being driven by regulations or common sense operating philosophy would be done now unless costs for ZD were feasible. SL 106260 ZERO DISCHARGE The scope of zero discharge as applied to PPG chemicals operations includes the following practices: 1. No process contaminated water will be discharge outside the plant boundaries. a. Process waters are waters that come into direct contact with process r.aw, intermediate or product materials. b. Process waters also include: 1. Cooling tower and boiler blowdown 2. Barometric condenser discharge 3. Runoff from process pads* 4. Once through heat exchanger cooling water at a lower pressure than the process 2. Storm runoff outside of process areas and higher pressure heat exchanger cooling waters are not process water. 3. SPCC controls will be established as necessary to prevent the discharge of spills and leaks outside of plant boundaries. ^System to be designed to contain a 24 hour, 25 year rain with pumps sized to a 15 minute, 25 year rain intensity rate. Reference is made to EPA 40CFR, Section 415,23 for a definition of Zero Discharge as applied by EPA to BAT for the aluminum sulfate industry. (Alterations to this criteria may be necessary to develop a practical engineering design.) (This is the only variance from the Natrium Zero Discharge Plant, which was designed for a steady rain fall rate of h" per hour, continously.) SL 106261 LI/1/83 Zero Discharge Policy It is the objective of PPG Industries, Inc., to ac h i e v e the goal of the Clean Water Act by eliminating the discharge of po llut ants into navigable waters or into groundwaters. PPG will assign pr ior i ties to those process streams which discharge toxic pollutants and w ill empha size the achievement of the goal through process modifications to r ecyc 1 e, re duce, or eliminate pollutants where practical rather than by supplementa1 control technology. Such analysis should recognize and avoid the probl em of merely shifting pollutants from one medium to another. All Authorizations for Capital Transaction request s to cons truct new, or modify existing, process units shall include an ass essment of the practicability of the elimination, recycling or reduct ion of process water discharges as well as a cost-benefit assessment of ava ilable treatment technologies. SL 106262 SL 106263 RUSSELL C. VANDENBERG Vice President Water Systems Engineers RESOURCES CONSERVATION CO. 3101 N E. Northup Way Tlx 350166 RCCSEA Bellevue, Washington 98004 (206) 828-2400 JOE BOSTJANCIC Regional Sales Manager Water Systems Engineers RESOURCES CONSERVATION CO. 3101 NE Northup Way Tlx. 350166 RCCSEA Bellevue, Washington 98004 (206) 828-2460 SL 106264