Document NezJ2zj4KdXmLno97EK8m3z3V

MEMORANDUM TO: Mr. C. R. Walbridge DATE October 22, 1971 ^ - , -J SUBJECT: LOUISIANA AIR CONTROL COMMISSION ')*n. Attached we are submitting for your review an inquiry from the Air Control Commission along with our LJ proposed answer. We are enclosing a copy of the final revision of the "Regulations of the Air Control Commission" booklet. *1 Please advise your approval and/or recommendations. " FPT :ew Attach. cc: Mr. P. N. Shellenberger Mr. 0. J. Parr Mr. R. E. Mumford --------------- --------------------- _________ P. B. Cornell, Manager Lf Baton Rouge North Works > T ,,__ -TT""? WSa ___ JDK. UCV 37 19V) toju jll dAbJ ^rJ^> /<a ^ C-639 16-63) (f). tTD. IN U.S.A. )V^u. ASI-PR 0004206 DRAFT 10/22/71 Industrial Chemicals Division ALLIED CHEMICAL CORPORATION P.O. Box 271, Baton Rouge, Louisiana 70821 (504) 356-3341 Mr. Gus Von Bodungen, P.E. Louisiana Air Control Commission Louisiana State Office Building New Orleans, Louisiana 701.60 Dear Mr. Von Bodungen: We acknowledge your inspection report d of the Baton Rouge North Works by Mr. Ledet and yourself andN^he requesr for a more specific schedule for improvement with p Specific plant areas referred to in your we recognize. As you know, the soda ash operation is very old, and until recently, phasing out of the operation was a definite possibility. \For this reason, maintenance and attention on the soda ash operation wasj^limited '-Hrcr-a^TTcTnlmyggl However, the business picture has since changed and production rates are being increased. As a result of this improved economic picture, the maintenance program has been expanded to upgrade equipment for increased production. Concurrent with this program, emphasis is being placed on improved dust control. It must be recognized that our soda ash product is essentially a dust and very difficult to contain in various stages of manufacturing. Improvements in dust control have been made over the years and such improvements will continue in the future. A monthly sampling program was started on September 1 and covers twenty-five air sample stations strategically located throughout the plant. This program is a continuation and expansion of the one started last spring, but temporarily discontinued due to federal deadlines on water effluents required to meet the Corps of Engineer's application for permits on July 1 and October 1, 1971. The monthly program will provide sufficient laboratory data to develop an air profile of our plant. The profile will establish and identify problem areas where an improvement plan can be implemented. ASI-PR 0004207 -2- Chlorine odors in various parts of the plant associated with short range operational problems have been detected from time to time; however, we know of no specific reason for such odors at the time of your inspection. Further testing will be required to pinpoint the problem. In order to establish a specific time table for further improvements in varous areas, we feel our sampling program will help identify the problems so that appropriate corrective plans can be made. Please be assured of our continued cooperation and we expect to communicate with you in the near future relative to our program. Very truly yours FPT/RMT:ew P. B. Cornell, Manager Baton Rouge North Works ASI-PR 0004208 -JUREW HEDMEG, M.O., CR WJ. T. HACKETT, VICE CHAIRMAN CHARLES J. PASQUA H. F. M. GARRETT, M.D. AN DAVE L, PEARCE LEE CASTAGNOS, JR. EVERETT JACOB JOHN E. TRYGG.TECHNICAL SECRET* LOUISIANA AIR CONTROL COMMISSION Louisiana State Office Building P.0. Box 60630 NEW ORLEANS 70160 August 9, 1971 Mr. P. B. Cornell, Manager Baton Rouge North Works Industrial Chemicals Div, Allied Chemical Corporation P. 0. Box 271 Baton Rouge, Louisiana 70821 Dear Mr. Corne11: An Inspection was performed on the Allied Chemical Corporation North Works at Baton Rouge, Louisiana on Monday, March I, 1971 by Mr. Henry Ledet and the writer. Excerpts from the inspection report are attached. We appreciate the courtesy and cooperation extended by Mr. A. J. LaVine during our visit. We recognize the fact that Allied Chemical has an air control program at this plant. As described in the excerpts of the inspection report and Item 6 D of your revised Emission Inventory Questionnaire a number of im provements have no definite time schedule listed. We recognize that Allied Chemical is striving to solve the air control problems at the North Works. We request that you provide us with a more specific schedule for the improvements and that you provide us with progress reports of your efforts. Very truly yours. Assistant Chief, Air Control Section Louisiana State Department of Health GVBijad Enc. cc: Mr. Henry Ledet, S. E. Regional Office East Baton Rouge Parish Health Unit RECEIVED BATON ROUGE N^PTH WORKS AUG 11 71 2* Summary A summary of this Inspection Indicates that the overall maintenance In the soda ash and caustic plants Is not as good as other Allied facilities and even other processes at this location. There are numerous dust emissions from soda ash handling and the lime kilns. As mentioned earlier in this report this area is the old part of the plant. Allied was just getting active in sampling at this plant and Mr. Sylvest advised he was expanding their measurements of suspended particulate and dust fall. There are considerable chlorinated hydro carbons being emitted from the VCM plant. Allied has a plan to reduce these but no definite time was stated for installation. I noticed chlorine odors In various areas of the plant, more so than the average well maintained chlorine-caustic plant. I don't know the concentrations Involved. On subsequent visits, I plan to concentrate more on the chlorine proc ss. There is a program of improvement of this plant. Some of the Items have definite completion target dates, others are general (next 5 years). We should evaluate their program and strive for definite dates In some of the nebulous areas. li ASI-PR 0004210 EXCERPTS OF INSPECTION PERFORMED ON MONDAY, MARCH I, 1971 ALLIED CHEMICAL CORPORATION NORTH WORKS BATON ROUGE. LOUISIANA Soda Ash The primary sources of visible emissions are various process areas In the Soda Ash Plant. Allied manufacturers soda ash by the Solvay process. In this process the raw materials are limestone, coke, ammonia and brine. This parti cular installation is very old (1935). Our visit occured a week or two after the Enjay explosion. Some of the broken windows and damaged corrugated metal were a result of the explosion. Some of the run down condition of the struc tures was obviously older than that. Dust is emitted from the four lime kiln stacks, from various transfer points in conveyor systems for the soda ash, the carbonating column and the light ash dryers. There was evidence of numerous dust spills in the soda ash conveyor systems. It is hard to say how much of the dust gets off the Allied property. Allied has enough suspended particulate in the air that they can not meet our Regulations. In addition their emissions are obviously in excess of our emission standards. We were informed by Mr. LaVine that numerous im provements are scheduled or presently in process. The degree of improvement remains to be seen. Chlorine - Caustic Allied manufacturers chlorine by the electrolytic process. Allied has an old cell room and a newer installation. Allied uses the Hooker diaphragm cell for production of chlorine and caustic. Hydrogen from the old plant is v nted. Hydrogen from the newer plant is cooled and used as boiler fuel or is used in the vinyl chloride monomer plant. The chlorine cells In the new plant use lead for electrical contact. The lead is recovered from depleted cells by melting. Allied also has a tinning furnace for tinning copper bars. No data was avail able on emissions from these furnaces. In the Hooker cell chlorine caustic process the caustic obtained is weaker than the desired shipping concentration of 50# NaOH. The weak liquor is con centrated by a triple effect evaporator. At the present time chlorine residues from the chlorine gas cooling tow r condensate are collected In the sewer system and neutralized with soda ash in a pond near the river. Mr. LaVine stated that a chlorine stripper would be in stalled for this chlorine but no specific schedule was provided. Vinyl Chloride Monomer Plant Vinyl chloride monomer is manufactured by cracking ethylene dlchlorlde. The ethylene dichloride is manufactured by direct chlorination of ethylen . The ethylene is supplied by Allied's Gelsmar plant. There are various Chlorinated hydrocarbons vented from this plant. Mr. LaVine stated that these emissions would be reduced by condensing some of the vapors. There was no specific sch dule mentioned for this activity. ASI-PR 0004211