Document RaxeeJYa6Lan9RY2K8NZX8QEa

VliB Qwwied Cowpaiy Lon uunv umko nor* Old Spanish Trafl, P O. Box 727 VMM Lewima 70649 Rnna (3W| 494>S140 April 10, 1990 jp Nr. fcustave Von Bodungen, Administrator Office of Air Quality Department of Environmental Quality Post Office Box 44096 Baton Rouge, Louisiana 70804 REcej v e d APR 1 2 90 Dear Nr. Von Bodungen: wttUAM l McClain Ve are requesting that your office approve a temporary change In location of emissions and a subsequent emissions reduction. The transfer Is being necessitated by the March 7 Final Rule, NESHAP, Benzene Emissions From Benzene Haste Operations, and March 28, 1989 Final Toxic Characteristic (TC) Rule. These rules will have profound Impact on Vista Chemical's Lake Charles Chemical Complex (LCCP) and compliance with them will require rapid and costly responses. Wastewater from our operations have historically been biologically treated In the LCCC wastewater treatment system. At times the Chemical Plant system taking wastewater from the VCN Plant and vice versa. The NPOES permit for the facility provides for switching flows back and forth to optimize treatment. For LCCC to achieve compliance with the NESHAP rule and the TC rule, Vista must promptly Implement several projects to modify our wastewater handling systems. As part of that project, Vista will change the service of Tank T-915 from No. 6 fuel oil storage to an NPDES wastewater surge tank. The tank will be modified to comply with the NESHAP standard for benzene waste operations practically two years before the March 7, 1992 deadline. The modifications will Include a floating roof and containment features. Attachment 1 contains the information needed to notify of the change In tank service. Vista will store wastewater that Is currently being treated in the Chemical Plant biological treatment system In Tank T-915. This water will then be. sent to the VCM Plant biological treatment system. This will decrease the fugitive emissions from the Chemical Plant system while Increasing the fugitive emissions from the VCM system. The emissions transferred to the VCM Plant will be significantly reduced when Vista constructs and operates the Steam Stripper/Dilution Steam System that will remove benzene and other hydrocarbons from wastewater going to T-915 and from other wastes. This will be done as part of the expansion and modification of the Ethylene Plant, Permit No. 052000003-01. Attachment 2 is a tentative schedule for reduction with the estimated emissions. Toluene Is the only other hydrocarbon with significant contributions. VEW-182U? Nr. Gustav* Von Bodungen Pag* 2 April 5, 1990 Since these fugitive emissions being transferred are not new emissions, Vista requests that the transfer be exempt from the permitting process and that Vista be allowed to commence the wastewater transfer by April 16, 1990. Your prompt attention and approval of this request will be appreciated. Should you require additional Information, please contact me at (318) 494-5439. Very truly yours. mbr bcc: JF PDC MGH CRD JCS ORB WLHcC VEV-182120 DESCRIPTION 1990 Wastewater Transfer Begins Ethylene Plant Turnaround Ethylene Plant Startup Steam Stripper Startup i*9i Normal Operation * ATTAOMEMT 2 ESTIMATED EMISSIONS FROM SENZENE UASTEMATEM OPERATIONS DURATION FLOW* ESTIMATED EMISSIONS (IBS) BZ TOL TOTAL 4/16-6/15 6/16-8/15 8/16-9/30 10/1-12/31 250 100 400 200 10,958 14 13,144 76 1,204 12,162 14** 1,445 14,588 55 131 1/1-12/31 200 303 219 522 *Flow consists of wastewater from Ethylene Plant and LAB Plant. **LAB contribution will not be reduced during ethylene turnaround. ASSUMPTIONS 1. All Benzene In LAB waste Is emitted. 2. All benzene and Toluene In the water Is emitted to the atmosphere after Installation of the steam stripper system (no accounting for bio-degradation which occurs). A YEW-182121 /fr77vcu r\Z*rr i- State of Louisiana Department of Environmental Quality auoevaouK* Qovomor PERMITTED FACILITY: PHYSICAL LOCATION: cum w tAK SERVICE NMSTA CHCmcM, Co. OlA ^p.AiW Tra'<\ PAUL TEMPLET Secretary __________________ KAUST CITY: contact rauoe: PT.cU<.l G. irWyt.3- NAILING ADDRESS: P.O. ballTD -y I JejS+UVi, L<A. TVBMte. nOCX."! DATE or UQOKST: April IP ___________________________________ XANK(S) CHANGE SERVICE Point Source 1*D. Htaber(s): T *1 - \ \S Description of Tuk(i): tie.& ow-r^k Control Device(a): Haterial(s) Currently Stored in Tenets): .Nona, prior "to__ beW KkiXOW or _________________ Material(s) To Be Stored in Tanfcts)s JPPE-S__ Uwfa LO<H^r Conditioa(s) Of Storage: NSPS Applicability: Nlo EMISSIONS BEFORE: O.Z3I ToWy**^ AFTER: O 9 DATE OF SERVICE CHANGE: +/\&f<>iO OTHER INFORMATION: Xrtta^nel roof _lyUlfcjA -To _ CoivM^Vy -ifl'rtU MCSHKP fitor -ha __ S*fVtC----------------- This is Co inform you that the above change of service has been approved under LAC 33:111.505.B. All current permits shall remain in effect. A Assistant Secratary cc Regional Office DATE Reviewer QEV-12122 OFFICE OF AIR QUALITY P.O. BOX 44096 BATON ROUGE. LOUISIANA 70804 AN EQUAL OPPORTUNITY EMPLOYER