Document X7wMdqaDM0rE0vXZO41aLknRG

Allied. Chemical MEMORAN b u date; May 9, 1977 SUBJECT: VCM IN BRNW OHC VENT to: A. S. Robertson, Director ICD, Engineering Dept., AB-G cc: R. P- Troeger W. L. Epting D. L. Magee With reference to your earlier request for clarification of the questions raised by J. L. Cost of Air products & Chemicals in regard to (1) the feasibility of feeding the vent from the VCM vent recovery system to the OHC reactor and (2) present VCM content of the BRNW OHC vent, the following comments are pertinent: 1. I spoke with J. L. cost and found that his concern was primarily whether VCM fed to OHC from the VCM vent recovery system would indeed be destroyed or would simply pass through unreacted. 1 assured him that the quantity of VCM found in the OHC vent was dictated largely Hv an equilibrium reaction and was essen tially independent of VCM fed to the ohC reactor, which largely converted to~~l.^i'-Lcliloroethane and eliminated as vacuum column bottom's. Thus, the concept'o'f feeding vent streams containing VCM to the OHC reactor is a sound method of disposal. Note that our patent application on this process has now been filed. 2. With respect to the present VCM content of the BRNW OHC vent, I spoke with D- L. Magee and he indicated that preliminary results with an on-stream analyzer are in the range of 60-70 ppm v/v with occasional excursions to about 90 ppm. It' as DLM's recollection that the allowable upper limit based on the EPA emission standard of 0.2 g vCM/kg EDC produced was some thing in excess of 100 ppm. This information was passed on to J- L- cost- - -k.-ao i-y - In order to verify the VCM concentration corresponding to the EPA emission standard. Dr. Amato has calculated this figure from recent BRNW operating data. The results are presented in the accompanying memorandum and range from 64 to 83 ppm. If correct, this implies that the BRNW OHC reactor is running essentially at the allowable limit for VCM emissions, a somewhat disturbing finding ~ot which i drd not inform Air Products. I suggest that this finding be passed on to the BRNW Environmental Group for their comments * original aioned BEKipts Attachment C-639(1-781 B. E. Kurtz, Engineering Research Syracuse Technical Center ASI 00006214 Allied Chemical MEMORANDUM date: 3JECT: to: May 5, 1977 CONVERSION OF THE EPA EMISSION FACTOR FOR OHC VENTS INTO A PPM VALUE USING SPECIFICS OF THE BRNW OHC UNIT B- E. Kurtz The Federal Register for Thursday, October 21, 1976, Part II, with the title "Environmental Protection Agency -- National Emission Standards for Hazardous Air Pollutants", lists the emission factor for OHC vents as 0.2 g VCM/kg EDC produced. In order to convert this figure to a ppm value pertinent to the BRNW OHC unit, data on vent rates and EDC production rates are needed. The following table lists this data together with the ppm values representing the limiting emission factor of 0.2 g VCM/kg EDC produced for three months of^Toduction in 1977. /[ \A three-month average of the above data yields a figure Sacf 76 ppm VCM as the maximum allowable VCM concentration in the vent Al WSArpts Attachment ljuy. i. (U& Wayne'S. Amato Syracuse Technical Center C-3*(1-75) ASI 00006215 -LyL 4 itfu I Month of 1977 No. of Days of Production Vent Flow for No. of Days of Production--lb moles EDC Produced in No. of Days of Production -- lbs ppm Value in Oxy Vent Which Corresponds to MaxAllowable Emission Factor Of 0.2 g VCM/kg EDC January February March April 15.3 0 28.5 26 3.00(105) - 7.18(105) 7.06(10 5) 6.039(10) - 1.85 (lO7) 1.64 (107) 64 - 83 74 r ASI 00006216