Document Yr1gNjYkwz1KVDMB6p57rwEzE

MORANDUM r. J- M. DeVoe RECEIVED fa JAN 1 7 1974 uiGAi qeel date January 15, 1^7 M- SUBJECT: REVISED AIR COMPLIANCE SCHEDULE - NON HYDROCARBON The attached subject schedule is for your review and approval. This revision includes the recommendations made by Mr. G. Von Bodungen of the Louisiana Mr Control Commission at the meeting reported to you in our memorandum dated November id, ]`)71. F Pr /RMT:e f At taoh. cc: Mr. E. n. Janes Mr. J . M. Oui nn w. J. E. Bow ler Mr. T. D. Kent Mr. n V_ * R. Walbridge a , *i ` F. B. Cornell, Manager Baton Rouge North Works i' (?)- PTO IN U.5.A- ASI-pR 0004090 DRAFT Industrial Chemicals Division allied chemical corporation P.O. Bo* 271. Baton Rouge. Louisiana 70821 (504) 356-3341 y - Mr. CTohn E. Trygg Technical Secretary Louisiana Air Control Conmission P. 0. Box 60630 New Orleans, Louisiana 70160 Dear Mr. Trygg: The attached is a revised Compliance Schedule which we believe will satisfy deficiencies reviewed with Messrs. Von Bodungen, Ledet and Lassalgne. We plan to subnit an updated Emission Inventory within the first quarter of 1974. Mo great changes are expected in the previously reported emissions. Very truly yours. FPT/RMT:ef Attach. P. B. Cornell, Manager Baton Rouge North Works , }' y >, 4H' + ^ ASI-PR 0004091 BATON ROUGE NORTH WORKS INDUSTRIAL CHEMICALS DIVISION ALLIED CHEMICAL CORPORATION REVISED AIR COMPLIANCE SCHEDULE JANUARY 197 4 GENERAL One of the principle products at this location is soda ash (sodium carbonate). The production of this product involves the following operations: calcining, conveying, grinding, screening, packing and loading. The effect from these operations creates a fugitive particulate {dust) condition, and our compliance schedule for abatement puts heavy emphasis on bag, dust collection systems. The Works' testing program has been primarily for dust fallout within Its battery limits. The reason for this measurement is due to the relatively large and dense particles which agglomerate in a humid atmosphere and fall as fugitive dust within the perimeter of the Works. Relative to State ambient standards, it is believed that fugitive particulate (dust) falls out much nearer the source than can be predicated by dispersion calculations. There is also a question on the value of dispersion calcula tions considering the multiple sources involved in an industrial complex. The dispersion calculations should incorporate valid point source data, accountability for all variables (meteorology) and computer programs appli cable to the problem. The above technique and expertise were not available at this location so that no dispersion calculations were made on fugitive dust Dust fallout data over the last year indicate the soda ash fugitive dusts settle out and meet the State ambient standard in a distance of less than a quarter of a mile from the source and, in general, within the boundaries of our plant. Limestone dust settles at a much faster rate. (Limestone is a major raw material used in the soda ash process). Attached for reference to this revised compliance schedule is the schedule submitted on August 23, 1972. EMISSION STANDARDS Section 18.0 - Smoke Control 1) General burning of natural gas as fuel for power generation, calcining soda ash and cracking is in compliance. These operations use natural gas which rarely produces smoke. 2) Emission of smoke from vertical kilns during intermittent charging operations is in compliance. Charging of each kiln with limestone and coke seldom exceeds Ringelmann 1. ASI-PR 0004092 -2- 3) Smoke generated in decoking of furnace tubes in the vinyl chloride monomer operation is not in compliance. a. The furnace rubes are heated and blown with air and steam twice per month for 18 hours each time. During the initial stage of this operation Ringelmann 1 is exceeded for a period of 1S-20 minutes. After the initial period during intermittent spalling with air, the smoke does not exceed Ringelmann 1 for more than four minutes in sixty consecutive minutes. b. The decoking procedure is a shutdown and start-up operation and on this basis we are asking the commission to approve compliance status under exemption 18.4 and/or 18.G.2 based on the limited amount of srroKe being emitted in an unpopulated area of the plant. i 4) The brine well storage system for Ethane and Ethylene near Plaquemine, Louisiana is in compliance. a. Pressure release venting for repair of lines, etc., does not cause smoke to exceed Ringelmann 1 more than an aggregate time of six hours in any ten consecutive days. The location for this operation is in an unpopulated oil field area. 5) Smoke emission from Test Burning of Standby Fuel Oil for power generation is in compliance. a. The standby fuel oil facilities are tested periodically for readiness in event of a natural gas outage. The smoke emitted during the changeover from gas to oil will be controlled within the limit of four minutes in any sixty consecutive minutes. 6) Flaring of gases from the Dichloroethane (EDO) and vinyl chloride operation is in compliance. a. Smoke emission from flaring during this operation does not exceed Ringelmann 1 more than an aggregate time of six hours in any ten consecutive days. It should be noted here that this flaring will be reduced when the hydrocarbon compliance plan submitted October 10, 1973 and further clarified by lett r dated January 7, 1974, is Implemented. 7) Smoke emissions from T.ead Melting Furnace is in compliance. a. The lead recovery process used for rebuilding diaphragm cells involves some organic matter which burns off in the lead melting furnace. The smoke generated during this operation will be controlled so that a Ringelmann 1 will not be exceeded for more than four minutes in sixty consecutive minutes. ASI-PR 0004093 Section 19.0 - Particulate Control l) Soda ash loading operations into ships and barges are considered to be in compliance on the basis of our fallout sampling over the past year. These fugitive dusts are covered further below under part III Ambient Air Standards. 2) Salt drying, conveying and loading operations are in compliance. Process weight Emission allowed Stack tests on wet scrubber 25,000 lbs/hr. 22 Ibs/hr. 18 lbs/hr. 3) Decoking of furnace tubes in the vinyl chloride monomer operation are in compliance. Process weight Emission allowed Calculated emissions 20,000 Ibs.-Oir. 10 ]bs/hr. 6 Ibs/lir. The furnace tubes are healed twice net' month for 18 hours. During this time the tubes are blown wicn air and steam for one to two minutes every thirty minutes. Estimate 200 Lbs. carbon is half burned and blown out during each IP-hour period. 4) Lime slakers producing milk of lime are in compliance. Process weight Particulate emissions allowed Estimated emissions 1,650 tons dry lime + 5500 tons water per day 62 lbs/hr. None visible (steam) 5) Vertical lime kilns during Limestone charging operations are considered to be in compliance on basis of our fallout sampling over the past year. These fugitive dusts are covered further, below under part III, Ambient Air Standards. A$I~pr 0004094 T"7 y ** Mt .>9 6) Other sources of particulate Fugitive dust and their respective compliance schedules were designated as Flans 1-4 and were submitted to the Air Control Commission on August 23, 1972 (see attached). Following is a review of emission data in these plans. Plan 1 - Design and install new dust collecting systems on lime kilns discharges and conveyors. Process weight 1650 tons/day Particulate omissions allowed 47 lbs/hour ^ , Estimated emissions 260 lbs/hour Expected emissions after installation of' planned equipment - 30 lbs/hour PI an 2 - Purchase and install three improved bag dust collector systems to replace present ones in Nos- 1, 3 and 4 elevator towers in soda ash section. Process weight Particulate emissions allowed Estimated emissions 0600 tons/day 61 lbs/hour 600 lbs/hour Expected emissions after installation of planned eguipment - 55 lbs/hour Plan 3 - Purchase and replace four bag dust systems in dense ash operating systems. Process weight Particulate emission allowed Estimated emissions 1800 tons/day 48 lbs/hour 300 lbs/hour Expected emissions after installation of planned eguipment - 30 lbs/hour Plan 4 - Design and install dust collecting systems on soda ash loadings into trucks and rail cars. Process weight (Light A s h) 1 oa d i ng 35 tons/hour Particulate emissions a11 owed 42 lbs/hour Estimated emissions 175 Ibs/hour Design criteria to be satisfied 30 lbs/hour ASI-PR 0004095 Process weight (Dense Ash) loading Particulate emissions allowed Estimated emissions Design criteria to be satisfied 70 tons/hour 47 lbs/hour 88 lbs/hour 3S lbs/hour Section 20.0 - Incinerator Standards Question 1 through 4 under incinerator compliance schedule guidelines are not applicable. We are in compliance because we use our refuse as land fill and do no open burning. Section 21.0 - Fuel Burning Equipment Standards ' We are in compliance because clean natural gas is used as fuel. Section A22.0 - Volatile Organic Compound Control This section is covered by our Hydrocarbon Compliance Schedule submitted on October 10, 1973 and further clarified by letter dated January 7, 1974. Section 24.0 - Sulfur Dioxide Control Sulfur dioxide from combustion of natural gas at the Baton Rouge North Works is in compliance. Natural gas contains less than 1 ppm sulfur. The resulting combustion products are witnin state standards at the property lines. Section 2S.0 - Carbon ISonozide Control Carbon monoxide from vertical kiln operations is in compliance based on being an existing operation and being classified as a priority III region. We have no new sources of carbon monoxide. Section 2h.O - Nitric Acid Industry Standards Not applicable industry. ITT. AMBIENT AIR -STANDARDS Section 9.0 ~ Suspended Particulate Level Control and Section 10.0 - bustfall Level Control In reference to both of the above sections, as previously indicated, our problem area is fugitive dust. These fugitive dusts, soda ash and limestone, are relatively large, heavy particulate which settle rapidly after becoming airborne. Our dust fallout data indicates compliance and implementation of our compliance plans Nos. 1 through 4 should Further improve particulates to the atmosphere. ASI-PR 0004096 -6- Examples of soda ash and lime dust sources and their effects on dust fall at the property lines are as follows: 1) The soda ash loading operation into ships and barges is located on the east bank of the Mississippi River and several precautions are taken to minimize dusting. The loading spout is maintained near the bottom of the vessels' holds to prevent a high freefall of the ash. The holds' covers are kept as closed as possible, and plastic sheeting is used on holds in some areas to minimize escape of dust. With these precautions, the dust fallout along the river from this operation compare with the state's ambient standard as follows: North Property Line = 5.8 tons soda ash/square mile/30 days South Property Line = 13.8 " " "" Ambient Standard = 20.0 tons dust/square mile/30 days 2) Fugitive dusts are created by intermittent charging of limestone and coke into the vertical kilns. Much handling by belt conveyors and proportioning and feeding equipment is involved. Wetting of the coke and stone at critical points is practical to minimize dusting. Most of these particulates settle quickly, and the average fallout along the property lines compare with the state's criteria as follows: Average along property lines - 8.3 tons limestone/sq. mile/30 days Ambient Standard = 20.0 tons dust/sq. mile/30 days Section 11.0 - Outdoor burning Standards Section 12.0 - Sulfur Dioxide Level Control Section 13.0 - Carbon Monoxide Level Control Section 16.0 - Nitrogen Oxide Level Control These above parameters (Sections 11.0, 12.0, 13.0 and 16.0) are in compliance or are not applicable as reported under Part II, Emission Standards. Section 14.0 - Hydrocarbon Level Control Section 15.0 - Oxidant Level Control These sections are covered by our Hydrocarbon Compliance Schedul submitted on October 10, 1973. A supplemental schedule covering Sections 14.0 and 15.0 will be submitted based on Federal approval of state regulations, as per guideline instructions and further clarified by letter dated January 7, 1974. IV. INCREMENTS OF PROGRESS Increments of progress are given in the attachment of the original compliance schedule submitted dated August 23, 1972. Periodic progress reports will be made to the Technical Secretary on the status of BRNW compliance schedule at six month intervals. ASI-PR 0004097