Document bOaBB2OvyLOG1NRoDNEXZyQED

I Interoffice Communication To B. I. Raffle - Houston From M. G. Hayes - Westlake Date -September 22, 1981 Subject VCM EXPANSION - PSD The VCM Expansion has been delayed for an indeterminate period. The conversion of the oxy process, however, will proceed. The basic is how PSD permitting which has occurred will be affected. Attached a re permitting determinations by EPA and the State. 1. The non-applicab ility determination states construction must commence within 18 months of August 7, 1980. Does conversion of the oxy process constitute commencement of construction for expansion purposes? //FT <sy 2. What constitutes breaks in construction should oxy ^conversion be considered commencement for PSD purposes? What time frame should be considered? 3. If not, is there a mechanism by which the non-applicability determination may be extended? If so, for how long? 4. In light of questions 1-3, please address how VCM expansion emissions should be considered when addressing contemporaneous emissions for permitting other projects. In preparing a response, please address any other areas you feel pertinent. If you have questions, please let me know. M. G. Hayes mbr Enclosure cc + enc.: RTF JADeB GLF*0CL JOH isss \r UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION VI 1201 ELM STREET December 19, 1980 DALLAS, TEXAS 75270 i CERTIFIED MAIL - RETURN RECEIPT REQUESTED 1356796 Mr. J. A. DeBernardi Lake Charles VCM Plant Manager Conoco Chemical Company P. 0. Box 605 Westlake, Louisiana 70669 Dear Mr. DeBernardi: The application which you submitted on April 11, 1980, regarding the proposed modification of your VCM Plant located in Westlake, Calcasieu Parish, Louisiana, has been reviewed. The purpose of this letter is to inform you of the applica bility of Prevention of Significant Deterioration (PSD) regulations to your proposed facility. Based upon the information provided in your application and other correspondence,. a PSD permit is not required under 40 CFR 52.21 as amended August 7, 1980, for the modification of your chemical process plant (PSD-LA-315) since (1) the modification was not subject to 40 CFR 52.21 as in effect on June 19, 1978, or under the partial stay of regulations published-on February 5, 1980, and (2) your state preconstruction permit for the modification was obtained before August 7, 1980. This exemption from PSD review is contingent upon the following: (1) construction must be commenced within 18 months from August 7, 1980, or any earlier time, required under the State Implementation Plan, (2) construction must not be discontinued for a period of 18 months or more, and (3) construction must be completed within a reasonable time. Your proposed emissions must also comply with all applicable New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAPS), and Louisiana State Implernentati Plan (SIP) requirements. If you have any questions concerning this matter, please contact Mr. Tom Diggs at (214) 767-1594. Sincerely, Jack Divita. Chief Air Programs Branch cc: Gus Von Bodungen, Chief Air Quality Division P. 0. Box 44066 Baton Rouge, Louisiana 70804 SAL 0<>0065215 FRANK a. ASHBY, JR. SECRETARY department of natural resources OFFICE OF ENVIRONMENTAL AFFAIRS AIR QUALITY DIVISION September - 2 , 19.80 B. JIM PORTER ASSISTANT SECRETARY Conoco Chemical Company P. 0. Box 605 Westlake, Louisiana 70669 Re: Modification of VCM Plant Dear Sir: This is to confirm that your permit request for the above referenced project at Conoco Chemicals Co., Lake Charles has been approved by the Louisiana Environmental Control Commission. The submittal was approved on the basis of emissions reported and the approval in no way guarantees the design presented will be capable of controlling the emissions to types and quantities stated. scheme the Date: March 25, 1980 Permit No. 1424 The attached 2 synopsis sheets and 3 data sheets establish the emission operating limitations which condition this certifi cate of approval. A new application must be submitted if the reported emissions are exceeded after operation begins. The permit number cited above should be referenced in future correspondence regarding this subject. Sincerely BJP/AB/ebp b. Jim porter Assistant Secretary Office of Environmental Affairs P.O. BOX 60630 . NEW ORLEANS, LA. 70150 . PHONE 50 4 568-5 1 2 1 . 325 OLA AVENUE oo LOUISIANA ENVIRONMENTAL CONTROL COMMISSION AIR QUALITY DIVISION CONOCO CHEMICAL COMPANY LAKE CHARLES VCM PLANT Westlake (Calcasieu) This permit request by Conoco Chemicals Company, a Division of Conoco Inc., is for permission to modify, its existing vinyl chloride monomer pro duction facility" located at Westlake in Calcasieu Parish to expand its production capacity from 700 million pounds per year to one billion pounds per year on an annualized basis. The expansion will be accomplished by adding a parallel train to the VCM system and debottlenecking existing equipment. The technology will be based on a well proven system. Process emissions will be controlled by recovering hydrocarbon as much as practical and then by incineration to meet the NESHAP Standard of less than 10 ppm VCM in any vent gas. . Process incinerators will be controlled with wet scrubbers and the new heater will use LoN0x burners. Sulphur oxide emissions will be controlled by using fuel of less than 0.7% sulfur content. The debottlenecking techniques employed will result in hydrocarbon and CO being reduced by 4609 and 1768 tons per year respectively. Dispersion modeling supplied by the company indicates that ambient air quality standards will not be violated. Table I shows the effect of this plant expansion on emissions of the faci1ity as a who!e. NSPS does not'apply to this facility. Recommendations ----------------- -(See Approval) JHS/ys 00006S317 SAL- RECOMENRATION: CONOCO CHEMICAL COMPANY LAKE CHARLES VCM PLANT WestlaRe (Calcasieu) Approval provided the following conditions are met. % 1) The synopsis sheets and the attached data sheets establish the emission and operating limitations and are a part of the permit. The synopsis and data sheets are based on the application for approval of emissions dated February 5. 1980 with supplemental information submitted February 8, 1980 ` "The application and supplemental information are also considered part of this permit by reference. 2) Construction must'commence within two years after the date of approval. 5) The permittee will submit to the Technical Secretary semiannual reports of progress defining the status of construction, noting any design changes, modifications or alterations in the construction schedule which have or may have an effect upon the emission rates or ambient air quality levels. Such reports shall continue to be submitted until such time as construction is certified as being complete. 4) ' Any emission testing performed for purposes of demonstrating compliance with the limitations set forth in Condition 1 shall be conducted in accordance with the methods described and referenced in Table- 4 of the current Louisiana Air Control Commission Regulations 5) The permittee shall, within ISO days after certifying.the completion of construction prepare and submit to the Technical Secretary a report detailing the actual emission rates as compared to those limitations specified in Condition 1. Hie report shall also include, but not be limited to, malfunctions and upsets. SAL 000065218 O GLOUISIANA ENVIRONMENTAL CONTROL COM-! J SSI ON Air Quality Data Sheet Pape ] ___________CONOCO CHEMICAL COMPANY Westlake (Calcasieu) Location of plant: i 5 UTM 47?. q Km E ttan 5 Km N Description of location: y whies north; interserfinn of Trnecdatp Rnarl and Old Spanish Trail ___________ Estimated starting date of construction: April 1981 .1 Estimated date operation will begin: , November 1982 Type of Dispersion Calculations Used: CRSTER _______ ___ Pollutant NOx Time Period .Annual S02 .Ann/24/8 CO 8/1 Part Annual/24 EFFECTS OF AMBIENT AIR Calculated Maximum Ground Level Concentration 4 ug/M3 1/6/14 ug/M3 3/6 ug/M3 3/24 ug/M3 Louisiana Air Control Commission Standard 100 80/365/1300 10000/40,000 75/260 NEW 0R MODIFIED 0 EMISSION SOURCES Stack I.D. n IIA Description Cracking Furnace IIB Cracking Furnace IIC Cracking Furnace IV-J Dock EDC Tank IV-K Dock VCM Vent V-A Vent Incinerator Operating Rate (Maximum) 17607 CFM 17607 CFM 22375 CFM 6 CFM 316 CFM 28817 CFM VCM Plant (Type of Source) Operating Schedule Hrs/Day Days/Wk Wks/Yr 24" 7 49 24 7 49 24 7 48 24. 7 52 3 1 52 24 7 52 SAL 000065;219 1 ' LOUISIAN ENVIROfiMENTAL CCNfRiOL COMMISSION Air Quality Data Sheet - Page 2 -Conogo Chemical Company (Lake Charles VCM Plant.) (Cohipany1 s NameJ ' _______West-1aVe (Nearest Town) EMISSIONS ARE LISTED USING THE UNITS LBS/HR JZal casi_ii___ (Parxsh) PER MITT ED EM I S S I 0 N S' Feet F CFM TSP 1 S02 1 . 1.1 1 * ,1.1' NOv 12.9 12.9 IIC 0.2 0.2 CO 1.0 1.0 Height 120 Tempera ture Flow Rate 550 17607 120 550 17607 7.3 17.3 6.7 1.5 2.0 120 550 - - ..11.9. - 35 85 22375 6 IV- K -- - <0.1 - 148 75 . 316 V-A 21.6 0.6 35.7 3.7 ' 0.7 75 125 28817 1