Document daazXq8Rq0k3yjk4bzMz0o2B6

VCM Plnnt May 16, 1978 r* ' - Tv'' 'v <<T -,)jjr.^f&'***%T^JNkw Conoco Chomicnls Contincnial Oil Company P.O. Box GO5 Wcstiako. Louisiana 70669 ___ , . , -- r--. 1310 491-521 1 R E C b. 1 V E U >1AY 2 2 1S73 Don R. Goodwin, Direaltor Emission Standards ard En gineering Division United States Environmen tal Protection Agency Office of Air Quality PI inning and Standards Research Triangle Par MC 27711 Dear Mr. Goodwin: Attached is the proce ss /ent information for the ethylene dichloride faci1ities at the CO 0C0 VCM Plane in Lake Charles. Louisiana. This information is in respc nse to your letter of April IP, 1978 to Dr. David A Kuhn, Director of Bi dinedhcal and Environmental Affairs for Continental Oil Company. The information on cc ntrbl devices and atmospheric vents is based on present operation. After the installation of a vent gas incinerator for compliance with EPA vinyl chlori de amission standards, all the vents identified in the attached listing will be incinerated except for the oxychlorination vent (2a). This vent wil1 continue to pass through the vent scrubber, C-500, to the atmosphere. If the attached infov mation is not sufficient to meet your requirements, we will try to supply ar y abditional information. is Enc CC + enc: DAK / BCC: REL-JEC-CRH-JD GL-F-PLF-JOG-JN vve 000012619 INFORMATION ON ETHYLENE DICHLORIDE UNIT CONOCO VCM PLANT, WESTLAKE, LOUISIANA Answers to EPA Questi )ns: 1) See Figure I for .1 process block flow diagram. 2 & 3) Gas Stream Information Stream la - Direct Chlorination Vent Process Cause: V ?nts inert gases introduced with incoming chlorine a|id ethylene from system. Flow: Approx. Composition: 10 ,000 SCFH (778 lbs./hr.) 4.^ % H2 (Mole %) 14.& % O2 12.8 % N2 1.1 % CO 16.3 % CO2 15.1 % CH4 3.3 % C2H4 0.8 % C2H6 0.01% Ethyl Chloride 0.02% Vinyl Chloride 1.7 % Ethylene Dichloride Temperature: 2(tF Reported flow rat 2 is, based on typically observed flow indication. Composition is ba ;ed on average GC analysis. This vent also contains small quantities )f Cl2 and HC1 (not routinely analyzed). Stream 2a - Qxychlorination Unit Vent Process Cause: ants, nitrogen and other inert gases introduced with ir ir produced by side reactions. Flow: 10,565 Ft.VMin. at Vent Conditions (44,750 lbs./hr.) Composition: lb./hr. Carbon Monoxide Carbon Dioxide 434 895 Hydrochloric Acid 59.8 Chlorine 7.3 Ethylene Dichloride 414 VCM 13.63 C2H4 117 Methane 42 Ethane 5 Ethyl Chloride 489 Miscellaneous Hydrocarbons 46 Nitrogen and Ox/gen 42,227 Temperature: lOC'OF 000012680 c Page 2 Reported flow rat e is based on material balance calculations, Compositions are based on routine GC and wet chemistry analyses as reported in Plan'; '$ Louisiana Air Control Commission Emission Inventory Questionnaire. Stream 3 - EDC Wt. shing System Vent Process Cause: Vent s inert gases liberated in washing process Flow: 9.9 Ft.3/f in. at vent conditions (54 lbs./hr.) Composition: 1b./hr. Carbon Monoxide .17 Carbon Dioxide 28.64 Ethylene Dichldride 4.54 VCM .47 c2H4 Methane .16 .91 Ethane .17 Ethyl Chloride 1.06 Nitrogen & Oxygen 17.88 Temperature: 12(IF Reported flow rate i s based on engineering calculations. Compositions are based on spec ial GC and wet chemistry analyses for Plant's Louisiana Air Control Comm ssi on Emission Inventory Questionnaire. Stream 4a - EDC I'uri fication Vent Process Cause: Vent s light hydrocarbons from purification system which dann ot be condensed in overhead water cooled exchangers Flow: (1) Composition: (1 Temperature: 130F (1) Purification ve nts are not routinely analyzed, and have not been analyzed for em ission reports. Likewise vent flow rate is not routinely calculated or m easured. This stream is included in C-500 vent. Stream 5 - EDC Stora qe Vent Process Cause: Urea thing losses from storage tanks due to inventory chan ges or ambient temperature increases. VVC 000012691 Page 3 Flow: 21.13 Ft.3/|Min Composition: Hydrochloric Aci Ethylene Dichioi+ide VCM Methane Ethyl Chloride Mitroqen at vent conditions (103 lbs./hr.) 1b./hr. .26 7.89 .74 .04 4.49 89.58 Temperature: Ambient Reported flow rate is based on engineering calculations. Compositions are based on specal SC and wet chemistry analyses for Plant's Louisiana Air Control Commitsio n Emission Inventory Questionnaire. Stream lb, 2b, aw: 4b - C-500 Vent Combined vent to the atmosphere. Flow: 11,076 Ft.f/Mi . at vent conditions (48,700 lbs./hr.) Composition: lb./hr. Carbon Monoxide 530 Carbon Dioxide 1040 Hydrochloric Acid 59.8 Chlorine 7.3 Ethylene Dichloihide 414 VCM 94 Ethyl Chloride 621 c2h4 208 Methane 144 Ethane 15.7 Ethylene 208 Miscellaneous Ili'dro carbons 119 Oxygen & Nitroge 45,448 Temperature: 100F Reported flow rate is based on engineering calculations. Compositions are based on rout ne GC and wet chemistry analyses as reported in Plant's Louisiana Air Control Commission Emission Inventory Questionnaire. 4) Nominal operating ca pjacity of the CONOCO VCM Plant ethylene dichloride facility is 1,100 MM Ibs./yr. 5) Control Devices C-500 Vent Scrubber: Control device is designed for HC1 removal and consists of a column with overhead water sprays. VVC 000012682 Page 4 6) Wastewater and Organic Waste Streams Wastewater - The ma jori wastewater sources are the water produced in the oxychlorination re ction and water from the EDO washing system. These streams are combin c>d and fed to the steam stripper as indicated in the block flow diagram (Fig. I) to remove ethylene dichloride and other volatile organics, Total flow from the stripper is about 75 gnm with an EDO content of 100 ppm or less. Cooling tower blowdown is used as the scrubbing medium in the C-500 vent scrubber. This adds 225 gpm of wastewater flow to effluent water treatment. Organic Waste Stre m - About 12 MM lbs./yr. of heavy ends are separated in the distillation se ction of the ethylene dichloride process. This material is transp dirte d to the Chemicals Division of PPG Industries, Inc. for further processsi ng and incineration. The heavy ends mainly consist of chlorinated C2 hyd roca rbons plus carbon and salt solids. The material is not routinely aria 1 y zed for volatile content. vvc oooca*63 WC 000012684 FIGURE I BLOCK FLOW DIAGRAM ETHYLENE DICHLORIDE PROCESS CONOCO VCM PLANT, LAKE CHARLES, LA. HCI from Vinyl Chloride Section VCM Plont CERTIFIED MAIL 4316086 RETURN RECEIPT REQUESTED May 9, 1978 ec^'v 0 Conoco Chemicals Contins-ntol Oil Company P.O. Box 605 Westlake, Louisiana 70669 (3181 491-521 1 Mr. Howard G. Bergmah Director, Enforcement D vision Region VI, Environmeita Protection Agency Fir'it International 3ui cl i ng 1201 Elm Street Dallas, TX 75270 Dear Mr. Bergman: The purpose of this let er is to inform you of a labor problem in the Lake Charles, Louisiana area which has halted construction work on the Continental Oil Company - VCM Plant vent gas incinerator project. I v/as in contact with Mr. Mar tin Brittain of your staff by phone on May 8, 1978 related to this problem As you are aware, trie C dntinental Oil Company - VCM Plant located in Westlake, Louisiana is presently p perating under a waiver of compliance from certain requirements of the nati onal hazardous emission standard for vinyl chloride (40 CFR Part 61 , Subpart F) granted by your office on July 5, 1977. The key to our final compliance with the national hazardous emission standard for vinyl chloride requires installation of a thermal incineration system to thermally decompose all plant vent streams with the exception of the oxychlorination system vent The incineration system is presently in construction On May 1, 1978 const rue tion work in the Lake Charles area was shut down due to a strike by Teams terb Local #969 against the Association of General Contractors. Contracts be tlwee the Building Trades Council and the Association of General Contractors exprired at mid-night April 30, 1978. Negotiations between the Association of Qenel~ al Contractors and the Teamsters broke off on April 28, 1978 without a settl erne it being reached leading to the Teamsters strike and the stoppage of construe tio work in the area until a settlement is reached. Therefore, work on Contir enit a 1 *s incinerator project has been halted by the strike since area contract rs working on the project are unable to man the job as a result of Teamster ick ating. This situation is entirely outside the control of Continental Oi1 Qomp^i ny since the labor dispute is not against Continental, but against the are co itractors being used on the incinerator construction project. Continentc 1 Oii l Company has not been, nor will they be, included in any of 'the bargainir 9 t iking place between the Association of General Contractor and the Bui 1ding Tr des Counci 1. UVC 0000 I've-'' l-.jy lJ, 15/A The not f feet or thi projects S'' ! < rb f o t Chloride !'f ;/'.k r; Lii-v e October 1, i070- I w number tr; days Aia<: < settle. r",'t berreeri th 1 here fore v I am re'p.'C rike will result in the delay of our compliance n a i. iono i i:a xn j ,(\c>us cmi s c ;Oi; s!. n nan r<! i or v i ny 1 1 raj v.'.jivcr da to ior completion cm construction of a iticipui.'' that this delay wi 11 amount fo the scum TO f':: I j L v/or: ppapo lsi'C3 i.c roue "(;a't n Vs! maters and Lhe Association of Go;iora 1 Contractors. j Lt.e I o 1 i O'. vi ncj: 1 . AM 'i r srhodHle cv:;'vl oti on of on-site construction Oct,or oor'.7. t in your letter of only h , 1077 he extended by the smye rrsbev o: days that t.h:: par-scut worl; scopnato lasts, with exesLi A: ! of those comoliarea daces which we have ali' xady ) oported as being complete. 2. The date of 1977 compli October 71 work stopp. x'l comp1 iui.ee and the date on vtiich the duly 5, :? v/aivci' terminates be extended beyond cue 72 date by the same mss,her of days that the present 1nsts. I will continue to keep your office informed related to the work stoppage, Once a soft 1 or wot is ro shod I will be able to inform you of the exact number of days extension J elm t squest'i ng. Sincerely, y J. A. DeBernardi is CC: James FA Coervcr Technical Secretary, LA(tC l>. 0. Sox 60-570 Hew Orleans, LA 701130 BCC: REL-JEC-CRH-JD-GLF-PLif'-jdG-JN 0oooiz69b yVC