Document e57y37YqqVm9jmGKE6bExXxnM

(conoco) Interoffice Communication To D. A. Kuhn - Houston From J. A. D^Beirnardi RECEi VEC r\ OCT 0 7978 ~ V'C Date October 113, 1978 Subject EVALUATt ON OF ALTERNATES AVAILABLE TO TEMPORARILY COMPLY WITH EPA-VCM EMISSION STANDARD A number of tempo :ar y alternatives appear to be available allow the VCM Pla it to comply with the EPA-VCM emission standard. This memo will briefly describe and evaluate these alternative to 1 Route Vents to Flare Stack No flare exi sts at the plant, so design, purchase and installation would be required, including rerouting of the vent sys tern piping and special care for installing instrumentat ion to operate safely. It is likely a corrosion re sistant compression system will be required to overcome line losses to the flare. Equipment design, procurement and installation will be time consuming. For instance we estimate lead time for delivery of the compressor w ould be 26-36 weeks. Moreover, hydrogen chloride is formed as a combustion product of the waste gas. We est imate 757 lbs./hr. of hydrogen chloride would be emi ttdd uncontrolled into the atmosphere from the flare. Route Vents to an Existing Boiler or Cracking Furnace The VCM Plant a oes not have fired boilers, however, cracking furnac es do exist. Extensive design modifications to the plant vent systems would be required to route vents to these furnaces. Since the furnaces are induced draft e ir type, they would require changes to assure there wc uld be sufficient oxygen for vent combustion. The elivery time on the air blowers and combustion con -t).rols necessary to do this is estimated to be 14-18 wee ks. Again, the hydrogen chloride formed on combusticn V'ould go uncontrolled to the atmosphere. Hydrogen chlor 4de is severely corrosive and may prematurely destroy the fur nace stacks and other equipment that it contacts. VVC 000012609 D. A. Kuhn Page 2 October 13, 1978 Secure a Portable Incinerator Our understc nding is that portable incinerators are not available fc r rent or purchase. They must be designed specifically for the job to be done. Even if they were available, ljydj|:ogen chloride would still be emitted uncontrolled. to the atmosphere. Route Plant Vents to an Existing Controlled Incinerator at Another liant Incinerators are available at the PPG Plant in Lake Charles. Th is plant is about three miles from ours, requiring tt e installation of a pipe line and compressor system to me ve the vents to PPG. Even if installing the pipe lir e compressor were feasible, PPG probably doesn't have spare incinerator capacity since, I believe they are ins tailing an additional incinerator to take care of thei r own VCM plant. Route Vents Through the Existing Oxy System Vent Control Devi ce Significant vent piping modifications would be required to route ver ts to the oxy system. In addition, compressors wi tih 26-36 weeks delivery time would be required to vent into the oxy system which operates at a pressure reater than any of the other venting process equi pment. Install Regenerable Carbon Bed Systems The length cf time necessary to design and procure a carbon bed system would make its completion too late to help. In addition, regeneration would be impossible unless a cortrol device was installed on the carbon bed regeneratior vent system, such as a flare or an incinera tor. Uncontrolled hydrogen chloride emissions would result from the: regeneration cycle vent burning system. VVC 000012610 D. A. Kuhn Page 3 October 16, 1978 Store Vents m a Large Pressure Tank and Ship by Tank Car or Tank Truck to a Disposal Site The length of time to design, procure and install a system would m.(ike completion too late to help. Equipment such as c ompressors (26-36 weeks delivery), refrigeration equipment (24-26 weeks delivery), instrumentation (14- 18 weeks delivery), piping and loading facilities wou Id be required. The overall conclus ion that must be reached in considering any of these altern ates is that time required to carefully evaluate and design any of the systems would be substantial Equipment required In all cases have long lead and delivery times. Installa-:io :i time would be substantial. Further more, in many of th ed options the uncontrolled liberation of hydrogen chloride p roduced by combustion would offset any benefit from the teinporary control. A. DeBernardi CC: REL-RDG-JD 0