Document oD05XKeyaY3k9YzoVp0Vy5ndE

ETHYL CORPORATION INTER-OFFICE To Mr. A. W. Helwig Address Richmond From Wallace F. Armstrong Subject- Project Requests Address Ethyl Tower Date June 26, 1978 The following project request papers are forwarded for handling by the Executive Committee at its meeting in Baton Rouge on July 10, 1978. H-3527 H-3549 H-3558 H-3851 H-3867 H-3947' H-3969^H-4037 ^C-2028. B-3252B-4002* B-4064M-2886 Improve Lead Hygiene, Part 2 C-20+ Alcohol Storage(ICD) Spare Electrical Feeder to Olefins Plant(ICD) Flow Switches on Lewis Pumps-TEL Increased Recovery of Chain Growth Steam High Purity Dodecene (ICD) Purchase T-80 Butene Trailer (ICD) Octene Storage (ICD) VC1 Emissions Reduction EPA, Part 5 Projects $25M and Less-PVC, Part 2(PD) Remove Acetylene From MeCl (ICD) Spare FCM Barrel-PVC (PD) Upgrade Boiler House Instrumentation ($M) Fixed Investment Planned By Substitution 25 620 76(ICD) 100 30 65 260 40(ICD) 817 250 50 150(ICD) 40(PD) 85 60 Total This Request($M) 25 696(Inc. W.C.) 100 30 65 260 40 817(Inc.W.C.) 250 50 150 40 150 2673 Substitutions: This Transmittal ($M) Previous Transmittals Dec. -July ($M) Total To Date ($M) % Allowable* 155 802.4 957.4 47.5% Allowable 1978 Year $3021.6M Ratable Dec. -July $2014.4M WFA:jm Attach. cc: Distribution EC ?49? FOR EXECUTIVE COMMITTEE ACTION AT MEETING OF JULY 11, 1978 ETHYL CORPORATION INTER-OFFICE June 22, 1978 To: From: Subject: Mr. R. Herzog Wallace F. Armstrong VCM Emission Reduction, EPA Project B-2028-5 cc: Executive Committee Mr. L. E. Blanchard, J: Mr. B. C. Gottwald Mr. F. D. Gottwald Mr. F. D. Gottwald, Jr, Mr. R. Herzog Mr. K. F. Cast Dr. W. E. Foster Mr. A. W. Helwig Mr. J. U. Jensen Mr. J. H. Kirby Mr. C. W. Montgomery Mr. R. A. Moser Dr. C. M. Neher Mr. D. E. Park Mr. W. C. Strader Mr. A. O. Wikman AUTHORIZATION REQUESTED Approval is requested for the attached Part 5 request of project B-2028, "VCM Emission Reduction-EPA". This request is for $250,000 and increases the total appropriations for B-2028 to $1,900,000. A Part 6 request, also on the order of $250,000 will be submitted in August and will complete the program as it is now understood. The program must be completed in accordance with regulations by October 21, 1978. BACKGROUND AND DISCUSSION On April 4, 1978, EPA denied Ethyl's waiver request involving use of a flare as a control device to eliminate VCM emissions. EPA stated in their letter that unless a plan was submitted to achieve compliance by October 21, 1978, Ethyl would be subject to appropriate legal remedies. At the May 9 Executive Committee meeting, we received approval to submit an alternate plan to EPA. The main parts of the alternate plan are: * Make process equipment and operating procedure changes in the PVC Area to improve the service factor of the existing incinerator and eliminate atmospheric venting of the incinerator feed gas.* * Eliminate flare burning of two process vents in the Hydrocarbon Area by incineration of these vents in an existing VCM furnace. The stack gas would be monitored to comply with the regulation. The inability to monitor flare emissions was the main point cited in EPA's denial of use of the flare. EC 2493 2- - * Revision of the VCM tank car loading procedure to eliminate venting of tank cars to the flare. At the May 9 meeting we also pointed out five other equivalency requests were pending with EPA. The alternate plan was submitted to EPA on May 19* 1978. Concerning the equivalency requests, EPA has approved one pending equivalency request and has denied the others. As a result of these denials, some additional expenditures will be required to achieve compliance. Finally, EPA is taking a very hard line on enforcement of the regulations with regard to emergency venting of VCM. Some further expenditures to reduce the frequency of emergency vents are required. As stated earlier, the final date to complete facilities to comply with the regulations is October 21, 1978. The items needed to achieve compliance that have not been funded are listed below: HC-9 Collection system, burner and analyzers to permit burning of vent gases in cracking furnaces and monitoring of stack emission PVC-14 Revise controls for monomer recovery system PVC-15 Oxygen analyzer PVC-I6 Barometric condenser revision FVC-17 Incinerator spare parts PVC-18 Head space analyzer PVC-19 Autoclave purge controls PVC-20 Broken batch stripping facilities PVC-21 Vacuum system revisions PVC-22 Emergency vent prevention This request provides funds for PVC-14, FVC-15, and PVC-18 which have been estimated to cost $155,000. It also provides $95,000 to be used to continue en gineering, order long delivery equipment, and start construction of the other parts of the project. The Part 6 request will be made after engineering estimates have been made to determine the costs of the remaining items. FC 2494 -3- The forecast for total project expenditure is now $2.2MM. This compares favorably with the forecast first made in January, 1977 which gave a range of project costs from $2.5 to $4. OMM. In our Part 4 request, we indicated that an incinerator-scrubber costing in excess of $1MM might have to be installed to comply with emission regulations and we planned to submit a request for funds for the incinerator on this project. We have postponed definitive design of the incinerator as we believe the present programs provide facilities needed to comply with existing regulations. However, an incinerator-scrubber will likely be required if new regulations limiting HCl discharges are promulgated. WFAjjm Wallace F. Armstrong EC 2495 kAbwu mt wwivuvti i i Lb avi iVfi ^ n a mwi imw jvl iW/ i / / v* Page! of 4 PROJECT REQUEST Ethyl Corporation 1. Division - Depsrtment Manufacturing X Tltto VCI Emissions Reduction - EPA S. Project Description 2. Location Baton Rouge, La. Problem No, 2028 Project No. B-2028 Date 6/14/78 Approp. Request No. 5 Projsct Accounting LoceSon Baton Rouge Pl<int 4. Primary Justification Pollution Abatement This Part 5 request for $250,000 is to provide additional facilities required to meet Environmental Protection Agency National Emissions Standards for Hazardous Air Pollutants Standard for Vinyl Chloride at the Baton Rouge plant. These facilities are required to provide means to operate the PVC plant without an atmospheric vent for the vinyl chloride recovery system. The existing atmospheric vent cannot be used after 10/21/78 Appropriations to date for the 4 previous parts have totaled $1,650,000. A Part 6 request will be submitted in August, 1978 to cover the remaining facilities needed to establish eampliaiice with EPA regulations. This request includes funds to start engineering, purchase long delivery items, and begin construction when necessary to meet the compliance deadline of items which will be included in the Part 6 requ st. - The primary justification for this project is pollution abatement. 6. Estimated Expenditures 8. Fixed Investment |1 b. Working Capital c. Operation* d. Other A. This Request . 250.000 B. Appropriated to Date C. Future Requests s 1.650r000 s Undefined* D. Total Project s Undefined* 7. Writeoff Total Project Expenditures Original Cost Depreciation Salvage Value $ 250,000 * 1,650,000 $ Undefined* s Undefined* Net Write-Off $ & Included in Capital Budget? Whet Year? No &Yes--J-^ 1978 Ref. No. If Substitution, give effect on return Amount $355,000** s 9. Patents $ s Project will be examined for patentable features. 10. Forecast Disbursements-Fixed Investment 11. Economic Summary-Based on Standard This Year 250.000 Calculation-IfAlternate!si Used, Attach Details This Request Subsequent years Fixed Investment s 250r000 Total 250.000_____ Other Expenditures Total Project S Undefined* Total $ 250,000 $ Undefined* 13. Class of l!stimate - This Request Speculative 14. Lease Commitments: Annual Amount Term After Tax Savings Or Income Psyout Period s s Yrs. Yr*. N ne Working Capital Requirements Total Capital Return on Total Capital Discounted Rate of Return $ $ 250.000 s %s Undefined* % %% Li 6. Remarks end Ultimate Effect | *Total project xpenditure is undefined at this time. Bas d on known scope, the total project cost is expected to be $2.2M . Compliance is required by October 21, 1978. ** $800M budgeted, $445M approved on Part 4, 5/8/78. EC 2496 ttc-------------------------------------------------------------------------------------- Problem No. VCI Emissions Reduction - EPA IfiT Explanation and Economic Justification This request for $250,000 will provide funds for the following; 2028 Pm2 of 4 Project No. B-2028 Request No. 5 PVC-14 - Install revised controls for the vinyl chloride recovery system. PVC-15 - Install a degasser stream oxygen analyzer system. PVC-18 - Install a new head space analyzer in the PVC plant quality control lab. Part 6 - Start engineering, purchasing, and initial construction of future items as required to meet EPA compliance. ECONOMICS; Justification is pollution abatement. This project is required to comply with EPA regulations. ENVIRONMENTAL AND ENERGY IMPACT; See attached sheet. CAPITOL PRO RATES TO DIVISIONS; Plastics Division: 100% 17. Tax Items: Qualifies for Pollution Syr. Writeoff CJyss ^No Qualifies for Tax Exemption Certif. ^ Yes TM No If Special Depreciation Allowance is Available, Describe: 18. Requests Approved By Division d[ Depq ^dnager j-------- cosponaor Sr. Vice President j Other Approvals i (Indicate Responsibility) w .r .Armstrong Chief Engineer or Division Engineer (Estimate and Sche^utoBespons(pity Manufacturing or Production Manager^ (IManutfactunring Rneeesppoonnssuibsiiliittyy)i , / W. c. Steder Asst .Gen.Mgr .Manj^actying Coepor-otAsst. DiivMfg.Tech-Senj D. E. Pork Cosponsor Cosponsor A. O. Wikm Division Economics Coordinator (Approval of Economics) y ^ T. A. Leeper Division Finance (Finance Review) ll .. t~ E. H. Rachal Cosponsor FC 2497 Page 3 of 4 Environmental and Energy Impact: Project PVC-14 will eliminate an existing atmospheric vent line that vents vinyl chloride gas (recovered monomer) to the atmosphere when the incinerator is shut down or overloaded. Project PVC-15 is expected to avoid conditions (air leakage into recovered monomer) that lead to incinerator overloading. These combined projects are expected to allow the monomer recovery system to operate with no vents to the atmosphere, except for those which occur through safety relief valves. The quantitive amount of vinyl chloride that presently vents to the atmosphere through the existing vent line is not accurately known; however, a significant decrease in atmospheric emissions should result from the projects. The net electrical energy requirement for the facilities covered by this request is 8.5 M KWhr per year. FC 2498 Page 4 of 4 PROJECT ESTIMATE Exhibit D J b No. 20281 Title: VCI Emission Reduction - EPA Appropriations 1, 2, 3, 4 This Part 5 Request N w Investment PVC-14 Monomer Controls PVC-15 Oxygen Analyzer PVC-18 Head Space Analyzer $78,000 42.000 30.000 Engineering, purchasing, and initial constiuction of future items 95,000 Sub-total $245,000 Scope Definition Contingency 5,000 Sub-total Investment Total* $250,000 Dote of Estimate 5/31/78 Estimate No. 2231 K Class of EstimoteSpecu lative Total Project $1,650,000 250,000 $1,900,000 * Investment Total: Based on 0) Start of Engineering in progress (ii) Start of Construction 2/15/28- (iii) Mechanical Completion by 1Q/2T/7R Included in Engineering Department Quarterly Forecast dated 3/16/7R Not included in last Engineering Department Quarterly Forecast but estimated net effect is: ET-154 B/5/77 Approved Director - Cost Engineeri ministration Date 7t FC 2499