Document oeXN4reybyR23J7ExrRVRZ2qE

AR226-2292 ' ' Chris E Shoop 10/17/200210:07 -":::'::;^^;N%^^i;%i:-'; AM____________________ To: Robert LRitchey/CUDuPontQDuPont CK Oscar T Gaiza/ABDuPont@DuPonl, Ta-Wei Fu/SBDuPont@DuPont, Fred M Lentz/SE/DuPont@DuPont, Kari G Kronberg/AE/DuPon@DuPont,Debbie J Mulrooney/AE/DuPont@DuPont, Robert I Wevodau/SE/DuPont@DuPonl Subject Explanation ol Input Data far Modeling Studies Bob. Per your request and in preparation for discussions with the Ohio EPA, please see the following descripflon of the development of the emission numbers used in the modeling studies for 2002 and 2003. The attached Excel workbook has date for the years 2001,2002, and 2003. We used a separate sheet to summarize the. emission point data for Mulrooney. 1 can provide that one as'well If you wish, but the one attached contains all the assumptions and adjustments. The emissions data for 2001 and for 2002 through July is based on the C-8 mass balance sheet we use for reporting air emissions to the WV DEP. The data for the remainder of 2002 and for 2003 is based on projections Karl and I obtained from the two area schedulers. The monthly numbers are shown just below the main calculaHon tables. Note the Fine Powder production is broken out into PP-1, -2, and -3 figures. The emissions for Fine Powder in 2002 are based on use of the original (primary) scrubber from January through April and use of the new Deep-bed scrubber from May through July. The projection for the remainder of the year also based on uss of the Deep-bed scrubber. The C-8 mass balance calculations provide a single emissions number and do not provide for allocafon of emissions to the respective vents. I distributed the emissions stated from mat catoulafion (2001 and 2002 January though July) as follows. First, 1presumed the efficiency of the Fine Powder primary scrubber to be 50% which is consistent with the test results from February 2002 and Zfpfel's earlier data. We used 95% as the efficiency for the Deep-bed scrubber. Though the August 13 test data indicates the Deep-bed scrubber efficiency is higher, the pound per hour emission rates is not that different so we chose to be conservative here. Second, Kari and I assigned an efficiency to PFA, based on test data and or internal studies conducted in the 2001 to early 2002 time frame Finally, I assumed that all three FEP scrubbers had the same efficiency, which probably is not quite true, and used the Excel "Goal Seek" function to "fit" the efficiency to meet the total reported emissions. Please see the "fitted" efficiencies cited on the sheet for each year. Note that emissions from Granular are not recovered, so they are calculated directly and are not part of the "fitting" process. For the projections in 2002 remainder and for 2003,1 applied the following conversion from production date to emissions estimate. The production number is multiplied by the QPU for 0-8 concentration (Ib C-8 per Ib dry product). This value is adjusted for the split of C-8 to the polymer versus water in the coagulators (and other water separatton devices). The is also adjusted based on the expected efficiency of the control devise for the emitting vent. The QPLFs, fractions to dryer, and efficiencies are shown in the main table. The fraction to dryer values are consistent with the assumpfcns we have used for the earlier modeling studies and were the best available at the time we assembled the table. The efficiencies were also stated at the values we felt were being and can be achieved, for copoly as well as for Fine Powder. For the pending application for FEP. Karl has applied a fraction to dryer of 0.35 after discussion with Ta-Wei. He has also stated the efficiencies of the scrubbers to be 87.5% which results in the emission rates being unchanged from those stated in the attached sheets- DJM001141 EID641220 After several discussions vwth Ta-Wei and Trini, we have reached the understanding that Ihe mass balance calculations we are using for the reporting, and the modeling study, tend to over-estimate the actual emissions. The impact of this on the modeling study is that much of the over-esBmated emissions are forced to the shorter copoly stacks which causes higher modeled emissions at the closer receptors. We believe the efficiencies of the copoly scrubbers are actually at or close to 90%. But the conservative nature of the mass balance calculation makes it difficult to show this. The planned preliminarytesting at FEP to be conducted later this month will be valuable for our reassurance that we can achieve the emission rates described in the prelections. Chris Shoop Stack Emissions Project DJM001142 EID641221 Currant Permlt/Appllcatlon/PDF # 815D (FP/D Scrubber) 815D(FP/DDeep8ed) 1353A Granular L2) Pre-ExistIng (Granular L1) 614A (FEP L1) 614A (FEP L2) 1953 (FEP L3) 2365A (PFA) 2001 Actual Emissions Ib/yr1 11058,0 0,0 2._6 5,'5 4238.0 4112.3 2300.7 4296.0 26005.0 "Fitted Efficiencies" 0.5 0,95 0.477614 0.477614 0.477614 0.5 Currant Parmlt/Appllcatlon/PDF # 8150 (FP/D Scrubber) S15D(FP/D Deep Bed) 1353A Granular L2) Pre-ExIstIng (Granular LI) 614A (FEP L1) 614A(FEPL2) 1953 (FEP L3) 23S5A (PFA) 2002 YTD Actual Emissions Ib/yr1 3851.9 358,1 1,7 3.3 1247.8 1799,1 697,8 2644,3 200Z Projected Production Ib/yr1 Qpu Fraction to Dryer 3,511,560 (See note 1)g . Scrubber Efficiency Projected Calculated Emissions Ib/yr Total Calculated Emissions 10599.0 Production Projections; FP-1 PP-2 FP-3 1711967 914827.5 884765 0.002S 0.003S 0.0045 0,92 0,92 0.92 0.98 0.95 0.95 196.8762 147,2872 183,1464 3937.524 "Pitted Efficien 0.6522 0.6522 0.6522 0 FEP lines 1/2 FEP line 3 PFA process K Aug-02 747 11 230 Sep-02 583 120 143 Oct-02 877 170 219 Nov-02 934 14 219 Dec-02 End 2002 861 4002 0 315 206 1017 Current Permlt/Appllcatlon/PDF # 815D(FP/D Scrubber) 816D (FP/D Deep Bed) 1353AQranularL2) Pre-ExistIng (Granular LI) 814A(FEPL1) S14A (F6P 1.2) 1953 (FEP L3) 2365A (PFA) 2003 Production |b/yr1 QPU Fraction to Dryer 9,631,432 (Seenotsl); Scrubber Efficiency Calculated Emissions Ib/yr 1446.2975 33.0 79,0 1,573.0 788,5 151,8 1,260,8 3330.37 Production Projections: FP-1 pp.2 FP-3 4695544 2509104 2426784 0,0025 0.0035 0,0045 0.92 0,92 0,92 0.95 0.95 0,95 539.9876 403.9657 502.3443