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George E: Hopkins Tq APh! C^c<7t V1S1A Da,c /,7 ' />>^// U . /nj2^/.7S- sz^L/ 7$r ^' 7'*^'7y j7f-~ -^z- ^/y1 ;r>I 1 i> plec,<? nett's ' I c/l' cc ffAC, frLA^GSUj^Pi, 1>C } J`u|>'"- ULU G>U> > ) v?r, tD iW'^ tiii'-c c-c > f $ o - ; t, ? Sc/?; S(/C. PlP TO: R.A. Conrad tv FROM: R.D. Hillman, S.V. Corkran, and G. e. Bacon (PED) fassil/y *4U &^ e* -f to ;<vhjz^_ re*\ja*j Jor >-<<Ley*\lr\e / yEc-i>^0 -M/CJmt. of <a . /V4 'frpc.'j o* /IQ r f A&Mt v cn aZZa*-** A*<2v- .ZZ tm*ZyZUzS- DATE: May 22, 1987 SUBJECT: Heavy End- Disposition White Paper /"testSty r*'/%>. /,* Attached are the results and recommendations from trhw study mdc to examine -hhn prnpaugW options for the disposition of P/>z the heavy ends material produced at the VCM Plant as a by-product in the manufacture of EDC and VCM. Several fDo-Ui W ,'6r options were examined with the majority of the time spent examining options which involved sending the heavy ends to PPG, as is currently done, sending the heavy ends to BFG in La Porte, Texas, and the use of the VCM Plant incinerators to burn the heavy ends. The results of this study indicate that the most desirable solution to the heavy ends disposition problem would be the option of continuing to-send about one-half of the material to PPG and to ncgotiat a contract with B.F. Goodrich in La Porte in which BFG would agree to take the remaining material or use as feedstock for their CATOXID Unit. This solution (with a# NPV of *92-98M relative to the current practice), would be more economical than &&JT'"the current practice jr**/;** 1 jmi'pu to PPGJ? or permitting and revising the VCM Plant i4* incinerators to burn the heavy ends (with an NPV of -fl71--380M relative to the current practice). /"*/<-/ r\ 1 pAis n.ryo,n<^y is Whi * <* ihc ^ffrvpricLt<. ^ Toh+ is /o0\pvHtirion would provide Vista with two disposition options t,J\ere. wh-i le-nuL a1 possible affect on trfre stream factors -erf*r There would be no increase in the risk of possibly increased regulation or enforcement measures applied to the incinerators which could result if the number of incinerator bypasses and stack excedances, which could be increased by burning.heavy ends, increases sufficiently to draw action by regulatory actions. SCO * *<.3 c.t A decisioni must be made'1 to determine^which of.Jbhe options discussed in the attached document ohdut 1 d- be Boon T5 i s |j> jl Li mUrb due to the existing deadlines which waui'U apply to the permitting process^of the incinerators. A complete permit application asubmitted by August 1987 to ensure that the complete permitting process can be completed by November 8, 1938. Even now the timing is such that it would be difficult to complete the time consuming and expensive permitting process in time to meet the exist ing deadline which was imposed by Congress. If the permit ting process is not completed (permit in hand) by the November 8, 1988 deadline, Vista would lose interim status and would have to cease burning heavy ends until the permit is approved. An alternate disposition option would then be required for the interim period. CWH 000008377 Please review the attached document and initiate the appropriate steps which are required to have the disposition decision made in the required time frame, questions, please contact us. If you have any Richard D. Hillman Process Engineer Sandra V. Corkran Process Engineer cc s PEM,GEH,WPS,MLA,SCR,PLF,HLH,MGH,ERT WLM,JCL fGWB,CRM,JDZ Graham W.Bacon PED Engineer CUH 00000837a HeAVY_END3_DISPQSITXgN_OPIIQNr SUMMARY A studv was made to examine disposition of the heavy ends by-product in the manufacture several proposed options to provide for the material orodu.ced at the VCM Plant as a of EDC and VCM. The objective was to deter mine whether the VCM Plant incinerators should be permitted to burn the heavy ends, which would be classified as a hazardous waste material. This decision is required at this time since currently the VCM PI ant^iaT ''-Urr'* ntf^, interim status for burning hazardous waste in the incinerators but in order to retain approval to do so a complete RCRA Part 2 permit applica tion, along with a test burn plan should be submitted by August 8, 1987. This is the expected latest date that would allow sufficient time to complete the permitting process bv i:he November' 8, 1968 oeadline set by Congress in the RCRA Amendments of 1984. If this deadline is not met, then Vista would lose the option of burnlno heavy ends in the VCM Plant incinerators until a complete reappiication could oe submitted and ap proved- An J ternace disposition option would have co be utilized during this interim period since Vista would have to cease ournina heavy ends once the interim status^ i$ lest- The following options were examined CUH 000008379 Option 1 - Continue to send the heavy ends to FFG without a signed con tract, possibly negotiating for a lower cost and a signed contract in the future. Option 2 -- Obtain a contract: with B. F. Goodrich to have them process the heavy ends material in their La Porte CATOXID Unit to recover the chlorine as HC1 which is fed to their Oxychlorination Unit to produce EDC while generating high pressure steam. Option 3 - Obtain a contractual agreement with B. F. Goodrich and approval from PPG which would allow Vista to send approximately the same amount of heavy ends to both plants. This would provide two disposition options thereby making Vista less dependent upon one industry tor the disposition of heavy ends, would allow for price negotiations with PPG, and would likely result in cost savings for Vista. Option 4 Permit the VCM Plant i nt.i Heritors to burn heavy ends and perform the required revisions to allow for this operation. op tion b Permit and construct a new hazardous waste incinerator to burn heavy ends at the VCM Plant. Option a -- Laciimercifll incineration or all heavy ends by par t i ci pat i on .in a take-or--pav arrangement with a company such as Chemical Waste Management or Gulf Coast Waste Disposal Authority. Option 7 - Negotiate an arrangement with Georgia Gulf in developing a pro cess similar to the CATOXID Process of B. F. Goodrich, possibly building such a process unit at or near the VCM PLant. The results o f this =u:udy indicate that the best option would be Ootion 3: Continue to send heavy ends material to PPG while negotiating a contract with B. F. Goodrich and then to split the shipments of heavy ends material between the two companies. This would provide two disposition options and would allow tor -future price negotiations. It should also provide for ar annual savings of about *3014 relative to the current cost of sending all oi the material to PPG. This option would also provide a minimum ot two tc three years in wnich other options, such as the Georgia Gulf process, coulc be examined or developed. There is also a choice to be made concerrunq the mode of transportatior utilised for transporting the heavy ends to the BFG Plant in La Porte. The NPV (relative to the PPG option) for both rail transportation and truckinc by Vista Transportation are about *90M. Mo capital revisions would proba bly be required for the truckina option whiie the revisions required at the VCM FI ant to allow for railcar loading of heavy ends, includinq loading rack r^lNpions (minor/ ana the required secondarv^coijtainment would cost about TMer ijym-Tu: f-yrlur however, sfu-?ui d--b-e, 'Che risK ^ of l serioLts^exposurt? incident vfn ish would be at t wie utecK--ter rai 1 shipments m tho ht'uvy onciu. igildli --rn--the use of truck's. This factor shoul d `ffiore thar sufficient to warrant tue use of rail transportation for this material. 000008380 yjuU ik'.i Currently Vista sends all of its heavy ends to PPG -where some of the ma terial is recovered in one of their solvent processes and the remaining material is incinerated. There is no signed contract and future environ mental regulations or changes in the solvent market could result in PPG refusing to accept the Heavy Ends upon a sixty--day notificatian. fSWy-ent 1 V this would leave Vista with no other disposition option except forcial mcioeracion which has an estimated *4-7 million annual cost. commer- Cur rent, i y V i sta pavs about *o.3.v, o00 annually to send about 11.4 million pounds of Heavy Ends to PPG. This material is shipped by truck and each shipment must bo shipped under a hazardous waste manifest and can be re fused far various reasons, (such as difficulty unloading due^high solids content). Each of these refusals necessitates state and 1 fodia^eri X X sn G X o i: n C c> 2: c c 01 Xc CI l Hoi *r crj Cl X *n --p -- X Za ? u: x c; >- z ^3 u. ^ o Li cr c h-- 4'. u *T Z ~ c XO X01 ,cv ci \ La A 4fl 0 z c C'l jJ K -- M- 3 l 1-- -`if ' 1- X --0 _j c3 2^ <2 x -- ^ h- Q 21 w ~ C' ^ 21 mKt---t uJ 'X 0 > x-- X, T X T. 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X x on c Ox xtil mX i- ~ to u oc cu Ll o UI _! zxg C XX Ui -> x e x i- x <r ozo zoz M O Z 1- O - Cl --IX crn* X X c c cmnm X1- u' CL a >-- cn G G 1- Z C rL ;O1* 0i. GI 1--1 cn X > >- h- --O wX G Z--r 01 tn 1--1 0 u -- Cl r? 1 to 0 cn T* X > > GX22 13 Z a X ii 11 ccnn 1! C3 C2 CD 0 II X X X X z CD h4 II X X X G z X tn II X M G cn z II 0 O as X CJ X X 0 jj X II t- II 01 X Ui X X z M U z M4 X z CJ X X li 0 1! z Q z X z1--1 X X u 2 X Cd 11 X UJ 0 cn X X cn X i| 1! II > > Q 1: G > > c XX ** z XX G 2 X G _1 31 *2 II X X > X m CJ G II X X X G X II X X CD II e 0 c G li z 21 3 X Z 22 5 II X X X u X 0 X ll tn tn tn X z u CD II II II 5M II c 1 to *r 111 0 c. X X X CJ X X X 0 X X D> X G X X X * CUH 0000083B1 notification in wmch the reason -For done to corr^c1: the problem. re+usai is Given along with what was e x ^ T3 / +Hm y-y It should be noted that the ac^w.1 cost of heavy enas to Vista, including the raw material value, pr cfogMing costs, and the disposition costs is currently about 3 1. vMM/year . M*ms indicate s di rect i onal 1 y the best use of capital eMpendi turss would be i v-red-- -i-n reduce the amount of ends produced. U> heavy ADVANTAGES 1. No need tor permitting nr^jnndi f icat i on-s--t^e--t-h-e--UCJ3 P .1 a inci ner'atars, 2. No potent i a l/uft-f-yect on the stream factor of the VCM Plan or the i nci nerators. ~ ---------------------------------------------- C :Jj:i )A ke } ?{?& 3. hio capital modi 11 cat i ans rcjquirea. DISADVANTAGES . nisk of having to resor t to commercial incineration or other option upon sixty-day no t i -r i. ca 11 on by PPG or refusal or heavy ends due to changes in eiv.her environmental regulations or solvent market cond i 1.1 ons>. ex* i/c$ /*%rv*c(* r 2. Vista would 'jit ill be dependent upon another company*f or the J disposition of heavy ends. 3. Cost - Visca nays about 3383,000 per year for sending heavy ends to PPG. 4. j-isaw ones rent to FF6 must be treated as hanarrJaus waste and each shipment, must be manifested arid is suo j&ct to all haz ardous waste shipping requlations. 5. No recovery of the raw material or energy value of the heavy enas by Vista. CWH 000008382 Option 2 _ " *3 ,,_i- .. wOODKCH^CAT(jX.!r D^PKQCcaa B. F. f oodt i c h lias developed a (.AT OX I L> froresa which uses a f ! u i d i so catalytic oea r^act-jr to oxidize <::h ] on nated hydrocarbon teen streams to HC1 , writyr, and nitrogen oxides wm cn are then red to their air--based Gx vch i. cm i na 11 on reactors to bo u.seu in tne production of EDC. Tney have a CATOXID IJn t l: in operation at their" La Porte, Texas facility and have pre sentee vista with a terms proposal in which they would agree to accept up to 12 million pounds of heavy ends per year tor a charge of 325 per tan. This would provide? --or Lhdisposition producea annua-iv at the VCM FI ant. at the currsnv. l. :L - 4 an 11 ion pounds Since the heavy ones material would tnen be class! tied as a feedstock, and not as a hazarac-us waste, the shipment ot heavy ends would he under a bill of lading instead ot having to manifest it., as is currently cone on ship ments to PPG. Approval has been received from the Louisiana Department of Environmental Quality and the Texas Water Commission for this interpreta tion of applicaole reaulations. Two truckloads of pling and testing CATOXID Process. of the heavy ends heavy ends were sent to the La Forte facility -tor sam for compatibility with their other feedstocks and the They reported no difficulties in unloading and blending material. The estimated cost of sending the heavy ends to E;PG would be >25 per ton for' processing ana 4'11.40 per ton pi us about 420M pier year- tar railcar t.r an spor t at i on costs -.-or a total annual expense of about 4227H per /ear to e^yrTd 1 1.4 million pounds of heavy ends to 4FG. An additional cost ot aoout 440ivU imouI d be requj. red for r. 'jilJlJi. U _,i containment and piping revisions which would allow for a.] i car loading at the? VCM Plaint. LJt ills at l on of Vista f^nsportatlon tor trucking tne heavy ends to AFG would cost aoout 419.05- ton for an annual expense of about 4250M with no capital revision require ments. The net present value of each of these ciptions^about 490rl relative to the current op11on. Therefore, economically it makes little difference whicn option is utilized. Fisk--wise, nowever, .re--pprays--trfiat tl>e utili zation of rail t r anspar t at i on vjuJl ^7./? r rirrfl orTai. 1 y i.m i ll t is * n the risk of having a serious public exposure incident should be significantly less H,c *.h>* 15 because of the reoecec number of trips 7 lated route wnich worn a nrooaoiy ds tation. 4^ required as -r a i 1 owe a for well the as the less popu railcar transpor- When approache possibility of 'Vista purchasing the CATOXID Tech- nology for use M Plant, BFG indicated that the current technology was not comaat i b 1 e v'.' i r. r; rne oxygen--Dasea fixed bed Oxychl or i nat i on Unit at the VCM PI arid. ora j so indicated that they had no immediate plans of de-- veIoolng the CATO X-[D >Jn i h aquiree t ecnnoluqy. Tins approx i mate cost of the La Forte aoout h i 0 million, indicates that even a smaller unit, such i5 wouici be guinea at c.his VCM Plant, could not be justified at this time. V<m 4:5f 7 /'ichl ~ --It $ - e w capi h .a i iTiaoif it a Lion s *. 4 ^0 r oss i d i e x o no --ter in sol u 11 on lq oJ0> CUh required. 00083g >j heavy ends disposition problem. nl i mi-nates the need to revise arid r. CPA permit the VCM PI tint incinerators to burn heavy ends. Provides for a lower disposition cost than either FFC3 or incineration. No potential effect on the stream factor far either the VCM Plant or the VCM Plant incmeraLors. Heavy ends would not be classi+ied as hazardous waste and would be subject to less stringent. shipping regulations, with only a bill of lading required instead of a manifest. Vista would have a signed contract with BFG3 with ,'qu.sr an teed method of heavy ends disposition tor a mini mum ot tiiree years Hj.cn 1 ess chance o-f being affected by future environmental roqul aliens or solvent market conditions which would cause PPG to shut down the solvent process in which they utilise some of the heavy ends materiai. DISADVANTAGES VCK frzJuc-rr^ 1. Vista would still be dependent upon another coinoany^for disposition of the heavy ends and wouLd neat recover any of the chlorine value in the heavy ends. 2. Increased expense and risk: involved in shipping the heavy ends to La Porte, Texas although these would be minimised by the use of railcars instead of trucks. 3. Cost -- Vista would still have to pay about 227,000 annually -for the disposition of the heavy onas. 4. Risk of ridvinq PPG arranae for another company to supply heavy enas material to fill the qao .left by the heavy enas sent by Vista to 3FG, thus eliminating a disposition option for that fraction of Vista heavy enas. OPT I! ON AirPANGE TG \j 1. VIDE THE HEAVY ENDS BETWEEN l-'PH--kNLi r FG This option would .invo; i e q o t i a t i p q w 11 h Doth hr G nci BEG to reacn aqrsemonti' wi th the two ccmoaiuss t hi s s h l p iri e n t -a o / ends Gould be split between them. Provisions -s---h---o----u---l-d--^, be mane ` ~ w~ h-,ti.ch i-irjU. ;.l allow amount sent to sacn o-;- tnem to do varied to meet awryorw: cond i f i oris. the The most economical split would be to maximize the amount or Heavy ends sent to r3FG wnii o ivuintaininq a share of PPG s uemanci The PPG share /A: tJHi should be ma .i. n c a j. iie<: company to fill the Ln order to prevent PPG from arranging for another :-.u left oy having Vista send heavy anas to BFu, 51 / / 2 J ^ Lr*. */,r &'*- ** at./? , fZ&ec-t & r<xj?hr{ijc h<=^ r/ j sSoorrtt oe>Sj /,'kL cl yj advantages ga* Cost s^/n/t'-cy i &.*. fc.t-3 Provides for two apt i one--for b-ho d i cp-ooi^ilui i o-f *7*IU Yearly cost, is aoout T33M less than the current Slf/j, , /**4-JZ. CWH 000008384 heavy ends. option with a NPV of 4 j6r****' _ ^.tvr r/i/d -ir-vO--fcCM relative to the current, option. Eliminates the need to revises and permit the VCM Plant i nc i ner at or s. No potential effect on the stream factors of the VCM FI ant or its l nciner ators. Reduces the risk of having to resort to other more costly options upon short notice due to future changes in either envi rnnrnontaj. regulations or L r i e solvent mar re L . either or which could cause PFG to refuse the niartvy n cl s l.ucju .a oO-dav not i c:e 7 $ar y **r.rs , Would pr uvHi'v! -,i <gu~ar an t eej^opT t i on for heavy ends d i sd os i i. i an'"- wn i oh could bo used to examine or develop other- more economical options. Would not involve the tie-up o-f large amounts of either- capital or encu nearing manpower. DISADAN1 AGE; prcUiA c.'Zf'S J Vista would still bo dependent upon outside companies^ -for" i". n e disposition of neavy ends. Increased risk and cost involved with transport!nq heavy enos tor further distances, although this would be minimised by the use of railcar transportation. Would provide for no recovery of raw material value of heavy ends by ctrWL /-M- ACT -***&snp di**t- } -itnxdd i.nc iriHr a cor 3_t g__hur n_Ho av y_.f.ng s ^ <i ii />ke tf Currently Vista nas .interim status burn, neavy ends in the VLti Plant incinerators, Unless a complete uenruty sop i 1 cat ion, mciudincj a trial plan is submitted bv Auaust 8, 1 v 5 7 *Fri ts , i n c. e r i m status will he lost. ^ .A ' VJ *1 tA<2 *'fPr ** t-M /> complete permitting process/'iViust y no campiececr by l-jovemoer 8, .1988 or burn The the entire process must be repealed. The permi c ti nq process required for n as -- ardous waste# incinerators is very time consuming ana is expensive. *The tinning is such that it would be difficult to nave the requirea vtork) com pleted i n time to meet the t/xistirt d^-auiines, C\j<cn iS - t s>6Cj/ fftrf/n>t \ 5omc studies and test burns have been completed to determine wnethor the heavy ends could be successfully burnoo in the- VCrl Plant incinerators, rrwious test burns were only partialLy successful but John Zink repre- sen t a. 11 ves feel that 'encoun t or sd would be present in the heavy it is possible. The major problem whicn would ce the need to remove cjs sen c l a j i v ail of the sod i urn ends. Past studies inuicace cnat the newly-installed `static mixers in conjunction with a mesh coaiecsur system shouid lower the current sodium concentration in the hea-vy ends rrom the current level of 1000 ppm to an wcceptab 1 e 10--20 ppm. The presence of sodium in the feed to the incinerators can cause1 excessive fouling of the waste heat boiler tubes and severe damage to the refractory iinmo. requiring frequent cleaning of the tubes and possibly annua?, replacement of the refractory lining.Beth of these would result in greater downtime for i:he iiquid-ourninq incinerator which would increase r.hP nsh: of having incinerator bypasses since the downtime required to re place the refractory is estimated to be three to four weeks during which time the VCM Plant would have no back:--up incinerator Bhould there be a nroiruem with the on-line incinerator, Recent tightening of trie regulations ana enforcement practices pertaining to the number of incinera tor bypasses and stack exceedances cause this added risk to be highly -1 n n f?j. rt> le a n d p o s s 1 b .1 e costly i n t ho ft. t. u r e. t-uj Van i AGfc. B CWH 000008385 This option would provide for in-plant d i spofii t i on of heavy ends no dependency upon other companies. Poms- possible revenues from increased steam and muriatic acid with i L 1 J *6 1 production , a i t.houqn these revenues would b riearlv nc?ql igibl^/since the esLra stearr :ias little current value and the martlet for Muriatic acid is nearly non-existent, especially for the low-grade acid which would be produced 3. Savinqs of costs for sending heavy ends to PPG or BFG C-f227M -- 4. Lower capital expenditure? when compared to building a new hazardous waste incinerator dedicated to heavy ends C i"5- J.OliM > . 1.3 ADVANTAGES 1. 2. 3. 4. ~:>. a. 7. 5. 9. 10. Higher risk of incinerator bypasses and the resulting possible increased enforcement measures by environmental agencies. This increased ru.sk is clue Los a> hiaher teeci r a c es co i.iu:-:? incinerator resulting in a i ower tolerance for possible upsets in the vent flows ana b) more downtime reauirea -for more frequent maintenance including a passi b i y annual 3 -4 week downt i me ream r ed f '.jr ref ractory rep i ace?mn c > -t-901 i) Increased maintenance cost -- about T200M per year RCRA permitting costs \ -v 1.3 Oil) and timing r equi re merits lindif icatnons rcequirea for sodium removal (f:230K) Add i t i canal 1 no i : it1'" a Lor i n a trumfentat i on rgi.i i r eu n y LC,I1m r ci u 1 at i ons . (carbon monanuie moi 11 tor i nq system and fuel shi.ic.--of f controls, costing about SQ\`\) . Need f or sec ondar y con ta i nmen t. aroun d the noavy anas t ued a cor age tank and feed pumps about 433H) Risk, of reducing cho urream -factor tor botn the v n c n. lira c or o and the 'v'Cfi Plant Possible capital mod if i cat i ons which may be required toachieve the r equi red 9 9 . 9 9X vies tr uc t i on ef f iciencv i not 3. i ke 1 y to d needed ) The v`Ci'1 Plant would become a hazardous waste disposal site and subject to anv applicable rouuia tions This option would involve trie tie-up of a large amount of capital (about 444ON> and engineering manpower (1.3-2 manyears) whicn could oe more profitably' utilized toward reducing the amount of neavy ends be?i nq produced. CUH 00008386 QLlIQl'i.!2_2_!^Qi22lL:-.yQI_!d^2_!ii!oL!lI-.'d_lil^w_I!i!QIL'Jiii6AIQR_IQ,,;iyi:iN_HEAVY_ENDc5 A quick e?x arm. na t i on of the option of constructinq arid permitting a new haz ardous waste .incinerator to burn heavy ends and possioly other -Vista-- i.ienz-r<.*i-.eci wast.es indicated that this option would not bo desirable at this time. If pniit at the VCM Plant it would cause? the 7CM Plant to be classi -- f i ed ca?-. a hazardous waste disposal site arid subject to all. app 1 i cab.1. o regu lations. I'iie esf.ima.tec3 cost (T3--10 million plus an undetermined operating cost) is not justifiable at this time. s>....................._ mDVhN tages f.u^C 1. Could provide capacity to process mucn of Vista's hazardous waste materiais. 2. Would be more capable of meeting the required destruction efficiencies for all types of waste produced by Vista. 3. Would eliminate the risk of decreasing the stream factor of the VCM Plant or its incinerators DISADVANTAGES 1. 3-5 years would be required before start--up of the new i nc i ner ator. 2. The VCM Plant would become a hazardous waste disoosal site? and slid ject to any aop 1 i cad I. e reguiati oris and enrorcemen c. measures . 3. Estimated cost - .5-10 million plus an undc-iter mi no a operation cost. QPIIQN-s_=-QQMMiRQiaL-INeiNeeariON_GP_ALL-HEAVY_mo-2 This option would involve vist.a par 11 ci pat i .net in a tuke~or-nav arrangement with other companies m which the exoc-nso or constructing, permitting, and upef'iting a commercial .mcinarator would no shared by the companies which wouia send material to be i nc i river a ted. Usually the companies auoscriuinq to the incineration services must agree l.<.j supply <a c or1 a in Traccion or Lne feed material to the incinerator or to pav che required in l n i mum fee tor processing that amount wliecher they send ic or non. Currently both Gulf Coast 'Waste Disposal Authority and Chemical Waste Man agement ar'e prepas-mg suen arrangements. 'm the of the Criemi cal Waste Management proposal the subscribers would be required to supply eicihtv per cent of the capacity of the incinerator -for a pt-riod or three to four vears deponamg on the required payback period. After the pavoack period, each subscriber would have an annual right of t i ri. refusal l:o renew its origi nal capacity commitment or to reduce its coinirn tinent if so desired. A sirni -- lar arrangement thorlty Viii-et. should be available from (On. tkts o^/ne. ? Gulf Coast Waste Management Au-- a <j v a n r !-i 5" sni*A ry "T*. /- 2 ecu r e , J. o no-- t e r m -ioiuti on t o 11 ea v y an cl s d.) &p as i t ion p r ob 1 bio need to permit and r ev i. ss t he VCM Pi ant i nc i ner a tor N rj d e m ax n ci o n .-AAi s t a engineering .'fianpower required No possi b 1 if (Sf/ec: t on the stream rac car of the-? VCM Plant m 'i u V A N1 j-iUEid CUJ-I 000008387 st:i. mated Ljp. be -/-9 million a n n u a 11 v rl ui i s--i-rjr Unterih'i disposal of heavy e n a s (> r u lie thc? .inririeratar is constructed (possibly in 1990) Increased risk of transporting hazardous waste further distances- 4. Increased onsite? and offsite storage capacity may Lie required. No raw material or energy recovery by Vista. Vista would have to commit to a Lake--or--pay arrangement with the company construct:i ng and per mi it i na this i nci nsration f aci i i tv wi tn no p aydsck ->r payout possioi 1 i ty. QTIQy_2_Z-.i:lSSQIIBI'g-6.N_ftBB.0NGEMENT_WITH_GEORGIA,,GyLF Georgia CATOX ID cessing Gulv has been working on developing a process similar to the Process or B. B". jjpodr 1 ch which could be at value to Vista -for pro- heavy ends. T las been some tentative contact with them and the initial impression is that they would possi b ly. wor k with V'ista in the de velopment of this process. Thev currently d^r\Hp have this process in oper ation and are probaulv several years away -from doing so. 1. Fossiole i emu-term solution to heavy ends disposition problem 2. Future bargaining tool ror riej-jati at i ng prici n q and '".arms with botn PPG ano 5FT; -3. night os Feasible to buiia a C A lux ID-- l l Re unit a c or near tne VCN Plant :<& ec. cner a joint vwfrcure; wi ch Georgia Gmf or by licensing the r. sc ri no i. ou y r om Georq i. a Gui and construct! nq e no u.n i t our so i ves . 4. i: a vs 2. o>v revenues -rom one recovery cjt the? c:n i or; ns ana energy vnue 1 . This option is v_ i i i several years away trom possible oneration. G. Na t i riii com mi tn'iom: or proposal Prom. G&oraia Gu i f is expected in tne near ruture. 3. Nay not ns economically Feasible due to the? possibly high capital expenditure required far the development and construction of this process. CWH 000008388 4i iP1-2 Revenues 1. PPG Disposal Fee Savings -- Heavy ends disposal fee coses are based on the yearly averaae (tor the last 17 months) oroduction rate of 11.355 MM lbs./yr of heavy ends with an average concentr at l on of 33. i57. EDC p1 us 1,1,2--Trieh1 oroethane with the current pricing formula. This price was held constant -for three years and then escalated at 3.57. annual 1y. 2. PPG Transport; =ticn Charges -- Transportacion costs were obtained from the estimates Vista cost of .120 nor . .. i -con load or noavy ends trucked to PPG by Vista 'iransportacioii. fnis cost escaiuued at 3.5/1 annual 1y. 3. (Muriatic .-icid -rules - The revenue from possible muriatic acid sales are oocained .rani too currsnc price paid by iexas umtEd for tine muriatic ,-aC i a produced currently *, '0. O0050 1 / 1 b ) . It. was assumed tnat 357. of :inc- ervanno in the neavv ends (assumed to be 33 wt7. chlorine) was recovered <as id wt/. HC1 and tnat 507. ot this recovered HC1 is pur in a see hv Texas united. This w as esc a.luted at 3. !;T>. annually. 4. ? CQGTS 1. cF G Processing ree -- i he charge by BFG fur processing our heavy enos in their CATCXID Unit was obtained frc.nri their- current terms proposal in which they otter to accept up to 12 MM Ib/yr of heavy enoi. This charge, -25/Lon, was held constant tor 3 years and then escalated at. 3. 57. annual 1 y. 2. BF6 Transportation Charges - The transportation charges tor- transporting heavy ends to the BF3 plant in La Porte, Texas were estimated -for two options: ^ 00000S389 (a) Railcars - The neqotiatied rate of .11.40/ton plus -20,000 -for annual maintenance and lease chsraes was used for the option which provided -for sending all or the heavy ends to 3FG. For thexf^tion providing -for sending only half of the heavy ends to 8FG, fcjjya) charge of -t L J. . 40/ton and -10,000 leasing was used. Both of these escalation race of -3.57. tor annual maintenance ganrr options involved an annual u ) i rue f: i net -- The estimated Vista cost ot -400 / 21 -- L on load tor trucking the heavy ends to La Porte, Texas by Vista Transporcation. This charge was estimated by assuming an hourly cost of- 440/hr -for the lu-nour round trip (two nours each for loading and unloadinq, and three hours each way tor the trip;*. This estimate made no allowances tar the possibility of higher maintonance costs, extra driver, etc. as well as increased -nmentsi risks incurred by transport1ng indj or iugnways longer distances. he Heavy ends on Acid N'iucralization Costs -- It was assumed that 301 of the chlorine in the neavy anas u^bout 33 wt/i) was recovered as Hf.1 with 73/1 of the remai in :i nq 15/1 of the acid producted being neutralized in the caustic scruboer 17 S >1 > and the limestone pits <25>1). These assumptions were originally made in a 4/23/33 memo by 3.J. Reynolds. It was also assumed tnat. 50/1 of the recovered HC1 was neuurallzed j. n the limestone pits with the remaining 50'/. being sold to I'ex as United. The cost of the caustic (0. 057/lb) and the limestone A'0.0093/1 b) were taken from the March, 1987 IPA sheet. These costs were then escalated at a 3.57. annual rate. 4. Electricity Costs -- The electricity costs were obtained from the 237.7 MKWKR/year incremental increase (per 4/23/83 budget estimate by S. J. Reynolds) witn prices supplied by PED. Incinerator Permitting Costs - The cost of permitting the VCM Plant cinerafors was obtained from estimates dv bcoit tnyi roflnrnental to Cheeefm4n (41COM for trial burn prep-n-f.t*:rr;n--and--wiiiniinn nn , xLat-a M. id j. irgt, r-fiPn--c t-c:. and ToOli for tne preparation or the actual permit) These costs were aividea evenly between 1957 and 1788. 4Ref r ac Lory Repiacsivent ~ ihetosc of ctrfiic. aciSBi ui y annua.). \ per i/31/84 memo ay j . 5, Cole) r ap i acen.ent of the ret "actory wai 1 => *../f i;he incinerator being used to burn Heavy- ends was an oroer c-t mag n i cuce iu-pi an L esc i mats. This cost was fiscal at eel at an annual rate or 4.8/. i'la !. nr. enance -- Ti i e annua i Gilded maintenance cost was estimated as 307. of the current annual cost ("62 7ti/yearl plus v'/. of the capital eiioeriai cure required tor burning neavy ends. This amount was then escalated at an annual rate ov 4.o'. * d. /*!**- < j r* * 7<u? j?t it* I v. -'Odi urn removal - i ; cost for revisions required for removing sodium from the neavy ends (-T250M) was D^.sed on a preliminary design by J. G. Cole ( 5/22/34) which provided for a mesh coalescer system to be used in con junction wj c;n a static mixer to lower the sodium level to tine L ar net 1 eve1 of 2l-'> the level rsou i red 0Af*M j d a in age to me AT/J >sn / 2-<P ppm. This target level was apparently chosen as to reduce fouling of the waste heat bailer tubes refractory material 4^ r p t*pi. mi f-n--1 reverl . Feed Rystem nf?visious -- The cost of the revisions required for burning n e a v y e i a s w as i j a a e d o \) a n esc a 1 a t e d cos t o f a d esi q n (J . G. Cole, 7/2 7/30; and 5.3. Reynoins, 5/6/84) to provide a circulation loop l.:o red i ice solids nuiid-up in the Heavy Ends 5 to ratio Tank:, T--405. It was assumed tinac the existing feed tank, teed pumps, and feed control -.ysLem w._>uid be su-r f i c i an t for burning all of the heavy ends. The ,L 9F.7 buuuet included an ad d i Lionai T1 OOii tor revising these comoont?nts jui; tiij.s r-mouiii: was not included in the base case. 10 A d d 11 i <:: n a i Inci n e r a t a r lnstrumisntati on - ITie cost required for the a u r:iitiona1 incinera tor i. nstrument. at i on r cjqui r ed by the RCRA r equ.i at i ons (-t30M) was obtained from the 1987 Budget Estimate which CUH 000008390 included * continuous carbon ronoKiue monitoring svscen: along with the required snut-otf controls and alarms. Secondary Containment for the Feed System - The cost, containment required at the heavy ends feed tank and estimated at #55M in a preliminary plant estimate. for the secondary feed pumps was ^ Insurance and Taxes -- This cost was estimated at c ap i t a 1 and escdl ated at .5/1 annually. (O '/. of the construct!n After Tax Start-Up cost - This cost was estimated as 63/1 of 57. of the construction capital costs. 000008391 CUH CUH 0 0 0 0 0 8 3 9 2 BFG OPTION - 10 YR H/RfiIL Project Year Revenues PPG DISPOSAL FEE SAVINGS FPG TRANSPORTATION SAVINGS Total Revenues Costs BFG PROCESSING PEE BFG TRANSPORTATION CHARGES Maintenance Insurance and Taxes Depreciation-Construction Capital Total Costs Taxable Income Income Tax After Tax Income Operating Cash Plow Investment Construction Caoital After Tax Startup Total Investment Net Cash Flow Internal Rate of Return,! = Discounted Payback Period,vrs s Cost of Capital ,7. = VISTA CHEMICAL COMPANY CALCULATION OF PROJECT ECONOMICS (HI) VERSION 12-86 Ol-Jan-BO "3 -2 -1 1 #4 0 4 5 6 7 0 9 10 2B6.20 40.55 2B6.20 40.55 236.20 40.55 296.22 41.97 306.58 43.44 317.32 44.96 328.42 46.53 339.92 48.16 351.02 49.85 364.20 51.59 326.75 326.75 326.75 338.19 350.02 362.28 374.95 388.08 401.67 415.79 141.94 141.94 141.94 146.90 152.04 157.30 162.88 168.58 174.40 180.58 84.72 84.72 84.72 07.68 90.76 93.92 97.20 100.62 104.14 107.70 4 2.00 2.10 2.20 2.30 2.41 2.53 2.65 2.70 2.91 3.05 1.00 1.04 1.07 l.il 1.15 1.19 1.23 1.27 1.32 1.36 10.00 16.00 9.50 7.50 7.00 0.00 0.00 0.00 0.00 0.00 239.66 245.79 239.43 245.49 253.36 255.02 263.96 273.25 282.85 292.77 37.09 00.96 B7.32 92.70 96.66 107.26 110.99 114.83 110.02 123.02 32.22 29.95 32.31 34.30 35.76 39.69 41.07 42.49 43.96 45.52 54.07 51.00 55.01 58,40 60.90 67.50 69.92 72.34 74.06 77.50 64. S7 67.00 64.51 65.90 67.90 67.58 69.92 72.34 74.86 77.50 0.00 0.00 0.00 0.00 0.00 50.00 1.58 0.00 51.53 0.00 0.00 0.00 0.00 0,00 0.00 0,00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0,00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0,00 0.00 0.00 0.00 -0.00 0.00 -51.58 64.87 67.00 64.51 65.90 67.90 67.58 69.92 72.34 74.06 77.50 127 3.9 131 NFV of operating cash flow = NPV of investment,working capital = NPV of net cash flow = 255.74 35.74 219.99 GFG ONLY 10-YEAR NITH TRUCKS Project Year Revenues PPG DISPOSAL FEE SAVINGS PPG TRANSPORTATION SAVINGS Total Revenues Ccsts EFG PROCESSING FEE EFS TRUCK TRANSPORTATION CHARGES Deoreciation-Construction Capital Total Costs Taxable Income Income Tax After Tax Income Operating Cash Flow ^ X Investment o Construction Capital ^ After Tax Startup O Total Investment CO ^ CO Net Cash Flow Internal Rate of Return,X 5 Discounted Payback Periodtyrs = Cost of Capital,X = VISTA CHEMICAL COMPANY CALCULATION DF PROJECT ECONOMICS (Ml) VERSION 12-86 ' Ol-Jan-80 -3 -2 -I 1 2 3 4 5 6 7 8 9 10 2B6.20 40.55 2B6.20 40.55 286.20 40.55 296.22 41.97 306.58 43.44 317.32 44.96 323.42 46.53 339.92 43.16 351.82 49.85 364.20 51.59 326.75 326.75 326.75 338.19 . 350,02 362.28 374.95 3BB.C3 401.67 415.79 Ml.94 103.15 0.00 141.94 108.15 0.00 141.94 108.15 0.00 146.90 111.93 0.00 152.04 115.85 0.00 157.38 119.90 0.00 162.8B 124.10 0.00 16B.58 128.44 0.00 174.48 132.94 0.00 180.58 137.59 0.00 250.09 250.09 250.09' 25B.83 267.89 277.28 286.98 297.02 307.42 310.17 76.66 76.66 76.66 79.36 62.13 85.00 87.97 91.06 94.25 97.62 23.36 28.36 23.36 29.36 30.39 31.45 32.55 33.69 34.B7 36.12 4B.3Q 4B.30 48.30 50.00 51.74 53.55 55.42 57.37 59.33 61.50 48.30 48.30 4a.30 50.00 51.74 53.55 55.42 57.37 59.38 61.50 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 -0.00 0.00 -0.00 43.30 48.30 4a.30 50.00 51.74 53.55 55.42 57.37 59.38 61.50 -203 3.0 13Z NPV of operating cash flow -- NPV of investment. Morking capital = NPV of net cash fl.OH = 195.11 0.00 195.11 BFG/PPG 10 YEAR OPTION Project Year Revenues PPS DISPOSAL FEE SAVINGS PPG TRANSPORTATION SAVIN6S Total Revenues Costs BFG PROCESSING FEE EFE RAIL TRANSPORTATION CHARGES Maintenance Insurance and Taxes Depreciation-Construction Capital Total Costs Taxable Income Income Tax After Tax Income Operation Cash Flow Investment Construction Capital After Tax Startup C *5' o o o o cf.oy so ** Total Investment Net Cash Flow Internal Rate of Return,! = Discounted Payback Period,yrs s Cost of Capital,! = VISTA CHEMICAL COMPANY CALCULATION OF PROJECT ECONOMICS (Ml) VERSION 12-Si 01-Jan-80 -3 -2 -1 123 4567 B9 10 143.10 20.28 143.10 20.28 143.10 20.28 14B.11 20.98 153.29 21.72 150.66 22.48 164.21 23.27 169.96 24.00 175.91 24.92 182.10 25.80 163.38 163.30 163.38 169.09. 175.01 181.14 187.48 194.04 200.83 207.90 70.97 42.36 2.00 1.00 10.00 70.97 42.36 2.10 1.04 16.00 70.97 42.36 2.20 1.07 9.50 73.45 43.84 2.30 1.11 7.50 76.02 45.38 2.41 1.15 7.00 78.69 46.96 2.53 1.19 0.00 81.44 43.60 2.65 1.23 0.00 04.29 50.31 2.78 1.27 0.00 87.24 52.07 2.91 1.32 0.00 90.29 53.89 3.05 1.36 0.00 126.33 132.46 126.10 128.20 131.96 129.37 133.92 138.65 143.54 148.59 37.05 30.92 37.28 40.89 43.05 51.77 53.56 55.39 57.29 59.31 13.71 11.44 13.79 15,13 15.93 19.16 19.82 20.49 21.20 21.94 23.34 19.43 23.49 25.76 27.12 32.62 33.74 34.90 36.09 37.36 33.34 35.48 32.99 33.26 34.12 32.62 33.74 34.90 36.09 37.36 0.00 0.00 0.00 0.00 0.00 50.00 1.5S 0.00 51.50 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 . 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 -0.00 0.00 -51.58 33.34 35.43 32.99 33.26 34.12 32.62 33.74 34.90 36.09 37.36 65 NPV of operating cash flow = 120.37 4.8 NPV of investment,working capital = 35.74 13*4 NPV of net cash flow = 92.63 BFG/PPB 50/50 10 YR SPLIT M/TRUCKS Project Year Revenues PPG DISPOSAL FEE SAV1N6S PFG TRANSPORTATION SAVINGS Total Revenues Costs BFG PROCESSING FEE BFG TRANSPORTATION CHARGES Decreeiation-Construction Capital Total Costs Taxable Incone intone Tax After Tax Incosie Operating Cash Flow Investment Construction Capital After Tax Startup Total Investment n c o o o o o CP CJ -a tp. VISTA CHEMICAL COMPANY CALCULATION OF PROJECT ECONOMICS IMF) VERSION 12-86 16-Mav-87 -3 -2 -1 1 2 3 4 5 6 7 8 9 10 143.10 20.28 143.10 20.20 143.10 20.28 148.11 20.9B 153.29 21.72 158.66 22.40 164.21 23.27 169.96 24.08 175.91 24.92 182.10 25.80 163.38 163.38 163.38 169.09 175.01 iai.14 187.48 194.04 200.83 207.90 70.97 54.07 0.00 70.97 54.07 0.00 70.97 54.07 0.00 73.45 55.96 0.00 76.02 57.92 0.00 73.6? 59.95 0.00 61.44 62.05 0.00 84.29 64.22 0.00 87.24 66.47 0.00 90.29 68.79 0.00 125.04 125.04 125.04 129.41 133.94 138.64 143.4? 14B.51 153.71 159.08 38.34 38,34 38.34 ' 39.68 41.07 42.50 43.9? 45.53 47.12 48.B2 14.19 14.19 14.19 14.60 15.20 15.72 16.28 16.85 17.43 18.06 24.15 24.15 24.15 25.00 25.87 26.77 27.71 28.63 29.6? 30.76 24.15 24.15 24.15 25.00 25.87 26.77 27.71 2B.60 29.6? 30.76 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CD o- CD Net Cash Flow -0.00 0.00 -0.00 24.15 24.15 24.15 25.00 25.07 26.77 27.71 29.69 30.76 Internal Rate of Return,7. = Discounted Payback Period,yr5 = Cost of Capital,X = -203 3.0 13X NF'V pf operating cash flow = NPV of invesUent,working capital = NPV of net cash flow = 97.57 0.00 97.57 BFG ONLY THREE YEAR OPTION Project Year Revenues FPG DISPOSAL FEE SAVINGS PPG TRUCK TRANSPORTATION SAVINGS Total Revenues Costs BFG PROCESSING FEE BPS RAIL TRANSPORTATION CHARGES Maintenance Insurance and Taxes Deoreciation-Construction Capital Total Costs Taxable Income Income Tax After Tax Income Q I- Operating Cash Flow Investment Construction Capital After Tax Startup o ^ ^0 Total Investment Net Cash Flow Internal Rate of Return,! = Discounted Payback Period,yrs = Cost of Capital,X = VISTA CHEMICAL COMPANY CALCULATION OF PROJECT ECONOMICS (KS) VERSION 12-B6 Ol-Jan-QQ -3 i. -l 1 L 3 4 5 6 7 8 9 10 266.20 40.55 286.20 40.55 286.20 40.55 326.75 326.75 326.75 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 141.94 84.72 2.00 1.00 10.00 141.94 B4.72 2.10 1.04 16.00 141.94 0.00 2.20 1.07 9.50 0.00 0.00 2.30 1.11 7.50 0.00 0.00 2.41 1.15 7.00 0.00 0.00 2.53 1.19 0.00 0.00 0.00 2.65 1.23 0.00 0.00 0.00 2.78 1.27 0.00 0.00 0.00 2.91 1.32 0,00 239.66 245.79 154.71 io.91 10.56 3.72 3.88 4.05 4.23 37.09 80.96 172.04 -10.91 -10.56 -3.72 -3.BB -4.05 -4.23 32.22 29.95 63.66 -4.04 -3.91 -1.37 -1.44 -1.50 -1.56 54.87 51.00 108.39 -6.87 -6.65 -2.34 -2.44 -2.55 -2.66 64.87 67.00 117.89 0.63 0.35 -2.34 -2.44 -2.55 -2.66 0.00 0.00 3.05 1.36 0.00 4.41 -4.41 -1.63 -2.78 -2.78 0,00 0.00 0.00 0.00 0.00 50.00 1.58 0.00 51.53 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 -0.00 0.00 -51.58 64.07 67.00 117.89 0.63 0.35 -2.34 -2.44 -2.55 -2.66 -2.70 127 3.9 13! NPV of operating cash flow = NPV of investment,working capital = NPV of net cash flow = 129.82 35.74 94. OB OPTION 3 - PERMIT VCM INCINERATORS Project Year Revenues FPG DISFDSAL FEE SAVINGS PP8 TRANSPORTATION CHARGES MURIATIC ACID SALES (507.) Total Revenues Casts ACID NEUTRALIZATION (501) ELECTRICITY PERMITTING INCINERATOR REFRACTORY REPLACEMENT (0NCE/YEAR1 Maintenance Insurance and Taxes - Decreeiation-Construction Capital Total Costs Taxable Income Income Tax ^ After Tax Income Operating Cash Flow Investment Construction Capital After Tax Startup o o o o a CO LO O Total Investment Net Cash Flow Internal Rate of Return,I = Discounted Payback Period,yrs = Cost of Capital,! = VISTA CHEMICAL COMPANY CALCULATION OF PROJECT ECONOMICS (Mt) VERSION 12-86 Ol-Jan-BO -3 2 -1 I 2 3 4 5 6 7 8 9 10 286.20 40.55 31.86 286.20 40.55 32.93 286.20 40.55 34.13 296.22 41.97 35.32 306.58 43.44 36.56 317.32 44.96 37.84 328.42 46.53 39.16 339.92 48.16 40.53 351.81 49.85 41.95 364.13 51.59 45.42 358.61 359.73 360.BB 373.51 386.58 400.12 414.1! 42B.61 443.61 459.14 29.17 9.73 65.00 90.00 199.00 8.70 B7.00 30.19 10.90 65.00 93.60 208.55 9.00 139.20 31.25 11.60 0.00 97.34 218.56 9.32 82.65 32.34 12.10 0.00 101.20 229.05 9.65 65,25 33.48 12.B0 0.00 105.29 240.05 9.98 60.90 34.65 13.30 0.00 109.50 251.57 10.33 0.00 35.86 13.50 0.00 113.88 263.65 10.69 0.00 37.12 13.80 0.00 118.43 276.30 11.07 0.00 38.42 14.00 0.00 123.17 289.56 11.46 0.00 39.76 14.20 0.00 128.10 303.46 11.86 0.00 488.60 556.45 450.72 449.59 462.50 419.35' 437.5B 456.72 476.61 497.38 -129.9? -196.72 -09.84 -76.08 -75.92 -19.23 -23.47 -28.11 -33.00 -3B.24 -48.10 -72.79 -33.24 -23.15 -28.09 -7.12 -8.6B -10.40 -12.21 -14.15 -81.89 -123.93 -56.60 -47.93 -47.B3 -12.12 -14.79 -17.71 -20.79 -24.09 5.11 15.27 26.05 17.32 13.07 -12.12 -14.79 -17.71 -20.79 -24.09 0.00 0.00 0.00 0.00 0.00 435.00 13.70 0.00 448.70 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0,00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 -448.70 5.11 15.27 26.05 17.32 13.07 -12.12 -14.79 -17.71 -20.79 -24.09 ERR NA 13! NPV of operating cash flow = NF'V of investment,working capita) = NPV of net cash flow * 17.22 397.08 -379.B6 u f not it icsti on done to cnrrsc wm ch Lhe f r?5Son ror the crobIsm. ref'..isa i. s given along with what was -J-t--mould -.-Tna 7*h e actuai. cost of heavy ends to Vista, including the raw material value, processing costs, and the disposition costs currently about -tl . vMM/year - This indicates^oirectionaily the best use is of attfST capital expenditures would be i ends wStriifa tar produced. "f-O reduciift the amount of ne&vy ADVANTAGES 1 No need for permitting or modifications to the VCM Plant .incinerators. fs|a potential effect on the stream factor of the VCM Plant or the ina ner at or s . Ho capital modifications required. DISADVANTAGES 1. Risk of having to resort to commercial incineration or other option upon si.vty-day not i f i cat i on by PPG of refusal or heavy ends due to changes in e11her environmental reauiations or sol vent mar ket conditions. " * VC*> r"<Wv~; 2. Vista would still be dependent upon another cafnpanyj for the disposition of heavy ends. 3. Cost - Vista pavs about 1-333,000 per year for sending heavy ends co PPG. 4. ;eaw onus sent to P F G must bo treated as Hazardous waste and each shi. pment must bo m:.ni rested and is subject to all hacar dous waste shippinq reejui at i one . 5i - Ha recov-erv ut the? raw material or energy vaii.ia of the heavy enas by Vista. 0d t i.cn 2 ^ _B ,, P ,, GODpR I QH_CAT0X I u__PRQCbad B. r . Goodr r:h has developed a CATCXI u Process wnich uses a f I m d i sc catalytic dog reactor to ozidize chlorinatt-d hyarocarbon feed streams is HC1 , w=o::er , -.rui nitroqsn oxides winch are then ed to the.i r ai r-oased Or. vch 1. or-i n.->. i on reactors to do ussu in trie product.;i.on of GDC. inoy have a CATO X ID Un.iL i. n operation at their L-a l-orie, Texas facility and have pre sented vi. ota with a terms proposal in which they would agree to accept up Lq 12 million uaunos of heavy enos per year' tor a charge of T2':i per ton. CWH 000008403 r Ti'is would praviai: -.-or the ai^position produced anrui-iv at the VCM Fiant. at tne currsn" .. 1 . -i -iU 1 i i :n pounds Since the neavy ones materia], would then ncs ciassinea ...> .... t sec; - cqc k , and not as a hazardous oast. e, r.he shipment o t heavy ends would he under -a bill of lading .instead c:-f having to manifest :i.t,, as is current 1y a one on ship ments to rF'b. Approval has Deen received from the Louisiana ilepai'tmern: of Environmental Quality and the Texas Water Commission for this 1 liter oreta-- i; i on of appliraole regulations. Two I: ruckl oaos of pling and testing CATOXID Process. of the heavy ends heavy anos were sent to the La Forte facility i or sam for compatibility with their other feedstocks and the They reported no difficulties in unloading and blending material. The estimated cost ut sending the heavy ends to jt-j-G woui d be iyb per ton for processing e.na .711.40 per ton plus about :J:20M per -/ear tar rail car tr ansportat i on vostii tor a total annual expense or about T227H per year to send 11.4 million pounds of hgavy ends to BFG. An additional cost, or aoout ~? S'O would be oqui rad for wLf/oivcii.r containment and piping revisions which would allow for railcar- loading sat the VCM 1-1 ant. Utilization of Vista Ifensportation -tor trucia ng the heavy ends to BFG would cost aoout -t-.!'f ,, Ob -- /ton for an annual expense of about 72G0M with no capital revision require ments, The net present value of each of these optionsabout $90Mj relative to the current opr.i or^Theretore , economical i y 11 makes 1 i tt 1 e di f f erence which option is iciLiad. rusk--wise, nowever, .w--anperai^--thi*.t--ih urili -- jation or rail yinspariauan ~ri - ^ ^ <- \ - , ,j y , q r r" f~ ** i rr r"r- the risr: of having a serious public exposure incident, should be signiticantly less because cf the roQuceo number of trips required as well as the less popu lated route wnicii wouia urooariiy be followed for the railcar transpor- tation. When approaches on eve possx di j. i tv of '-'isiii purchasing the? CATGXID Tech nology for use at tne 'VC,-I Plant, SFG indicated that the current technology was not compatible wiun me ox vgen-baseo fixed bed Gx yeti i or i na t i on Unit at the VCM Plant. BFG also indicated that they had no immediate plans of de veloping the required feennoiogy. The approximate cost of the La Porte CATOXiD Unit., aoout t i 0 million, indicates that even a smaller unit, such as would be required at c.he VCM F'la.nt, could not be justified at this time. hl)VAMT Ai-jFo SO . r pw c a p i t a i m oa i t i c at ions \ -v A- 0.0 0 tj ) r e q uired. 2. Possible .Long-term solution to hsaw ends disposition problem. 3. Eliminates the need to revise and F.CF\A permit the VCM PI an t incinerators to burn heavy ends. x. provides for a lower disposition cost thaneither FrG or incineration, b. Htl5 potent i al effect on the stream factor for either the VCM Plant or the VCM Plant incinerators. 6. Heavv ends won1d not be classified as hazardous waste and would be subject to less stringent, shipping regulations, with only a bill of leading required instead of a manifest. 7. Vista would have a signed contract with E-:|-G with a quarantsed method^ ClJH 0000013404 [0 of heavy ends dispositicni tor a minimum of three years wicn less chance of bi nq a f f acted by future envi roninent al rsqul at ions or solvent market conditions which would cause PPG to shut down the solvent process in which they utilize some of the heavy encis material. DISADVANTAGES 4p^ ^CA1 prvJ**'**'; 1. Vista would still be dependent upon another comoanyj for disposition of the heavy ends and would not recover any of the chlorine value in the heavy ends. 2. Increased expense and risk involved in shipping the heavy ends to La Porte, Texas although these would be minimized by the use of railcars instead of trucks. 3. Cost - Vista would still have to pay about Y227, C'OO annually tor the disposition of the heavv ends. 4. Risk of having PPG arrange r or another company mo supply heavy encis material to fill the gau .Left by the heavy ones sene by Vista to SFG ,, thus eliminating a disposition option for that fraction of Vista heavy ends. OPTION -- ftHKANOir. ru u l VIDE I HE HEAVY ENDS PE T HP in N PPG--hMI) BP'G Thi s opti on woui d i nvnj. ve isqot i---a--/--ci ons,^ iwi t h both f-FG ana Br G to reach s*s> , .,, SU<1\ +* l. a a r e e m e n o w j. t! i c n e 1: w o c a m o a n :l e s >%- -WR-i'Ci> the shipments of he aw ends Qould be split, between "hem. Provisionnss should be made which- wou > d allow the Amount sent to each of them to bee varied to moot ^vj-rtri i:. conditions. The most economical split would be to maximize the amount or neavy onus -oci ng sent, to BFG wrcilo lii-iintaininq share of P'PG ' s demand. Ihe PPG share should be ffsa 1 a t.a i ied i.: i oraer r.o prevent PPG from company to fill the cap I ef l; dv havi no : -1- cr ca j-i rl arrsnaincj for another ADVANTAGES 1 . Pr > w+4 c /* i ^rv- t w in opt luu -a Pei 'the uTTSpoei L i cm erf heav y e n d s . Year.lv cost r>tw =5 about Y 33H less than the current option with a NPV of 4. wl . o. f>wt .H -rr-fi'i-- PEN rel at.i ve to tIne urrent opti on. LE*lfimi nates t h e need to revise and permit the VC'i Plant i nci iterators 4--3* p o t s n 11 a 1 effect on the stream factors of the VCM Plant or its i ncinsrators . Reduce s t iie ris sin or z r o i; i c e .J i j of having to resort to other more costly options upon ho future changes in either c-nvi r on merit a J. regulations or r. he SO 1 Vf;|-| i; liffArkeh. ei. tiier of which could cause PPG refuse trie i i e a v y f-ncs upon Noul d provide a s 60--nay notice. fur- i liu i' u i i t u... ji option for heavy ends disposition -4-C c a u 1 d ne used t ex ami ne or d eve 1 op other more oc on am ,i c a 1 op tions. Won 1 L.I ; o t invoi * the tie--up of large amounts of either cap it til or enqine aring man CUB 000008405 / JJ'.[ SwD AM T AGEq J prif&lu Vista would still be Dependent upon outside ccmpanieSj far d i sposi t i on o t h e a v y e n d s . Increased risk and cost involved wi t h t r anspor t i nq tie a y e n a s a r further distances, although this would be minimised by the use of railcar transnortation. Would provide for no recovery of raw material value of hea' en a s Vista. y clXJLW.tid ti k'!H_tL*QL._XQ:i- Qi2CPdC'5_Q--8bQ._bi-sy y_ifnos Currently Vista has interim status c.o hum. nsavy enos i. n the vLM Plant incinerators. Unless a. complete ^plication, maadina a trial ourn plan is submitted by Au^ugc i 9 8j ^ c n 1 s interim status will be Lost. complete permi ttinq proccjfs^rriUii. oJe completed by November 6, 1988 or I"he the entire process must be repeated. The permitting process required for- haz arauus wast cy :l nc l ner ators l a ver y c 1 mo cansumi nq ana i. s r'ycTT/ he t. i m i i "i g is such that it would be difficult to n a v er-'T: he" re nuirea work p1eted in time to meet the existing deadlines. ve>\ tf Ljtt* deetdtA c: a ra to ciome studies amid test burns have been completed to determine whether the heavy ends could be succssstully burned in the VCi'l Plant incinerators. Previous test burns were only partially successful but John Zink repre sentatives feel that it is possible. The major problem which would tie 'encountered would be the need to remove asseiKiai i.v all of the sodium present in the heavy ends. Past studies indicate chat tne newly-installed static mixers in conjunction with a mesh coalecsur system should lower the current sodium concentration in the heavy ends vro/n the current level of 1000 ppm to am acceptable 10 -- 20 ppm. The presence of sodium in the feed to the incinerators can cause excessive? fouling of the waste heat boiler tubes and severe damage to the refractory iinincu requiring frequent cleaning of the tubes; and possibly annual replacement or the refractory lining. Both of these would result, in greater downtime for the 1iquid--burninq incinerator which would increase the risk of havLno incirnsratar bypasses since the downtime required to re place the refractory is estimated to be three to four weeks during which Lime the VCM Plant would have no back-up incinerator should there be a problem with the on-line incinerator. Recent tightening of the regulations and enforcement practices pertaining to the number of incinera tor- bypasses anti stack exceedances cause this added risk to be highly u n d e s i r a b 1 e a n d o o s s :i. fo le costl y i n t h e + u t u r e. This option would provide for in-plant disposition of heavy ends no dependency upon other companies. Some possible revenues from increased steam and muriatic acid with CUI-I 000008406 7 o J) praaucton , a j. revefiaes wou.l a be near 1 y neq 1 i i b I e since c Li r r e n t v a i u e a-a-e- ( h.HT mar f.~ g'll1--or iimri a L~t-c Jgl-d--ii.,a i.'if-4 T --oj;:pc-ei-:a \-y---- kns--Jmew-gr-acic--acid--wh i-gh w;ul d--b-e--nr odn Sdvinqs c;t costs ^or sending l'ieavy ends to f-'Fld or Bi-o ( T227M -- 333M / year ; 4 Lower capital expenditure when compared to building a new hazardous waste incinerator asd i paced to heavy ends S3-- 1 OliM) . DISADVANTAGES 1. 2. 3. 4. 5. 6. 7. 3. 9. 10. Higher risk of incinerator bypasses and the resulting possible increased enforcement measures dv environmental agencies. This increased risk is due to: a; higher feed races <.o lhe incinerator resul cinq in a lower tolerance for pm c cj i i.j I r- apexes in the vent flows ana b) marp^t^ntiirie reciuirea for inorr-; -frequent maintenance including a |ocj i v annual 3--4 iieek downtime required for refractory repiacemen c. i-?-9oid,' Increased maintenance case - about :i'200M per year R C R A pe r m 1 11: inq cost s ( -v .1.3 0 i1) a. n d timing req u i r e rn e n r. s Hoditications required for sodium removal (#23011; *** Add i t. i ir:>n a i i. nci nor a tor instrumentation (carbon (non ax i or men i. Lor i ng systeni and about i:80M) . required by RCKh r -uulations. f ne 1 shut--of f ccrii;ro Is, costing Meed for secondary containment around the heavy ends veod storage tank and xeeci pumps idioui: -=:33H> Risk of reducing cho s1 r earn factor for both the i ncinerators and the VCM Plant Possible capital modi f i. cat i ons winch may be required to acta eve the required 99.99X destruction efticiencv (not likely to fie needed) The vCi'1 riant won 1 d become a hazardous wash;o disposal site? and sudject to any applicable reu u.l a. t i ons This option would involve the tie--up of a large amount of capital (about 4'440M) and engineering manpower (1.3-2 man years; which could be more profitably utilized toward reducing the amount of Heavy ends inei nq produ.ced . QPIIQCl-^_Z-!rfQii!'Hl&UQI_ANQ_PE5:[!!II_A_NJiW_ I.NCINEftAT0R_Xg_3yBN_HEAVY_END3 A quiet: ox am j. na t :i. on of the option of constructing and psrnu tti ng a now haz ardous waste incinerator to burn heavy ends and possiuiy other Vista-- ueneraLeci wastes indicated that, this option would not be desirable at this time. It uuiit at the VCM Plant it would cause the VCM Plant to be classi fied ns a iictarrlous waste disposal site and subject to all appiic.aD.Ie regu lations. Tne estimated cost (#'5-1.0 million plus an undetermined operating cost; is not: ;j us t .i f i ab 1 e at. this time. CUM 000003407 i. Could provide capacity to process rnucri at vista's hazardous waste mat er i a I s. 2.. Would be more capable of nteetinq the required destruction efficiencies for ail type's of waste produced by vista. 3. Would eliminate the risk of decreasing the stream factor of the VCM Plant or its incinearators D I S A DV A NIA G E 3 1. 3-5 years would be required before start-up of the new incinerator. 2. The VCM Plant would become a hazardous wasr.e disposal sits and subject to any appli. caP L e regulations and entercernenr .easures. 3. estimated cost -- f"5-10 'nillion plus an undetermined operation cost. QP:IIQN_^_Z--QQddg!2Q16L._INCIHRA riON_Qr._ALL_HF:;fiVV_t;ND8 This option wouiu involve vista participating in a take-or-pay arrangement with other companies in which the expense of constructing, permitting, and operating a commercial incinerator would be shared by the companies which would send material to be incinerated. Usually the companies suoscrioinq to the incineration services must agree Lu supply a certain Traction ot the feed material to the incinerator or to pay rne required minimum fee for processing that amount whether they 'send it or not. Currently bath Gulf Coast Waste Disposal Authority and Chemical Waste han-- 'aqement are proposing suen arrangements. in the Cdse of the Chemical Waste Management proposal the subscribers would oe required to supply eighty per cent of the? 'capacity of the incinerator for v period or three to four years depending an the required payback period. After the payoack period, each subscriber would have an annual right of Tirol retusal to renew its origi nal capacity commitment or to reduce its coiniiu tment it 'so desired, fa simi tar arrangement should be available from Gulf Coast Waste Management Au thor! ty. ADVAWT AGh.5 1. Secure, long-term solution to heavy ends disposition problem 2. Mo need to permit and revise? the? VCM Plant incinerators 3. No demand on Vista enqireerinq manpower requireu I. No possible -affect, on the stream factor of the-? VCiv! Plant D I. 3 A 0 V A N T AG E 3 1. Cost. - estimated to be 7-9 million annual 1 v 2. fir? i+r ou i s. rom: f or Xn't er l m disposal of heavy snusAwh i i c? the? md neriitor is constructed (possiolv ky LV90) 3. Increased ri sk of transport i nq ha:: ar clous waste fur hhor el i stances 4. Increased onsite rand offsite storage capacity may be required. 5. No raw material, or energy recovery oy Vista a. Vista would have to commit to a take-or-pay arrangement, with the CUN 000008408 companv ajnstrMctinq and pyrmi.tf.ina the i rcinyration -r at:: i J. i tv with no p ayr.)?.i: x payout-. poss.i Di 1 ity. QE:lJ.QN_Z_z..i'i!iSOii hIE_an_hrrangei:ient_wij;h_gedrgir_..6lilf Georgia Gulf has been working on developing a process similar to the CATOXID Process cut 8. F. Goodrich which could be ot value to vista tor pro cessing heavy ends. Thepehas been some tentative contact with them and the initial impression is that tPiey would possibly work with Vista in the de velopment of this process. Thev currently d o|~i 61 have this process in aoeracion and are probably several years away tram doing so. HD yANXAGb 1 . Passi b 1 e L onq -- ter m sal ut l on t.o heavy enas d i spos >. t. i on prob .1 em 2. Future bargaining iooi fcr neqatiatinq pricing and -norms with both PPG and E>FG 3. Flight ds -f'easiole to build a CA I 0X1D-1 l ke unit at or- near the VCM Plant as either a joint vrva.ire with Georgia Gulf or by licensing the t. echriG i on y t r or;: 6eor o i a Gui t and con struct i n q the un i t our- sel ves . 4. Possible revenues -rain tne recovery of tne cnior:. ns and energy value of ivr;neavv ends. 1. This option is t l i 1 i several years away r rom possible oner at i on. 2. No tirm commitment or proposal from Georgia Gulf is expected in tne .1 ear future. 3. Pay not. be economi cai. .1 v feasible due to the possibly high capital expenditure required for the development and construct!on of this process. CUH 000008409 h. C 0 N 0 j''I ]: C 8 i:i -313 Revenues 1 PFG Disposal Fee Savings - Heavy ends disposal -fee costs are based on the yearly averaae (tor the last 17 months; production rate of 11.355 MM lbs./yr of heavy ends with an average concentration of 33,157 EOC plus 1 , 1,2-Tr:ic:h 1 oroethane with the current pricing formula. This price was held constant for three years and then escalated at 3.5/1 annual 1y. (noi ai/ocatj PF'G Transport, ation Charges -- Vr anspor tan i on cosps were cbtai ned this estimated vista castJ of f 13'3 per .fib-can .Load Or i i. a v y ends to F'F'G by vis La Transportacion, [h1 a cost v:hs aacai av.eci at . 5 annual 1v. from rucked Mur i=it it_ acid dales fhe revenue from p os si Pie mui i at i c acid sales are obtained from the current price paid ov Tex as ijmr.ea for the muriatic ac id produced currently (:.t:0 . U0350 1 / 1 b ; . if., was assumed tnat 857. of the cniarme in the heavy ends (assumed to be 33 wt7. chlorine; was recovered as 13 wt'/. HC1 and Lnat 507. ot tnis recoversci HC1 is purchased by Texas United. This was escalated at -3.57. annually. COSTS 1. BFG Processing Fee -- The charge by BFG fmr processing our heavy enos in their CATGXID Unit was obtained from their" current terms proposal in which they offer to accept up t.o .12 MM Ib/yr -of heavy ends. This charge. -725/3 on,, was held constant for 3 years and then escalated at 3. 5 7. a n n u at 1 1 y. 2. BFG Transportation Charges - 'Hie transportation charges for transporting heavy ends to the BFG plant in La Forte, Texas were estimated for two options: (a) Railcars - The neqotiatied rate of 31 1.40/ton plus #20,000 -for annual maintenance and lease charges was used for the option which provided for sending all of the heavy ends to BFG. For the option providing for sending only half of the? heavy ends to BFG, tf^e charge of -til.40/ton and #10,000 for annual maintenance f.and leasing was used. Bath of these options involved an annual escalation rate of 3.57.. Li Trucking -- The estimated Vista cost, of f 400 / 2 1 ~ L on load for trucking the heavy ends to La Force, Texas by Vista Transportation. This charge was estimated by assuming an hourly cost of T4o/hr for the 10-hour round trip (two hours each for loading and unloading, and three hours each way for the trip). This estimate made? no allowances for the possibility of higher maintenance costs, extra driver, etc. as well as increased CWH 000008410 n v .1 r onmer t. a 1 i sk s 1 near red by Lr an sport i nq ch e naavv ends on rirn~? i'i i a j o r ; 11 g f i w a y s longer distanc e s. held r>ieu Lr a i i z ar. x on Costs -- It was assumed that 313% of the chlorine; in the neavy ends ''.about 33 wtV.) was recovered as HC1 with 73% of the refltauuriq 13% of the acid produced being neutralized in the caustic scruDoer '.75%) and the limestone pits (253). These assumptions were originally made in a 4/23/33 memo bv 3. J. Reynolds,. It was also assumed that. 30% of the recovered HC1 was neu. tr&.L i z ec.i in the limestone pits with the remaining 50% being sold to l'ex as United. The cost of the caustic (20.057/lb) and tine limestone cfO.uO'73/lb) were taken from the March, 1937 IF'A sheet. These costs were then escalated at a 3.5% annual rate. Electricity Costs -- ihe electricity' costs were obtained from MKWHR/year incremental increase `.per 4/2;:/33 budget estimate by 3. J. Reynolds) with prices supplied by RED. the 237.7 Incinerator Permitting Casts -- The cast of permitting the VCM Plant incinerators was obtained from estimates by Scott nviroonmental to M. V/. Cheesfinan ( 2100 hi for trial burn ^i1 gjp-iu rat,a an .rrrd--cfwiiuci'ji, nq j--dtetra rn'i 1 -rti nn_--ene. ectnd 230M for the preparation of tne actual permit). Those costs were divided evenly between 1937 and 1933. %C,m Refractory kepiaceruent. -- i he/\co = t of poasi e-f 7 unnuaJ. ipBr 1/31/B4 memo ay J. 3, Cole) r sp i acernen t of the refractory walls of the incinerator being used to burn neavy ends was an oroer of niugnituae in-piant estimate. This cast was escalated at an annual rate of 4.3% Ma 1 n cenance -- T! te annual uaded mai nt an an ce cost, was esc 1 mac ed as 30% of the current annual cost (2627M/year) plus 4% of the capital x et"1 a ,i. f. ur e r e q u 1 r sd t c-r C tx r n 1 n q h e a v y ends. I"h 1 s 1 n aun z w as t h ei'i escalated at an annual rate of 4-. 3%. . ."odium Removal - The ccsc for revisions required for removing sodium from the neavy ends (2230M) was based on a preliminary design by J. G. Cole (5/22/34) which provided for a mesh coalescer system to be used in conjunction wj. hr. a static mixer' to lower the sodium level to the target level of 20 ppm. This target 1 evel was apparently chosen as the level required to reduce fouling of the waste heat rjoiler tubes JSfandVdamacie r.o me refractory material fro fHimfritfeP -^^1! ..iiil ^ !. 1 l_- Feed 3ystern Revisions - The cost of the revisions required for burning heaw ends was based an an escalated cost, of a design (J.6. Cole, 7/2.7/30; and 3. J ,, Reynuias, 6/6/84) to provide a circulation loop to reduce solids nuiid-up in r. he Heavy Ends Storage Tank , T--405. It was assumed that the existing feed tank, teed pumps, and feed control system w-juid be sufficient for burning ail of the heavy ends. The 1 vo/ bucuet included an additional 21COM for revising -these componen ts uni. tills ci.iitounwas not included in the base case. Additional Inc 1neretor aciditionaL incinerator requ.lationiii i 2 80 kb was Instrumentation - The cost required for the instrumentation required by the RCEA obtained from the 1937 Budget Estimate which CUH 00000B4U i nc i. udeci a continuous carbon mono;-: i as monitoring sysceiii along with the required shut-off control s and alarms. Secondary Containment tor the Feed System -- The cost containment required at the heavy ends teed tank and estimated at SSSM in a preliminary plant, estimate. -for the secondary -feed purnps was Insurance? and Taxes -- This cost was estimated at 27. of the construction capital and escalated at. 3.57. annually. After Tax Start-Up Cost -- This cost was e?stimated as 63/1 of 57. of the construction capital costs. CWH 000008412