Document ppp1YerDjbmDX7R5YJRLg5mXw

INTERNAL CORRESPONDENCE CHEMICALS AND PLASTICS TO (M*MS . COMPANY Dr, W. R. Manning Building #2000-3311 TECHNICAL CENTER day*: RECEIVE ^ *1 , Tr:': ogt afl W76 ^i P, O, BOX 47} ^ TCXA* CITY, T*AA* 773 October 22, 1976 CO*Hf TO ' fV `V=-. Mr. M." E. Eisenhour * Mr. J. F. Erdmann if Me, R. L, Frantz .Mr.^R. A. Herrington Mr. J. B. HolUngaworth-MY Mr. J. B. Leverton Mr, W. A. Maxxolini Dr, B. R. Montgomery, Mr., it.. E> O'Bryan . Mr, jL A. Petarson Me, 'F* . Provenzano . D Robinson ' Mr ,. ? ,F . Tacquard Mr+iR* N. Wheeler-514 . .< . A- ^ K BUliCCT JJgn^Solvejj^fSuspension EPA VCM Compliance Projects ``V ^ .Attach*d-in Appendix I is a current " with the anticipated EPA regulations that the unit personnel have colled this list in an attempt to minimize the amount of money required for this work. . The currant estimated totalx are $650M for. Suspension and- $420H for Non-Solvent. At this point in time these eatieatea 'ere plus- or minus- 50%, - This means that the Suspension portion Is- between- $325 and $975M and that the Mon-Solvent portion la ; between $$10 end: . V Appendix Ilsujnearisee a briel^description of the scope of each of the 13 phrt* t>f the dompdlance., ft should be noted that tk* unit perxitranelj-have, cjpaflten te make the following asaueptioos which have ah important, part.3a;reducing the estimated project coats fro* the original totalsf^r?thtt4twd|fs^[ilitie?of 91.7MR.(^50I> to the current figure. The eaJ,or as#unqittonm!;n* summarized below: "* / '.; v.'.. _/ ' L' - - ' ' V. J '1 . "-'i-.tW''5A*'?' * .-.V i . ' - - ' 'V ,, - ; , : a% That Non-rSdlvdnt,. rwsia can be stripped to -less than. 400 ppm VCJf " f using existing, equipment^with,limited changes and additions; b.f that double dealing oT uempreeeors will he done by unit personnel - :,,and this project should only provide instrumentation; i 'jX-'i, - - - f ` that- * shdrtstpfT^ysteat-im not required- for1 Non-Solvent- autoc laves; '-/ r if *:-. , W -- ^ -? .. * Vj-t 'ii-s O-> ' u - *. K* ; 4 .h f l, , T <v - c, ^ -a '*; h, lt*L f J ucc Vv) 052691 d. that a method la not required for inspecting Suspension autoclave rupture discs without opening the autoclaves; e. that emergency remote operated isolation valves and pump shutdowns are not required; , that a portable scavenger system is not required for maintenance preparation of equipment; g. that the present pilot plant facilities in Texas City require no changes as the law is currently proposed. The t50Z estimates provided at this time are the best numbers currentl available. Additional information will be required from unit personnel and further engineering will be required before these numbers can be reduced to the conventional I'lOX accuracy. Very truly yours, KPB/kb Attachments APPENDIX I i SEEPING PROJECTS FOR EPA VCM COMPLIANCE SUSPENSION 3. PROJECT SL'-l Reciprocating compressor seal instrumentation b!.'-2 Blowdown tank agitator seals Sl-3 Rupture disc/safety valve installations SL'-u Boiler vent analysis and modifications Su-5 Tank car unloading revisions SU-6 Data collection system Sl'-7 Tracifier drain SU-8 HEX stripper calandrla S'J-9 MEK wash tank vent to vent rec. sys. SU-10 Lab equipment and revisions SUBTOTAL COST MS 5 90 115 50 140 15 15 75 100 45 650 NON-SOLVENT N/A-i Reciprocating compressor seal instrumentation N/S-2 Stripping tank agitator seals N/3-3 Rupture cisc/safety valve Installations h/S-4 Tracifier drain N/S-5 Non-Solvent slurry stripping SUBTOTAL 5 20 130 15 250 420 Total Suspension/Non-Solvent $1,070M t5Q% NOTE: New 60 point alarm panel has been prorated to these jobs. Existing unit spare alarms are inadequate to support the anticipated requirements. UCC 052693 APPENDIX II BRIEF PROJECT SCOPE SUMMARIES SUM-__ Reciprocating Compressor Seal Instrumentation Instrumentation to be provided to protect seals (double packing). Unit to do all seal design and installation work. 51-2 Blowdown Tank Agitator Seals Double seals to be installed on six blowdown tank agitators. Instrumentation to be provided to maximize dependability and warn of Impending problems. S'-'-3 Rupture Disc/Safety Valve Installations Rupture discs to be installed under all VCM safety valves. Some safety valve replacement required due to restrictions for using rupture discs under certain brands of safety valves. Some vessel nozzle enlargement or addition of additional relief capacity may have to be provided for any borderline capacities. (Relief capacity requirements will have to be determined for a total of 56 safety valves-Non-Solvent included.) Spare rupture discs and assemblies will be purchased. S-90 type discs (reverse buckling without knife blades) will be used. Potential pressure buildup between disc and safety valve will be handled by a free vent to the atmosphere through a restriction orifice. This vent will be monitored manually as part of the unit leak detection program. Sti-4 Boiler Vent Analysis and Modifications Piping to be modified to allow the vent to go to only one boiler at the powerhouse. Automated analyzer will continuously monitor " the boiler vent stream. " SU-5 Tank Car Unloading Revisions Double gas seals to be installed on two Sundyne compressors. Seals to have protective instrumentation and vent to a low pressure VCM vent header. (May require a new header to Bldg. L19 if existing tank car vent header not suitable.) Double mechanical seals and support facilities required for two pumps at unloading rack. Pumps are not to be connected to existing suspension seal liquid system due to their remoteness. SU-6 Data Collection System Money Is to be provided for a small data handling system for processing EPA data. If possible the planned system for the Solvent Unit and the Non-Solvent/Suspension facility will be cqmbined for operating efficiency. ucc 052694 Appendix II continued :> > SU-7 Tracifier Drain A small pressure system will be provided for collecting and handling the VCM compressor tracifier oil drains, SO 3 MEK Stripper Calandria An installed spare calandria will be provided to help assure that the active time of thia system will be as close to LOO? as possible. Isolation valving will be provided to allow an "on the fly" change of calandrias. An anticipated shutdown of the system of two to three days would probably be required for making this installation. SC-9 MEK Wash Tank Vent to Vent Recovery System A small compressor (to boost the pressure to 75 psig) would be provided with piping and control system to feed this vent to the MEK vent recovery system or the boiler. Stream composition and flow rate data are required to better define the needs. SU-LQ Lab Equipment and Revisions A new analyzer will be purchased to handle the batch stripper samples required each shift. In addition a new lab bench and hood will be provided for sample preparation and handling. Mo special disposal of the lab hood exhaust is anticipated at this time. N/S-l Reciprocating Compressor Seal Instrumentation Same provisions as for SU-1. N'/'S--2 Stripping Tank Agitator Seals Double seals to be provided for two agitators. Instrumentation to be provided to maximize dependability and warn of impending problems. M/S-3 Rupture Disc/Safety Valve Installations Same provisions as for SU-3. N/S-4 Tracifier Drain Same provisions as for SU-7. UCC 05269$ Appendix II - continued 6. N/S-5 Zfon-Solvent 'Slurry Stripping The basic, assumption has been made that by using a combination of the currently operated stripping tank In series with the spare stripping tank and the flash tank that sufficient contact and residence time can be provided to get VCM on the stripped slurry consistently well below 400 PPM. Some baffle trays nay have to be provided for the second stripping tank as well aa pumps and some instrumentation. Piping and instrument revisions may also be required on the primary stripping tank and the flash tank. This project is highly nebulous since no teat data whatsoever is available. If the stripping proves to be much more difficult than anticipated, this coat could jump to $500M, ucc 052696