Document wDVz3wqn1GKXnNYaNDRm8XBRJ

( REQUEST FOR WAIVER OF COMPLIANCE ABERDEEN PVC PLANT The General Provisions discussion regarding Hazardous Air Pollutants, 40 CFR 61.10, describes the information needed for requesting a waiver of compliance. The Aberdeen Plant has no specific forms for filling out this information. In lieu of submitting forms, ve have attached the information as described in 40 CFR 61.10 on the following pages. ( SAL 000109097 I REQUEST FOR WAIVER OF COMPLIANCE i ABERDEEN PVC PLANT 1. Name And Address Of The Owner Conoco Chemicals Company P. 0. Box 91, New Highway 25 Aberdeen, MS 39730 2. Location Of The Source The Aberdeen PVC Plant Is located at: Lat. N 33 48 min. 32 sec. Lon. W 88 32 min. 33 sec. In the City of Aberdeen in the County of Monroe In the State of Mississippi. 3. Type of Hazardous Pollutant Emitted The Aberdeen PVC Plant, in the course of its normal operations, emits vinyl chloride monomer. On December 24, 1975, under section 112 of the Clean Air Act, the Environmental Protection Agency added vinyl chloride to the list of hazardous air pollutants. 4. Description Of The Stationary Source ' Please refer to Attachment A for a description of the nature, size, design, and method of operation. 5. Weight Of Material Processed In Past 12 Months Please refer to Attachment B for historical operating rate data for the Aberdeen Plant. 6. Description Existing Control Equipment Please refer to Attachment C for information concerning existing control equipment for each emission point. 7. Statement Regarding Compliance Compliance with all facets of the EPA regulation will not be possible by January 20, 1977. Additional time is required to install the control systems, optimize their operation and conduct the testing required to prove compliance. SAL 000109098 J. Continued As the Aberdeen Plant will not be In compliance as of January 20, 1977, we request the EPA to grant us a waiver for a period during which operating and equipment modifications, which are now in progress, will be completed. Based upon our best Information upon requirements for process design calculations, mechanical design engineering, vendor delivery data, startup debugging and compliance testing, all necessary equipment for total plant compliance will be Installed and fully operational by Hay 1, 1978. Between May 1, 1978 and June 1, 1978 we will prepare an Emission Testing Program to prove compliance and will submit this to the EPA for approval. Emission testing to prove compliance will commence on July 1, 1978. The plant will have completed all testing proving compliance with all areas of the emission regulation by August 1, 1978. Our schedule is to submit our emissions report including all data and calculations showing that compliance has been achieved by August 31, 1978. In support of our request for a waiver we are Including the following: Attachment D - Compliance Plan For each emission limitations this section contains the following data: Emission Limitation Requirement Emission Sources Applicable Compliance Action Compliance Schedule Interim Control Steps As indicated in Attachment D, we intend to commence compliance testing as of July 1, 1978. At that time all control devices will be opera tional. In the interium period we will be obtaining data and reporting this information. We assume that the attached information is sufficient so that the EPA will grant us a waiver of emission test ing per 40 CFR 61.13 until such time as all control systems are operable. 5^V O*9 ( REQUEST FOR WAIVER OF COMPLIANCE ABERDEEN FVC PLANT ATTACHMENT A DESCRIPTION OF THE STATIONARY SOURCE I SAL 000109100 ( 1. General The Aberdeen Plant Includes facilities to produce polyvinyl chloride resins, PVC compound, PVC dry blend and plasticizer. The compound, dry blend and plasticizer operations are downstream operations which do not involve vinyl chloride monomer but only the further processing of the resin product. Thus, these operations are not relevant to the compliance plan on VCM emissions. The Plant has the capability of producing 1 MM pounds per day (350 MM pounds per year) of PVC resin. Existing operating permits for water effluent limitations (NPDES Permit No. 0001970) and particulate emission limitations (Mississippi Air and Uater Pollution Control Commission Permits No. 1673, 1674, 1675 and 1676) are based upon this operating rate which was demonstrated on a daily basis in late 1974. The Plant has not functioned at its design capacity during either 1975 or 1976. Massive plant changes have been in progress during this period relative to meeting OSHA limits on employee VCM exposure and anticipating the EPA regulations on atmospheric emissions. These changes have necessitated the temporary shutdown of approximately 50% of the Plant's reactor facilities for revisions. We anticipate resuming full operation at design capacity during 1977. 2. Size a) Vinyl Chloride Monomer Unloading Vinyl Chloride is received into the plant in railcars. The plant has six unloading spots for such railcars. Maximum unloading capability is about 1.5 Ml pounds per day or 525 Ml per year. The monomer is stored in two bullets and in a large sphere at the unloading site. Total storage capacity is approximately 6 Ml pounds. This represents 6 days storage at the plant design capacity of 350 Ml pounds per year. b) PVC Polymerization Capacity The plant attained its full design polymerization capacity in late 1974. This capacity was approximately 1 Ml pounds per day or 350 MM pounds per year. At that time, the plant was operating 44 polymerization reactors; 40 of these were 2200 gallon, glass lined reactors. The remaining four were 18000 gallon, electropolished, stainless steel reactors. In early 1975, in response to a slack market demand, the 40, small, 2200 gallon reactors were temporarily shutdown. Various engineering feasibility studies were conducted regarding the necessity to reduce employee exposure to VCM and in anticipation of the EPA regulations on emissions. These studies concluded that due to limitations of design, the multitude of point emission sources and the manual nature of the operation, the eventual compliance with OSHA and EPA restrictions was uncertain. Control of emissions in the large reactors was deemed SAL 000109101 far more manageable due to design considerations and automated control systems. As a result of these various studies it was determined to tem porarily restrict production to approximately 50Z of design capacity. The 40, 2200 gallon reactors were permanently shutdown. Engineering efforts for VCM containment have been concentrated on the large, 18000 gallon reactors. The temporary production loss will be re gained through installation of four additional 18000 gallon reactors. This work is now in progress. It will be completed and full productivity will be restored at design capacity during 1977. At that time, the polymerization facilities will consist of eight 18,000 gallon reactors. c) PVC Drying Capacity The plant has seven, rotary, gas fired dryers. Each has a capacity of 50 MM lbs./Yr. for the full rated design capacity of 350 MM Lbs./Yr. d) Product Storage Capacity The PVC resin product is shipped from Aberdeen in railcars, in trucks and in bags. Silo storage is 4.6 MM lbs. Warehouse space for bag material is approximately 50 MM pounds in internal and leased storage. e) Other In addition to PVC resin production, the plant operates two PVC compound lines, a dry blend facility and a plasticizer manufacturing plant. The rated capacities of these units are: --v . Compound Dry Blend Plasticizer - 85 MM Lb./Yr. 40 MM Lb./Yr. 40 MM Lb./Yr. 3. Design and Method of Operation Section 1 of Attachment D contains an overall process flow drawing for the Plant. This drawing also shows how the major emission control systems for vent gas incineration, in process waste water stripping, slurry stripping and fugitive emission recovery will be integicated into the overall plant operation. a) Vinyl Chloride Monomer Unloading Attached Figure 1 depicts the Vinyl Chloride unloading operation. Vapors from the sphere are compressed with Corken compressors. The pressurized gas flows to the railcar and forces the liquid to flow to one of the two VOI liquid storage bullets. The liquid from the bullets is periodically pumped to the 15,000 barrel storage sphere. SAL 00010910 The Aberdeen Plant has the capability of producing 1 MM pound per day of PVC resin. This is true of all plant facilities excepting poly merization capacity. All other plant facilities, including VCM unloading, PVC slurry storage, PVC dryers, PVC silo storage, PVC bagging equipment, particulate emission abatement equipment and water pollution treatment facilities were designed to be functional at the 1 MM pound per day rate. The polymerization facilities have been undergoing upgrading changes since 1972. Reactor facilities to 'function at the 1 MM pound per day rate were in place in late 1974. However, polymerization capacity has, since eaTly 1975, been limited to 550 M pounds per day as a. result of substantial plant changes necessitated by the OSHA standard and in anticipation of the EPA regulations. These changes will be completed and full productivity restored at 1 MM pounds per day in late 1977. In 1972 the Aberdeen Plant consisted of three reactor buildings (V-10, V-ll, and V-12) each consisting of twenty polymerization reactors. In addition, the plant had a single, large experimental reactor (D-300) involving technology developed in the Aberdeen Plant. 1972 Capacity In Polymerization V-T6 65 m Lb./Yr. V-ll 65 M4 Lb./Yr. V-12 75 M4 Lb./Yr. D300 30 m Lb./Yr. Total 235 m Lb./Yr, At this point, a plan was developed to increase and modernize the reactor facilities to achieve a 375 MM pound per year production. Extensive, simultaneous changes in dryers, silo storage and unloading facilities were also planned. The first step in this program involved the shutdown of the 20 small reactors in the V-10 building, the addition of another large reactor (D-400) and debottlenecking of the V-12 small reactors and the two large reactors. This step was completed by 1974. 1974 Capacity In Polymerization V-10 Shutdown V-ll 65 M4 Lb./Yr. V-12 100 MM Lb./Yr. D300/D400 100 KM Lb./Yr. Total 265 MM Lb./Yr. The next step was to complete debottlenecking of the V-ll small reactors and to add two additional large reactors (D500 and D-600). This modification was completed in December 1974. Changes in auxiliary facilities (dryers, silos, etc.) were also completed in 1974. SAL 00010910 Period July 1974 Aug. 1974 Sept.1974 Oct. 1974 Nov. 1974 Dec. 1974 Jan. 1975 Feb. 1975 Mar. 1975 Apr. 1975 May 1975 June 1975 July 1975 Aug. 1975 Sept.1975 Oct. 1975 Nov. 1975 Dec. 1975 Jan. 1976 Feb. 1976 Mar. 1976 Apr. 1976 May 1976 June 1976 July 1976 Aug. 1976 Sept.1976 Oct. 1976 TABLE 5 HISTORICAL OPERATING RATE DATA ABERDEEN PVC PLANT VCM Unloading PVC PVC PVC Resin Dry Blend Compound 23.6 22.7 22.1 25.3 21.0 13.7 22.0 22.2 20.7 23.9 20.0 12.1 3.3 3.1 2,7 3.0 1.4 0.6 6.9 6.2 6.0 4.3 1.8 1.3 9.4 2.9 10.7 12.9 8.9 11.2 9.0 2.8 10.3 12.1 8.7 10.4 1.2 0.4 1.0 1.8 2.1 1.6 1.4 1.3 1.1 1.3 1.3 1.9 9.3 8.4 9.0 13.4 10.2 16.5 8.8 8.1 8.7 13.0 9.8 15.9 0.3 0.2 0.6 0.8 0.9 1.7 2.8 2.8 2.3 3.9 4.0 4.7 11.5 13.3 15.8 15.2 16.9 12.4 11.1 13.2 15.5 14.6 17.1 12.5 2.3 2.2 3.0 3.1 3.1 3.2 2.6 1.9 2,9 2.2 2.6 2.1 15.3 15.9 15.3 16.1 15.1 15.8 14.9 15.8 2.4 2.8 3.0 2.7 2.7 2.9 3.1 2.7 Plasticizer 2.2 1.8 2.0 1.2 1.0 0,4 0.0 0.3 0.6 0.4 0.4 0.8 1.8 1.3 0.9 0.0 0.6 0.9 0.8 0.7 1.1 0.6 1.1 0.8 0.7 1.3 0.9 1.0 Total Product 34.4 33.3 31.4 32. 24 2 14.4 11.6 4.8 13.0 15.6 12.5 14.7 13.7 12.4 12.5 17.7 15.3 23.2 16.8 18.0 22.5 20.5 23.9 18.6 20.9 22.8 21.9 22.2 Avg. for Last 12 Months 14.5 14.3 2.5 2.9 0.9 20.6 SAL 000109104 1974 Capacity In Polymerization V-10 Shutdown V-ll 100 m Lb./Yr. V-12 100 MM Lb./Yr. D300/400/500/600 175 m Lb./Yr. 375 Wl Lb./Yr. The plant considers its design capacity as based upon the above figure. During late 1974, it became clear that major process alterations would be needed to meet OSHA limitations in all plant areas. After several studies of methods of meeting OSHA requirements and of anticipating EPA regulations, decision was made to significantly change the polymerization reactor facilities. Production capability was temporarily cut in half ' to permit the changes. The changes were: 1. Permanent shutdown of the 20 reactors in the V-ll facility. 2. Permanent shutdown of the 20 reactors in the V-12 facility, 3. Replacement of the forty small reactors with 4 large reactors. This program is now in progress. Completion is scheduled for late 1977. The status of plant polymerization will then be: 1977 Capacity In Polymerization V-10 Shutdown V-ll Shutdown V-12 Shutdown Replacement Reactors 175 M4 Lb./Yr, D300/400/500/600 175 MM Lb./Yr. Total 350 MM Lb./Yr. ( SAL 000109105 SAL 000109106 t / 1 This node of unloading railcars continues until as much liquid as possible has been driven with the pressurized vapor from the rail- ! car. Completion of this step is indicated by vapor flow in the i liquid unloading line which is visually observed via a sight flow glass. At this point, the operator lines up to pull vapors from the rail cars via the Corken compressors and push these vapors into the bullets. This mode of operation continues until the railcar pressure drops to 10 pslg. At this point, unloading is complete. The railcars are isolated, the compressors shutdown and the lines to the railcars disconnected. The unloading system utilized three Corken compressors and six unloading spots for railcars. The system is capable of trans ferring 1.5 MM pounds per day of VQi to storage from railcars. VCM for the sphere is transferred to the reactor area via pumps. The pumps are automatically started and stopped as required to supply the operating area. The point emission sources of vinyl chloride in the railcar unloading area are identified on Table I. b) PVC Polymerization ( This area of the plant clearly is the major area where emissions can occur. This is also the area which is most specifically regulated within the emission standard. To simply the discussion of this area of the plant, it is sub divided into three segments. (i) Reactor Charging System The reactor charging system consists of those operations and that equipment associated with the filling of the polymerization reactors. At the full design capacity of the plant, the polymerization facilities will consist of eight reactors. They will be sep arated into two modules of four reactors each. Each module will have a separate charging system. The operation of each of the two charging systems is identical. Figure 2 depicts the process flow of the Reactor Charging System. VCM from the unloading area is batch transferred to the fresh VCM receiver which is large enough for one reactor batch (approximately 60,000 pounds). 0001091 Recycled VCM is unreacted monomer which is collected at the end of the reaction process. This material is contained in the recovered VCM receivers. It is batch transferred to the fresh VCM receiver by the recovered VQi pumps. This material is filtered during the transfer. Approximately 10-30Z of the VCM charged to the reactor is recycled material. .oc CVB f4 X 0 0 0 c *4 H 0oe 0 m4 0) 44 4 0 44 0 u CCMB S. ub o> b b0 9 O0 CM H C CU 44 o B <b ^4 09 4J 44 o0 u H K <0 os b OOB OB 9 OB O b 0 O 9C c4o 00 44 ^a4; OB 01 b gou- b4) 40C4D X .H OB *b cb b 0u00> a. CB X9> e r34 O eo b 0 o o o 0 CM 0> ft* b 45 OB 0 OB 0 1 0> 44 > 0> 0> X OB a. <o44 fb *b *H a00 U OB O *4 >>>> 01 > 6o m b 44 CU tu b 4o4 a b 0 *4 0) ul 0 44 0) CM 0) 44 u/ ^4 b ^4 b -< 01 0) <u OS oB os os 3 C O k fa5af,. * 404 r9-l Ve X *H 0) *9 b as C X a OB OB b O OB OB a> OB "O 01 9b tb a U B MO > s m\o sO <0 > * mco cO u m co *m XX mm cmo mce CO cO TABLE 1- POINT SOURCES VINYL CHLORIDE MONOMER UNLOADING ABERDEEN PVG PLANT os 6 eo S S oH I 4e0 H 44 0 44 3 CM 5 8 S 6I > s 59 sc $ c/1 co t SAL 000109108 The actual charging of the reactor is a completely automated process. Solid state, programable control systems start and stop pumps, open and close valves and control material quantities. When all safety and operating interlocks are satisfied, the operator pushes a single start switch to initiate the various charge functions. VC34 is pumped from the fresh VCM receiver through the charge filters to the reactor. Appropriate quantities of water and suspension agents are added simultaneously. When the selected quantities of these materials are in the reactor, the transfer pumps are stopped and the systems iso lated via the programed control system. The reaction initiating agent is then pressured into the reactor with high pressure water. The point emission sources of vinyl chloride associated with the Reactor Charging System are identified on Table 2. ii) Polymerization Reactors Figure 3 illustrates a typical polymerization reactoT. The reaction of vinyl chloride to form PVC resin is carried out in eight, 18,000 gallon polymerization reactors. Each reactor is equipped with an agitator for mixing and a condenser for cooling during the exothermic reaction. Cooling is also supplied to a jacket on the vessel. -- As mentioned previously, the plant is now functioning at about 50% of design capacity. Thus only four reactors are now operating. The additional four reactors will become operational late in 1977 when the plant regains the capacity which was temporarily lost when the 40 small reactors were shutdown. The physical properties of the product of the suspension poly merization are controlled by several factors. Among these are temperature conditions, amount of suspension agent, additives, and conversion. Reactor cleanliness prior to reaction is essential for product quality reasons. The reactor Is first thoroughly cleaned with an extended hot water or hot chemical rinse. All air is then removed from the vessel with steam jet ejectors. The vacuum is then broken with vinyl chloride vapor and the reactor is charged with ingredients as previously described. The reaction is initiated with a peroxide catalyst. Inert gases, mostly CO-, accumulate in the top of the reactor and are purged to facilitate temperature control. One sample of resin per batch is withdrawn and examined under a microscope. The completion of the reaction is signaled by a drop in pressure in the reactor. At a specified condition for each resin grade, a reaction terminating chemical is pressured into the reactor SAL 000109110 s( Cl at h* C3D 28 ct e hat Cl Cl I Cl - u-i as e eg 0e1 uaI c>d e > 09 3 4a0 i w>aH| MDat fHea0oV1 01 Cl O 0a1 ic-*i oo cu B oeeo eo mmm H>at Q Ha0>t H>at (D >>> 4- 4) 41 4> oait at os at ea Ceoi at > uat at Cl oe 09 CD e >at m ma 13a * CCDl CD ai at CU00>H11l *-He4 caQ *iCa3t-ltl iCHcC0a1ll Me *hci Cati JaSt CCDl e at ha0 "CeHl at a Catl o jczi Cati 3o CaDt 3 *H h ec MB C9D iu o CC85ll JoO BH 09 HCaatl 3B3uBCl Cl CCDl >aHt Ca0)tl at ct cat ct 4k VO i rH vO *4 4k <n * *o oO *m ia A vo SO rH vO SO <v- c m sO pv ON * m 4 4k .0 o WO * 4k 4k 4k IA IA lA A SC SO vO vO H f-4 M H SO vO NO vO TABLE 2- POINT SOURCES REACTOR CHARGING SYSTTO ABERDEEN PVC PLANT 5 6 e >at I m e h at l AJ S * aat Muoae. SAL 000109.111 sal 00109i13 with water. At this point the process of recovering unreacted vinyl chloride and of stripping the reactor contents is initiated. The monomer recovery system which consists of compressors and vacuum pumps remove unreacted material. Simultaneously steam is injected directly into the reactor contents. The mass in the reactor is heated above the glass transition point of the resin thus releasing most of the vinyl chloride trapped within the resin particle. At the conclusion of the monomer recovery and slurry stripping operation the contents of the reactor are dropped through a screener and pumped to the blend tanks for eventual drying in the rotary dryers. The reactor now is cycled to the clean ing phase and the process restarted. The point emission sources of vinyl chloride associated with the polymerization reactors are identified on Table 3. iii) Monomer Recovery System The Monomer Recovery System collects, compresses and condenses unreacted vinyl chloride. The vinyl chloride is subsequently reused in the polymerization reactors. Figure 4 depicts the Monomer Recovery System. At the initiation of the reactor recovery step, the unreacted vinyl chloride will flow to the Cooler Scrubber. The pressure at the Cooler Scrubber is controlled at less than 40 psig so as to not over pressure the compressors. The Cooler Scrubber knocks out any entrained resin and condenses water by direct contact during steam stripping. The cooling is facilitated by circulating water through a water cooler exchanger. A second K. 0. Scrubber provides additional cooling and carryover knockout volume prior to the compressors. During the Initial phase of recovery down to a reactor pressure of about 10 psig the compressors operate alone. In the final phase, below 10 psig, the compressors operate in series with vacuum pumps. Both machines are liquid ring sealed with re circulated seal water. The seal water is separated at the outlet of the compressors In a seal water separator. The water is circulated, with a pump, through a cooler, back to the vacuum pumps and compressors. The recovered VCM vapor exits the separator and flows to the condensers. The condensed VCM flows into a collection tank and then is pumped back to the Recovered VCM Receivers. SAL 000109113 oc e ( ss >o mi O9 Ml X a9 aO I TtrJvl 9bO 9 H Mi mi Mi CO o Ml . ao t- w r Mi 9 H 9 8 9 U o 99 6 9 Mi h 9 Xo Ml a to ^8 V *H MUl Ml MJ M X 2L* 9 9 ae H Ml Ml Ml T3 JO 9 O9a MOl mi Mi 9 99 x Mi 9 9 9 Ml X 9 9 9 9 U I9- U a9 B) MJ eo cn Mi Mi Mi 9O U M 06 g Cm ec e9 ae *"1 -H A* H O9 C *H *-4 9B B 8 X) U c *w *A9-<t <H U > 9O O gs e sMI 6 Ml -I 9 A4 "O 9 -rt XM 8C eo Ml 9 C H 99 ft 9 At 9 g-. 6> m a-sI o Ml Ml U9 9 TJ 96 B 9 * 9 "a. "5 38 9X 9 *4 8& ( Mo 1 <M fO * * *o sr SO vO sO sO H X H (*1 9 9X X m xx xm XXX X H X 9 9 sMl Ml f9t CO O X -9 Mel 3 X 9 -CHJ 9 *MOi > Ml 9 > a &a pH 9 H 9 co as 9 9 60 nn xx 9 00 f 000!>tu sa/_ 000U>91 ls Some amount of water is accumulated in the Cooler Scrubber, K. 0. Scrubber, and Seal Water Separators. This water is drained off manually or automatically. The point emission sources of vinyl chloride associated with the Monomer Recovery System are identified on Table 4. iv) PVC Dryers Figure 5 shows this part of the plant production process. The PVC slurry, following reactor recovery and slurry stripping, fall through a Sweco strainer. Oversize material is removed from the product. The slurry is pumped to slurry blend tanks to even out batch to batch polymerization variations. Slurry is pumped from the blend tanks to one of seven dryer trains. Each train consists of one centrifuge, to produce a wet cake with 25Z moisture, and a rotary, direct fired dryer. The dryer uses cocurrent air flow and dries the proauct to less than 0.3% moisture content. The material is batch conveyed from the dryer to bagging, storage silos or transportation vehicles. The plant's program to contain VCM will result in these sources" hot being subject to EFA regulation as the plant will strip Slurry to a 400 ppm level in the polymerization reactors. v) Other The plant has other processes for manufacture of PVC Compound (85 MM lb./yr.), PVC Dry Blend (40 MM lb./yr.) and plasticizer (40 MM lb./yr.). These processes are downstream operations and will not be relevant to the Vinyl Chloride Emission Standard. 0001 09 i SAL 000109H7 SAL Olo 9Uq REQUEST FOR WAIVER OF COMPLIANCE ABERDEEN PVC PLANT ATTACHMENT B WEIGHT OF MATERIAL PROCESSED IN LAST 12 MONTHS SAL 0001091 ( REQUEST FOR WAIVER OF COMPLIANCE ABERDEEN PVC PLANT ATTACHMENT C DESCRIPTION OF EXISTING CONTROL EQUIPMENT ( ( SAL 000109120 r i The designation of primary and secondary control devices does not appear applicable in this case. The plant, however, has installed and is now operating systems to control emissions from various sources. i 1. Reactor Slurry Stripping System PVC resin is now steam stripped in the PVC reactors during the reactor recovery step. The slurry is heated to a temperature in excess of 100C and held for a period of time. The direct injection of 150 psig steam into the slurry is used. Prior to starting this procedure the PVC slurry was typically 15000 ppm of vinyl chloride in the resin. Currently our data indicates a value of 360 ppm. Both values are on a dry resin basis. The * estimated control efficiency is 97.6%. 2. Reactor Opening Loss An indirect effect of steam stripping in the reactors is a reduction of vinyl chloride emitted to the atmosphere as a result of reactor opening. Prior to stripping, the vapor space above the slurry contained essentially 1002 vinyl chloride vapor at a pressure of 10 in Hg vacuum. Under stripping conditions, this vapor-is displaced'to'the monomer recovery system with water vapor emanating from the water/PVC slurry. The estimated control efficiency of this procedure is 93.62. 3. Manual.Vent From Reactor The reaction process employed in the plant involves condenser cooling for process control. Decomposition of the catalyst and deareation of reactor contents result in 02> N? and CO2 accumulating on the top of the reactor. This accumulation limits heat transfer. These inerts must be purged off the condenser so that proper process control can be maintained. Previously, this stream was purged to the atmosphere for aperiod of 60 seconds per batch. Revisions have been made so this stream is directed through an enclosed system to the monomer recovery system. The estimated control efficiency is 100%. 4. Vent Gas Refrigeration The inert gases described above, as well as other inert gas sources which result from vessel clearing and vacuum recovery all are now directed to the recovered monomer receivers. Periodically these inerts must be bled off to avoid over pTessuring the vessel. Previously, this was done directly to the atmosphere at a vessel pressure of 75 psig. The plant has now installed a vent gas refrigeration unit. This system cools, condenses and collects vinyl chloride from'this stream. Estimated control efficiency is greater than 98%. 5. Relief Valve Discharge The plant experiences periodic power failures due to severe weather, etc. Typically, two such power outages occur per year. Previously this occasioned the emission of substantial quantities of vinyl chloride i sal OOQj 09.z 2l from relief valves on the reactors. The plant has now installed a reaction killing system to stop the reaction so that no emissions occur during power failures. Estimated control efficiency should be 100%. 6. Magnetic Gauges on Railcars The plant does not use the level devices on the railcars. No emissions occur from this source. In any event, magnetic devices which eliminate emissions are being installed on all railcars in VCM service. 7. Reactor Agitators All polymerization reactors in vinyl chloride service are equipped with agitators with double mechanical seals. 8. Reactor Relief Valves All relief valves on the reactors are equipped with rupture disks. 9. Sphere Relief Valves The two relief valves on the VCM storage sphere are equipped with rupture disks. 10. Process Waste Water Stripping Water accumulates in the recovery system during the reactor stripping operation. In addition, water accumulates in the recovered monomer receivers and is used for the purpose of vessel clearing. This water Contains about 1000 ppm in an unstripped condition. This in process waste water is directed into a stripping tank and stripped to the recovery system with direct injection of steam. Estimated control efficiency is 96%. ( SAL 00010912 ( ATTACHMENT D COMPLIANCE PLAN CONTROL OF VINYL CHLORIDE EMISSIONS CONTENTS 1. GENERAL DISCUSSION 2. SPECIFIC SOURCE COMPLIANCE a) Reactor Exhaust Gases b) Reactor Opening Loss c) Manual Vent Discharge d) Exhaust Gas Discharge e) Monomer Recovery System ) Sources Following Stripper g) Relief Valve Discharge h) Loading And Unloading Lines 1) Rotating Pump Seals j) Rotating Compressor Seals k) Reciprocating Compressors l) Agitator Seals m) Relief Valve Leakage ( n) Manual Venting o) Equipment Opening p) Samples q) In Process Wastewater 3. GENERAL COMPLIANCE SYSTEMS a) Vent Gas Emission Recovery System b) Vent Gas Refrigeration c) Vent Gas Incineration d) Process Wastewater Stripping 4. LEAR DETECTION PROGRAM 5. EMISSION TEST PROGRAM 6. ANALYTICAL METHODS SAL 000109123 ATTACHMENT D COMPLIANCE PLAN SPECIFIC SOURCE COMPLIANCE a) Emission Limitation Requirement: Reactor Exhaust Gases The concentration of vinyl chloride in exhaust gases discharged to the atmosphere from each reactor is not to exceed 10 ppm except as other wise provided. Emission Sources Applicable At full design capacity the plant will have eight operating polymerization reactors, four in each module. These reactors utilize top mounted con densers for reactor cooling. As a result of catalyst decomposition, inerts, mostly CO2, accumulate In the condenser and must periodically be purged to maintain reactor control. 1. Module No. 1 Reactor Inerts Vent (4) 2. Module No. 2 Reactor Inerts Vent (4) Compliance Action These vents were previously purged to the atmosphere. System modifications on Module No. 1 now vent this stream to the RVCM receivers where it Is now treated via refrigeration. A similar system will be Installed on Module No. 2 prior to resuming this operation. Eventually the emissions from the refrigeration system will be treated via incineration. Compliance Schedule The following compliance schedule refers to Installation of the inert gas vent collection system. Final compliance will await completion of the incineration project as described in the '^General Compliance System" section. Module No. 1 Module No. 2 Process Design Completion: Mechanical Design Completion: Equipment Ordered: Installation Initiated: Installation Completed: Compliance Achieved: Interim Control Steps Complete Complete Complete Complete Complete Complete January, 1976 April, 1977 May, 1977 April, 1977 December,1977 January, 1978 Module No. 1 now contains this emission source as described above. Module No. 2 will not operate until a similar containment system is in place. SAL 00l09l  ( ATTACHMENT D 2. SPECIFIC SOURCE COMPLIANCE COMPLIANCE PLAN c) Emission Limitation Requirement: Manual Vent Discharge Except for an emergency manual vent valve discharge, there Is to be no discharge to the atmosphere from any manual vent valve on a polyvinyl chloride reactor. Emission Sources Applicable 1. No. 1 Module Reactors (4) 2. No. 2 Module Reactors (4) Compliance Action The only normal reactor vent was previously described. The plant has developed a reaction kill system. This system is completely effective and should prevent emissions In a power failure situation. Compliance Schedule None Interim Control Steps None SAL 0001091 ( ATTACHMENT D I i 2. SPECIFIC SOURCE COMPLIANCE COMPLIANCE PLAN d) Emission Limitation Requirement: Exhaust Gas Discharge The concentration of vinyl chloride In exhaust gases discharged to the atmosphere from mixing, weighing and holding containers in vinyl chloride service are not to exceed 10 ppm. Emission Sources Applicable 1. Sphere Vent 2. Tank Farm Bullets Vent 3. Recovered VCM Receiver Vent Compliance Action The sphere and the tank farm bullets are vented very infrequently. A header system will route these vents to the atmospheric collection system in the tank farm area. From this system the vent gases will be contained by the Emission Recovery System as described in "General Compliance Systems". ( All vent gases will be routed to the Recovered VCM Receivers. Here these vapors will be refrigerated to remove as much vinyl chloride as possible. They will then flow on pressure control to the incineration system where final treatment to 10 ppm will occur. The refrigeration system and incineration system are described in "General Compliance Systems". Compliance Schedule The following schedule applies to the installation of the vent gas header system. The schedule for incineration is described in "General Compliance Systems". Process Design Completion: Mechanical Design Completion: Equipment Ordered: Installation Initiated: Installation Completed: Compliance Achieved: January 1, 1977 October 1, 1977 October 1, 1977 October 1, 1977 December 1, 1977 February 1, 1978 Interim Control Steps The vent gas refrigeration system is in place and operating to reduce emissions. S$L ooi 6 ATTACHMENT D I SPECIFIC SOURCE COMPLIANCE COMPLIANCE PLAN e) Bnlssion Limitation Requirement: Monomer Recovery System The concentration of vinyl chloride in exhaust gases discharged from each monomer recovery system is not to exceed 10 ppm. Bnlssion Sources Applicaple The plant will, at its full operating condition, have three monomer recovery systems: 1. Module No. 1 Recovery System 2. Module No. 2 Recovery System 3. Bniaslon Recovery System Compliance Action Any vents from (1) and (2) will discharge into the RVCM receivers. They will subsequently be treated by refrigeration and incineration as described under "General Compliance Systems". The vent from (3) will also be routed to the RVCM receivers in Module No. 1 and will be similarly treated. Compliance Schedule The recovery system vents are now routed as described above. No com pliance schedule is applicable. Interim Control Steps None SAL 000109127 ATTACHMENT D COMPLIANCE PLAN SPECIFIC SOURCE COMPLIANCE f) Emission Limitation Requirement: Sources Following Stripper In pisnts using stripping technology the weighted average residual vinyl chloride in the resin processed thorugh the stripper may not exceed 400 ppm. Bnlasion Sources Applicable The controlled source of emissions in this case is the slurry that exists in the reactor at the end of the recovery steam stripping step. 1. No. 1 Module Reactors (4) 2. No. 2 Module Reactors (4) Compliance Action The plant steam strips the reactor slurry in the reactor during the recovery process. 150 pslg steam is directly Injected into the slurry. The material is heated to a temperature above the glass transition temperature of the resin. The slurry is held at this condition =and at a vacuum to remove the vinyl chloride down to the 400 ppm level. Compliance Schedule The plant now steam strips each batch. Extensive data indicates a 400 ppm level is usually obtained. Further testing of operating and product quality parameters is now in progress. Module No. 1 Module No. 2 Process Design Completion: Mechanical Design Completion: Equipment Ordered: Installation Initiated: Installation Completed: Process Development: Compliance Achieved: February, 1975 March, 1975 March, 1975 April, 1975 October, 1975 Continuing June, 1977 January, 1976 April, 1977 May, 1977 November, 1977 December, 1977 January, 1978 Interim Control Steps The plant is usually obtaining the 400 ppm level on each batch. Module No. 2 will not be operated without steam stripping equipment. SAL. 0001091 ATTACHMENT D COMPLIANCE PLAN SPECIFIC SOURCE COMPLIANCE g) Emission Limitation Requirement: Relief Valve Discharge Except for an emergency relief discharge there is to be no discharge to the atmosphere from any relief valve on equipment in vinyl chloride service. Emission Sources Applicable As required by ASME code and other safety needs all equipment in vinyl chloride service are equipped with relief valves. These valves will only discharge in an emergency. Compliance Action None Compliance Schedule None Interim Control Steps None SAL- 0001091- ( ATTACHMENT D COMPLIANCE PLAN 2. SPECIFIC SOURCE COMPLIANCE h) Emission Limitation Requirement: Unloading Lines Vinyl chloride emissions from unloading lines which are opened after each unloading operation are to be minimized so the quantity of vinyl chloride released from each line is no greater than 0.13 cu. ft. (1 gal.) of vinyl chloride at standard temperature and pressure. Emission Sources Applicable The plant has six unloading spots for vinyl chloride railcars. Each spot has three lines which are connected to each railcar and are sub ject to this provision of the regulation. Compliance Action Valves will be installed at the ends of each line. The pressure between the valve on the end of the unloading line and the valve on the railcar will be drawn down by the Emission Recovery System (See "General Compliance Systems") so the amount of VCM released complies with the regulation. Compliance Source The following schedule applies only to the revisions to the unloading lines. The Emission Recovery System compliance schedule is included under "General Compliance Systems". Process Design Completion: Mechanical Design Completion: Equipment Ordered: Installation Initiated: Installation Completed: Compliance Achieved: January, 1977 October, 1977 October, 1977 November, 1977 March, 1978 May, 1978 Interim Control Steps Existing lines will be evacuated to 10 psig prior to c 000 J.09130 ATTACHMENT D COMPLIANCE PLAN 2. SPECIFIC SOURCE COMPLIANCE i) Emission Limitation Requirement: Rotating Pump Seals The emission standard demands that emissions from pump seals on pumps in vinyl chloride service be minimized by installing double mechanical seals. Pressure between seals is to be maintained so leakage is into process. Alternatively, any vinyl chloride between seals can be ducted through a control system. Emission Sources Applicable 1. Tank Farm Bullet Transfer Pumps (2) 2. Sphere Transfer Pumps (2) 3. No. 1 Module Charge Pumps (2) 4. No. 2 Module Charge Pumps (2) 5. No. 1 Module RVCM Pumps (2) 6. No. 2 Module RVCM Pumps (2) 7. No. 1 Module RVCM Transfer Pumps (2) 8. No. 2 Module RVMC Transfer Pumps (2) ( Compliance Action Double mechanical seals will be Installed on the above pumps. The vinyl chloride from items (1) and (2) will be ducted to an atmospheric pressure collection system, a refrigeration system and subsequently an incineration system. The ultimate emission location will be the exhaust gases of the incineration which will not exceed 10 ppm. The mechanical seals of item (3), (4), (5), (6), (7), and (8) will utilize high pressure water as the sealing fluid. This will mean any leakage will be into the pump. Compliance Schedule The compliance schedule for installing this control system is: Module No. 1 Module No. 2 Process Design Completion: Mechanical Design Completion: Equipment Ordered: Installation Initiated: Installation Completed: Compliance Achieved: December, 1975 September, 1976 September, 1976 November, 1976 August, 1977 October, 1977 January, 1976 April, 1977 May, 1977 Novenber, 1977 December, 1977 January, 1978 ( SAL 000109:131 I i) Continued Interim Control Steps No emissions will occur from items (A), (6), or (8) as Module No. 2 will not operate until double mechanical seals have been installed on these items. SAL 000109132 Continued 6. All emissions will be directed to the RVQf receivers in Module No. 1. These gases will lov through a refrigeration system to remove most of the vinyl chloride. Inerts with any remaining vinyl chloride will be bled to an incinerator system to distruct the vinyl chloride as required to a 10 ppm level. 7. Where possibly the plant will propose calculation procedures, operat ing conditions, and monitoring procedures to prove compliance. Section 2 of this compliance plan describes how each source will be contained. Schedules and Interim Control Steps are also indicated. Section 3 describes the central control systems which will be needed. Schedules and Interim Control Steps are also included. -v.- Section 4 describes the Plant's leak detection program which will be required by the Standard. The Compliance Plan also includes the Emission Test Program and Analytical Methods which are proposed to prove '.compliance. These methods are very similar, in most cases, to those included in the EPA's regulation. There are, however, some variations which the Plant requests the EPA accept ' - r as equivalent methods under paragraph 61.66. In addition, the plant proposes to delay emission testing to prove compliance till the appropriate time when compliance systems are functional and analytical equipment has been obtained. SAL 000109133 ATTACHMENT D GENERAL DISCUSSION COMPLIANCE PLAN The requirements Co achieve compliance with the VCM emission regulation ere very complex. A great number of emission sources must be collected, contained and treated. Some of the required systems in themselves produce compliance with the regulation. Examples of this are rupture disks under relief valves and double mechanical seals. A far greater number of required systems involve Interaction between equip ment and processes. The effectiveness of the reactor inert venting method may, for example, relate to the effectiveness of the water stripping operation. The net effect of these relationships cannot be demonstrated until all systems are operable. Attached Figure 1 illustrates each emission source in the plant. The interactions of each system are also indicated. Figure 2 Illustrates the overall process flow scheme for the plant. The following actions will be pursued by the plant to achieve compliance with the regulation: 1. Rupture discs will be Installed under relief valves. 2. Double mechanical seals will be Installed on pumps, compressors and agitators. 3. An Emission Recovery System will be Installed. This will collect and route all exhaust and vent gases to the R7CM Receivers: a) Unloading Line Vents b) . Samples c) Vessel Vents d) Equipment Opening Vents. e) Water Stripping Emissions f) Reactor Inerts Vent 4. A water stripping system (2) will be Installed. This will collect waters and strip them to 10 ppm. Water sources which will be collected are: a) Recovery System Drains b) Receiver Drains c) Seal Water Drains d) Water Drains From Equipment Opening 5. The reactor slurry will be batch stripped in the reactor to 400 ppm. Direct injection of steam will be used. The reactor will be held at a boiling condition to purge the vapor space with steam to meet the reactor opening requirement. SAL OOO109134 ( ATTACHMENT D COMPLIANCE PLAN 2. SPECIFIC SOURCE COMPLIANCE j) Billsa Ion Limitation Requirement: Rotating Compressor Seals The emission standard demands that emissions from rotating compressor seals on compressors In vinyl chloride service be minimized by Installing double, mechanical seals. Pressure between the seals is to be maintained so leakage is into the process. Emission Sources Applicable 1. No. 1 Module Vacuum Pumps (2) 2. No. 1 Module Compressors (3) 3. No. 2 Module Vacuum Pumps (2) 4. No. 2 Module Compressors (3) 5. Buission Rec. System Vacuum Pump (1) 6. Emission Rec. System Compressor (2) Compliance Action Double mechanical seals will be installed on all of the above items. ( In all cases,-high pressure water will be utilized as the sealing fluid. This will mean that any leakage will be into the process. Compliance Sdhedule The compliance schedule for installing this control system is: Module No. 1 Module No. 2 Process Design Completion: Mechanical Design Completion: Equipment Ordered: Installation Initiated: Installation Completed: Compliance Achieved: Interim Control Steps December, 1975 September, 1976 September, 1976 November, 1976 August, 1977 October, 1977 January, 1976 April, 1977 May, 1977 April, 1977 December, 1977 January. 1978 No emissions will occur from items (3), (4), (5), or (6). These items will not operate until they have been equipped with double mechanical seals. C SAL 000109135 / f ATTACHMENT D COMPLIANCE PLAN 2. SPECIFIC SOURCE COMPLIANCE k) Emission Limitation Requirement; Reciprocating Compressors VI117I chloride emissions from seals on reciprocating compressors are to be minimized by Installing double outboard seals. The vinyl chloride from between the seals is to be ducted to a control system, the emissions from which are not to exceed 10 ppm. Bnission Sources Applicable 1. Unloading Compressors (3) Compliance Action The crankcase and the area between the double seal packing will be vented to an atmospheric pressure collection system, a refrigeration system and subsequently an incinerator system. The ultimate emission location will be the exhaust gases of the incinerator which will not exceed 10 ppm. Emissions will not be controlled untiL the incinerator system ia complete. Present action involves installing the double distance pieces on the compressors. Other steps are the Emission Recovery System and Incinerator system the compliance schedules of which are indicated elsewhere. Compliance Schedule The compliance schedule for modifying the compressor crankcases, crank- _ . _ shafts and seals is as follows: Process Design Completion: Mechanical Design Completion: Equipment Ordered: Installation Initiated: Installation Completedr Complance Achieved: Januay, 1977 October, 1977 October, 1977 November, 1977 March, 1978 May, 1978 Interim Control Steps None sal 000.l09.f36 < I ATTACHMENT D COMPLIANCE PLAN SPECIFIC SOURCE COMPLIANCE m) Emission Limitation Requirement: Relief Valve T-paVnpp Vinyl chloride emissions due to leakage from relief valves on equip ment in vinyl chloride service are to be minimized by installing rupture disks under the relief valves or by routing the relief valve discharge into the process. Emission Sources Applicable 1. Unloading Area Equipment (10) 2. Module No. 1 Equipment (12) 3. Module No. 2 Equipment (12) 4. Module No. 1 Reactors (13) 5. Module No. 2 Reactors (12) Compliance Action On each of the above pieces of equipment rupture disks will be Installed . between the equipment and relief valve to minimize leakage. Compliance Schedule Process Design Completion: Mechanical Design Completion: Equipment Ordered: Installation Initiated: Installation Completed: Compliance Achieved: Items 1 and 2 January, 1977 July, 1977 July, 1977 September, 1977 November, 1977 November, 1977 Items 3 and 5 January, 1976 April, 1977 May, 1977 April, 1977 December, 1977 January, 1978 Interim Control Steps The two relief valves on the sphere in the unloading area now have rupture disks installed. All reactors in Module No. 1 have installed rupture disks. Items (3) and (5) in Module No. 2 will not operate until all rupture disks are in place. SQL ooi09l3? ( ATTACHMENT D COMPLIANCE PLAN 2. SPECIFIC SOURCE COMPLIANCE 1) Bnlssion Limitation Requirement: Agitator Seals Vinyl chlOTide emissions from seals on agitators in vinyl chloride services are to be minimized by installing agitators with double mechanical seals. If double mechanical seals are used, the pressure be maintained so any leakage is into the process. Emission Sources Applicable 1. D-300 Agitator 2. D-400 Agitator 3. D-500 Agitator 4. D-600 Agitator 5. D-701 Agitator 6. D-702 Agitator 7. D-703 Agitator 8. D-704 Agitator Compliance Action ( The above agitators will have double mechanical seals. The seals will utilize an external Duraseal unit. The seal oil pressure will be maintained so that any leakage is into the process. Compliance Schedule The compliance schedule for having all reactor agitators equipped with double mechanical seal systems is: Module No. 1 Module No. 2 Process Design Completion: Mechanical Design Completion: Equipment Ordered: Installation Initiated: Installation Completed: Compliance Achieved: Complete Complete Complete Complete Complete Complete January, 1976 April, 1977 May, 1977 April, 1977 December, 1977 January, 1978 Interim Control Steps Items (1), (2), (3), and (4) are now in operation and are in compliance. Items (5), (6), (7), and (8) will not operate until the compliance system is operable. SAL OOOlo?;i38 ( ATTACHMENT D COMPLIANCE PLAN SPECIFIC SOURCE COMPLIANCE m) Emission Limitation Requirement: Relief Valve Leakage Vinyl chloride emissions due to leakage from relief valves on equip ment in vinyl chloride service are to be minimized by Installing rupture disks under the relief valves or by routing the relief valve discharge into the process. Emission Sources Applicable 1. Unloading Area Equipment (10) 2. Module No. 1 Equipment (12) 3. Module No. 2 Equipment (12) 4. Module No. 1 Reactors (13) 5. Module No. 2 Reactors (12) Compliance Action On each of the above pieces of equipment rupture disks will be installed . between the equipment and relief valve to minimize leakage. Compliance Schedule Process Design Completion: Mechanical Design Completion: Equipment Ordered: Installation Initiated: Installation Completed: Compliance Achieved: Items 1 and 2 January, 1977 July, 1977 July, 1977 September, 1977 November, 1977 November, 1977 Items 3 and 5 January, 1976 April, 1977 May, 1977 April, 1977 December, 1977 January, 1978 Interim Control Steps The two relief valves on the sphere in the unloading area now have rupture disks installed. All reactors in Module No. 1 have Installed rupture disks. Items (3) and (5) in Module No. 2 will not operate until all rupture disks are in place. Q00109139 S AS- { ATTACHMENT D COMPLIANCE PLAN 2. SPECIFIC SOURCE COMPLIANCE n) Emission Limitation Requirement: Manual Venting All gases manually vented from equipment in vinyl chloride service are to be ducted to a control system the concentration of the exhaust gases from which is not to exceed 10 ppm. Emission Sources Applicable The sources of potential manual vents were described under d) previously. There are no other manual vents which are normally used in the operation of the plant. Compliance Action - None Compliance Schedule ( None Interim Control Steps None I f ( SAL 000109140 ( ATTACHMENT D 2. SPECIFIC SOURCE COMPLIANCE COMPLIANCE PLAN o) Emission Limitation Requirement: Equipment Opening Vinyl chloride emissions from opening equipment are to be minimized by reducing the vinyl chloride in the equipment to 2.0Z or 25 gal. of vinyl chloride at standard temperature and pressure. Bttission Sources Applicable All equipment in vinyl chloride service is subject to this part of the regulation. Compliance Action The plant is installing: 1. A vacuum header to the emission recovery system from all affected equipment. 2. Steam lines to all affected equipment. ( 3. Water lines to all affected equipment. Compliance will be achieved by filling the vessels with water, purging then with steam, and evacuation with the Emission Recovery System. Combinations of the above methods may also be used. Actual operation and testing will be required before the most effective method is identified. Eventually, the plant will develop a calculational method to insure that compliance is being obtained on each equipment opening. Compliance Schedule The following schedule applies to Installation of the vacuum recovery header and to steam and water lines to the equipment involved: Process Design Completion: Mechanical Design Completion: Equipment Ordered: Installation Initiated: Installation Completed: Compliance Achieved: February, 1977 July, 1977 August, 1977 October, 1977 December, 1977 March, 1978 Interim Control Steps None c 000.10914.t ATTACHMENT D COMPLIANCE PLAN 2. SPECIFIC SOURCE COMPLIANCE p) Emission Limitation Requirement: Samples Unused portions of samples containing 102 by weight vinyl chloride are to be returned to the process. Emission Sources Applicable 1. Fresh Monomer Sampling 2. No. 1 Module Charge Monomer Sampling 3. No. 2 Module Charge Monomer Sampling 4. No. 1 Module RVCM Sampling 5. No. 2 Module RVCM Sampling 6. No. 1 Module Reactor Sampling (4) 7. No. 2 Module Reactor Sampling (4) Compliance Action In each case above, process sampling systems will be installed. The sample will be circulated through a sampling bomb with the sample being recirculated to the process. The process lines will be evacuated prior to disconnect. Unused portions of samples will be returned to the process. Compliance Schedule The compliance schedule for each sampling system installation is as follows: Module No. 1 Module No. 2 Process Design Completion: Mechanical Completion: Equipment Ordered: Installation Initiated: Installation Completed: Compliance Achieved December, 1975 December, 1976 December, 1976 January, 1977 April, 1977 May, 1977 January, 1976 April, 1977 May, 1977 April, 1977 December, 1977 January, 1978 Interim Control Steps Samples will be taken only as absolutely necessary. No routine samples are Involved. SAL 0001091A ATTACHMENT D COMPLIANCE PLAN SPECIFIC SOURCE COMPLIANCE q) Emission Limitation Requirement: In Process Waste Water The concentration of vinyl chloride in each in process waste water stream containing greater than 10 ppm vinyl chloride is to be reduced to no more than 10 ppm before being exposed to the atmosphere. Emission Sources Applicable The following sources of water contain greater than 10 ppm vinyl chloride: 1. No. 1 Module KVQi Receiver Drains (2) 2. No. 2 Module RVCM Receiver Drains (2) 3. No. 1 Module Seal H2O Sep. Drains (2) 4. No. 2 Module Seal H2O Sep. Drains (2) 5. No. 1 Module K. 0. Drum Drains (2) 6. No. 2 Module K. 0. Drum Drains (2) 7. Displacement Steam For Equipment Opening 8. Displacement Hater For Equipment Opening Compliance Action Each of the above sources of in process waste water will be collected and drained to a vessel in which steam stripping of the water to achieve compliance will occur. There will be two such water stripping systems, one located in each module. Further discussion of the Process Haste Water Stripping is included under General Compliance Systems. Compliance Schedule The following schedule applies to Installation of the collection system for in process waste water: Module No. 1 Module No. 2 Process Design Completion: Mechanical Design Completion: Equipment Ordered: Installation Initiated: Installation Completed: Process Development: Compliance Achieved: Interim Control Steps Complete Complete Complete Complete Complete April, 1977 May, 1977 January, 1976 April, 1977 May, 1977 April, 1977 December, 1977 January, 1978 Items No. (1), (3), (5), and (7) are now being collected and stripped in a system as described under "General Compliance Systems". No excessive emissions will occur from items (2), (4), and (6) as Module No. 2 will not operate until its water stripping system is functional. SAL ATTACHMENT D f 3. GENERAL COMPLIANCE SYSTEMS COMPLIANCE PLAN ' The overall plan for achieving compliance with the emission regulations will require four final treatment systems. The specific source and collections systems were indicated in Section 2. The final treatment systems are described on the following pages. It should be noted that no interim control steps are applicable to these four systems. SAL 0109144 ATTACHMENT D COMPLIANCE PLAN 3. GENERAL COMPLIANCE SYSTEMS a) Vent Gas Emission Recovery System Purpose This system will provide a source of vacuum for various fugitive emission sources. The system will draw these emissions and compress them so they can be contained. The emission will be directed through condenser to the recovered VCM receivers in Module No. 1. The following sources will not be in compliance until this system is Installed: Tank Farm Pump Seals Tank Farm Compressor Seals Unloading Lines Samples Equipment Opening Vessel Vents ( Water Stripping Description An atmospheric pressure holding tank will be installed at the loading area to collect these vents. The Emission Recovery System will consist of one vacuum pump and two compressors. The machines will be liquid ring type with rouble mechanical seals. It will operate at a suction pressure of 10 in. Hg vacuum and discharge at 75 pslg. Compliance Schedule Process Design Complete: Mechanical Design Complete: Equipment Ordered: Installation Initiated: Installation Complete: Startup: January 1, 1977 October 1, 1977 October 1, 1977 November 1, 1977 February 1, 1978 March 1, 1978 SAL 000109145 ATTACHMENT D COMPLIANCE PLAN GENERAL COMPLIANCE SYSTEM b) Vent Gas Refrigeration Purpose As described earlier,. all vents will be directed to the Recovered VCM Receivers in Module No. 1. This point will serve as a collection point for vapor emissions. The Vent Gas Refrigeration will cool this stream to about 10F thus minimizing any vinyl chloride vented. Note that this subsequent vent will be to an incineration system. Description The refrigeration system consists of Knock Back condensers which are installed directly atop of the Recovered VCM Receivers. Cooling is supplied to the condensers via a Freon compressor refrigeration system. Compliance Schedule This system was installed in 1975 and is now operable. SAL OOGIO?!*6 ATTACHMENT D COMPLIANCE FLAN 3. GENERAL COMPLIANCE SYSTEMS c) Vent Gas Incineration Purpose As noted all exhaust and vent gases will be directed to the Recovered VCM Receivers in Module No. 1. These will then be treated via refri geration. The standard demands treatment to a 10 ppm level. The subsequent outlet vapors will be directed to an Incineration unit which will 'lower the vinyl chloride to the required 10 ppm level. In absolute terms no emission source involving vinyl chloride vapor recovery will be in total compliance until the incinerator system is installed and operating. Description The vent gases from the aforementioned refrigeration unit will flow to the treatment area. These will be burned to eliminate the vinyl chloride. The HCL will be scrubbed with HjO so as to minimize any HCL discharges. ( Compliance Schedule Process Design Complete: Mechanical Design Complete: Equipment Ordered: Installation Initiated: Installation Complete: Startup: April 1, 1977 December 1, 1977 January 1, 1978 April 1, 1978 May, 15, 1978 July 1, 1978 SAL 000109147 ATTACHMENT D COMPLIANCE PLAN GENERAL COMPLIANCE SYSTEM d) Process Water Stripping Purpose The emission regulations require that in process vaste water be treated to a 10 ppm level prior to discharge. This system will batch strip collected waters to the required 10 ppm level. The waters which will be collected are: Recovery K. 0. Tank Drains Recovery Seal HO Separator Drains Monomer Receiver Drains Drains From Equipment Opening Description Two water stripping systems will be installed, one in each module. The waters will be stripped with the direct Injection of steam into the vessels. Vapors will be collected and contained by the Vent Gas Emission Recovery System. Compliance Schedule Process Design Complete: Mechanical Design Complete: Equipment Ordered: Installation Initiated: Installation Complete: Startup: Module No. 1 November, 1975 February, 1976 February, 1976 February, 1976 May, 1976 June, 1976 Module No. 2 January, 1976 April, 1977 May, 1977 April, 1977 December, 1977 January, 1978 Note: No. 1 system is in place and operable although completion of the Vent Gas Emission Recovery System is needed before the water stripping will be fully effective. Module No. 2 will not operate until this system is installed. SAL 000109148 SAL 000109149 ATTACHMENT D COMPLIANCE PLAN 4. LEAK DETECTION PROGRAM The Plant's program for Leak Detection has been developed and previously given to the EPA on December 2, 1976. The same plan, except for correction of typographical errors, is Included on the following pages. ( ( SAL 00109], 50