OxyVinyls, LP Page 1 of 4 Alternative Monitoring Parameter Request

Deer Park/La Porte Texas August 21, 2014

ALTERNATIVE MONITORING REQUEST

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR

POLYVINYL CHLORIDE AND COPOLYMERS PRODUCTION

ADDENDUM TO THE SITE-SPECIFIC PERFORMANCE TEST PLAN

DATED JULY 30, 2014

OXY VINYLS, LP

DEER PARK AND LA PORTE, TEXAS

The Oxy Vinyls, LP (OxyVinyls) requests that the United States Environmental Protection

Agency (EPA) approve alternative monitoring parameters for demonstration of compliance with

the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Polyvinyl Chloride

and Copolymers Production. As stated in the reference Site-Specific Performance Test Plan

(Test Plan) submitted on 7/31/14, the Deer Park Plant is subject to the NESHAP for Stationary

Polyvinyl Chloride and Copolymers Production Area Sources (PVC Area Source NESHAP)

codified in 40 Code of Federal Regulations (CFR) Part 63 Subpart DDDDDD. The process

vents from the PVC production facility are controlled by two thermal oxidizers located at the

OxyVinyls facility in La Porte, Texas. The La Porte Plant is not a PVC production facility and is

therefore not subject to the PVC Area Source NESHAP. However, the thermal oxidizers are the

control device for the Deer Park Plant process vent gases.

Also as stated in the Test Plan submitted on 7/31/14, OxyVinyls intends to demonstrate

compliance with the emission standards of the NESHAP for Stationary Polyvinyl Chloride and

Copolymers Production Major Sources (PVC Major Source NESHAP) codified in 40 CFR

Part 63 Subpart HHHHHHH. The additional demonstration (for major source standard

compliance) is being included as a possible future scenario that the Deer Park Plant becomes

subject to the PVC Major Source NESHAP or other MACT requirements applicable to major

sources (e.g., EPA’s developing regulations for ethylene dichloride (EDC)/vinyl chloride

monomer (VCM) processes).

Therefore, in accordance with 40 CFR §63.8(f)(4)(i), OxyVinyls is submitting this request as an

addendum to the referenced Test Plan to propose alternative monitoring parameters for the

performance test (i.e., to establish operating parameter limits). If in the future Major Source

NESHAP requirements apply to the Deer Park and/or LaPorte Plants, this AMR may satisfy

applicable monitoring requirements.

As required by 40 CFR §63.11985(c)(5) and §63.8(f)(4)(ii), the following paragraphs present:

 A description of the parameter(s) to be monitored to ensure the control technology or

pollution prevention measure is operated in conformance with its design and achieves

the specified emission limit;

 An explanation of the criteria used to select the parameter(s);
OxyVinyls, LP Page 2 of 4 Alternative Monitoring Parameter Request

Deer Park/La Porte Texas August 21, 2014

 A description of the methods and procedures that will be used to demonstrate that the

parameter indicates proper operation of the control device, the schedule for this

demonstration, and a statement that OxyVinyls will establish an operating limit for the

monitored parameter(s) as part of the notification of compliance status if required in the

future under this subpart, unless this information has already been submitted;

 The frequency and content of monitoring, recording, and reporting, if monitoring and

recording is not continuous; and

 The rationale for the proposed monitoring, recording, and reporting system.

The Deer Park Plant PVC process vent is routed to the La Porte Plant, commingled with the La

Porte process vent streams, and controlled by two thermal oxidizers. The exhaust gas from

each thermal oxidizer is routed through a waste heat boiler and then a two-stage wet scrubber.

The lower section of the two-stage scrubber is an absorber that uses water to recover hydrogen

chloride (HCl) to produce hydrochloric acid for plant use. The upper section is a scrubber that

uses caustic and sodium thiosulfate to remove any remaining HCl and chlorine (Cl2) from the

exhaust gas before being exhausted to the atmosphere.

The following table presents the monitoring requirements in 40 CFR §63.11940(a-c). The

monitoring options selected by OxyVinyls in our current plan are indicted by bold face type.

Citation Option 1 (i) Option 2 (ii) Option 3 (iii)

§63.11940(a) Flow indicator on

intermittent stream

None None

§63.11940(b) Temperature in

oxidizer firebox or

in ductwork

immediately

downstream of

firebox

N/A – Applies to catalytic

oxidizers

N/A – Applies to

catalytic oxidizers

§63.11940(c)(1) Influent liquid flow

of absorber or

scrubber1

Influent liquid flow None

Influent gas stream flow

and liquid-to-gas ratio (l/g):

 design blower capacity

with adjustments for

pressure drop,

 measurement of gas

stream flow at absorber/

scrubber inlet, or

 previously determined l/g

from compliance testing, if

the conditions are

representative of current

operations
OxyVinyls, LP Page 3 of 4 Alternative Monitoring Parameter Request

Deer Park/La Porte Texas August 21, 2014

Citation Option 1 (i) Option 2 (ii) Option 3 (iii)

§63.11940(c)(2) Pressure at inlet and

outlet of absorber or

scrubber, monitoring

pressure drop

Scrubber gas stream exit

temperature, if ΔT

between inlet liquid and

inlet gas >38°C1

Specific gravity on

scrubbing liquid inlet

and outlet, if ΔP

≥0.2 specific gravity

units

§63.11940(c)(3)2 pH of scrubber

liquid effluent

Caustic strength of the

scrubber liquid effluent

Conductivity of the

scrubber liquid

effluent

1

In the 7/30/2014 Test Plan, OxyVinyls indicated monitoring of parameters for the combined

two-stage scrubber (i.e., absorber, or lower, section and scrubber, or upper, section).

2 Applicable if the scrubbing liquid is a reactant (e.g., lime, sodium hydroxide).

OxyVinyls is requesting EPA approval to monitor alternative parameters to those proposed in

the 7/30/2014 Test Plan, as shown in the attached revised Table 4-1 of the Test Plan. Figure 1

is a process flow diagram of the control devices and the locations of the monitors that were

proposed in our 7/30/2014 Test Plan. Figure 2 shows the parameters that are proposed under

this AMR and reflected in the revised Table 4-1.

OxyVinyls selected the proposed monitoring parameters because these parameters have been

established as indicators of proper control device performance. OxyChem is already complying

with the Hazardous Organic NESHAPs (HON) process vent monitoring requirements listed in

40 CFR §63.114, including:

 Firebox temperature,

 Where a scrubber is used with an oxidizer:

o Scrubber effluent liquid pH

o Scrubber influent liquid flow rate

o Scrubber effluent gas flow rate (so that Scrubber l/g can be calculated).

The absorber was included in the original Test Plan to enable the measurement of scrubber gas

stream exit temperature by the use of existing monitoring equipment (i.e., the temperature

difference across the absorber and scrubber combined is >38°C). Operational control is

provided on the absorber so that product HCl is supplied to the plant for use. Monitoring of the

absorber is not included in this AMR.

Although temperature is sometimes used as a measure of adequate scrubber liquid flow,

continuous tracking of scrubber effluent pH, liquid flow rate, and l/g has proven successful in

ensuring proper operation of these existing scrubbers. In scrubbers, absorption of acid gases is

limited primarily by the amount of reactant available in the liquid phase to react with the

contaminant in the stack gas as it diffuses into the liquid.1 OxyVinyls believes that the proposed

monitoring parameters provide effective assurance of HCl emission control. During the stack

test the stack gas flow rate will be maximized and the scrubber liquid flow rate will be minimized.

1 Control of Gaseous Emissions – Student Manual APTI Course 415, Third Edition, Section 2.2.2; Author:

John R. Richards, Ph.D., P.E., Air Control Techniques, P.C.; Developed by ICES Ltd.; EPA Contract

68D99022.
OxyVinyls, LP Page 4 of 4 Alternative Monitoring Parameter Request

Deer Park/La Porte Texas August 21, 2014

OxyVinyls believes that the parameters shown above are adequate indicators of proper

operation of the control devices used to comply with the emission limitations. OxyVinyls has

demonstrated the adequacy of these parameters in the past:

 OxyVinyls utilizes the above parameters, with less frequent averaging periods, for

compliance with the HON requirements listed in 40 CFR §63.113 (process vent

provisions) and §63.115. OxyVinyls has conducted compliance performance tests for

the HON, and continues to routinely demonstrate compliance with these parameters.

 After rebuilding the La Porte Plant scrubbers in 2007, OxyVinyls measured the above

scrubber parameters during a June 2008 stack test conducted for TCEQ to demonstrate

compliance and re-establish operating parameter limits (OPLs).

 EPA previously accepted the 2008 HCl test data in lieu of additional sampling for the

2009 and 2011 Section 114 Information Collection Request.

With respect to OPLs, OxyVinyls currently has OPLs established for HON compliance.

OxyVinyls will reassess the OPLs as a contingency during the scheduled performance testing in

September 2014 and will revise the OPLs in the future, if the test data indicates such changes

are appropriate and it becomes a requirement. The existing HON monitoring practices will be

revised so that the data acquisition and handling system calculates block 3-hour averages

instead of daily average values from the continuous monitoring data.

OxyVinyls appreciates EPA’s review and consideration of this AMR. OxyVinyls believes that the

information included with this AMR, together with the Test Plan and response to EPA’s request

for clarification on the Test Plan provide sufficient documentation for consideration of the AMR.

However, if EPA requires additional supporting documentation or clarification, please do not

hesitate to contact Ms. Deanna Strain at (281) 476-2909 or Ms. Stephanie Engwall at (972) 404-

3291.
TABLE 4-1 (REVISED)

CONTINUOUS PARAMETER MONITORING SYSTEMS

“A”OXIDIZER

INSTRUMENT

TAG NUMBER

“B” OXIDIZER

INSTRUMENT

TAGNUMBER

DESCRIPTION UNITS MEASUREMENT METHOD

CHANGE FROM ORIGINAL TEST

PLAN DATED 7/30/2014

FT4286 FT4286 Deer Park Plant process vent

flow indicator On/Off

Orifice plate and differential

pressure transmitter indicating

flow by measuring scfh

Clarifying flow rate is used to

denote when flow is present rather

than monitoring a flow rate as an

OPL.

TT4528, TT4529 TT4530, TT4531 Thermal oxidizer fire box

temperature

°C Type K thermocouples and

transmitters 1 No change.

FT4197,

FT42126A,

FT42122A,

FT42123A,

FT42120A

FT4199,

FT42126B,

FT42122B,

FT42123B,

FT42120B

Two-stage Scrubber influent

liquid flow rate (l) 2

gpm,

block 3-hr

avg.

Magnetic flow meters

Revising to measuring scrubber inlet

liquid flow only (i.e., removing inlet

flow monitoring for absorber

section of the two-stage scrubber).

Clarifying block 3-hr average.

TT45105A TT45105B Two-stage scrubber exit gas

temperature 2 °C Resistance temperature detectorsand transmitters

Substituting scrubber effluent gas

flow rate for this parameter.

FI42101A FI42101B Scrubber effluent gas flow

rate (g) 2

acfm,

block 3-hr

avg.

Orifice plate and differential

pressure transmitter indicating

flow by measuring acfm

Adding this parameter in lieu of

scrubber exit gas temperature.

Note that l/g is calculated for a

block 3-hr block average for the

scrubber, not absorber and

scrubber combined.

AT40032B,

AT40032C

AT40033B,

AT40033C

Scrubber (second stage) effluent

pH 2

Standard

units pH probes and transmitters 3

No change.

1

Each thermal oxidizer has two redundant temperature monitors to ensure continuous data availability.

2

Not required to demonstrate compliance with the PVC Area Source NESHAP. However, these parameters are being included in this

test plan to allow for a smooth transition to the PVC Major Source NESHAP if ever required.

3

Each scrubber effluent has redundant pH monitors to ensure continuous data availability.