P.1 

OAR Box 1107 

Prepped by Ollie Stewart 

Document Number: 

5DIV-B-1 

Docket Number: 

A-81-21 

Printed 4/11/2008 3:03:47 PM Sheet 51 of 90 
P.2 

CORPORATION £-•8 -21 

IV-B-l 

MEMORANDUM 

Date: January 18, 1985 

To: W. Fred Dimmick 

Standards Development Branch 

From: Karen K. Fidler 

Radian Corporation 

Subject: Summary of Findings from Industry Discussions 

on Control Device Operations and Performance 

Purpose 

This memorandum summarizes information received during recent 

discussions with representatives of four vinyl chloride (VC) industry 

companies on the subject of control device operations and bypass 

occurrences. Information is presented for five ethylene dichloride/VC 

monomer (EDC/VC) plants and seven polyvinyl chloride (PVC) plants operated 

by the four companies. The information presented in this memorandum was 

collected for the purpose of improving understanding of incinerator and 

other control device operations in the VC industry and to serve as a 

basis for assessing the need for a control device bypass provision in 

the VC standard. 

Summary of Findings 

Table 1 summarizes information on the control devices operated by 

the five EDC/VC plants to meet the 10 ppm requirements of the VC standard. 

Also in Table 1 is a summary of the reported bypass performance in 1984 

for each EDC/VC plant. In Table 2, the reported bypass performance by 

the EDC/VC plants is broken down for three 3-month periods. Finally, 

Table 3 classifies the reported bypasses at EDC/VC plants according to 

type (i.e., full vs. partial vent bypasses) and cause (i.e., process 

upset vs. incinerator malfunction). Mechanisms by which incinerators 

trip with resultant bypasses at each EDC/VC plant are also noted in 

Table 3. Table 4 summarizes control device information and reported 

bypass performance for the seven PVC plants. 

Based on the information presented in Tables 1, 2, 3, and 4 and 

additional information from the meetings (see individual meeting reports), 

the following general observations about control device operations and 

performance can be made. 

o All plants have (at least) dual control devices. 

o Under normal operating conditions, each plant has excess 

incineration capacity available. 
Table 4. CONTROL DEVICES AND BYPASS PERFORMANCE FOR PVC PLANTS 

Plant 

Number 

of 

control 

devices 

Control device description 

Primary Backup 

Bypass performance (1983-1984) 

Vent gas 

storage 

capacity 

available 

Number 

of 

bypasses 

Amount 

bypassed 

(lb) 

Total 

bypass 

time 

(hr) 

Percent 

bypags 

time 

Percent 

backup 

control 

device 

usage 

B.F. Goodrich - A Incinerator None NA 429 22 0.13 

B.F. Goodrich - B Solvent absorber Incinerator 1.3 

B.F. Goodrich - C Solvent absorber Incinerator 3.4 

B.F. Goodrich - 0 Solvent absorber Incinerator 15.5 

B.F. Goodrich - E 

B.F. Goodrich - F 

Solvent absorber 

Solvent absorber 

Incinerator 

Solvent absorber 

4.6 

NAd 

Borden/111iopol is, 

IL 

Incinerator 

1.2 x 106 Btu/hr 

Incinerator 

(capacity unknown) 

"Percent bypass time = Total bypass hours JY Total operating hours 

Percent backup incinerator usage = Incinerator operating hours x 

Total operating hours 

NA = not available. 

Unknown 

Vent gas storage capacity varies but is reported to be typically equivalent to amount of vent gases generated during 8-hour shift. 
Table 3. CLASSIFICATION OF INCINERATOR BYPASSES AT EDC/VC PLANTS 

Plant/location 

No. 

l/t 

Qi 

cr. 

"£ 

> 

<c 

of bypasses by type" 

1/1 (/> 

>> 

, 

'Z Par 

<u Oxy 

| 

tdow 

JZ 

Z i .-

fO j +-» 

• J o 

OO 1— 

Percent by| 

a h 

jass time by type ' 

1 

1/1 J i/> 

<u j >/> 

cn | >> 

> ! • - A l l Par 

C 

Oi Oxy 

tdo 

3 

. C 

o. 

3 

-»-> 

•M 

LO 

ra Tot 

bypasses 

by cause 

ction 

3 

ra 

E 

i~ 

O 

4-> 

t -

<u 

c I nc 

i 

t 

! 

at \ 

CL 

tn C 

i n 5 

OJ 

o Pro o 

c U nk 

Percent bypass 

time by cause * ction 

3 

ra 

E 

i -

o 

•-» 

s-QJ 

c Inc 

4-> 

OJ 

«/C> L 

3 

U. 

l/> 

01 Pro 

c 

2 

o 

c Unk 

t . atu 

o 

E 

a> 

- C H ig 

OJ 

3 

•*- • 

ra 

Ql 

a. 

E 

+-Low 

Incinerator "trip " mechanisms 

h flow 

CJ> 

SI 

Qi 

t/) 

OJ 

c functi 

ra 

F tor 

t_ 

ra 

SZ E Hig F la 

at c 

E O 

ra -r~ 

t— •*-» 

•^- c 

OJ ure t fai l 

c 

at 

E q ui 

>, 

M- O ra 

E OJ *r- F la det A ux 

OJ I i l u cal fa 

+-» 

<_» e le 

OJ 

c •--

(U ' ra 

E . «*-

P 

+-» (U I ns 

o 

1 ror 

QJ 

ra Ope 

d 

1 

| i 

1 

i | i 

1 

OJ 

•M 

O 

1 

1 

! | 

f °- 1 

1 *- '£ » j 

; o : 

; C j 

! >. 

1 r. 1 o 

1 ^ Ver 

PPG 

Lake Charles, LA 

Vista 

Westlake, LA 

Borden 

Geismar, LA 

B.F. Goodrich 

La Port, TX 

B.F. Goodrich 

Calvert City, KY 

163 NA NA 169 0.01 0.47 

NA NA NA NA 48 NA NA 

NA 

NA 

NA 

NA 

0.48 46 66 57 0.12 0.21 0.15 J V 7 V V V V V -J V -I 

0.17 NA NA NA NA NA NA -NA147 87 32 3 269 0.48 0.17 0.10 0.02 0.77 68 68 133 0.18 0.19 0.40 V V V 

5 0 0 0 5 0.04 0 0 0 0 050 0 0.04 0 

1 00 0 10.0 2 0 0 0 0 0 1 0 0 0.02 0 

V V 4 ,1 V V V 

AI V V 

NA = not available. 

Bypass type: 

All vent gases - Bypass consists of all VC-containing vent gases normally incinerated. 

Partial bypass - Bypass consists of portion of VC-containing vent gases normally incinerated. 

Oxyvent - Bypass consists of oxychlorination vent only. 

Startup/shutdown - Bypass consists of VC-containing gases vented during startup/shutdown of process equipment. 

bn . t ,. Total bypass hours ,„„ Percent bypass time = T , .

 itr-= n x 100 * Total operating hours 

cBypass cause: 

Incinerator malfunction - Malfunction of incinerator equipment and instrumentation causing incinerator to "trip" or necessitating shutdown for repair. 

Process upset - Any condition causing abnormal variation in vent gas or utility feed to the incineration system. 

Mechanisms by which incinerator "trips" have occurred with resultant bypassing of vent gases. 

Failure of equipment auxiliary to the incinerator, e.g., waste heat boiler feed water pumps, air blowers, header knockout vessels, etc. 

^ 
Table 2. INCINERATOR BYPASS PERFORMANCE BY EDC/VC PLANTS DURING 

THREE 3-MONTH PERIODS (MARCH - NOVEMBER 1984d) 

Plant/location 

Number of bypasses Total lbs VC bypassed 

Mar- Jun- Sept- Mar- Jun- SeptMay Aug Nov May Aug Nov 

Average lbs VC 

per bypass 

Total bypass 

time (hr) 

Average bypass 

duration (min) 

MarMay 

JunAug SeptNov MarMay 

JunAug SeptNov 

MarMay 

Jun- SeptAug Nov 

Percent . 

bypass time 

MarMay JunAug SeptNov 

PPG 101 

Lake Charles, LA 

Vista > 

Westlake, LA 

Borden 86 

Geismar, LA 

B.F. Goodrich 2 

La Porte, TX 

B.F. Goodrich 0 

Calvert City, KY 

34 

101 

34 368 172 96 3.6 5.1 2.8 18.4 6.9 6.8 11 12 12 0.83 0.31 

-No data 

81 5,140 4,136 2,428 60 41 30 23.5 16.1 11.3 16.4 9.6 8.3 1.06 0.96 

166 129 0 83 65 

0 NA" NA" 

2.5 0.9 0 84 27 0 0.13 0.04 

0 0 2 0 0 120 0 0 

0.31 

0.83 

0.09 

Represents first three reporting periods under the State of Louisiana's new and more extensive bypass reporting reguirements. 

bD „„ . . „, ... _ Total bypass hours lnn Percent bypass time = T . ,

 Jr

. . r x 100 Total operating hours 

Monthly performance data was not provided by Vista. 

Amount of VC bypassed not available. 
Table 1. Concluded 

Plant/location 

Number 

of 

control 

devices 

Control device description 

Normal operation Standby 

Percent excess incineration 

capacity available 

Normal 

operation Standby Total bypasses 

1984 reported incinerator performance 

Amount Total 

Number VC bypass Percent 

of bypassed time bypass 

(lb) (hr) time 

B.F. Goodrich 

La Porte, TX 

Incinerator ("A") None >100' _g >100 295 0.04 

Incinerator ("B") 

B.F. Goodrich 

Calvert City, KY 

Incinerator 

("Primary") 

Incinerator 

("Secondary") 

15 15 23 NA" 0.02 

Incinerator 

("Oxy") 

Control devices reportedly operated under normal process operating conditions. 

Control devices reportedly operated when one or more normally operated control devices is down for repair or maintenance. 

c 

Percent excess incineration capacity available to handle vent gas surges under the following conditions. 

Normal operation - When normally operated incinerators are on-line. 

Standby - When standby incinerator is operated in place of one or more normally operated incinerators. 

Total - If all available incinerators are operated simultaneously. 

"Percent bypass time = total bypass hours Jr total operating hours 

Available excess capacity varies depending on which normally operated incinerator(s) is replaced by standby. 

Plant reports that vent gases are easily handled by one incinerator but are typically divided between two. 

^No standby control device; excess capacity built into normal operation. 

NA = not available. 
Table 1. CONTROL DEVICES AND BYPASS PERFORMANCE FOR EDC/VC PLANTS 

Plant/location 

PPG 

Lake Charles, LA 

Vista 

Westlake, LA 

Borden 

Geismar, LA 

Number 

of 

control 

devices 

4 

2 

3 

Control device 

Normal operation 

Incinerator 

("No. 3") 

70 x IO6 Btu/hr 

258 T/D vent gas 

Incinerator 

("No. 2") 

48 x IO6 Btu/hr 

180 T/D vent gas 

Incinerator 

("No. 1") 

48 x 10G Btu/hr 

180 T/D vent gas 

Incinerator 

("Primary") 

48 x 10G Btu/hr 

Incinerator 

("Primary") 

48 x IO6 Btu/hr 

Incinerator 

("VCR") 

(capacity unknown) 

description 

Standby 

Incinerator 

("No. 4") 

48 x IO6 Btu/hr 

180 T/D vent gas 

Incinerator 

("Secondary") 

48 x 106 Btu/hr 

Incinerator 

("Secondary") 

28 x 106 Btu/hr 

Percent excess incineration 

capacity available 

Normal 

operation Standby Total 

30 0-30e 45 

50 50 100 

70 0-40e -W7 

1984 reported incinerator performance 

Amount Total 

Number VC bypass Percent 

of bypassed time bypass 

bypasses (lb) (hr) time 

168 636 32 0.48 

[Marc h - November ] 

48 364 14.6 0.171 

[Januar y - November ] 

269 11,704 51 0.77 

[Marc h - November ] 

(continued) 
P.8 

m4M*!AN 

-2-

Except at one EDC/VC plant, at least some VC is bypassed 

whenever an incinerator "trip" occurs. 

Approximately equal numbers of bypasses are attributed to 

process upsets and incinerator malfunctions based on the 

"classifiable" bypasses reported. (Note the number of bypasses 

for which the cause could not be identified exceeds the number 

for which causes are known.) 

EDC/VC plants with high bypass frequencies reported that 

incineration of the oxychlorination vent contributed to bypass 

frequency; plants with low bypass frequencies reported the 

oxyvent to have little or no impact on incinerator operations. 

EDC/VC plants with highest bypass frequencies and percent 

bypass time (PPG and Borden) are integrated chemical plants 

whose incinerators combust vent gases from processes in addition 

to EDC/VC production; these plants operate more than 

two incinerators. 

Startup/shutdown procedures do not routinely involve bypassing 

the control device(s), except for startup/shutdown of the 

oxychlorination reactor at some "air process" EDC/VC plants. 

PVC plants have vent gas storage capacity available to virtually 

avoid bypasses in the event of control device malfunctions 

during periods of normal process operation. 

KKF/mad 
P.9 

Mr. Gustave Von Bodungen 

October 3, 1983 

Page 4 

Date 

6/22/83 

6/23/83 

6/24/83 

6/26/83 

Cause of Emission 

There were five (5) emissions on this date. The primary 

incinerator tripped four times. The exact cause is unknown. 

The secondary incinerator tripped. The exact cause is unknown. 

The exact cause is unknown. 

There were six (6) emissions on this date. The primary 

incinerator tripped three (3) times. The exact cause is 

unknown. 

6/27/83 

6/29/83 

7/5/83 

7/8/83 

7/9/83 

7/10/83 

7/17/83 

7/19/83 

7/20/83 

The exact cause is unknown. 

There were two (2) emissions on this date, 

is unknown. 

The exact cause is unknown. 

There were two (2) emissions on this date, 

is unknown. 

The exact cause 

The exact cause 

There were six (6) emissions on this date. Inerts were being 

vented from the VCM column condenser. The vents were switched 

to the chlorine recovery incinerator then later the chlorine 

incinerator tripped and the vents had to be switched back to 

the primary. 

The exact cause is unknown. 

There were two (2) emissions on this date. The exact cause is 

unknown. 

The exact cause is unknown. 

There were two (2) emissions on this date. The primary 

incinerator tripped due to the refractory temperature indicator 

! failure. After this was repaired, the incinerator was restarted. 

There has not been any emissions since July 20, 1983, until September 15, 

1983, the cut-off date of this report. Should you have any questions concerning 

this report, please contact me. 

Sincerely, 

David T. McLemore 

Environmental Coordinator 

DTM/ah 
P.10 

^ ^ > FORMOSA PLASTICS CORPORATION LOUISIANA U*^ 

P.O. BOX 271 • BATON ROUGE. LOUISIANA 70821 • TEL: (504) 356-3341 • TLX: 586-414 FPC USA BTR 

CERTIFIED MAIL 

P 181 812 871 

March 15, 1985 iV C • 

; />. - -

Mr. Gustave Von Bodungen, Administrator 

Air Quality Division 

Louisiana Department of Environmental Quality 

Post Office Box 44096 

Baton Rouge, Louisiana 70804 

Dear Mr. Von Bodungen: 

RE: LESHAP SECTION 77.11 

QUARTERLY REPORT 

Pursuant to the referenced regulation, the following quarterly report for 

Formosa Plastics Corporation is being submitted for the period December 1, 

1984 through February 28, 1985. 

Our records indicate no supplemental use of the flare was required during the 

reporting period. The vinyl standard for the oxy vent, 0.02 pounds of VCM/100 

pounds EDC produced by oxychlorination, was exceeded as follows: 

POUNDS VCM IN OXY 

DATE TIME VENT/100 POUNDS EDC 

12/28/84 2000 0.023 

01/25/85 1700 0.034 

As stated in our letter of January 4, 1985, we are currently training additional 

personnel on trouble shooting the incinerator and are compiling a list of 

necessary spare parts to minimize downtime. Finally, outages lasting for more 

than one hour have been reported to your office by phone and separate letter. 

If you have any questions regarding this matter, contact S. A. Heath at 

(504) 356-8644. 

Sincerely, 

A. L. Andre 

Plant Manager 

ALA:pjj 

Enclosure 
page l 

p.11 

INCINERATOR OUTAGES 

DATE 

12/31/84 

TIME 

OUT 

0905 

1010 

1035 

TIME POUNDS VCM DIVERTED 

IN TO OXY FROM VVRS 

1000 ^ 

1019 * 

1047 IT7.95 

7.06 

9.40 

CAUSE 

Auxiliary burner replacement 

Re-start problems 

Re-start problems 

12/18/84 0310 0316 <» 2.16 

12/19/84 08-25 

0905 

0925 

1230 

091D 

0855 30 

0935 '* 

1240 '> 

7.74 

10.84 

10.84 

10.36 

High-pressure on scrubber recycle 

Lost scrubbe*" recycle 

Low temperature K.O. 

Low temperature K.O. 

Low temperature K.O. 

12/28/84 2030 2100 3' 91.54 High temperature K.O. 

12/29/84 

12/31/84 

01/01/85 

01/02/85 

727 

1615 

0000 

0000 

740 

2400 

2400 

2145 * 

z 

1-nO 

6.57 

0.28 

730 

1464 

Low boiler feed water pressure 

CPU went out 

Loss of CPU 

CPU replacement and reprogramming 

01/05/85 

01/07/85 

01/08/85 

01/09/85 

01/16/85 

0100 

0620 

1200 

550 

1005 

1330 

0110 

0645 

1230 

605 

1100 

1420 

|0 

7S 

10 

li 

si 

So 

7.42 

18.70 

3.60 

13.30 

17.52 

27.30 

Cause not found 

Cause not found 

Patching auxiliary burner block 

Low steam drum level 

Preventive maintenance 

Patching auxiliary burner block 

01/20/85 1508 1820 / ^ 

1830 1835 i 

1915 1920 i 

20.4 

1.7 

1.7 

Frozen actuator to auxiliary burner, 

natural gas valve 

Pressure switch sticking 

Pressure switch repair 

01/24/85 1650 1700 >o 1.0 Low temperature K.O. 

01/25/U5 1000 1040 ^ 

1145 0100 -K 

1.0 

635 

Low temperature K.O. 

Auxiliary burner 

01/26/85 0250 0350 l*° 

0925 0940 -? 

93.80 

10.44 

Low boiler feed water pressure 

Cause not found 

1015 

01/27/8!-; 0720 

01/29/85 1108 

1040 ic-

1125 -'-^ 

1150 ^ 

13.17 

153 

17.06 

Cause not found 

Oxy vent valve, solenoid shorted out 

Low steam drum level 

H-i^A <Vl 
Page 2 

INCINERATOR OUTAGES continued 

P.12 

DATE 

TIME TIME POUNDS VCM DIVERTED 

OUT IN TO XOY FROM VVRS 

02/03/85 1000 1020 to 0.47 

CAUSE 

Low temperature K.O. 

02/12/85 1230 1240 

02/10/85 044 

H O Low temperature K.O. 

044'b 

13 .^C. 

1344 

16-30 

0515 

1338 

1405 

1650 

20 

to 

1\ 

10 

10.95 

0 

0 

0 

Cause not found 

Cause not found 

Cause not found 

Cause not found 

02/20/85 0314 0324 to 16.8 Waste shutdown 

02/24/85 0810 0840 3" 7.96 

0930 

1013 

1653 

02/25/85 1030 

1115 

1700 

1750 

1900 

2015 

2035 

2045 

2130 

1000 

1040 

2345 

1050 

1130 

1720 

1810 

10/lfi 

2030 

2040 

2120 

0105 

3<> 

Vl 

M a 

\ o 

IS 

1 ° 

T.0 

uO 

1$ 

b 

iC 

~? i b 

7.50 

6.84 

323 

5.47 

1.58 

0.21 

0.17 

2»; co 

50.37 

16.12 

116.9 

663 

JJV sensor on auxiliary burner 

shorting out 

ditto 

ditto 

ditto 

02/26/85 0140 0215 i/ 69.20 

ditto 

ditto 

ditto 

ditto 

ditto 

ditto 

ditto 

ditto 

UV sensor replacement 

Low scrubber circulation pressure 

/ouo 
P.13 

FORMOSA PLASTICS CORPORATION LOUISIANA 

P.O. BOX 271 • BATON ROUGE. LOUISIANA 70821 • TEL: (504) 356-3341 • TLX: 586-414 FPC USA BTR 

CERTIFIED MAIL 

P 165 028 631 

December 11, 1984 

RECEIVE D 

Mr. Gustave Von Bodungen, Administrator 

Air Quality Division ^t'C J X J934 

Louisiana Department of Environmental Quality 

Post Office Box 44066 AIR QUAL /Tv n«„ 

Baton Rouge, Louisiana 70804

 v L " r D'v.<S/0N 

Dear Mr. Von Bodungen: 

RE: LESHAP SECTION 7 7.11 

QUARTERLY REPORT 

Pursuant to the referenced regulation, the following quarterly 

report for Formosa Plastics Corporation is being submitted for 

the period September 1, 1984 through November 30, 1984. 

Our records indicate no supplemental use of the flare was 

required during the reporting period. The vinyl standard for 

the oxy vent, 0.02 pounds VCM/100 pounds EDC produced by 

oxychlorination, was exceeded as follows: 

POUNDS VCM IN OXY 

DATE TIME VENT/100 POUNDS EDC 

T0713/84 0100 0.021 

10/20/84 1200 0.034 

10/20/84 1300 0.024 

Most of the incinerator outages, which are shown in this report, 

were the result of instrument failures and misadjustments made 

after a larger air blower was installed during our September turnaround. With the help of Trane engineers, the adjustments have 

been corrected and the incinerator operation has improved. Finally, 

outages lasting for more than one hour have been reported by phone 

and separate letter. 

If you have any questions regarding this matter, contact S. A. Heath 

at (504) 356-8644. 

Sincerely, 

A. L. Andre 

Plant Manager 

ALA:pjc 

Enclosure 
INCINERATOR OUTAGES 

P.14 

DATE 

9/1/34 

9/1/84 

TIME 

OUT 

0856 

092S 

TIME 

IN 

0901 C* 

09 51 xi> 

10/8/84 

C 

POUNDS VCM DIVERTED 

TO OXY FROM VVRS 

0.03 

0 

1136 

1950 

2020 

2055 

1145 «-

2015 *<--

2050 --° 

13.69 

0.32 

10.45 

356 

CAUSE 

Water from heads 

column K.O. pot 

9/7/84 

10/7/84 

0945 

0705 

1015 

0715 

1° 

.?_ 

0.50 

0.19 

Cause not found 

Cause not found 

Short in the 

Thermocouple 

«rfi/9/84 0040 

0636 

0230 "o 

0650 IM 

46J 

0 

Cause not found 

Cause not found 

10/10/84 1202 1217 K 0 Cause not found 

•10/14/84 0900 

0936 

0910 io 

0945 <\ 

4.69 

4.22 

Cause not found 

Cause not found 

10/19/84 0945 1040 ss" 71.32 Thermocouple replacement 

viO/20/84 0925 1710

 L'.t<: 80 Dirty flame sensor 

10/21/84 1145 1240 ££ 43.50 Low temrieratur e K.O. 

10/22/84 1420 1440 io 5.25 Low temperature K.O. 

10/24/84 0920 .1045 ^ 72 Trane making adjustments 

10/25/84 0840 0910 6.25 Upset at oxy caused 

excess ethylene to 

incinerator 

uK)/29/8 4 0938 1248 i*o 113 Plugged pilot light 

air line 

^1/2/84 1345 

1800 

135 5 <o 

210 0 i?o 

0.01 

33 

High temperature K.O. 

Low boiler feed water 

pressure. 

11/3/84 0630 0740 TO 13 Auxiliary burner problem 

11/6/84 2005 

2040 

2125 

2020 '£ 

2110 30 

2140 >C 

61.5 

129 

70.6 

11/15/84 0830 1210 VT-O 0.460 

u.'.--rt 

pH controller went out 

pH controller went out 

pH controller went out 

11/11/84 

11/12/84 

2250 

1145 

2310 

1240 

T.O 

ss 

28.98 

26.32 

Low boiler feed water 

pressure 

Loss of circulation 

on HCl tower 

Down for maintenance 

and adjustments 
P. If 

PATRICIA L. NORTON 

SECRETARY 

OFFICE OF AIR QUALITY AND NUCLEAR ENERGY 

September 21 , 1984 

L. HALL BOHLINGER 

ASSISTANT SECRETARY 

Mr. A. L. Andre 

Plant Manager 

Formosa Plastics Corporation 

P. 0. Box 271 

Baton Rouge, LA 70821 

Dear Mr. Andre: 

We are in receipt of your quarterly report dated September 14, 

1984 and covering June, July and August, 1984. 

This report is complete in that it contains all of the information 

required in Section 77.11 of Louisiana Emission Standards for Hazardous 

Air Pollutants. 

We wish to remind you that no exceedances are allowable. For 

the reported quarter, Formosa has been in violation of Section 77.3(A) 

34 times and of Section 77.3(b) 3 times. Any exceedances of a hazardous 

air pollutant standard is considered a major air quality violation 

and subject to investigation and a possible monetary penalty. 

Sincerely, 

WillMam H. Davis 

Chief, LESHAP Unit 

WHD/CCJ/bs 

cc: Capital Regional Office 

V-' . 

\ \

r

<. Ho. 

Fil e 18.40.9 

AIR QUALITY DIVISION • P.O. BOX 44066 • BATON ROUGE. LOUISIANA 70804 • PHONE (504) ?42-1206 
P.16 

_TM FORMOSA PLASTICS CORPORATION LOUISIANA 

>^£ / PO. BOX 271 • BATON ROUGE. LOUISIANA 70821 • TEL: (504) 356-3341 • TLX: 586-414 FPC USA BTR 

CERTIFIED MAIL 

P 223 537 649 

September 14, 1984 

SEP 1 ? j S 3 4 

* * «MLITV Dms, 

Mr. Gus Von Bodungen 

Air Quality Division 

Louisiana Department of 

Natural Resources 

Post Office Box 44066 

Baton Rouge, Louisiana 70804 

Dear Mr. Von Bodungen: 

RE: LESHAP SECTION 77.11 

QUARTERLY REPORT 

Pursuant to the referenced regulation, the following quarterly report is 

being submitted for the period June 1, 1984 through August 31, 1984. 

Our records indicate no supplemental use of the flare was required during 

the reporting period. The vinyl emission standard for the oxy vent, 0.02 

pounds VCM/100 EDC produced by oxychlorination, was exceeded as follows: 

DATE TIME 

7/16 

8/4 

8/23 

2300 

1500 

2200 

POUNDS OF VCM IN OXY 

VENT/100 POUNDS EDC 

0.024 

0.021 

0.047 

As requested from your office, this quarterly report will also include 

incinerator outages during the reporting period. This data includes the 

time of the outage, the time the incinerator was put back on-line, the 

pounds of vinyl diverted to oxy through the vinyl vent recovery system and 

the cause. 

As you can see from the attached chart, there were s'everal outages during 

the month of August. Most of these minor outages resulted from two causes, 

liquid from incinerator feed knock-out pots and boiler level dropped due to 

a decrease in heat load. The boiler level problem is to be corrected during 

the turnaround that is currently taking place. The liquid problem from the 

knock-out pots is to be corrected by pumping the liquid to storage. Also, 

during this turnaround, a larger blower is being installed. This may reduce 

IT. \ c I <> u\ A i"-
P.17 

Mr. Gus Von Bodungen 

September 14, 1984 

Page 2 

the number of outages that occur when the cause cannot be found. Finally, 

outages lasting for more than one hour have been reported by phone and 

separate letter. 

If you have any questions regarding this matter,- contact Stan Heath, 

Environmental Affairs Manager, at telephone number 356-8644.. 

Sincerely, 

A. L. Andre 

Plant Manager 

ALA:pjc 

Enclosure 
P.18 

FPC INCINERATOR OUTAGES 

DATE 

6/14/84 

7/16/84 

7/17/84 

7/22/84 

7/28/84 

8/1/84 

8/2/84 

8/4/84 

8/5/84 

8/6/84 

'8/7/84 

8/11/84 

TIME 

OUT 

2. 

2300 

0500 

1315 

1425 

1215 

0730 

0823 

0835 

0935 

1532 

0220 

0732 

0810 

0200 

1315 

0930 

1045 

1145 

2222 

0545 

TIME 

_IN 

42 hrs 

2315 

0315 

1320 

2215 

1230 

1215 

0830 

0843 

0945 

\^< 

\S 

\S 

a 

M T O 

\S 

<ff& 

n 

tf 

H> 

1547 tS 

0240 2-" 

0742 

0812 

0210 

1342 

1029 

1115 

1215 

2235 

ro 

T, 

10 

zn 

^7 

3 © 

3 0 

Im. 

0710 //ii' 

<zC 

POUNDS DIVERTED 

TO OXY* 

322** 

33.33** 

33.33** 

7.08*** 

JO 666*** 

27.47 

"ZOS" 390 

9.92*** 

11.33*** 

14.17*** 

21.25*** 

44.44** 

14.17*** 

2.83*** 

22.22** 

14.24 

84.48 

78.07 

83.84 

37.72 

218.93 

--vMU?TCAUSE 

Low pH 

Caustic line plugged 

Caustic line plugged 

Cause not found 

Lightning storm knocked out 

instruments necessitating replacement 

Liquid from knockout pot 

Burner replacement 

Flame arrestor plugged 

Flame arrestor plugged 

Flame arrestor plugged 

Flame arrestor plugged 

Low cooling water pressure 

Liquid from knockout pot 

Liquid from knockout pot 

Low cooling water pressure 

Repair leak on oxygen meter 

Valve replacement 

Low temperature 

« 

Low temperature 

Low temperature 

Plugged caustic line 

I \°\\> 
FPC INCINERATOR OUTAGES CONTINUED 

P.19 

DATE 

8/15/84 

TIME 

OUT 

1100 

TIME 

J_N 

1120 2- » 

POUNDS DIVERTED 

TO OXY* 

58.26 

8/21/84 

8/23/84 

8/25/84 

8/30/84 

8/31/84 

0818 

0732 

0810 

1248 

2140 

0835 

1850 

1900 

1910 

0710 

0755 

2110 

0850 I t0746 \*\ 

0825 iS 

1315 l l 

2220 **«> 

1845 it> 

1854 ** 

1905 X 

1915 s 

0730 i» 

0840 **S 

2140 2>t> 

^-\• ^ 

37.43 

30.66 

0 

0 

89.31 

0.65 

0.26 

7.63 

7.63 

7.88 

85.22 

157.22 

M??.'£ 

CAUSE 

Outside contractor broke an air 

line on the oxy reactor, caused a 

surge from the oxy vent 

Low cooling water pressure 

Boiler level dropped 

Cause not found 

Liquid from knockout pot 

Cause not found 

Liquid from knockout pot 

Liquid from knockout pot 

Liquid from knockout pot 

Liquid from knockout pot 

Liquid from knockout pot 

Low cooling water pressure 

Cause not found 

* Most vinyl diverted to oxy is destroyed by addition of chlorine from the 

HCl feed. 

** Computer down, based on an average of 153.3 lbs VCM/hr when loading VCM. 

*-** Computer down, based on an average of 85 lbs VCM/hr when not loading VCM. 
P.20 

EDWIN W. EDWARDS 

GOVERNOR 

PATRICIA L. NORTON 

SECRETARY 

Mr. A. L. Andre 

Plant Manager 

Formosa Plastics Corporation 

P. 0. Box 271 

Baton Rouge, LA 70821 

Dear Mr. Andre: 

We are in receipt of your June 7, 1984 letter which contains Formosa's 

quarterly report covering March, April and May, 1984. The report is 

not complete in that it does not include the incidents of incinerator 

by-passes. Because Formosa does not have an approved secondary control 

device for vinyl chloride emissions, any vent stream which contains 

vinyl chloride and by-passes the incinerator must be reported when 

the concentration of vinyl chloride released to the atmosphere is greater 

than 10 ppm averaged over any hour period, Section 77.11(c)(1). In 

addition, any incinerator by-pass of streams subject to the 10 ppm 

emission limit that last longer than one hour must be reported by telephone 

within three hours and followed by a written explanation, Section 77.9(A) 

and Section 76.18. 

It is my understanding that you are compiling a list of incinerator 

by-passes for Mr. Chris Roberie, SIP, Air Division. We would appreciate 

a copy of that list and expect all incinerator by-passes in this quarter 

and future quarters to be fully documented as to date, time, duration, 

vinyl chloride released (lbs.) and the reason for the by-pass. 

Your cooperation in this matter is appreciated. 

Sincerely, 

-iukh 

Im""H. Davis 

Chief, LESHAP Unit 

WHD/CCJ/bs 

cc: Capital Regional Office 

Fil 

MATURAL RESOURCES BUILDING . P.O. BOX 44066 . BATON ROUGE, LOUISIA' pi'.o-.-.,

.

v 
P.21 

FORMOSA PLASTICS CORPORATION LOUISIANA 

P.O. BOX 271 • BATON ROUGE, LOUISIANA 70821 • TEL: (504) 356-3341 • TLX: 586-414 FPC USA BTR 

CERTIFIED MAIL 

P 223 537 622 

June 11, 1984 RECZl\/ED 

— •'• I H 1S34 

Mr. Gus Von Bodungen AIR QUALITY DlVlSlQN 

Air Quality Division 

Louisiana Department of Natural Resources 

Post Office Box 44066 

Baton Rouge, Louisiana 70804 

Dear Mr. Von Bodungen: 

Re: 40 CFR SUBPART F 

QUARTERLY REPORT VCM 

Pursuant to the referenced regulation 61.70, the following quarterly report is 

being submitted for the period March 1, 1984 through May 31, 1984. 

Our records indicate no supplemental use of the flare pond was required during 

the reporting period. Other records show the vinyl chloride emmission standard 

for the oxy vent, 0.02 pounds VC1/100 pounds EDC produced by oxychlorination, 

was exceeded as follows: 

VINYL IN OXYCHLORINATION VENT 

DATE AND TIME WHEN VINYL EXCEEDED 0.02 POUNDS 

VC1/100 POUNDS EDC PRODUCED 

DATE 

3/22/84 

TIME 

0300 

POUNDS OF VCM IN OXY 

VENT GAS/100 POUNDS EDC 

0.025 

Should you have any questions regarding this matter, please contact Dr. S. A. Heath, 

Environmental Affairs Manager, at (504) 356-8644. 

Sincerely, 

A. L. Andre 

Plant Manager 

SWP:pjc 

cc: Dick Whittington, EPA Region VI 

Frank S. Craig, III 
P.22 

March 14, 1985. Certified 

Mr. Gustave Von Bodungen .— 

Program Administrator f\ t ".

 !""' VT H 

Air Quality Division

 K" '~- l ^ L U 

Department of Environmental Quality 

PO Box 44066 Mfiy! I cj jq.qc 

Baton Rouge, LA 70804 ^ °D 

Dear Mr. Von Bodungen: ° QUALITY OiV'ISiQN 

Subject: LESHAP Quarterly Report - Polyvinyl 

Chloride and Vinyl Chloride Plants 

Pursuant to Section 77.11 of the Louisiana Air Quality Regulations, please 

find the attached LESHAP Quarterly Report for the Georgia Gulf polyvinyl 

chloride and vinyl chloride plants. This report covers the period from 

December 1, 1984 to February 28, 1985. 

Contained in this report are data pertaining to: 

1. Emissions which were in excess of prescribed emission standards. 

2. The residual vinyl chloride monomer (RVCM) content of our PVC resin. 

3. PVC reactor opening losses. 

4. Periods of the VCM gas and liquid incinerator continuous emission 

monitor downtime. 

Included as an addendum to this report are PVC Reactor "0" ring checklists 

and documented results of manway preventive maintenance inspections which 

was required by the Secretary in the Compliance Order issued December . 

20, 1984. 

A meeting was held with Mr. Bill Davis, of your staff, on January 22, 

1985 to discuss the terms of the above mentioned Compliance Order. At 

that time, Mr. Davis indicated that the Order could possibly be amended 

to eliminate the submittal of this large amount of redundant paperwork. 

Georgia Gulf is ready to meet with you or your staff, at any time, to 

discuss an amended Order. • 

If you have any questions concerning this report, or the addendum, please 

contact Bill Newman at (504) 387-0211. 

Sincerely, 

y^s-j^^,/-. 

Vincent J. Tretter, Jr. 

Environmental Manager 

VJT/WTN/dsh 

File 200.10.3.1 

cc: Messrs. E. A. Schmitt, Georgia Gulf, Plaquemine, LA 

W. C. Baker, Georgia Gulf, Plaquemine, LA 

T. Marshall, Georgia Gulf, Plaquemine, LA - w/o attachments 
RECOUP OF VINYL CHLORIDE EMISSIONS IN EXCESS OF STANDARDS 

VCM PLANT 

Date 

12/27/84 

1/10/85 

1/10/85 

1/10/85 

1/20/85 

1/21/85 

1/21/85 

1/21/85 

2/4/85 

2/16/85 

2/19/85 

2/26/85 

Time 

2000 

1029-1038 1 

1025 

VH r ' 

1529-1533 ^ 

VCM 

Released 

0.24 pounds 

0.51 poundst 

10 pounds 

0.51 pounds 

wf^5 / 

2000 1/20 to 108 pounds

 7 

2000 1/21r 

0102 H f " 

wf* 

0430-1000^0 

1700-1705 

1815-2000 

1400 *RJ 

0700 S^J 

1121 J*' 

vtr

4> 

0304 

MO 

0.44 pounds 

32 pounds V 

0.13 pounds 

0.3 lbs/hr 

0.06 pounds 

0.08 pounds 

0.41 pounds 

Source 

V-420 VCM Humidifier 

V-318 Emergency Vent 

Scrubber 

V-405 Absorber L. 

Intercooler 

V-318 Emergency Vent 

Scrubber 

V-641 Process Water 

Stripper 

V-318 Emergency Vent 

Scrubber 

V-318 Emergency Vent 

Scrubber 

V-312 DH Still Feed Dr 

V-310C Phase Separator 

Process Water Stripper 

Feed Tank 

Process Water Stripper 

Feed Tank 

V-318 Emergency Vent 

Cause 

Plug blew out of teflon spacer spilling VCM saturated water to pad 

Excessive dry vent loading due to power failure caused diversion of the dry vent 

from incinerators to V-318 

Power outage caused overpressure of absorber system, lifting relief valve on lower 

intercooler 

Incinerator tripped out due to high vent load from liquid phase startup 

Ice pluggage in stripper overhead condenser forced bypass of the wet vent header 

Normal shutdown of OHC Reactor R-301-C 

OHC Reactor R-301-D was vented to V-318 since, frozen incinerator instrumentation 

would not allow the additional load 

DH Still Feed Drum overpressure due to ice pluggage in the wet vent caused both 

rupture discs to burst 

Premature failure of rupture disc 

Rupture disc burst due to overpressure - reason unknown 

Rupture disc burst due to overpressure - reason unknown 

Normal shutdown of OHC Reactor R-301-B Scrubber 
RECORD OF VINYL CHLORIDE EMISSIONS IN EXCESS OF STANDARDS 

PVC PLANT 

Date 

1/20/85 

1/31/85 

1099-1902 

.:\V 

0955 T 

Amount 

VCM 

Released 

22 pounds 

71 pounds 

Source Cause 

#1 Receiver Sight Glass Extremely cold temperatures caused sight glass to crack, spilling water saturated 

with VCM to pad 

#2 Jockey Pump Seal Unsupported pressure controller fell, shearing seal flush tubing 

Flush Tubing 
P.25 

Georgia Ffeicific Corporation P. O. Box 629 

Plaquemine, Louisiana 70764 

Telephone (304) 687-6321 

December 13, 1984 

Certified 

L

- ^ i~ ] Y F 

-D 

14 

«';-? 

•Ui\ 

Mr. Gustave VonBodungen 

Program Administrator 

Air Quality Division 

Department of Environmental Quality 

P. 0. Box 44066 

Baton Rouge, LA 70804 

Dear Mr. VonBodungen: 

Subject: LESHAP Quarterly Report-Polyvinyl 

Chloride and Vinyl Chloride Plants 

Pursuant to Section 77.11 of the Louisiana Air Quality Regulations, please 

find the attached LESHAP Quarterly Report for the Georgia-Pacific (Plaquemine 

Division) polyvinyl chloride and vinyl chloride plants. This report covers 

the period from September 1, 1984 to November 30, 1984. 

Contained in the report are data pertaining to: 

1. Emissions which were in excess of prescribed emission limits. 

2. The residual vinyl chloride monomer (RVCM) content of our 

PVC resin. 

3. PVC reactor opening losses. 

4. Periods of the VCM gas and liquid incinerator continuous 

emission monitor downtime. 

If you have any questions concerning this report, please contact Bill Newman 

at 387-0211. 

Sincerely, 

E. A. Konderla 

Plant Manager 

EAK/VJT/kr 

File 200.10.3.1 

Attachments 

Vincent J. Tretter, Jr. 

Environmental Manager 
RECORD OF EXCESS VINYL CHLORIDE EMISSIONS 

VCM PLANT 

DATE TIME AMOUNT RELEASED SOURCE CAUSE 

10/10/84 1234-1236 1- 0.56 Pounds V-318 High ethylene content ln the liquid phase 

reactor vent caused incinerator trip-out. 

10/16/84 

11/28/84 

11/27/84 

thru 

11/29/84 

1013-1014 

1437-1447 10 

Approx. 72 hrs. 

3.78 Pounds 

0.98 Pounds 

219 Pounds 

V-318 

V-318 

DH Still 

Feed 

Drum 

Change out of process control memory card 

caused a momentary shutdown of the liquid 

phase reactor and Incinerator by-pass. 

Pressure switch malfunction during repairs 

to atomizing steam line on the liquid 

incinerator diverted the dry vent to V-318. 

Failure of rupture disc caused wet vent 

header to backflow to atmosphere. 

PVC PLANT 

DATE TIME AMOUNT RELEASED SOURCE CAUSE 

10/28/84 

11/13/84 

11/27/84 

0307-0308 

2049-2200 

0620-0651 

1.4 Pounds 

101 Pounds 

59 Pounds 

82 PVC Reactor 

05 PVC Reactor 

ffl PVC Reactor 

Misalignment of manway during charging. 

Failure of defective "0" Ring. 

PVC particle prevented "0" Ring Seal. 
P.27 

Georgia-Pacific Corporation P.O. BOX 629 

Plaquemine, Louisiana 70764 

Telephone (504) 687-6321 

September 14, 1984 Certified 

RECEIVED 

S£P 17 1984 

Mr. G. A. Von Bodungen 

Program Administrator 

Department of Environmental Quality 

Air Quality Division • •*» • 

PO Box 44066 Am QIMJJTY Division 

Baton Rouge, LA 70804 

Dear Mr. Von Bodungen: 

Subject: LESHAP Quarterly Report - Polyvinyl Chloride and Vinyl Cloride 

Plants 

Attached you will find the Quarterly Report for the Georgia-Pacific 

(Plaquemine Division) polyvinyl chloride and vinyl chloride plants. This 

report conforms to the requirements of Section 77.11 of the Louisiana 

Air Quality Regulations. The report covers the period from June 1, .1984 

to August 31, 1984. 

Contained in the report are data pertaining to: 

1. Emissions which were in excess of the prescribed emission limits. 

2. The residual vinyl chloride monomer (RVCM) content of our PVC resin. 

3. PVC reactor opening losses. 

4. Periods of the VCM gaseous and liquid incinerator continuous emission 

monitor downtime. 

If you have any questions, concerning this report, please contact Bill 

Newman at (504) 687-6321. 

Sincerely, 

E. A. Konderla Vincent/J. Tretter, Jr. 

Plant Manager Environmental Manager 

EAK/VJT/WTN/dsh 

Attachments 

File 200.10.3.1 
RECORD OF EXCESS VINYL CHLORIDE EMISSIONS 

VCM PLANT 

. DATE 

6/6/84 

7/9/84 

8/4/84 

8/5/84 

8/8/84 

TIME 

1100-1105 

1131-1135 

5MO 

1900-0400 

0900-0925 

AMOUNT RELEASED 

2.58 pounds 

0.82 pounds 

3.4 pounds 

2.18 pounds 

SOURCE 

D.H. Still Feed Tank 

V-318 

V-318 

V-318 

CAUSE 

Failure of Rupture Disc caused wet vent header to relieve to atmosphere 

Incinerator trlpout due to heavy vent from loading rack 

r

1 

Failure of Modlcon system required venting of absorber column 

Shutdown of OHC Reactor R-301-B 

PVC PLANT 

. DATE 

6/13/84 

8/2/84 

TIME 

0415-0630 

1437-1440 

AMOUNT RELEASED 

90 pounds 

135 pounds 

yr- - •—••-• • • 

SOURCE CAUSE 

ff7 PVC Reactor Defective "0" Ring caused manway leak 

S.W. Charge Filter k Premature failure of relief valve 
P.29 

• t. -

c

7 

Georgia F&cific Corporation 

P.O. Box 629 

Plaquemine, Louisiana 70764 

Telephone (504) 687-6321 

June 15, 1984 R *^t0 

CERTIFIED ::* 

>WR < '~* A , , 

Mr. G. A. Von Bodungen 

Program Administrator 

Department of Environmental Quality 

Air Quality Division 

P. 0. Box 44066 

Baton Rouge, LA 70804 

SUBJECT: LESHAP Quarterly Report for the Polyvinyl 

Chloride and Vinyl Chloride Plants 

Dear Mr. Von Bodungen: 

Attached you will find the Quarterly Report for the 

Georgia-Pacific (Plaquemine Division) polyvinyl chloride 

and vinyl chloride plants. This report conforms to the 

requirements of Section 77.11 of the Louisiana Air Quality 

Regulations. The report covers the period from March 

1, 1984 to May 31, 1984. 

Contained in the report are data pertaining to: 

1. Emissions which were in excess of the prescribed 

emission limits. 

2. The residual vinyl chloride monomer (RVCM) content 

of our PVC resin. 

3. PVC reactor opening losses. 

4. Periods of the VCM gaseous and liquid incinerator 

continuous emission monitor downtime. 

If you have any questions, concerning this report, please 

contact Bill Newman at (504) 687-6321. 

Sincerely, 

Edward A. Konderla 

Plant Manager 

Vincent/7J. Tre-ferter, Jr 

Environmental Manager 

EAK/VJT/WTN:cgp 

File 200.10.3.1 
RECORD OF EXCESS VlNYL CHLORIDE EMISSIONS 

VCM PLANT 

Date 

3/14/84 

3/26/84 

4/11/84 

5/25/84 

Time 

1530-1535 

0854-0927 

0630-0634 

1355-1405 

Amount 

Released 

0.70 pounds 

0.071 pounds 

-

34.8 pounds 

34 pounds 

Source 

V-318 

V-318 ^ 

PVC PLANT 

Wastewater 

Stripper 

#2 Weigh 

Tank 

Cause 

The dry vent header bypassed the 

incinerator to V-318 due to failure 

of an in-line rupture disc. Disc 

failure was due to heavy vent load 

from VCM barge loading. " 

Wet and dry vents bypassed the incinerator to V-318 due to plant power 

"failure. 

Failure of the stripper level control 

valve and overhead pressure controller caused the column to overfill 

and lift the relief valve. 

A defective 1" flex hose attached to 

the weigh tank developed a split 

along the weld. 
P.31 

Georgia-ffecific Corporation p.o. Box 629 

Plaquemine, Louisiana 70764 

Telephone (504) 687-6321 

March 15, 1984 

CERTIFIED.. 

Mr. G. A. Von Bodungen 

Program Administrator 

Department of Environmental Quality 

Air Quality Division 

P. 0. Box 44066 

Baton Rouge, LA 7 0804 

•ntUEM/E D 

MR 16 im 

SUBJECT: LESHAP Quarterly Report for the Polyvinyl Chloride 

and Vinyl Chloride Plants 

Dear Mr. Von Bodungen: 

Attached you will find the Quarterly Report for the 

Georgia-Pacific (Plaquemine Division) polyvinyl chloride 

and vinyl chloride plants. This report conforms to the 

requirements of Section 77.11 of the Louisiana Air Quality 

Regulations. The report covers the period from December 

1, 1983 to February 29, 1984. 

Contained in the report are data pertaining to: 

1. Emissions which are in excess of the prescribed emission 

limits. 

The residual vinyl chloride 

of our PVC resin. 

monomer (RVCM) content 

3. PVC reactor opening losses. 

4. Periods of the VCM gaseous and liquid incinerator 

continuous emission monitor downtime. 

If you have any questions, concerning, this report, please 

contact Bill Newman at (504) 687-6321. 

Sincerely, 

Edward A. Konderla 

Plant Manager 

EAK/VJT/WTN:cgp 

File 200.10.3.1 

Vincent J. Trdtter, Jr 

Environmental Manager 
RECORD OF EMISSIONS * VCM Plan t 

a t e 

12-12-8 3 

12-25-8 3 

12-25-8 3 

12-25-8 3 

12-25-8 3 

12-28-8 3 

12-28-8 3 

12-28-8 3 

Time 

184 7 - y 

185 9 

14 00 > 

1 

14 00 '*' 

140 0

 / 

010 0 -

140 0 

161 9 

222 6 '• 

011 6 * 

Emission 

Point 

V-31 8 

V-31 8 

V-31 8 

V-31 8 

SV-66 2 

V-31 8 

V-31 8 

V-31 8 

Concentratio n 

(ppm) 

" 

— 

— 

Approximate 

Quantity 

(pounds) 

. 1 7 lb s 

VCM y 

. 0 2 lb s 

VCM 

. 0 2 lb s 

VCM y 

. 0 2 lb s 

VCM 

1.5 6 lb s 

VCM 

1.3 2 lb s 

VCM / 

. 4 2 lb s 

VCM

 y/ 

.62 1 lb s 

VCM , , 

Cause 

Startu p o f OHC R-301-B . 

Shutdown of R-301-D . 

Shutdown of R-3 01-C 

Shutdown of R-301-B 

Proces s H2 0 from V-64 1 wa s sen t t o SV-662 

d u e t o freez e u p of V-64 1 stripper . 

OHC R-301B startu p an d shutdow n 

Startu p of OHC R-301-B . 

Startu p of OHC R-301-D . 
RECORD OF EMISSIONS - VCM Plan t 

lat e 

1-4-8 4 

1-4-8 4 

1-20-8 4 

1-20-8 4 

Time 

211 5 -

213 8 

140 9 -

141 1 

130 2 - ,o 

130 8 

135 1 - A 

140 0 

Emission 

Poin t 

V-31 8 

R-301-B 

V-31 8 

V-31 8 

Concentratio n 

(ppm) 

— 

— 

" 

Approximate 

Quantity 

(pounds) 

. 3 3 lb s 

VCM y 

7 . 5 lb s 

VCM 

. 0 4 lb s 

VCM •/ 

.10 2 lb s • / 

VCM 

Cause 

Startu p of R-301-B 

Blown ruptur e dis c on R-301-B . 

Shutdown R-301-B fo r turnaround . 

Shutdow n R-301- D fo r turnaround . 

. — 
RECORD OF EMISSIONS - VCM Plan t 

)ate 

2-3-84 

2-3-84 

2-4-84 

2-5-84 

2-5-84 

2-8-84 

2-8-84 

2-13-84 

2-13-84 

2-20-84 

Time 

2234 

2333 

1610 

1724 

0004 

0033 

1028 

1033 

1419 

1441 

0245 

1333 

1400 

0136 

0138 

1033 

1041 

0925 

0952 

- , 

" S<\ 

- 7M 

- 2 V 

- 5 

- -LZ 

~ 7.1 

z. 

- % 

-11 

Emission 

Point 

V-318 

V-318 

V-318 

V-318 

V-318 

R-301-A 

V-318 

V-318 

V-318 

V-318 

Concentration 

(ppm) 

— 

TM 

Approximate 

Quantity 

(pounds) 

.78 lbs 

VCM 

.50 lbs 

VCM 

.29 lbs 

VCM 

.07 lbs 

VCM 

.24 lbs 

VCM 

9.1 lbs 

VCM 

.28 lbs 

VCM 

.02 lbs 

VCM 

.20 lbs 

VCM 

.18 lbs 

VCM 

•/ 

y 

/ 

v/ 

J 

J 

J 

J 

/ 

J 

Cause 

Startup of R-301-A after turnaround. 

Startup of R-301-D after turnaround. 

Startup of R-301C after turnaround. 

R-301-A was shutdown due to a section of 

lined pipe (tee) was found leaking. 

Startup of R-301-A after leak on pipe 

repaired. 

Premature rupture disc failure on R-301-A. 

Startup of R-301-A after rupture disc 

failure. 

Shutdown of R-301-A after an expansion 

joint failed on the secondary condensor. 

Startup of R-301-A after expansion joint 

repair. 

Startup of R-301-B due to increase in 

production. 
RECORD OF EMISSIONS - VCM Plan t 

Date 

2-28-8 4 

Time 

075 1 -

080 3 ^ 

/ 

Emission 

Point 

V-31 8 

. 

Concentratio n 

(ppm) 

Approximate 

Quantity 

(pounds) 

1 . 2 lb s v / 

VCM 

Cause 

Lost 0 2 t o R-301- D fo r n o apparen t reaso n 

h a d t o shutdow n an d restar t by ventin g 

t o V-318 . 
RECORD OF EMISSIONS - PVC Plan t 

)at e 

2-23-8 4 

V 

i 

Time 

192 6 -

200 0 

Emission 

Poin t 

N o . 6 

Reacto r 

• 

Concentratio n 

(ppm) 

Approximate 

Quantity 

(pounds) 

309 lb s 

VCM 

Cause 

Reacto r "0 " rin g leak . 
Georgia-Pacific Corporation P.O. Box 629 

Plaquemine, Louisiana 70764 

Telephone (504) 687-6321 

December 20, 1983 

CERTIFIED 

Mr. G. A. Von Bodungen 

Department of Natural Resources 

Office of Environmental Affairs 

Air Quality Division 

P. 0. Box 44066 

Baton Rouge, LA 7 08 04 0EA/u-::z '*iDH 

SUBJECT: LESHAP Quarterly Report for the Polyvinyl Chloride 

and Vinyl Chloride Plants 

Dear Mr. Von Bodungen: 

Attached you will find the Quarterly Report for the 

Georgia-Pacific (Plaquemine Division) polyvinyl chloride 

and vinyl chloride plants. This report conforms to the 

requirements of Section 77.11 of the Air Quality Division 

regulations. This report covers the period from September 

1, 1983 to November 30, 1983. 

The report contains data pertaining to 

(1) 

(2) 

emissions which are in excess of the prescribed emission 

limits. 

the residual vinyl chloride 

of the resin. 

monomer (RVCM) content 

(3) PVC reactor opening losses. 

If you have any questions, please contact Marilee Parks 

at (504) 687-6321. 

Sincerely, 

Edward A. Konderla 

Plant Manager 

Vince*ft J. Trotter, Jr. 

Environmental Manager 

EAK/VJT/MDP:cgp 

cc: William Taylor, U. S. Environmental Protection Agency, Dallas, TX 

File 200.10.3.1 
RECORD OF EMISSIONS - PVC PLANT 

Date Time 

Emission 

Point 

Approximate 

lbs. Cause 

10-18-83 

11-2-83 

11-23-80 

18:10 

to 

18:13 

10:15 

03:00 

Northwest 

VCM Charge 

Filter 

Reactor #1 

Northeast 

VCM Charge 

Filter 

287 Blown rupture disk/relief valve lifted, 

137 

7.95 

Malfunction of valves 510 A & B 

Malfunction of valve XV-521-3 
Date 

9-16-83 

9-24-83 

9-24-82 

9-24-83 

9-24-83 

9-25-83 

9-25-83 

10-1-83 

Time 

8:00

 M D 

to 8:40 

15:00 

15:02 

16:46

 n 

to 17:03 

7:10 

12:20 to 

12:58 *« 

5:21 to 

5:34

 ]i 

12:59 to 

13:00 i 

Emission 

Point 

IN-662 

R-301C 

R-301B 

R-30.1D 

R-301C 

• 

R-301B 

R-301C 

V-318 

Approximate 

lbs. 

5.0 ^ 

9.4 

9.4 

0.188 

5.8 

0.435 

0.18 

0.03 

Cause 

The mechanism which feeds the wet and dry vent 

header (fuel gun) to the liquid incinerator 

developed an 1/8" leak at a gasket joint; the 

gasket was subsequently replaced. 

Two reactors overpressured due to an 

unavoidable high pressure pack of nitrogen which 

was being piped to the OHC reactors. The rupture 

disk on reactor R-301B was blown, followed 

by the rupture disk on reactor R-301C. 

See above. 

Normal startup of reactor R-301D. 

The rupture disk on reactor R-301C failed during 

start up. The rupture disk was newly installed, 

but was defective as received from the manufacturer 

Normal startup of reactor R-301B. 

Normal startup of reactor R-301C. 

A defective thermocouple associated with the liquid 

incinerator gave a false temperature reading 

which subsequently attempted to shut down the 

liquid incinerator and divert its feed stream to 

the gaseous incinerator. A bad pressure switch 

on the gaseous incinerator would not allow the 

switch, so the feed streams subsequently went to 

V-318. Both the thermocouple and the pressure 

switch were replaced. 
Date 

10-2-83 

10-3-83 

10-10-83 

11-10-83 

11-10-83 

11-30-83 

Time 

4:30 to 

4:45 

10:05 

7:57 to 

8:11 n 

5:06 to 

5:08 T. 

11:15 to 

11:27 iT20:49 to 

20:50 , 

Emission 

Point 

VCM absorber 

tower 

Filter 601-B 

V-318 

V-318 

V-318 

V-318 

Approximate 

lbs. 

52.0 

23.75 

0.086 

0.02 

0.17 

0.019 

Cause 

This leak occured through a misfitting seat on a 

pressure relief valve. The bad fit was caused by 

corrosion from standing rain water and was 

corrected. 

The release occurred from the thermal relief valve 

on filter 601B in the sphere area. The VCM filter 

had been blocked in and as the filter warmed during 

the day, the pressure built up and blew the rupture 

disc. The VCM vapors escaped out thru a leaking 

tattle tale device, but did not lift the relief 

valve. 

The low temperature shutdown switch to the OHC 

reactor thermocouple failed due to a loose wire. 

This caused the oxygen feed valve to close which 

created a high pressure in the reactor. The 

reactor was vented to V-318 until the pressure 

subsided. 

Reactor R-301D had to be shutdown and vented to 

V-318 so that Maintenance could repair a 3" flange 

on bottom of the primary condenser. 

Normal startup of OHC reactor, 

OHC reactor shutdown due to decrease in production. 
1 

P.41 

Georgia-Pacific Corporation P.O.Box629 / * ~~^y. 

Plaquemine, Louisiana 70764 CJ 

Telephone (504) 687-6321 

September 15, 1983 :Q 

SEP i 6 ^ ^ 

A m

 ^*ur y Dl,//C. r 

CERTIFIED ^E^/D^fi >''"''0'V 

Mr. G. A. Von Bodungen 

Department of Natural Resources 

Office of Environmental Affairs 

Air Quality Division 

P. 0. Box 44066 

Baton Rouge, LA 70804 

SUBJECT: NESHAP Semi-Annual Report for the Polyvinyl Chloride and 

Vinyl Chloride Plants 

Dear Mr. Von Bodungen: 

Attached you will find the Semi-Annual Report for the Georgia-Pacific 

(Plaquemine Division) polyvinyl chloride and vinyl chloride plants. 

This report conforms to the requirements of Section 61.70 of 40 CFR 

61, Subpart F and Section 77.11 of the Air Quality Division regulations. 

This report covers the period from March 1, 1983 to August 31, 1983. 

The report contains data pertaining to 

(1) emissions which are in excess of the prescribed emission limits. 

(2) the residual vinyl chloride monomer (RVCM) content of the resin. 

(3) PVC reactor opening losses. 

If you have any questions, please contact Robert Vigil at (504) 687-6321. 

Sincerely, 

ed^u A. /^dA^/g 

Edward A. Konderla 

Plant Manager 

Vincentt^J. Tretter<f Jr. 

Environmental Manager 

EAK/VJT/RDV:cgp 

cc: William Taylor, U. S. Environmental Protection Agency, Dallas, TX 

File 200.9.3 

•tettMMiitoiH 
Polyvinyl Chloride riant 

RECORD OF EMISSIONS 

Date 

4/21/83 

4/26/83 

5/7/83 

8/4/83 

Time 

1330 

1945-2055 

1127-1137 

0153-0238 

Emission 

Point 

Coalescer 

Relief Valve 

No. 3 Blowdown 

Tank Lid 

Reactor Train 

No. 2 Blowdown 

Header 

Reactor No. 1 

Top Lid 

Approximate 

Quantity 

(pounds) 

19 

2 

Unknown 

56 

• 

Cause 

Relief valve discharged at 60 PSI (rated at 180 PSI) 

Suspected malfunction of relief valve. / 

Leak developed in blowdown tank lid 0-ring. 

Ruptured piping on blowdown header. 

Top Lid 0-ring failure. 

-

• 
Record of Emissions 

VINYL CHLORIDE PLANT 

te 

/16/83 

/08/83 

/13/83 

/21/83 

/2 7/83 

/06/83 

Time 

1715-

1915 

2133-

2318 

1200-

1330 

2124-

2224 

1850-

1910 

1045-

1100 

1400 

7,7 

ii 

10 

<„& 

n 0 

1^ 

Emission 

Point 

R-301-D 

Primary 

Cyclone 

V-318

 : 

V-421-B 

V-318 

V-318 

V-318 

Approximate 

Quantity (Lbs.) 

2rO 

1.5" 

\.0 

o. 53 

3/-fc 

0.8 9 

0.06 

0.04 

0.57 

30.0 0 

2 . 3 

Cause 

Leak Developed in Primary Cyclone requiring 

a reactor shutdown. 

y. Swap over of incinerators caused the dry vent 

header valve to V-318 to open. 

^Leaking valves on product neutralizer caused 

the diversion from the control device. 

^ Chlorine header pressure swing caused R-201 

imbalance and tripped the incinerator. 

,„ Chlorine feed gas problems caused the trip out 

of the Direct Chlorination Reactor, and sub-

, sequent trip out of the incinerator. 

^ Refrigeration compressors tripped causing the 

shutdown of three OHC.Reactors. Start-up and 

shutdown of OHC Reactor "A". 

./06/8 3 1530 - 3x> 

1600 

)/06/83 1540 

V-318 o.s 

Product 

Still Reflux 

Drum 

i/0 6 t o 2100 - 3 V-318 a r\ 

»/07/8 3 0600 % y ' W 

i/10/83 0100-

0830 

V-318 7,5 

76.0 0 

133.0 0 

1.35 

0.054 

Dry vent header vented to V-318 due to operational problems with OHC Reactor and Fractiona-

: tion area. 

i 

Overpressure of drums caused relief to lift. 

h v\At^rc\c\r\<.y b\ scheme. t kep°H 

•3-7 Ucfi'ed & /'-> 

Start-up of three OHC Reactors 

Leaking Auto Trip Valve and blown rupture disc 

on dry vent header. Accumulated organic 

liquids in dry vent header released to V-318. 
;cord of 

ite 

)/17/83 

>/18/83 

5/24/83 

5/29/83 

5/30/83 

5/13/83 

5/15/83 

5/17/83 

5/18/83 

5/19/83 

6/20/83 

5/20/83 

3/21/83 

S/21/83 

Emissions 

Time 

1652-

1718 

1713-

1826 

0900 

0300-

0600 

1328-

1420 

1155 

2230-

2300 

1322-

1346 

1232-

1237 

1229-

1244 

0242-

0249 

0845-

1410 

2001-

2016 

2209 

2240 

M l 

=f3 

O 

o 

3 0 

2 S 

iT 

/r 

"7 

< 0 

100 

K 

3/ 

- VINYL CHLORIDE PLANT (Cont'd*j 

Emission Approximate 

Point Quantity (Lbs.) 

V-318 O '^3 

V-318 ' 

0.45 t0.4 5 

,1 /> f J 

V-318 /*;55w^'e ' ^ 0.45 

OHC 7,0 

Reactor "A" 

F-601-B <S| & 

Relief Valve^^ ^ 

V-318 fosum0'!1* 

V-318 O / 3 

V-318 Ou H 

V-318 'C 1 ^ 

V-318 'Q. 3 5" 

V-318 (0 ,\ ^ -

V-318 ^ 

V-318 Q.*5 " 

V-318 (V,3,r>s 

0.004 

f'1 ° • 1 

l

" 0.45 

40.00 

0.13 

0.45 

0.08 

0.45 

0.54 

0.33 

0.17 

ray c i. ui j 

Cause 

Due to pluggage with catalyst in the recycle 

nozzles, OHC Reactor "B" was shut down. 

Start-up of OHC Reactor "D" 

Shutdown of OHC Reactor "C" 

Leaking valve on OHC Reactor "A" atmospheric 

vent line. 

Relief valve leaking through on F-601-B 

Shutdown of OHC Reactor "D" 

Start-up of Direct Chlorination Reactor and 

loss of liquid incinerator. 

Start-up of OHC Reactor "B" 

Shutdown of OHC Reactor "B" 

Start-up of OHC Reactor "C" 

Shutdown of OHC Reactor "D" 

Liquid trapped on upstream side of dry vent 

valve leaked through to V-318. 

Vents tripped out of liquid incinerator during start-up. 

Start-up of OHC Reactor "A" 

-

„ 

-
tuy e j u i J 

cord of Emissions - VINYL CHLORIDE PLANT (Cont'd*) 

ite Time 

)/23/83 0322-

0326 

Emission 

Point 

Approximate 

Quantity (Lbs.) 

7/17/83 0630-

0915 

V01/83 1153- *o 

1213 

3/04/83 1100 

3/18/83 2000 

8/19/83 0126- M 

0130 

Product Less than 1 Lb, 

Still Feed , £>'/ 

Drum 

)/23/83 0152- ,z V-318 

0204 

5/24/83 1947- ,3 V-318 

2000 

7/15/83 2107- g- V-318 

2112 

Or!3 

\ 

Quench £ . 7 5 

Liquid Drain 

Valve 

V-318 

Absorber 

Intercoo 

Head Gas 

0,33 

0.16 

3.2 

0.02 

0.003 

0.2 

VCM Vent 

Condenser 

(E-661) 

V-318 

/V^ty 93 5 

Jit P-r^a . 

,07 0.60 

Cause 

Cracked tubing on level transmitter 3141. 

Start-up of OHC Reactor "B" 

Liquid phase reactor start-up caused excessiye 

dry vent header loading to trip incinerator. 

Incinerator tripped due to low temperature 

caused by nitrogen purging of product neutralizer. * 

Leaking bonnet on valve. 

Shutdown of OHC Reactor "A" 

Head gasket on exchanger failed for no 

apparent reason. 

Pressure gage leak 

A hole developed in the liquid incinerator 

firebox 

8/24/83 0200-

0600 

8/25/83 1137-

1727 

VCM L-t . 0 

Barge Filter 

V-318 5*. 7? 

3/29/83 0800-0820 Byproduct C?/6 7 

1000-1020 Holding drums 

0.5 

0.55 

6.7 

->,< 

Relief valve on F-604 leaked through. 

Blown rupture disc on tank vent header 

Vented drums to change out rupture discs and 

service relief valves. 
P.46 

Occidental Chemical Corporation 

March 6, 1985 

R F r <-

Mr. Custave Von Bodungen ' l l- V/ JL. , -

Administrator 

Air Quality Division yyr^ • 

LA Dept. of Environmental Quality '"" '

 x 'x

 ^085 

P. O. Box 44066 

Baton Rouae, LA 70804 AiR Qlj;.; n- . .,, 

RE: LESHAP QUARTERLY REPORT 

DECEMBER, 1984 TO FEBRUARY, 1985 

Dear Mr. Von Bodungen, 

As required by Subpart B, Section 77.11 of the Louisiana Emission Standards 

for Hazardous Air Pollutants (LESHAP), the Addis facility is submitting the 

quarterly report covering the above period. 

This report includes resin slurry stripping residual monomer values, reactor 

opening loss data, and a report of incinerator vent excursions for the quarter. 

During this period, unusually cold weather conditions during January affected 

operating conditions, resulting in a higher than normal excursion rate for 

reactor opening losses. The slurry stripping non-compliance figures were 

due to episodic column upsets which were short-term, and back in compliance 

the following day. The incinerator vent excursion was also a result of subfreezing conditions. 

As a result of our recent LESHAP annual inspection, a procedural change was 

made as requested to utilize a 10 ppm standard gas in place of a 100 ppm 

standard gas for our incineration system. Also included in this report is our 

annual compliance test required for our wastewater stripping system. 

« 

If you have any questions, please contact this office. 

Sincerely, 

2£ uO 

Kelly ?(. Ewen 

Environmental Engineer 

O X Y 

^ ^ S KPE/md 

PVC Resins 

Highway 1 at East Sid Richardson Road, Box 8, Addis. Louisiana 70710 504/383-6297 
P.47 

INCINERATOR 

DECEMBER, 1984 

No VCM excursions during the month of December. 
P.48 

INCINERATOR 

JANUARY, 1985 

Two excursions for the month of January were recorded on \ < /. 

January 21st (subfreezing weather) in which a greater than / / 

100 ppm reading of VCM was recorded for approximately ' 

5-minutes at 7:05 p.m. and again for approximately 8-minutes 

at 7:37 p.m. the same day. "~" 

On January 22nd, the calibration procedure was changed to 

utilize a 10 ppm standard gas in place of a 100 ppm standard 

gas for which we had been using. This procedural change is 

the result of a recent LESHAP inspection recommendation. 
P.49 

INCINERATOR 

FEBRUARY, 1985 

No reportable excursions for the month of February. 
P.50 

Occidental Chemical Corporation 

CERTIFIED MAIL - P331-077-984 

November 27, 1984 

/ ! 

•> \„t ; 

* to 

•' '^••vh 

Mr. Custave Von Bodungen 

Administrator 

Air Quality Division 

LA Dept. of Environmental Quality 

P. O. Box 44066 

Baton Rouge, LA 70804 

RE: LESHAP QUARTERLY REPORT 

SEPTEMBER, 1984, TO NOVEMBER, 1984 

Dear Mr. Von Bodungen: 

As required by Subpart B, Section 77.11 of the Louisiana Emission Standards 

for Hazardous Air Pollutants, the Addis facility is submitting the quarterly 

report covering the above period. 

This report includes resin slurry stripping residual monomer values, reactor 

opening loss data, and a report of incinerator vent excursions for this quarter. 

As the 100% compliance for November results indicate, we have found and 

eliminated minor problems encountered in our "closed-reactor" program 

accounting for the three reactor opening losses. The two slurry stripping 

non-compliance figures were out because of improper temperature/pressure 

conditions. These accomplishments stress our attitude and goal of making 

our facility a leader in safety and environmental responsibility. 

If you have any questions, please contact this office. 

Sincerely, 

I 

% CJUJ 

Kelly P. Ewen 

Environmental Engineer 

KPE/md 

Attachment 

O X Y 

PVC Resins 

Highway 1 at East Sid Richardson Road. Box 8, Addis. Louisiana 70710 504/383-6297 
P.51 

INCINERATOR 

SEPTEMBER, 1984 

No VCM excursions during the month of September. 
P.52 

INCINERATOR 

OCTOBER, 1984 

No VCM excursions during the month of October. 
P.53 

INCINERATOR 

NOVEMBER, 1984 

NO VCM EXCURSIONS DURING THE MONTH OF NOVEMBER 
P.54 

Occidental Chemical Corporation 

CERTIFIED MAIL - P22 9890692 

August 29, 1984 

Mr. Gustave Von Bodungen 

Administrator 

Ait* Quality Division 

LA Dept. of Environmental Quality 

P. O. Box 44066 

Baton Rouge, LA 70804 

RE: LESHAP QUARTERLY REPORT 

JUNE, 1984 TO AUGUST, 1984 

- ** a~ ^ i„ i w r- -

Dear Mr. Von Bodungen: 

As required by Subpart B, Section 77.11 of the Louisiana Emission Standards 

for Hazardous Air Pollutants, the Addis facility is submitting the quarterly 

report covering the above period. 

The report includes resin slurry stripping residual monomer values, reactor 

opening loss data, and a report of excursions at the incinerator vent during 

July, 1984 and August, 1984. We feel these incinerator vent excursions were 

due to fuel oil temperature malfunctions. 7 

As previously reported, we have increased batch cycles in our reactors. 

The X factor shows the number of cycles between openings. 

If any additional information is needed, please contact this office. 

Sincerely, 

uJ> 

Kelly P. Ewen 

Environmental Engineer 

KPE/md 

Enclosure t^nclo: 

O X Y 

PVC Resins 

Highway 1 at East Sid Richardson Road. Box 8, Addis. Louisiana 70710 504/383-6297 
INCINERATOR 

JULY, 1984 

P.55 

Jul y 19 2 Peaks 12:55 p.m . to 1:10 p.m . 

1:50 p.m . to 1:55 p.m . 

100_ppm 

100 ppm 
P.56 

INCINERATOR 

AUGUST, 1984 

August 12 4:35 a.m. - 4:42 a.m. > 100 PPM 

August 15 7:35 p.m. - 7:45 p.m. > J00_P_EM—-

During this reporting period, two excursions at the stack were recorded. 

Both levels were due to fuel oil temperature malfunctions which since has 

been repaired. 
P.57 

Occidental Chemical Corporation 

CERTIFIED MAIL - P22 9890671 

June 5, 1984 

RECEIVED 

Mr. Gustave Von Bodungen 

Administrator *>Uti £ fc ]qox 

Air Quality Division 

LA Dept. of Environmental Quality AIR OIIAI IT 

P. 0. Box 44066 ^^t'JJ DlVl$i0N 

Baton Rouge, LA 70804 

RE: LESHAP QUARTERLY REPORT' 

MARCH, 1984 to MAY, 1984 

Dear Mr. Von Bodungen: 

As required by Subpart B, Section 77.11 of the Louisiana Emission Standards 

for Hazardous Air Pollutants, the Addis facility is submitting the quarterly 

report covering the above period. 

The report includes resin slurry stripping residual monomer values, reactor 

opening loss data, and a report of excursions at the incinerator vent during 

March, 1984 and April, 1984. These excursions were a continuation of fuel 

gun tip problem of the past. Since a local supplier of these tips was found, 

the excursions in April were due to a "fine tuning" effort. 

During the past three months, we have been doing some work with a two 

batch cycle in some reactors. The calculated VCM g/Kg will reflect this. 

The two batch cycles are designated by a 2x. 

If there are any questions concerning this report, please contact this office. 

Sincerely, 

R. C. Knight ' 

Environmental Coordinator 

RCK/md 

Enclosure 

O X Y 

PVC Resins 

Highway 1 at East Sid Richardson Road. Box 8, Addis. Louisiana 70710 504/383-6297 
P.58 

INCINERATOR VENT 

MARCH, 1984 

The following are periods during March, 1984, that the 

10 ppm of VCM maximum averaged over a one hour period 

was exceeded. It was during this period a locally manufactured fuel gun tip was installed. 

March 7 3:20PM - 3:35PM >100 ppm 

5:20PM - 5:40PM >100 ppm 

March 11 10:30AM -11:10AM >100 ppm 

March 25 9:40AM -10:05AM 25 ppm - hour average 

1:45PM - 2:20PM 50 ppm - hour average 

The period of time the limit was exceeded was reduced to a 

minimum by reducing the feed to the incinerator as soon as 

the alarm was activated. All personnel associated with this 

operation are aware of the seriousness of exceeding the 10 ppm 

limit and acted accordingly to minimize the time of the excursion. 

y, i-« ^-
P.59 

INCINERATOR VENT 

APRIL, 1984 

The new tip was installed during Apri l and the following 

excursions were the result of finding the optimum operating 

conditions. If you will note, the concentrations were only 

slightly over the limit. 

Apri l 9 3:30PM - 4:30PM 40 ppm - hour average 

4:45PM - 5:30PM 20 ppm - hour average 

Apri l 10 10:00AM -11:00AM 14 ppm - hour average 

Apri l 22 10:20AM -10:40AM 50 ppm - hour average 
P.60 

OccidentaS Chemical Corporation 

CERTIFIED MAIL P 331 077 611 March 7, 1984 

/;.'/•-. 

-—-.mmi^A- iS ^ 

Mr. Gustave Von Bodungen 

Administrator 

Air Quality Division 

Dept. of Environmental Quality 

P. O. Box 44066 

Baton Rouge, LA 70804 

RE: LESHAP QUARTERLY REPORT FOR DECEMBER, 1983, TO 

FEBRUARY, 1984 

Dear Mr. Von Bodungen: 

As required by Subpart B, Section 77.11 of the Louisiana Emission Standards 

for Hazardous Air Pollutants, the Addis facility is submitting the quarterly 

report covering the above period. 

The report includes resin slurry stripping residual monomer values, reactor 

opening loss data, and a report of excursions at the incinerator vent during 

December and January. It should also be noted that during the period, vinyl 

chloride was burned in the No. 2 boiler while the incinerator was out of service 

for repairs. At no time was vinyl chloride vented without going through a 

control device. 

As of this writing, the correct configuration tips for the fuel gun have not 

been received from the manufacturer. An alternate source of these tips has 

been found and we will proceed in that direction. We are not at all happy 

with the service provided by the manufacturer, but are frustrated by the lack 

of avenues of recourse. We feel, through our own initiative, that we have 

solved most of the problems since there were rio_excursions during F phriiar y -

Also, beginning in January, we initiated a two batch cycle in reactors #1 and #2. 

These are designated with a 2x on January's ROL data and since it was continued 

during the entire month of February, the 2x was deleted. By doing this , 

emissions are reduced by roughly 50% on these two reactors. This procedure 

will continue until August, 1984, when the internal flushing system is installed 

in all reactors, allowing us to reduce emissions even more by not opening after 

every batch. 

If any additional information is needed, please contact this office. 

Sincerely, 

RCK/md 

cc: Mr. William Taylor, Jr. 

O X Y Technical Section (6AW-AT) 

U.S. EPA, Dallas, TX 

R. C. Knight 

Environmental Coordinator 

PVC Resins 

Highway 1 at East Sid Richardson Road. Box 8. Addis, Louisiana 70710 504/383-6297 
P.61 

INCINERATOR VENT 

DECEMBER, 1983 

T he following are periods during December, 1983, that the 

10 ppm maximum averaged over a one hour period was exceeded. 

It was reported in the last quarterl y report that the fuel gun 

tips were replaced and some problems were stil l encountered. 

It was later discovered that the replacement tips supplied by 

the manufacturer were different than the original tips . Brule' 

was again notified and will visit the plant on Januar y 9, 1984, 

to evaluate the system. 

Dec. 2 

Dec. 3 

Dec. 4 

7:15AM 

6:15PM 

12:05AM 

1:00AM 

7:00AM 

9:20AM 

3:05PM 

10:45PM 

3:30AM 

10:15AM 

1:00PM 

- 7:30AM 

8:45PM 

-12:45AM ^ 

- 2:00AM > 

- 7:30AM ''-

-12:40PM -> 3 

• 3:35PM -

•11:15PM '•• 

- 3:40AM -t 

-10:55AM b' 

• 1 :20PM b 

30 ppm 

>100 ppm 

MOO ppm 

>100 ppm 

30 ppm 

60 ppm 

20 ppm 

65 ppm 

20 ppm 

i 15 ppm 

40 ppm 

averaged for 1 hr. 

averaged for 1 hr . 

averaged for 1 hr . 

averaged for 1 hr. 

averaged for 1 hr. 

averaged for 1 hr . 

averaged for 1 hr . 

Dec. 6 11:15AM -11:30AM' \ 30 ppm averaged for 1 hr. 

1z. 

b o ,~b- , 
P.62 

INCINERATOR VENT 

JANUARY, 1984 

During this reporting period, two excursions at the 

incinerator stack were recorded. 

On January 10, 1984, between 10:00 a.m. and 11:00 a.m. 

an average VCM concentration of 15 ppm was recorded. 

On January 15, 1984, between 4:45 a.m. and 5:45 a.m. 

an average VCM concentration of 50 ppm was recorded. 

Also, on January 18, 1984, the incinerator was off line 

for repairs. The VCM vapors were burned in the No. 2 

boiler. This boiler is designed for VCM destruction and 

since the operating parameters have not changed since a 

compliance test was conducted in 1980, we are confident of 

complete destruction. 
P.63 

INCINERATOR VENT 

FEBRUARY, 1984 

During this reporting period, VCM vapors were burned in 

our No. 2 boiler during the time the incinerator was out of 

service. These dates were January 26, February 8, and 

February 9. The boiler was operating at peak efficiency 

while burning VCM. 
P.64 

/ 

i.' 

Occidental Chemicai Corporation r>.~ _ 

December 7, 1983

 v U U 

r

^C0 9i983 

CERTIFIED MAIL - RETURN RECEIPT REQUESTED P331 077 59Q 

* ' « QUAUTY D,VK-n 

OEA/ONJ $!0N 

Mr. Gustave Von Bodungen ' *'~ 

Administrator 

Air Quality Division 

Office of Environmental Affairs 

Post Office Box 44066 

Baton Rouge, LA 70804 

Re: LESHAP Quarterly Report for September 1983 to November 1983 

Dear Mr. Von Bodungen: 

As required by Subpart B, Section 77.11 of the Louisiana Emission Standards 

for Hazardous Air Pollutants, the Addis facility is submitting the quarterly 

report covering the above period. 

The report includes resin slurry stripping residual monomer values, reactor 

opening loss data and excursions at the incinerator vent during November. 

The excursions were caused by some instrumentation problems but mainly 

by combustion ratio problems. New tips for the fuel guns were ordered 

from the manufacturer and installed but these still created some excursions. 

The manufacturer has been contacted and a remedy is expected. 

If any additional information is needed, please contact this office. 

Sincerely, 

R. C. Knight 

Environmental Coordinator 

RCK/clg 

Enclosures 

cc: Mr. William Taylor, Jr. 

Technical Section (6AW-AT) 

U.S. EPA Region 6 

1201 Elm Street 

Dallas, Texas 75270 

O X Y 

PVC Resins 

Highway 1 at East Sid Richardson Road. Box 8. Addis. Louisiana 70710 504/383-6297 
P.65 

INCINERATOR VENT 

VCM IN PPM'S 

NOVEMBER, 1983 

The following are excursions recorded on the incinerator stack during the month of 

November, 1983. These excursions were caused by instrumentation problems plus 

fuel gun nozzle ti p problems . Thi s caused poor combustion of the fuel oi l firing 

the incinerator. New tips were ordered from the manufacturer and installed. 

DATE DURATION AVERAGE CONCENTRATION 

November 1 4:00 A.M . to 5:15 A.M . / i< 90 ppm 

7:55 A.M . to 8:40 A.M . *•=" 100 ppm 

November 6 6:30 A.M . to 6:50 A.M . 50 35 ppm 

3:50 A.M . to 5:00 P.M . v 150 ppm 

November 7 9:05 A.M . to 9:40 A.M . ' y 90 ppm 

10:05 A.M . to10:35A.M . ^ c 95 ppm 

November 8 2:00 P.M . to 2:45 P.M . ^ - 100 ppm 

3:45 P.M. to 4:45 P.M. I 150 ppm 

6:30 P.M. to 7:0.0 P.M. ^ ° 150 ppm 

7:35 P.M. to 8:10 P.M. ^ ' 150 ppm 

9:05 P.M . to10:00 P.M . *% 150 ppm 

November 9 12:50 A.M . to 1:30 A.M .

 !fo 120 ppm 

2:05 A.M . to 2:25 A.M . 2e 120 ppm 

November 14 3:00 A.M . to 3:30 A.M .

 7-'° 130 ppm 

9:10 A.M . to 9:30 A.M .

 x° 150 ppm 

1:15 P.M : to 1:35 P.M. 2? y 150 ppm 

n.< 

NOTE: Since the chart is on a 0-100 scale, the values recorded over 100 ppm ar e 

estimated values . 
P.66 

- / 

Occidental Chemical Corporation

 / / f^l RECEIVE 

September 7, 1983 

CERTIFIED MAIL - RETURN RECEIPT REQUESTED P33 

fcD" 

•

JL- 121983 

1 077 5 70 '-''-''VOiVft 

Mr. Gustave Von Bodungen 

Administrator 

Air Quality Division 

Office of Environmental Affairs 

Post Office Box 44066 

Baton Rouge, LA 70804 

Re: Occidental Chemical Corporation 

LESHAP Semi-Annual Report 

Period February 26, 1983, to August 25, 1983 

Dear Mr. Von Bodungen: 

As required by 40 CFR, Part 61, Subpart F, Section 61.70 and 

also under Subpart B Section 77.11 of the Louisiana Emission 

Standards for Hazardous Air Pollutants, Occidental Chemical 

Corporation is submitting the semi-annual for the Addis 

facility covering the above period. 

The report includes suspension slurry stripping residual 

monomer values, reactor opening loss values and excursions 

at the incinerator vent in August. You will note the facility 

is still manufacturing four types of polymer. These are noted 

as to the dates of production in the report. These different 

types have different batch yields and is reflected in the 

calculation of reactor opening loss. These are available 

at this office. 

If any additional information is required concerning this 

report, please contact this office. 

Sincerely, 1 

R. C. Knight 

Environmental Coordinator 

RCK/clg 

cc : Mr. William Taylor, Jr. 

Technical Section (6AW-AT) 

U. S. EPA Region 6 

1201 Elm Street 

Dallas, Texas 75270 

OXY 

PVC Resins 

Highway 1 at East Sid Richardson Road, Box 8. Addis. Louisiana 70710 504/383-6297 
i, " t 

INCINERATOR VENT 

AUGUST 1983 

During the startup of the plant after a 2 week maintenance 

shutdown, 23 separate occasions of exceeding the limit of 10 

ppm of vinyl chloride exiting this control unit were recorded 

on the continuous monitoring unit. 

P.67 

After such an extensive 

must be purged of all o 

is then purged from the 

This purge is directed 

the carbon adsorption u 

and then to the inciner 

startup, the purge oper 

in the secondary gas ho 

normal level. In turn 

this concentration and 

These breakthroughs or 

incinerator . 

shutdown the complete 

xygen by using nitrogen 

system with vinyl chlo 

to the secondary gas ho 

nit in an effort to rec 

ator. During the first 

ation caused the VCM co 

lder to increase to a h 

the carbon unit could n 

numerous breakthroughs 

surges caused the excur 

production unit 

The nitrogen 

ride monomer, 

lder, through 

over the VCM 

3 days of 

ncentration 

igher than 

ot handle 

occurred. 

sions at the 

In an effort to minimize, or hopefully, eliminate the 

excursions several moves were made. A series of Tedlar 

bag samples were obtained and analyzed to verify the emissions 

When the emissions were verified to be VCM, production was 

reduced in an effort to reduce the load on the recovery 

system. The line from the recovery area to the incinerator 

was inspected and was found to have an accumulation of 

foreign matter from the shutdown and startup procedure. 

The line was cleaned. The fire checks at the incinerator 

were also cleaned several times. 

We feel the problem was minimized by these positive actions 

but unfortunately, not eliminated. The following are the 

dates, duration and concentrations of the excursions: 

DATE 

August 8 

TIME AVG. CONCENTRATION OF VCM 

August 9 

4 :00 

6 :30 

10 :15 

12:30 

2:30 

4:30 

6:30 

8:30 

10:45 

12:45 

2:45 

4:40 

6 :45 

8:45 

1 1 :45 

3:00 

4:45 

6:45 

8:05 

9:30 

AM 

AM 

AM 

PM 

PM 

PM 

PM 

PM 

PM 

AM 

AM 

AM 

AM 

AM 

AM 

PM 

PM 

PM 

PM 

PM 

to 

to 

to 

to 

to 

to 

to 

to 

to 

to 

to 

to 

to 

to 

to 

to 

to 

to 

to 

to 

5:00 

7 :00 

1 1 :30 

12:45 

3:30 

6:15 

7:30 

9:15 

1 1 :30 

1 :50 

3:45 

6:00 

7 :20 

9:30 

12:15 

4:15 

5:45 

7:35 

8:45 

AM 

AM 

AM 

PM 

PM 

PM 

PM 

PM 

PM 

AM 

AM 

AM 

AM 

AM 

PM 

PM 

PM 

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/ 

r 

I 

. b>. 

/ 

9-

I 

.s 

/)? 

1 

I 

».*"> 

.15 

.'/5 

,$ 

1 

t 

1 

.':> 

80 

•7100 

7100 

7100 

>100 

>100 

>100 

>100 

80 

>100 

>100 

>100 

>100 

80 

20 

>100 

45 

50 

60 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 

ppm 
P.68 

Occidental Chemical Corporation 

. ^p-

% 4* ^V;\ 

CERTIFIED WAIL - RETURN RECEIPT REQUESTED 

March 7, 1983 a/ ' D, *fy ^^ , 

Administrator Air Quality Division "£, A *%fe ^ S\-

Office of Environmental Affairs <3^ <£>, ^ ^ 

Mr. Gust ave Von Bodungen Q\ C\ 'S-k .-*%% 

c\ o 

Box 44066 ^ ^ 

Baton Rouge, LA 70805 % 

Re: Occidental Chemical Corporation 

NESHAP Semi-Annual Report 

Period August 26, 1982 to February 25, 1983 

Dear Mr. Von Bodungen: 

As required "by Part 61 section 61.70 of the NESHAP regulations 

for Polyvinyl Chloride facilities, Occidental Chemical Corporation 

is submitting its' semi-annual report covering the polyvinyl 

chloride stripping columns and reactor opening loss analysis 

results. 

During the Occidental reporting periods of September and October 

of 1982 there were excursions on the incinerator vent. The 

durations of time and concentrations have been reported in each 

months report. These excursions were caused by mechanical 

problems relating to the carbon adsorption unit and a feed 

control valve hanging up at the incinerator. These problems 

were corrected as expeditiously as possible and no excursions 

at this vent have been recorded since that time. 

As you will note in the data provided the Addis facility is 

now producing different grades of polymer. These have different 

batch yields and the reactor opening loss calculations reflect 

these differences. Also during the month of September some 

experimental work on putting two batches through a reactor 

before opening. The calculations of the reactor opening loss 

on these openings reflect this fact also. 

If any additional information is needed concerning this report, 

please contact this office. 

Sincerelv, 

a 

R. C. Knight 

Environmental Coordinator 

cc: Mr. A. M. Davis, Director 

/ ^^.ir & Waste Management Div. 

OXYJ S EPA Region 6 

, 1201 Elm Street 

Dallas. Texas 75270 

PVC Resins 

Highway 1 at East Sid Richardson Road. Box 8. Addis. Louisiana 70710 504/383-6297 
P.69 

INCINERATOR VENT /-^ ^ 

SEPTEmER, 1bT83" 

During the September reporting period thirteen hours of noncompliance at this vent are being reported. 

On September 17, between 2:35 P. M. and 2:4-5 P. M. a value 

of 100 ppm was recorded for ten minutes. This averages to 16 

ppm for the hour. 

On September 19, between 6:45 p. M. and 7:4-5 P. M. an average 

of 15 ppni was recorded. 

On September 20, three periods of over 10 ppm were noted. 

The following are the times and concentrations of each event. 

4:45 A. M. to 5:20 A. M. the average was 15 ppm, 10:40 A. M. 

to 12:45 P. M. the average was 16 ppm, and 4:00 P. M. to 

5:40 P. M. was 45 ppm. 

On September 21, an event was recorded from 8:20 A. M. to 

9:15 A. M. with an average concentration of 50 ppm. 

On September 22, five excursions were recorded at the following 

times. 2:40 A. M. to 2:50 A. M. a value of 110 ppm was recorded 

for an average of 18 ppm for the hour. 4:20 A. M. to 5:25 A. M. 

the average was 150 ppm, 8:00 A. M. to 8:50 A. M. averaged 

95 ppm, 10:30 A. M. to 11:25 A. M. averaged 90 ppm, and 12:35 

P. M. to 2:30 P. M. the average was 80 ppm. 

On September 25 the following two events were recorded. 11:50 

P. M. (9/24/82) to 1:20 A. M. (9/25/82) the average was 20 

ppm and 2:05 A. M. to 4:20 A.. M. the average was 75 ppm. 

The incinerator was on stream during the September reporting 

period for 744 hours and with thirteen hours of excursions it 

resulted in a 98.2% compliance value. 
I " V f 

P.70 

DATE TIME AVG. CONCENTRATION OF VCM 

August 10 

2:05 AM to 

4:00 AM to 

9:35 AM to 

1 :30 AM <-7 

2:55 AM / 

5:00 AM /, 

9:50 AM <"> 

r 

70 ppm 

22 ppm 

80 ppm 

>100 ppm 
P.71 

INCINERATOR VENT 

OCTOBER, 1932 

During the October reporting period based on the Occidental 

Chemical Corporation's fiscal month, three hours of noncompliance are being reported. 

On September 29 between 4:00 P. M. and 5:30 P. M. an average 

concentration of 75 ppm was calculated. 

On the same day an average of 40 ppm was calculated for the 

period from 9:00 P. M. to 9:30 P.M. 

On September 30, between 2:45 A. M. and 3:4-5 A. M. an average 

of 50 ppm was recorded. 

The incinerator was on stream for a total of 720 hours during 

the period for a 99.6% compliance value. 
P.72 

DOW CHEMICAL U.S.A. 

March 11, 1985 LOUISIANA DIVISION 

P. O. BOX 150 

PLAQUEMINE. LOUISIANA 70766-0150 

604 389-800 0 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED KfcY-1"/.. 

'"» S J! -A • , 

- I \/ . 

Mr. William Davis 

Chief, LESHAP Unit 

Department of Environmental Quality 

Air Quality Division 

P. 0. Box 44066 

Baton Rouge, Louisiana 70804 

2 13 85 

QUARTERLY LESHAP REPORTS FOR DECEMBER - FEBRUARY, 1985 

VINYL I AND II FACILITIES, DOW CHEMICAL U.S.A., LOUISIANA 

DIVISION 

Dear Mr. Davis: 

Attached are the quarterly LESHAP reports for the period 

December, 1984 through February, 1985 for our Vinyl I and II 

facilities. 

Please let me know should there be any questions. 

Very truly yours, 

.JUA 

Robert Kalish 

Environmental Control 

Attachments 

sb 

AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY 
P.73 

QUARTERLY REPORT 

DECEMBER .1984 - FEBRUARY 1985 

VINYL I PLANT 

DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

Per Section 77.6(b), we had the following excursions occurring 

at our control device in excess of 10 ppm:. 

None 

During the reporting period, the control devices and monitoring 

systems were in service full time. 
P.74 

QUARTERLY REPORT 

DECEMBER/JANUARY/FEBRUARY, 1985 

VINYL II PLANT 

DOW CHEMICAL U. S. A., LOUISIANA DIVISION 

There have been no incidents in which emissions exceeded the limits 

described in Sections 77.3(a) and (b), 77.4(a), or 77.6(b). 

During this period, there were no excursions on our flare. The 

flare system, control devices, and monitoring systems were in 

service full-time. 
P.75 

DOW CHEMICAL U.S.A. 

December 6, 1984 

LOUISIANA DIVISION 

P. O. BOX 150 

PLAQUEMINE. LOUISIANA 7076S-0150 

504 389-800 0 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Mr. William Davis 

Chief, LESHAP Unit 

Department of Environmental Quality 

Air Quality Division 

P. 0. Box 44066 

Baton Rouge, Louisiana 70804 

H F ^ r~ , 

c

^Ej\/c to 

"

, :<- 1 j io S4 

/</<? .•• j'/. -

' ' Z*fSio <->/y 

QUARTERLY LESHAP REPORTS FOR SEPTEMBER - NOVEMBER, 1984 

VINYL I AND II FACILITIES, DOW CHEMICAL U.S.A., LOUISIANA 

DIVISION 

Dear Mr. Davis: 

Attached are the quarterly LESHAP reports for the period 

September through November, 1984 for our Vinyl I and II 

facilities. 

Please let me know should there be any questions. 

Very truly yours, 

_<fju^-

Robert Kalish 

Environmental Control 

Attachments 

sb 

AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY 
P.76 

QUARTERLY REPORT 

SEPTEMBER - NOVEMBER, 1984 

VINYL I PLANT 

DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

Per Section 77.6(b), we had the following excursions occurring 

at our control device in excess of 10 ppm: 

None 

During the reporting period, the control devices and monitoring 

systems were in service full time. 
P.77 

QUARTERLY REPORT 

SEPTEMBER/OCTOBER/NOVEMBER 1984 

VINYL II PLANT 

DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

There have been no incidents in which emissions exceeded the limits described in 

Sections 77.3(a) and (b) or 77.4(a). Per Section 77.6(b), we had the following 

excursions occurring at our control device in excess of 10 ppm. 

DATE 

10/03/84 

11/28/84 

DURATION 

HOURS 

AVG. CONC. 

(PPM) 

33.2 

15.1 

DESCRIPTION 

F-420 overloaded due to procedure error; 

too much feed added too quickly. 

F-410 incomplete combustion due to drop 

in control temperature 

During this time period, there were no excursions on our flare. The flare 

system, control devices, and monitoring systems were in service full time. 
P.78 

DOW CHEMICAL U.S.A. 

September 10,1984 LOUISIANA DIVISION 

P. O. BOX 150 

PLAQUEMINE. LOUISIANA 70766-0150 

604 389-800O 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

n fc L •: H/Pn 

•-**• < 

Mr. William Davis 

Chief, LESHAP Unit 

Department of Environmental Quality 

Air Quality Division 

P. 0. Box 44066 

Baton Rouge, Louisiana 70804 

y.',t, 

+•!•. I' r 

QUARTERLY LESHAP REPORTS FOR JUNE - AUGUST, 1984 FOR 

VINYL I AND II FACILITIES, DOW CHEMICAL U.S.A., LOUISIANA 

DIVISION 

Dear Mr. Davis: 

Attached are the quarterly LESHAP reports for the period 

June - August, 1984 for our Vinyl I and II facilities. 

Please let me know should there be any questions. 

Very truly yours, 

/JL* 

Robert Kalish 

Environmental Control 

Attachments 

sb 

AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY 
P.79 

QUARTERLY REPORT 

JUNE/JULY/AUGUST 1984 

VINYL II PLANT 

DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

There have been no incidents in which emissions exceeded the limits described 

in Sections 77.3(a) and (b) or 77.4(a). Per Section 77.6(b), we had the 

following excursions occurring at our control device in excess of 10 ppm. 

DATE 

07/16/84 

08/23/84 

DURATION 

HOURS 

1 

1 

AVG. CONC. 

(PPM) 

17.4 

39.0 

DESCRIPTION 

ST-423 fuel rich 

ST-412 leak in feed housing 

FLARE EQUIVALENCY REPORTING DATA 

DATE 

06/29/84 

07/01/84 

07/11/84 

08/22/84 

HOURS 

DURATION 

AVG. CONC. 

(PPM) 

7,430 

12,405 

3,846 

3,171 

DESCRIPTION 

HCl & other vent opened to flare header 

when F-420 tripped and R-400 feed line 

was plugged. 

F-103 & 4 auto trip scheme failure 

and overpressure through D-112 

F-102 EBV leaking by - repiped it into 

D-101 

V-141A SV relieved from hydraulic 

head while plant was shutdown 

y 

During the reporting period, the flare system, control devices, and monitoring 

systems were in service full time. 

Submitted: 09-05-84 
P.80 

QUARTERLY REPORT 

June - August, 1984 

Vinyl I Plant 

Dow Chemical U.S.A., Louisiana Division 

Per Section 77.6(b), we had the following excursions occurring 

at our control device in excess of 10 ppm: 

Date 

6-3-84 

6-3-84 

6-4-84 

6-14-84 

6-15-84 

Time 

07:00-08:00 

10:00-11:00 

18:00-19:00 

05:00-06:00 

20:00-21:00 

Duration 

(Hours) 

1 hour 

1 hour 

1 hour 

1 hour 

1 hour 

Avg. Cone. 

(PPM) 

11.9 

13.8 

10.3 

12.8 

10.6 

Description 

No apparent cause 

Analyzer problem. 

Reactor upset. 

Reactor upset. 

Swap loading. 

During the reporting period, the control devices and monitoring 

systems were in service full time. 
P.81 

•«^ia!'5v>*'.> 

^ (, ?" 

DOW CHEMICAL U.S.A. 

Jun e 7, 1984 LOUISIANA DIVISION 

P. O. BOX 150 

PLAQUEMINE. LOUISIANA 70765-0150 

504 388-8000 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Mr. Gus VonBodungen 

Department of Environmental Quality 

Air Quality Division 

P. 0. Box 44066 

Baton Rouge, Louisiana 70804 

H • »* ***» nil 

^

;

' - ^ I 1S34 

AIR QU,\irv „„„_ 

'o/v 

NESHAP/LESHAP QUARTERLY REPORT, VINYL I AND VINYL II 

FACILITIES - DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

Dear Mr. VonBodungen: 

Attached are the NESHAP/LESHAP quarterly reports for the 

period of March through May, 1984 for our Vinyl I and 

Vinyl II facilities. 

Please let me know if there should be any questions. 

Very truly yours, 

CU^x-— ^.<(jU*A 

Robert Kalish 

Environmental Control 

Attachments 

sb 

AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY 
P.82 

QUARTERLY REPORT 

MARCH - MAY, 1984 

VINYL I PLANT 

DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

Per Section 77.6(b), we had the following excursions occurring at our 

control device in excess of 10 ppm: 

N AVG. CONC. 

DESCRIPTION 

No apparent cause 

No apparent cause 

No apparent cause 

No apparent cause 

No apparent cause 

No apparent cause 

No apparent cause 

Analyzer problems 

Putting vents on 

boilers 

Reactor upset 

Vent upset 

No apparent cause 

Analyzer problem 

Analyzer problems 

Putting vents on 

boilers 

No apparent cause 

During the reporting period, the control devices and monitoring systems 

were in service full time. v 

I I, „ 7 \\i-L. f I \~ 

"*• • rv' 

DATE *"' 

3/1/84 

3/6/84 

3/7/84 

3/7/84 

3/7/84 

3/8/84 

3/9/84 

3/9/84 

3/12/84 

3/23/84 

3/25/84 

3/29/84 

4/22/84 

4/23/84 

5/2/84 

5/20/84 

'\T;.w.^ 

:'jTIME 

09:00-10:00 

04:00-05:00 

04:00-05:00 

06:00-07:00 

10:00-11:00 

06:00-07:00 

04:00-05:00 

09:00-10:00 

04:00-05:00 

06:00-07:00 

1 3: 00-14: 00 

1 0: 00-1 1 :00 

07:00-08:00 

18:00-19:00 

09: 00-10: 00 

16:00-17:00 

DURATION 

(HOURS) 

1 

AVG. CONC. 

(PPM) 

10.7 

17.0 

15.8 

18.3 

10.8 

14.6 

10. 3 

10.5 

10. 6 

11.3 

10. 5 

10. 6 

12.6 

12.6 

10.8 

14.4 

•<2 ^ rf> 

J^c^^uJk^ t o^loJ A ^ SkJ- »HnrJ»«£"~ 
P.83 

QUARTERLY REPORT 

MARCH - MAY, 1984 

VINYL II PLANT 

DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

There have been no incidents in which emissions exceeded the limits 

described in Sections 77.3(a) and (b) or 77.4(a). Per Section 

77.6(b), we had no excursions occurring at our control device in 

excess of 10 ppm. 

FLARE EQUIVALENCY REPORTING DATA 

AVG. CONC. DURATION 

DATE (PPM) (HRS.) DESCRIPTION 

5/3/84 1771 4 F104 safety valve 

leaking slightly 

5/13/8 4 4701 y2c-°[l ' 2 — T1 30 safety valve 

leaked prematurely 

r . 

During the reporting, the flare system, control devices and monitoring 

systems were in service full time. -); 

.... itr.\ 

1- '/ 

<*~l AW^— nX~ cX O(JL«_*_ i y TUov ?4-*--H- Is- cy\t_ crvv . 

«t[u,A<-U<-
P.84 

DOW CHEMICAL U.S.A. 

Jul y 6, 1984 

LOUISIANA DIVISION 

P. O. BOX 150 

PLAQUEMINE. LOUISIANA 70764-015 0 

6 0 4 389-800 0 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Mr. William Davis 

Chief, LESHAP Unit 

Department of Environmental Quality 

Air Quality Division 

P. 0. Box 44066 

Baton Rouge, Louisiana 70804 

REVISED LESHAP QUARTERLY REPORT OF MARCH - MAY, 1984 FOR 

VINYL II PLANT 

DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

Dear Mr. Davis: 

As requested in your letter of June 19, 1984, we are 

enclosing a revised report for our Vinyl II Plant for the 

period of March - May, 1984. The revised report indicates 

the actions that were taken to reduce the vinyl chloride 

concentrations to below 1500 ppm. 

We trust that the revised report contains all of the 

required information but please contact me should there be 

any questions. 

Very truly yours. 

Q^yl^JUyA*- <(jLX 

Robert Kalish 

Environmental Control 

Attachment 

s b 

£C 

JUL 0 9 1334 

AIR QUALITY DIVISION 

AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY 
P.85 

QUARTERLY REPORT 

MARCH-MAY, 1984 

VINYL II PLANT 

DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

There have been no incidents in which emissions exceeded the limits described 

in Sections 77.3(a) and (b) or 77.4(a). Per Section 77.6(b), we had no 

excursions occurring at our control device in excess of 10 ppm. 

FLARE EQUIVALENCY REPORTING DATA 

DATE 

05/03/84 

05/13/84 

AVG. CONC. 

(PPM) 

1771 

4701 

DURATION 

(HRS.) DESCRIPTION 

F104 safety 

valve leaking 

slightly. 

T130 safety 

valve leaked 

prematurely. 

ACTION TAKEN 

F104 shutdown; 

spare safety 

valve installed. 

Swapped safety 

valves and 

repaired defective 

safety valve. 

During the reporting, the flare system, control devices, and monitoring systems 

were in service full time. 

...,. .-» /=> r- E \ ;" ~ p \ 

I \ L. O L. 1 \- L- U 

Re-submitted; 07/03/84 

JUL 0 91984 

AIR QUALITY DIVISION 
1

 \L< I U • I 

DOW CHEMICAL U.S.A. 

March 15 , 1 984 LOUISIANA DIVISION 

P. O. BOX 160 

PLAQUEMINE. LOUISIANA 70764-016 0 

604 389-8000 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

M r. Gus VonBodunge n 

Departmen t o f Environmenta l Qualit y 

A i r Qualit y Divisio n 

P . 0 . Box 4406 6 

Baton Rouge, Louisiana 70804 

\/ 

:

0N 

NESHAP/LESHAP QUARTERLY REPORT, VINYL I AND VINYL II 

FACILITIES - DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

Dear Mr. VonBodungen: 

Attached are the NESHAP/LESHAP quarterly reports for the 

period of December, 1983 through February, 1984 for our 

Vinyl I and Vinyl II facilities. 

Please let me know if there should be any questions. 

Very truly yours, 

Robert Kalish 

Environmental Control 

Attachments 

sb 

AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY 
P.87 

QUARTERLY REPORT 

DECEMBER, 198 3 -FEBRUARY, 198 4 

VINYL I PLANT 

DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

Per Section 77.6(b), we had the following excursions occurring at our 

control device in excess of 10 ppm: 

DATE TIME DURATION AVERAGE CONC. 

12/24/83 14:00-15:00 1 hour 

01/06/84 18:00-19:00 1 hour 

13.8 ppm 

10.4 ppm 

DESCRIPTION 

Water in analyzer 

Upset on D.C. 

reactor 

02/04/84 22:00-23:00 1 hour 

A

VV7 

\ / 

/ 

02/06/84 05:00-06:00 1 hour 

14:00-15:00 1 hour 

02/09/84 03:00-04:00 1 hour 

02/10/84 14:00-15:00 1 hour 

02/11/84 19:00-20:00 1 hour 

10.1 ppm No apparent cause 

however, boiler 

was shut down four 

days later and 

internal leak was 

found 

12.9 ppm No apparent cause 

10.2 ppm No apparent cause 

18.8 ppm Putting vents on 

boiler 

12.3 ppm Upset on D.C. 

reactor 

18.2 ppm No apparent cause 

During the reporting period, the control devices and monitoring systems 

were in service full time. 
P.88 

QUARTERLY REPORT 

DECEMBER, 1983 -FEBRUARY, 1984 

VINYL II PLANT 

DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

There have been no incidents in which emissions exceeded the limits 

described in Sections 77.3(a) and (b) or 77.4(a). Per Section 

77.6(b), we had one excursion occurring at our control device in 

excess of 10 ppm. 

CONTROL DEVICE EXCURSIONS 

DATE 

12/6/84 

AVG. CONC. 

(PPM) 

22.8 

DURATION 

(HRS.) 

2 hours 

DESCRIPTION 

Burner feed housing 

refractory seal 

leaking slightly 

FLARE EQUIVALENCY REPORTING DATA 

DATE 

12/20/83 

AVG. CONC. 

(PPM) 

1,994 

DURATION 

(HRS.) 

2 hours 

DESCRIPTION 

2" emergency block 

valve leaking by 

F-1 02 

01/07/84 

01/13/84 

4,992 

10,014 

2 hours 

1 hour 

Source could not be 

determined 

Safety valve relieved 

on load rack vent 

drum 

During the reporting, the flare system, control devices and monitoring 

systems were in service full time. 
P.89 

' -'*'""'" 

DOW CHEMICAL U.S.A. 

December 14, 1 983 

LOUISIANA DIVISION 

P. O. BOX 160 

PLAQUEMINE. LOUISIANA 70764-0150 

604 389-8000 

Mr. Gus VonBodungen 

Department of Natural Resources 

Air Quality Division 

P. 0. Box 44066 

Baton Rouge, Louisiana 70804 

RECEI\/ED 

J u C

 1 5 1983 

NESHAP/LESHAP QUARTERLY REPORT, VINYL I AND VINYL II 

FACILITIES - DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

Dear Mr. VonBodungen: 

Attached are the NESHAP/LESHAP quarterly reports for the 

period of September, 1983 through November, 1983 for our 

Vinyl I and Vinyl II facilities. 

Please let me know if there should be any questions. 

Very truly yours, 

Q-o-c— • <JL*A 

Robert Kalish 

Environmental Control 

Attachments 

sb 

AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY 
P.90 

QUARTERLY REPORT 

SEPTEMBER - NOVEMBER, 1983 

VINYL I PLANT 

DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

CONTROL DEVICE EXCURSIONS (ABOVE 10 PPM) 

AVG. CONC. DURATION 

DATE (PPM) • (HRS.) 

9/6/83 12.6 2 

9/6/83 11.5 4 

10/23/83 20.8 1 

10/30/83 11.7 1 

During the reporting period, the control device and monitoring systems were in service at all times. 

BK: sb 

12/14/83 
P.91 

QUARTERLY REPORT 

. SEPTEMBER - NOVEMBER, 1983 

VINYL II PLANT 

DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

CONTROL DEVICE EXCURSIONS (ABOVE 10 PPM) 

DURATION 

DATE (PPM) . (HRS. ) 

AVG. CONC. 

(PPM) . 

20 

24 

20 

. 4 

. 5 

. 2 

10/6/83 20.4 2 

10/18/83 24.5 1 

10/27/83 20.2 2 

FLARE EQUIVALENCY REPORTING DATA (ABOVE 1500 PPM) 

AVG. CONC. DURATION 

DATE (PPM) (HRS.) DESCRIPTION 

11/4/83 2524 2 F104 2" EBV Air 

Tube Broke 

During the reporting period, the flare system, control 

device and monitoring systems were in service at all times 

BK: sb 

12/14/83 
P.92 

ft ' H& A!Ao > 

DOW CHEMICAL U.S.A. 

September 14, 1983 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Mr. Greg Gasperecz 

- ^ "£& 

NESHAPS Unit Leader 

Department of Natural Resources 

Air Quality Division 

P. O. Box 44066 

Baton Rouge, Louisiana 70804 

LOUISIANA DIVISION 

P. O. BOX 150 

PLAQUEMINE. LOUISIANA 70764 

504 389-800 0 

RFnr-,,^ 

>\ L. .^ r , -/T h 

V T 

SEP I 5 1353 

AlR QUAUt-v •,.... 

.J 

NESHAP/LESHAP SEMI-ANNUAL REPORT, VINYL I AND VINYL II 

FACILITIES - DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

Dear Mr. Gasperecz: 

Attached are the NESHAP/LESHAP semi-annual reports for the 

period of March, 1983 through August, 1983 for our Vinyl I 

and Vinyl II facilities. In accordance with the recently 

promulgated state regulations, reporting shall be on 

quarterly basis henceforth. 

Please let me know if there should be any questions. 

Very truly yours, 

Robert Kalish 

Environmental Control 

Attachments 

cc: Allyn M. Davis, EPA 

sb 

AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY 
P.93 

DOW 

SEMI-ANNUAL REPORT 

MARCH - AUGUST, 1983 

VINYL I PLANT 

CHEMICAL U.S.A., LOUISIANA DIVISION 

CONTROL DEVICE EXCURSIONS (ABOVE 10 PPM)-

DATE 

AVG. CONC. 

(PPM) 

3/6/83 

3/20/83 

3/21/83 

4/6/83 

7/10/83 

8/8/83 

8/19/83 

8/20/83 

8/22/83 

8/22/83 

13.5 

16.2 

10.9 

15.8 

10.6 

14.0 

16.2 

10.8 

10. 3 

13.5 

DURATION 

(HRS.) 

During the reporting period, the control device and monitoring systems were in service at all times. 

BK:sb 

9/14/83 
P.94 

SEMI-ANNUAL REPORT 

MARCH - AUGUST, 1983 

VINYL II PLANT 

DOW CHEMICAL U.S.A., LOUISIANA DIVISION 

CONTROL DEVICE EXCURSIONS (ABOVE 10 PPM) 

DATE 

5/20/83 

7/22/83 

7/27/83 

AVG. CONC. 

(PPM) 

75.0 

10.2 

15.8 

DURATION 

(HRS.) 

1 

1 

1 

FLARE EQUIVALENCY REPORTING DATA (ABOVE 1500 PPM) 

DATE 

AVG. CONC. 

(PPM) 

DURATION 

(HRS . ) DESCRIPTION 

4/8/83 2842 1 Overpressurized while 

cleaning with nitrogen 

6/1/83 2707 V-141 safety valve y 

re lease. 

8/29/83 2208 C-100 safety valve 

release. 

During the reporting period, the flare system, control 

device and monitoring systems were in service at all times. 

BK: sb 

9/14/83