OAR Box 1107 

Prepped by Ollie Stewart 

Document Number: 

47) IV-E-3 

Docket Number: 

A-81-21 

Printed 4/11/2008 3:03:46 PM Sheet 47 of 90 

P.1 
P.2 

A-8I-2I 

IV-E-3 

MEMORANDUM 

DATE: January 10, 1985 

TO: Leslie B. Evans, Chemicals and Petroleum Branch 

FROM: Karen K. Fidler, Radian 

SUBJECT: Meeting Report - Incinerator Bypass Discussion with 

BF Goodrich Representatives 

I. PURPOSE 

Representatives of BF Goodrich provided infonnation on incinerator 

operations and incinerator bypass occurrences at their two ethylene 

dichloride/vinyl chloride (EDC/VC) facilities and six polyvinyl chloride 

(PVC) facilities. This information will be used to study the need for a 

control device bypass provision for the VC standard. The purpose of the 

meeting was to gain familiarity with the design and operation of control 

devices used by the EDC, «C and PVC industries. 

II. PLACE AND DATE 

U.S. Environmental Protection Agency 

North Carolina Mutual Building 

Durham, North Carolina 

January 7, 1985 

III. ATTENDEES 

Fred Dimmick, EPA/OAQPS/ESED/SDB 

Leslie Evans, EPA/OAQPS/ESED/CPB 

Bob Rosensteel, EPA/OAQPS/ESED/CPB 

Gil Wood, EPA/OAQPS/ESED/SDB 

Susan Wyatt, EPA/OAQPS/ESED/CPB 

Karen Fidler, Radian Corporation 

Jeff Shumaker, Radian Corporation 

Jim Fannin, BF Goodrich 

W.C. Holbrook, BF Goodrich 

IV. DISCUSSION 

Prior to the meeting, EPA provided the BF Goodrich representatives with 

a list of information needs to serve as the basis for the meeting discussion. 

(See letter from Evans, L. to Holbrook, W., December 5, 198^^Docket No. 

.) Information presented on BF Goodrich's two EDC/VC facilities and 

six PVC facilities is summarized below. 

Progress Center/3200 E. Chapel Hill Rd./Nelson Hwy./P.O. Box 13000/Research Triangle Park, N.C. 27709/(919)541-9100 
P.3 

1. EDC/VC - La Porte, Texas 

BF Goodrich's LaPorte facility produces VC from ethylene by an 

air-based process. The plant was purchased from Diamond Shamrock in 1982. 

The facility was started up in 1978. 

1.1 Incineration System Design and Operation 

Two identical John Zinc incinerators were included as original 

equipment in the LaPorte facility. Each incinerator is equipped with a 

waste heat boiler and HCl scrubber. One of the systems has steam turbine 

driven combustion air blowers and boiler water pumps and a cylinder supply 

of instrument air so that it can be operated during a power failure. 

Design and operating parameters for the two incinerators are as 

follows: 

Design capacity 

Heat input rate - [Confidential] 

Waste gas load - [Confidential] 

Temperature 

Operating - 1,800°F 

High shutdown - 2,100°F 

Low shutdown - 1,470°F 

Residence time - 3 sec 

The two incinerators are operated simultaneously unless one is down for 

maintenance or repair. Although each incinerator is capable of handling all 

of the vent gases generated under normal process operating conditions with 

spare capacity, the vent gases are typically split between the two incinerators. In the absence of waste gas load, the incinerators can be maintained 

at their operating temperature by firing natural gas at about 15 to 20 percent 

of the design heat input rate. The incinerators are capable of burning 

liquid wastes, but usually are not used for this application. 

1.2 Incinerator Bypasses 

Three headers (the dry vent, the wet vent and the oxyvent headers) 

transport vent gases to the incinerator. Manual valves positioned remotely 

from the control room are available to direct the flow in each header 

between the two incinerators. However, the valves are normally open. In 

the event one incinerator trips, an automatic control valve at the incinerator 

inlet closes thus diverting the portion of the vent gases going to that 

incinerator to the other incinerator. (This can be done without upsetting 

the second incinerator in part due to the large excess capacity of both 
P.4 

systems.) If both incineration systems go down, each of the headers are 

equipped with manual control valves which can be activated remotely from the 

control room to bypass the vent gases to the atmosphere. Such bypasses do 

not occur automatically but require operator activation. (In addition to 

the manual bypass control, the system includes pressure relief valves with 

rupture discs to ensure system safety.) Bypassed vent gases are discharged 

without scrubbing to the atmosphere at stack elevation. 

Conditions which automatically result in shutdown of an incinerator and 

automatic diversion of vent gases to the second incinerator include: 

Fuel gas pressure too high or low; 

Combustion air pressure too low; 

Flame sensor; 

Low water level in steam drum; 

High water level in scrubber; 

High temperature; 

Low temperature; and 

Low pressure in atomizing steam when burning liquids. 

1.3 Method for Estimating VC Emissions During Bypass 

To estimate the amount of VC emissions in incinerator bypasses, flow 

volume during the bypass is noted by flow measurement devices in the 

header(s) and a grab sample is taken of the bypass stream(s). Determination 

of VC emissions in this way is considered to be more reliable than estimates 

based on bypass duration and typical vent stream characteristics. Gas 

samples of bypassed streams are taken during or as soon as practical 

following a bypass event. The operator's first priority is to regain system 

operation. 

1.4 VC Emissions During Startup/Shutdown 

A special technique used by this plant enables the oxychlorination 

reactor to start up and shut down without venting to the atmosphere (as do 

other "air based" oxychlorination processes). Details on this procedure are 

not available. The remainder of the plant was designed for normal startup/ 

shutdown operations without venting to the atmosphere. Unplanned or "crash" 

shutdowns similarily do not require incinerator bypass under most 

circumstances. 
P.5 

1.5 Impact of Oxychlorination Vent 

The oxyvent makes up 94.8 percent by weight of the vent gases burned in 

the incinerators. However, because of the excess capacity available for the 

two incinerators, oxyvent surges are easily handled. As a result, no 

incinerator bypasses have occurred over the past two years (1983 - 1984) 

because of oxyvent surges. 

1.6 Incinerator Bypass History 

The following information on 10 ppm exceedences and incinerator 

bypasses during 1983 and 1984 was provided: 

1983 1984 

10 ppm exceedences 2 hr 0 hr 

Cumulative bypass time 1.2 hr 4 hr 

The BF Goodrich/LaPorte facility has experienced a total of five 

incinerator bypass incidents during the two-year period 1983 through 1984. 

Information on the bypass incidents is summarized as follows: 

Duration Amount 

Date (min) (lb VC) Cause 

12/83 - 0.4 Frozen boiler feed water line. 

5/84 148 166 Steam pressure lost during power 

failure. Problem was at adjacent 

Diamond Shamrock facility from which 

power is received. Power failed 

twice in succession; bypass occurred 

during second failure. 

5/84 20 - High heat content in vent gas caused 

by faulty liquid/vapor interface 

indication. Instrument failure is 

attributed to the earlier power 

failure. 

7/84 7 15 Vent header bypassed to atmosphere 

while investigating two leaks in the 

incinerator feed line. The first 

leak was stopped and the second 

reduced; the second leak was repaired 

during the next bypass below. 

7/84 46 114 Vent header bypassed to atmosphere 

while repairing section of incinerator feed line. 

<+ 
P.6 

12/84 17 - Plant steam boilers shut down, 

triggering gas line pressure surge 

and high steam demand from incinerator heat recovery system. Incinerators tripped due to either pressure 

surge or low water level in heat 

recovery steam drum. 

2. EDC/VC - Calvert City, Kentucky 

BF Goodrich's Calvert City facility currently produces EDC and VC in 

several production units. The newest unit was added in 1982. 

2.1 Incineration System Design and Operation 

Three incinerators are available to burn vent gases at the Calvert City 

facility. The "primary" and "secondary" incinerators, manufactured by John 

Zinc, were added to the older EDC/VC production unit to meet the VC standard 

regulations. The "oxy" incinerator, manufactured by McGill, was constructed 

with the newest EDC unit in 1982. The primary and oxy incinerators are 

equipped with waste heat boilers and HCl scrubbers; the secondary 

incinerator vents directly to the atmosphere. 

Design and operating parameters for the three incinerators are as 

follows: 

Design heat input rate 

Primary - [Confidential] 

Secondary - [Confidential] 

Oxy - [Confidential] 

Design waste gas load 

Primary - [Confidential] 

Secondary - [Confidential] 

Oxy - [Confidential] 

Operating temperature 

Primary - 1800°F 

Secondary - 2000°F 

Oxy - 1800°F 

Residence time 

Primary - 2 sec 

Secondary - 2 sec 

Oxy - 1 sec 

4f 
P.7 

Turndown capability (% of design heat input) 

Primary - 30% 

Secondary - 20% 

Oxy - 25% 

The oxy incinerator was sized to handle the oxychlorination vent from 

the new plant in addition to the other process vents from both production 

units. (The oxyvent from the older plant is not required to be incinerated 

for VC or hydrocarbon control purposes and is therefore vented to the 

atmosphere.) The primary incinerator can burn all vents from both units 

with the exception of the new oxyvent. Normally, the primary and oxy 

incinerators are operated at all times with the secondary incinerator on 

cold standby. The primary incinerator can be maintained at operating 

temperature by burning natural gas only. If either of the primary or oxy 

incinerators trips, the vent gases (except the oxy vent) are manually 

diverted to the operable incinerator from the control room. If either of 

the primary or oxy incinerators is down, the secondary incinerator is 

brought up to hot standby and operated as needed. (Startup of the cold 

incinerator requires 1 day.) The secondary incinerator is used only on an 

as needed basis. 

2.2 Incinerator Bypasses 

Five vent headers (two dry vent headers, two wet vent headers and one 

decommissioning line) carry vent gases from the two production units to the 

primary incinerator. These vent streams can be manually switched from the 

control room to the secondary or oxy incinerator. The oxyvent from the new 

unit is ducted in a separate header to the oxy incinerator. 

When pressure in one of the vent headers exceeds the capacity of the 

operating incinerators, a portion or all of the vent gases in the header are 

automatically diverted from the incineration system. In the case of the dry 

vent and decommission vent headers, the diverted vent gases are burned in a 

flare. Diverted wet vent and oxyvent gases are vented to the atmosphere. 

The flare used to burn diverted dry vent gases was constructed prior to 

the VC standard for safety purposes (i.e., to handle reliefs of flammable 

materials). Currently, the flare is primarily used for VC service. Specifically, the flare is maintained at hot operating conditions (i.e., natural 

gas continually burned in the flare head burner) to combust occasional 

VC-containing relief valve discharges and incinerator bypasses. The flare 

is equipped with a smokeless tip. The flare was sized to handle sporadic, 

emergency vents; sufficient capacity is therefore available to handle 

incinerator bypasses. The VC destruction efficiency in the flare is unknown. 

BF Goodrich has focused administrative attention on incinerator 

bypasses at the Calvert City facility in an attempt to minimize their 

frequency and duration. As a result, steady improvement in performance has 

<o 
P.8 

reportedly been achieved. Hardware improvements include flame arrestor 

replacement, addition and replacement of knockout pots, and addition of 

cross-connections between vent headers to minimize the effect of plugged 

headers. The new oxy incinerator is located on the opposite side of the 

plant from the older primary and secondary incinerators and consequently has 

a separate feed line system. This arrangement ensures that a feed line plug 

will render only one of the incinerators inoperable. 

2.3 Method for Estimating VC Emissions During Bypasses 

The amount of VC bypassed is calculated on the basis of the bypass 

duration and VC content design data representative of the operating 

conditions prevailing at the time of the bypass. The vent headers at this 

facility are not equipped with flow measurement devices and sampling points. 

2.4 VC Emissions During Startup/Shutdown 

During startup, the oxychlorination reactor in the new unit is vented 

to the atmosphere for a period of 15 to 20 minutes. VC emissions during 

startup do not exceed the 0.2g/kg EDC standard. (Meeting the standard is 

only a problem if process upsets occur during startup and the process goes 

down without little or no resulting EDC production.) 

2.5 Impact of Oxychlorination Vent 

BF Goodrich reports no significant impact by the oxyvent on incinerator 

operations at this facility. Incinerator on-stream time is reportedly more 

affected by the age of the incineration system than the presence of the 

oxyvent. 

2.6 Incinerator Bypass History 

The BF Goodrich/Calvert City facility provides information on 10 ppm 

exceedences, flare usage and incinerator bypasses to the state of Kentucky. 

A summary of the information reported for 1983 and 1984 is given below. 

1983 1984 

10 ppm exceedences 3 hr 4 hr 

Cumulative bypass time 1 hr 2 hr 

Flare usage 15.9 hr 121.6 hr 

Information on bypass incidents and flare usage during 1983 and 1984 is 

as follows: 

1 
P.9 

Bypasses 

Date 

2/83 

3/83 

4/83 

5/83 

12/83 

11/84 

Date 

9/83 

9/83 

10/83 

10/83 

12/83 

12/83 

1/84 

1/84 

1/84 

1/84 

4/84 

Duration 

(hr) 

0.23 

0.05 

0.25 

0.17 

0.25 

2.0 

Duration 

(hr) 

0.05 

0.17 

0.12 

-

0.3 

• — 

0.4 

Amount VC 

Bypassed (lb) 

-

-

-

0.75 

Flare Usage 

Amount VC 

Vented to Flare (lb) 

0.1 

10,400 

-

0.12 

1,825 

0.13 

430 

0.16 

0.6 

2 

0.8 

Cause 

Unknown 

Unknown 

Unknown 

Unknown 

Internal power 

failure 

Internal power 

failure; loss of 

instrument air 

Cause 

Instrument 

failure 

Cracked valve on 

relief valve 

header 

Internal power 

failure 

High pressure 

drop in 

scrubber 

Leaking valve on 

relief valve 

header 

Process - upset 

high fuel content in vent 

stream 

Plugged flame 

arrestors 

High vent load; 

1 incinerator 

down for 

maintenance 

Liquid in feed 

Plugged flame 

arrestor 

Process upset in 

HTDC reactor 

t 
P.10 

4/84 

4/84 

96 

0.08 

5/84 

6/84 

6/84 

7/84 

7/84 

0.09 

0.37 

0.01 

0.07 

0.07 

9,750 

20 

55 

16.5 

350 

0.13 

1880 

Level controller 

malfunction on 

VC stripping 

column 

Overpressure in 

VC loading pump 

suction line 

High pressure in 

vent header 

Instrument error 

on VC column 

Premature rupture 

disc failure on 

VC cracking 

column 

Process upset 

during startup 

of HTDC reactor 

Premature rupture 

disc failure on 

VC cracking 

column 

3. PVC Plants 

BF Goodrich operates six PVC plants in the U.S. The plants vary in 

size, age and resin types made. Information on the design and operation of 

the control devices used at the six plants is summarized as follows: 

Plant Control Device 

Primary Backup 

Incinerator None 

B Solvent absorber Incinerator 

Performance History 

(1983-1984) 

- no 10 ppm exceedences 

- 22 hr cumulative bypass 

time 

- 429 lb VC bypassed 

- Causes: instrument 

failure; high inert 

load; high temperature 

in quench water 

Note: plant can shut 

down without venting. 

- no 10 ppm exceedences 

- no bypasses 

- backup incinerator 

operated 1.3% of time 

1 
P.11 

C Solvent absorber Incinerator 

D Solvent absorber Incinerator 

E Solvent absorber Incinerator 

F Solvent absorber Solvent absorber 

1 hr 10 ppm exceedence 

no bypasses 

backup incinerator 

operated 3.4% of time 

75 hr 10 ppm exceedence 

no bypasses 

backup incinerator 

operated 15.5% of time 

171 hr 10 ppm exceedence 

no bypasses 

backup incinerator 

operated 4.6% of time 

33 hr 10 ppm exceedence 

no bypasses 

The BF Goodrich representatives made the following general observations 

about control device operations at their PVC plants: 

Plants B through F have available pressurized storage tanks to 

temporarily store vent gases in the event of control device 

failure. Capacity of the storage vessels vary but can typically 

hold vent gases generated during a normal .8 hr shift. 

Reported exceedences of the 10 ppm standard by gases that are 

vented through solvent absorbers are typically caused by high vent 

flow, cold solvent, VC monitor malfunctions. 

Past experience indicates that absorber problems can usually be 

remedied before the backup incinerator is started up (about 1-2 

hours). Operator attention is usually focused on correcting the 

absorber problem rather than on storing and incinerating vent 

gases. 

/b