P.1 

OAR Box 1107 

Prepped by Ollie Stewart 

Document Number: 

52) IV-B-2 

Docket Number: 

A-81-21 

Printed 4/11/2008 3:03:47 PM Sheet 52 of 90 
RADIAN 

CORPORATIO N 

MEMORANDUM 

DATE: 

TO: 

FROM: 

March 21, 1985 

Vinyl Chloride Docket 

Karen K. Fidler 

A--8\-

IV-B-2 

e-iu 

-21 

SUBJECT: Information Submitted to the State of Louisiana Concerning 

Incinerator Bypasses at PVC and VC Plants 

Attached are compliance reports submitted by plants producing 

polyvinyl chloride (PVC) and vinyl chloride (VC) to the State of Louisiana 

containing information on incinerator bypasses and other 10 ppm excursions. 

These reports cover performance between March 1983 and February 1985. 

Compliance reports are included for 5 PVC plants and 7 EDC/VC plants. 

The reports were obtained during a visit to the Louisiana Department of 

Environmental Quality in Baton Rouge, Louisiana, on March 21, 1985. 

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

/ , , / -_/• / 

FFIANK P. SIMONEAUX 

SECRETARY 

B. JIM PORTER 

ASSISTANT SECRETARY 

DEPARTMENT OF NATURAL RESOURCES 

OFFICE OF ENVIRONMENTAL AFFAIRS 

AIR QUALITY DIVISION 

November 8, 1983 

GUSTAVE VON BODUNGEN 

PROGRAM ADMINISTRATOR 

Mr. C. A. Gellner 

Plant Manager 

Certainteed Corp. 

Pipe and Plastic Group 

P. 0. Box 253 

Sulphur, LA 70663 

Dear Mr. Gellner: 

We have received Certainteed Corporation's semi-annual report dated 

September 7, 1983 covering the period from March 1, 1983 to August 31, 1983. 

This report is required under Section 77.11 of Louisiana Emission Standard 

for Hazardous Air Pollutants (LESHAP). 

In reviewing the table included with the report, we note several reasons 

given for excessive incinerator emissions. All of these reasons seem to point 

to a problem with the Arcus Air Monitoring System or the DEC computer system. 

These problems have persisted for the past two years as summarized on the 

following table: 

Month/Yr 

Sept., 1981 

Oct. 

Nov. 

Dec. 

Jan., 1982 

Feb. 

Mar. 

April 

May 

June 

July 

August 

Hours in Excess 

of Standards 

8' 

Hours with no data or 

computer problems 

1 

1 

3 

111 

56 

24 

38 

46 

120 

312 

360 

24 

24 

24 

161 

264 

312 

P.O. BOX 44066 . BATON ROUGE, LOUISIANA 70804 . PHONE 504/342-1206 
P.4 

Mr. C. A. Gellner 

November 8, 1983 

Page two 

Month/Yr 

Sept. 

Oct. 

Nov. 

Dec. 

Jan., 1983 

Feb. 

March 

April 

May 

June 

July 

August 

Hours of Excess 

of Standards 

36 

12 

56 

59 

Hours with no data or 

computer problems 

312 

72 

24 

144 

192 

24 

72 

336 

120 

188 

48 

We feel that the reliability of your incinerator stack monitoring 

system must be improved in order to comply with Section 77.9 of the regulations. 

This section requires that emissions be monitored on a continuous basis, and 

that these emissions be reported on the quarterly report. 

In your letter of June 24, 1983 you stated that the Arcus instrument was 

moved to an air conditioned building and that a maintenance contract was 

established to improve system performance. Despite these efforts the system 

was out of service for over 225 hours during July and August, 1983. Unless the 

system performance shows dramatic improvement during the current quarterly 

reporting period we see no alternative than to order Certainteed to meet all the 

requirements of Section 77.9. 

As always, we are ready and willing to meet with you and your staff to 

discuss ways that we can assist Certainteed in achieving compliance. Should 

you desire such a meeting or if you have questions concerning this letter please 

contact Ms. Mary Wright of my staff at (504) 342-1206. 

Sincerely, 

TCC/MFW/bs 

Thomas C. Coerver 

Program Manager, Surveillance 

cc: Mr. Joe Withers 

Mr. Greg Gasperecz 
P.5 

CertainTeed Corporation 

Pipe & Plastics Group 

P.O. Box 253 

Sulphur, LA 70663 

(318) 882-1441 

CertainTeed 

March 15, 1985 

CERTIFIED MAIL. 

HETURN RECEIPT 

Mr. Gus Van Badunqt1!"! 

F

:;'roqram Admi ni strator 

A.3. r Qi..ta 1 i t,y Oi v:i. si o n 

Den art. ment of Natural 

P.. u. So;: 94096 

hi a ton Rouge., LA 70S34 

- : tl•' •1-\ll' 

cir". Gus Von Bodunqen: 

V.ur tai n Teed Corporation is hereby submitting a quarterly report o-f vinyl 

.-hioride eiiiissions as required tar compliance with LE3HAP Part IV, Subpart B, 

Paragraph 77.11(a) covering the period -from December 1, 1984 to February 28, 

fables 1 through T a tils 3 summarizes by month ths daily weighted average vinyl 

chloride content, in polyvinyl chloride polymer as required -for compliance with 

Paragraph 77. 11 (c) (2) . 

••bJ.es. 4 throng!' i s u m;JJ a!' • ii. 2. siiii D y i) i o nt i h the daily records o-f emissions which are 

in excess at the prescribed limits as required for compliance? with Paragraph 

".'•7.11(c)(1). 

Data on emissions -Prom reactor openings as stated in Paragraph 77.11(c) (3) is 

riot provided separately because in the bulk polymerisation oro cess used ov 

CertainTeed Corporation, reactor vessels anz; also stripper vessels. As can be 

s&en from Tables 1 through 3, all ooi ynxsr produced is stripped cf residual vinyl 

chloride to below 40i3 PPM by using a temperature and vacuum orocess. 

is indicate a in paragraph /"7.8(g) ir5) iii) z>>~; appro;; i mat i on of the VCM 

using the initial VCM concentration and ti i e pr i n c j. ri 1 e o f p a r t i a I iiirs' j lo r 

successiv e vacuum strippin g operations. . Nitere CO i s th e initia l VCM 

concentratio n and P.i. i s th e absolut e pressur e achieved on th e firs t vacuum 

•; t r i p pin p o p e r a c i o n „ t h e c: o n c e n t r a t ii. o n o f V CM i n t h e s t r i p p i n q 

r j. !•'• s t s1 r i p p :i. n q o p e r a t i * J n . CI , i s f o u n d f r • o m •• 

CI ^ CD X PI 

14. 7 PSI A 

esse l af t ei 

01-91-0283 
P.6 

Mr,, Gus Von Bod un gen 

larch 15, 198c 

Since CertainTsed's stripping procedure uses a minimum of four vacuum stripping 

operations with the first vacuum at least 2,7 PSIA and the remaining vacuums at 

least 1.5 PSIA, the final VCM concentration calculates to approximately 2i30 PPM 

in the stripping vessel. Reactor" opening lass (Paragraph 77.8 (g) (5) (i)) can be 

calculated by substituting the following values in the equation given: 

W

 :" 50 cubic meters 

Cb •= 200 PPM VCM 

Y •= .1. batch 

2 = 21,818 kg PVC produced 

'Therefore, the reactor opening loss calculates to 1.2 X .l(3e--3 gram VCM per kg 

P\'C produced,. This is an order of magnitude beiow the requirements of paragraph 

77.5(a) (2)„ Since the minimum conditions or CertainTeed's vacuum stripping 

procedure aret always met before the PVC is discharged from the stripper, 

CertainTeed certifies that the reactor opening loss associated with each batch 

of PVC produced in this period is below the value specified in paragraph 

77.5(a)(2). 

If you have any further questions or comments, please contact me 

SincereI 

Bruce J„ Brocka' 

T e c h n i c a 1 S u p e r v i s o r 

mci 

Attachments 
P.7 

TA3LE.._4 

k'i:L?.i''.'iAE...L.*:lBJ ik?.*;....§y3Ei!6Bi...§ .i.J6.6it9?&B.$fiH ZZ-.lA.lc 2. .IS/. 

QU6RIi6:UZ....REPQfi;i 

Q£RIyINI£i!2._CQ PQUY.MiB..EUAy.I 

DECEMBER 1984 

DATE 

01 

02 

03 

04 

05 

06 

07 

08 

09 

10 

11 

12 

13 

14 

15 

HOURS IM EXCESS 

OF EMISSION LIMITS DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS 

0 

0 

0 

GJ 

0 

& 

0 

0 

0 

0 

0 

0 

0 

16 

17 

1 8 

1 9 

2 0 

2 1 

'? a 

28 

29 

30 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

(3 
P.8 

IASLE...5 

LESHAP PART_.I.V. SUBPART §.=...,..PARAGRAPJ:]_77 A.i..isr.l.A 

@UARJ;ERLY...REPORT 

Q£6:I6:Ib!I££y QQBPQBAI.^ 

JANUARY 1965 

MT 

DATE 

01 

02 

03 

04 

05 

06 

07 

08 

09 

10 

11 

12 

13 

14 

15 

HOURS IN EXCESS 

OF EMISSION LI MITE 

0 

DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS 

W 

0 

TURNAROUND 

TURNAROUND 

TURNAROUND 

TURNAROUND 

TURNAROUND 

0 

0 

0 

0 

1 7 

18 

19 

20 

30 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 
P.9 

i > i-i..... 

TABLE ..6 

fAET IV, SJJBPART...BJ..,_PARAGRAPH 

@yaRIi.RLY.._REPORT 

CERIAINTEED CXiR£ORATIQN..:~._LAKE._CHA 

FEBRUARY 1985 

DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS 

HOURS IN EXCESS 

OF EMISSION LI MI 

01 

02 

03 

04 

05 

.06 

07 

08 

09 

10 

11 

12 

13 

14 

15 

0 

0 

0 

0 

0 

0 

0 

17 

18 

19 

20 

21 

^a 

28 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 
P.10 

CertainTeed Corporation 

Pipe & Plastics Group 

P.O. Box 253 

Sulphur, LA 70663 

(318) 882-1441 

Cerlairiieed 

REC£/V£D 

DSC J ? i5M 

AIR giMury CIV/SICN 

December 14, 1984 

CERTIFIED MAIL 

RETURN RECEIPT 

Mr. Gus Von Bodungen 

Program Administrator 

flir Quality Division 

Department of Natural Resources 

P.O. Box 44066 

Baton Rouge, LA 70804 

Mr. Gus Von Bodungen: 

CertainTeed Corporation is hereby submitting a quarterly report of virryl 

chloride emissions as required for compliance with LESHAP Part IV, Subpart B, 

Paragraph 77.11(a) covering the period from September 1, 1984 to November 30, 

1384. 

Tables 1 through Table 3 summarizes by month the daily weighted average vinyl 

chloride content in polyvinyl chloride polymer as required for compliance with 

Paragraph 77.11(c)(£). 

Tables 4 through 6 summarises by month the daily records of emissions which ar^e 

in excess of the prescribed limits as required for compliance with Paragraph 

77. 11 (c) (1). 

Data on emissions from reactor openings as stated in Paragraph 77.11(c)(3) is 

not provided separately because in the bulk polymerisation process used by 

CertainTeed Corporation, reactor vessels are also stripper vessels. As can be 

seen from Tables 1 through 3, all polymer produced is stripped of residual vinyl 

chloride to below 400 PPM by using a temperature and vacuum process. 

As indicated in paragraph 77.8(g)(5)(ii) an approximation of the VCM 

concentration remaining in the stripping vessel (autoclave) can be calculated by 

using the initial VCM concentration and the principle of partial pressures for 

successive vacuum stripping operations. Where CO is the initial VCM 

concentration and PI is the absolute pressure achieved on the first vacuum 

stripping operation, the concentration of VCM in the stripping vessel after the 

first stripping operation, CI, is found from: 

CI = CO X P I 

14. 7 PSIA 

01-91-0283 
P.11 

Since CertainTeed's stripping procedure uses a minimum of four vacuum stripping 

operations with the first vacuum at least £.7 PSIA and the remaining vacuums at 

least 1.5 PSIA, the final VCM concentration calculates to approximately £00 PPM 

in the stripping vessel. Reactor opening loss.<Paragraph 77.8 (g)(5)(i)) can be 

calculated by substituting the following values in the equation given: 

W = 50 cubic meters 

Cb = £00 PPM VCM 

Y = 1 batch 

Z = £1,818 kg PVC produced 

Therefore, the reactor opening loss calculates to l.S X 18e-3 gram VCM per kg 

PVC produced. This is an order" of magnitude below the requirements of paragraph 

77.5(a)(£). Since the minimum conditions of CertainTeed's vacuum stripping 

procedure a-re always met before the PVC is discharged from the stripper, 

CertainTeed certifies that the reactor opening loss associated with each batch 

of PVC produced in this period is below the value specified in paragraph 

77.5(a)(£). 

If you have any further questions or comments, please contact me. 

Sincerely, 

Bruce J. Brocka* 

Technical Supervisor 

mg 
P.12 

IABLE_4 

!=ISHAP_PART_IVL_SyBPART_BL_PARAGRAPH_77^iilcll£i 

__B_I_R!=¥__§E__I 

___I___I_______.5___I_____.J=____^ 

__EI__________ 

_______ _ ______ _ _______________ _ 

DATE OF EMISSION LIMITS DATE OF EMISSION LIMITS 

01 0 16 0 

0£ 0 17 © 

03 0 18 0 

04 0 19 0 

05 0 £0 0 

06 0 £1 0 

07 0 ££ 0 

08 0 £3 0 

09 0 £4 OUT OF CALIBRATION 

10 0 £5 0 

11 0 £6 0 

1£ 0 £7 0 

13 0 £8 0 

14 0 £3 0 

15 0 30 0 
P.13 

TABLE_5 

•____9E_E9BI________E9BI____E9B9_B9E__ZZ_________ 

__9BI_B___B_E_BI 

QiBI9I_Iii__QQBEQ_9IlQ__z_k9-_i_Q_BB_i__EQUY_IB_E-_9!_I 

OCTOBER 1984 

DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS 

01 

0£ 

03 

04 

05 

06 

07 

08 

09 

10 

11 

1£ 

13 

14 

15 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

16 

17 

18 

19 

£0 

£1 

££ 

£3 

£4 

£5 

£6 

£7 

£8 

£9 

30 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 
P.14 

I9__I__ 

kI_d9E_E9BI_I___§y5E9BI_I__E9B9§B9E__ZZ_iii_il§! 

__9_I_______2_5I 

__BI9__IIi____BE_B9I_______9_____BB____E__^ 

_____BER___8_ 

_______________ . ________________ 

DATE OF EMISSION LIMITS DATE OF EMISSION LIMITS 

01 0 16 0 

0£ 0 17 0 

03 0 18 0 

04 0 19 0 

05 0 £0 0 

06 0 £1 0 

07 0 ££ 0 

08 0 £3. 0 

09 0 £4 0 

10 0 £5 0 

11 0 £6 0 

1£ 0 £7 0 

13 0 £8 0 

14 0 £3 0 

15 0 30 0 

31 
P.15 

CertainTeed Corporation 

Pipe & Plastics Group 

P.O. Box 253 

Sulphur, LA 70663 

(318) 882-1441 

CertainTeed O 

S e D t e m b e r 14 , 19 S 4 

CFRTTF I 

RECEIVED 

SEP X 7 1904 

4'R .QUAUTY DIVISION 

J E R ! .!. r J. i_D M A .!. L 

R E T Li R N R EF C E I P T 

Mr. Gus Von Bodunqen 

Program Admi nistrator 

A i r Qua I ity D i v i s i. on 

Department of Natural Resources 

P.O. Bo;; 44066 

Baton Rouge,, L.A 70804 

D t? a r !v1 r „ V o n P' o ~.i u n o e n » 

CertainTeed Corporation is hereby submitting a Quarterly report o-f vinyl 

c:h I or i de emi ssi ons as rsgui red f or comp 1 i ance wi th L..EE?SHAP Part IV,, Subpa 

1-3. Paragi-aph 77., 11(a) covering the period -from June 1, I9S4 to August 31 

1984. 

Tables 1 through Table 3 summarizes by month the daily weighted average 

vinyl chloride 

compl i ance wi Li 

•* r vt. in p o .1 y v i n y I c h 3. o rid e p o 1 y m e "equi reel tor 

aragrap 

... r.. t._ ~T " 1 •! ( !- 1 I •? 1 

Tables 4 through 6 summarises by month the daily records af emissions which 

are in excess o-f the prescribed limits as required -for compliance with 

Paragraph 77. }. .1. ic) (1) .. 

Data on emi •rom :or openings as stated in Paragraph 77.11(c 

is not provided separately because in the bulk polymerization process used 

by CertainTeed Corporation., reactor vessels are also stripper vessels. As 

can be seen from Tables 1 through 3,, all polymer produced is stripped ot 

residual vinyl chloride to below 400 PPM by using a temperature and vacuum 

process. 

As indicated in paragraph 77.8(g) (5) (i i ) an approximation o-f the VCM 

concientrat i on remai ni ng i n the str i pping vessel (autoc 1 ave) c:an be 

c:a 1 cu 1 ateiii! I•)y usi i~,g the i ni t i a 1 VC!v! concentrali on and the pr i nci pi e of 

parti a], pressures for successive vacuum stripping operations.. Where CD is 

tho? initial VCM concentration and PI is the absolute pressure achieved on 

the first vacuum stripping operation, thie concentration of VCM in the 

-stripping vessel after the first stripping operation, CI, is found from:: 

CI == CO X PjL 

14"77~PSIA 

01-91-0283 
P.16 

I'lr. Gus Von 'i.-iodungen 

September 14., j. 9S4 

Paqe 2 

Si nce Certai nTeed ' s str i ppi ng procedure usBS a mi ni mum of f our vacuum 

stripping operations with the first vacuum' at least 2.7 PSIA and the 

remaining vacuums at least 1.5 PSIA. the final VCM concentration calculate 

to appro;: i matel y 200 PPM in the stripping vessel. Reactor opening loss 

(Paraaraoh 77.3 (a)(5)(i)> can be calculated bv substitutina the fallowino 

'alues in the sauati. o n q i. v e n 

W

 := 50 cubic meters 

Cb = 200 PPM VCM 

Y = 1 batch 

Z = 21,SIB kg PVC oroduced 

Therefore, the reactor opening loss calculates to 1.2 X 10e-3 gram VCM per 

kg PVC produced,, This is an order of magnitude below' the requirements of 

paragraph 77.5(a) (2)., Sines.- the minimum conditions of CertainTeed's vacuum 

stripping procedure are always met before the PVC is discharged from the 

stripper., CertainTeed certifies that the reactor opening loss associated 

with each batch of PVC produced in this period is below the value specified 

in paragraph 

If vau have 

'.5(a) (2) 

* further questions or comments, please contact me. 

Bzii i. 1 ncere. 1 (... ii r iI i i y . 

Bruce J. Brocka 

Personnel/Safst v Mar 

jet 

Attachments 
P.17 

a TABLE 4 

LESHAP PART IV ......SUBPART B.i.....P^RAGRAi?^....ZZ^i.L.i£ii/2. 

_y6BIi'BLY_.5'iPQR.I 

.QiBIl^I'lIl^i ^ CHARI,ES_PQLYMER_PLAN.T 

JUNE 1984 

DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS 

01 

02 

03 

04 

05 

06 

07 

OS 

09 

10 

11 

12 

13 

14 

OUT OF CALIBRATION 

OUT OF CALIBRATION 

U 

(..) 

18 

21 

26 

28 

29 

(..) 

u 

t! 

O 

V 

IJ 

TURNAROUND 

TURNAROUND 

TURNAROUND 

NO DATA 

15 !) 
P.18 

TABLE 5 

CO 

LESHAP_PART_IVL_SyBPARI_BL_PARAGRBPH_77^iilci^i 

_y9_I_B___B_ESEI 

£IBI9I_IiI__QQREQR9IIQ____L8_I__d9BkIs_pgLYMER_PLBNT 

JULY 1384 

DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS 

01 

0£ 

03 

04 

05 

06 

07 

08 

09 

10 

11 

12 

13 

14 

15 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

IS 

17 

18 

19 

£0 

£4 

£5 

£6 

£7 

£8 

£9 

30 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 
P.19 

I9_____ 

_iSH9£_P9RI_iyt_SyBP9RI_B^_P9R9GR9PH_77^iilc).i.£i 

_yBBI_B_¥_R_E_BI 

_iBI9I_Ii___QQ3EQBBIIQ__z_U9_i_£H9RLES_PQLYMER_PL9NT 

9y_y_i_____ 

HOURS~lN~EXCESS HaURS_Irvi~EXCESS_ 

DATE OF EMISSION LIMITS DATE OF EMISSION LIMITS 

01 0 IS 0 

0£ 0 17 0 

03 0 18 0 

04 0 19 0 

05 0 £0 0 

06 0 £1 O 

07 0 ££ . 0 

08 0 £3 0 

09 0 £4 0 

10 0 £5 0 

11 0 £6 0 

1£ 0 £7 0 

13 0 £8 0 

14 0 £9 0 

15 0 30 0 

31 0 
P.20 

/ _.<X 

CertainTeed Corporation 

Pipe & Plastics Group 

P.O. Box 253 

Sulphur, LA 70663 

(318) 882-1441 . 

.•A « 

V 

vrAsy CeriainTeedE 

June 15, 1S84 

CERTIFIED MAIL 

RETURN RECEIPT 

Mr. Gus Von Bodungen 

Prog rani Adm i n i s t ra t o r 

Air Quality Division 

Department of Natual Resources 

P. G. Box 44066 

Baton Rouge, LA 70804 

R £-,-*.. r 

•• i •/1~- ' v'fc D 

AIR Cv. 

••^ivr-j 

Mr. Gus Von Boduricsn: 

Certainieed Corporation is hereby submitting a quarterly report of vinyl 

chloride emissions as recuirea for compliance with LESHAP Part IV, Subpart 

B, Paragraph 77.11(a) 

1984. 

covering the period from Marco 1, 1984 to May 31, 

Tables 1 through Table 3 summarises by month the? daily weighted aver-aye 

vinyl chloride content iri polyvinyl chloride polymer as required for 

cornpliance with Paragraph 77. li (c) <£) . 

Tables 4 through 6 summarizes by month the daily records of emissions which 

are in excess of the prescribed limits as required for compliance with 

Paragraph 77. 1i <c> (1). 

Data ori emissions from reactor openings as stated in Paragraph 77.11(c) <3) 

is not provided separately because in the bulk polymerisation process used 

by CertainTeed Corporation, reactor vessels are also stripper vessels. As 

csri be seen from Tables 1 through 3, all polymer produced is stripped of 

residual vinyl chloride to below 400 PPM by using a temperature and vacuum 

process. 

As indicated in paragraph 77.8<p> (5) (ii) art approximation of the VCM 

concentration remaining in the stripping vessel ("autoclave) can be 

calculated by using the initial VCM concentration and the principle of 

partial pressures for successive vacuum stripping operations. Where CO is 

tne initial VCM concentration arid PI is the absolute pressure achieved on 

the first vacuum stripping operation, the concentration of VCM in the 

stripping vessel after the first stripping operation, CI, is found from: 

C I -• CG X __P i 

1A-. 7 PSIA 

01-90-0283 
P.21 

__s 

O 

O 

Since Cert a i n T e e d ' s s t r i p p :i. n g p r o c e d u r e u s e s a. mini m u m of f o u r v a c u u m 

stripping operations with the first vacuum at least 2.7 PSIA and the 

remaining vacuums at least 1.5 PSIA, the final VCM concentration calculates 

to approximately 200 PPM in the stripping vessel. Reactor opening loss 

(Paragraph 77.8 (g) (5) (:i. ) ) can be calculated by substituting the following 

values in the equation given: 

W = 50 cubic meters 

Cb = 200 PPM VCM 

Y = 1 batch 

Z = 21,318 kg PVC p r od uc ed 

b 

Therefore, the reactor opening loss calculates to 1.2 X 10e-3 gram VCM per 

kg PVC produced. This is an order of magnitude below the requirements of 

paragraph 77.5(a)(2). Since the minimum conditions of CertainTeed ''s vacuum 

stripping procedure s.r<s always met before the PVC is discharged from the 

stripper, CertainTeed certifies that the reactor opening loss associated 

with each batch of PVC produced in this period is below the value specified 

in p ar ag r aph 77.5(a) (2). 

If you have any further questions or comments, please contact, me. 

Si ncerely, c^^& KJ 

Br uc e J . Br oc k a ' 

Personnel/Safety Manager 

j w 
P.22 

TABLE....4 

______„„BB\]1__V 

_y9BIiBL-__BIE'£_I 

££BI_I_Iii__..£QRTORATigN...::_LAKE__C 

MARCH 19S4 

DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS 

01 

02 

03 

04 

05 

06 

07 

08 

09 

10 

11 

12 

13 

14 

15 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

16 

17 

13 

19 

20 

21 

2 6 

O Q 

30 

31 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

rr 

0 

0 
P.23 

.a S^BPAfn_.la_BaBBGBfc!!BH..ZZj;..iii.-=ii.21 

TABLE_..5 

-lr.orlMr ri-tK i J. v 

_y8BIiBUY..BiBQBI 

£ERTAlN^rEED__.CgRPj:)RATigN^._r„LAKE 

APRIL 1984 

DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS 

01 

02 

03 

04 

05 

06 

07 

08 

09 

10 

11 

12 

13 

14 

15 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

16 

17 

IS 

19 

20 

21 

24 

25 

26 

27 

2S 

29 

30 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 
P.24 

______ _ 

LESHAP...PART .IV... ...SUBPART ._.B._ ..„PARA_BAB__.ZZ_iil_112i 

i-y9BI_BLY._RE.PQRI 

£iBI9I_IiiP__£QBBQB9IlQ__-_LAi<E_CHARLES_p 

MAY 1984 

D( 

HOURS IN EXCESS 

OF EMISSION LIMITS DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS 

01 

02 

03 

04 

05 

06 

07 

08 

09 

10 

11 

12 

13 

14 

15 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

16 

17 

18 

19 

20 

2.1. 

24 

26 

29 

30 

31 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 
P.25 

V"£-£& >;A 

,L\ 

/? 

CertainTeed Corporation 

Pipe & Plastics Group 

P.O. Box 253 

Sulphur, LA 70663 

(318) 882-1441 

&•? 

CertainTeed __ 

RECEIVE D 

M/iK i 6 I3B4 

AIR QU/JUTy W(SJ0 N 

March 15, 1984 

CERTIFIED MAIL 

RETURN RECEIPT 

Mr. Gus Von Bodungen 

Program Administrator 

Air Quality Division 

Department of Natual Resources 

P.0. Box 44066 

Baton Rouge, LA 70804 

Mr. Gus Von Bodungen: 

CertainTeed Corporation is hereby submitting a quarterly report of vinyl 

chlpride emissions as required for compliance with LESHAP Part IV, 

Subpart B, Paragraph 77.11(a) covering the period from December 1, 1983 

to February £9, 1984. 

Tables 1 through Table 3 summarizes by month the daily weighted average 

vinyl chloride content in polyvinyl chloride polymer as required for 

compliance with Paragraph 77.11(c)(2). 

Tables 4 through 6 summarises by month the daily records of emissions 

which are in excess of the prescribed limits as required for compliance 

with Paragraph 77.11(c)(1). 

Data on emissions from reactor openings as stated in Paragraph 

77.11(c)(3) is not provided separately because in the bulk 

polymerization process used by CertainTeed Corporation, reactor vessels 

are also stripper vessels. As can be seen from Tables 1 through 3, all 

polymer produced is stripped of residual vinyl chloride to below 400 PPM 

by using a temperature and vacuum process. 

As indicated in paragraph 77.8(g)(5)(ii) an approximation of the VCM 

concentration remaining in the stripping vessel (autoclave) can be 

calculated by using the initial VCM concentration and the principle of 

partial pressures for successive vacuum stripping operations. Where CO 

is the initial VCM concentration and PI is the absolute pressure 

achieved on the first vacuum stripping operation, the concentration of 

VCM in the stripping vessel after the first stripping operation, CI, is 

found from: 

CI - CO X PI 

14. 7 PSIA 

01-90-0283 

* ~ "*• 

^AU&Hd J24L#J */&#L^V ^ ^y^^JZ/H--^ 
P.26 

TABLE 4 

LESHAP...PART.._.I.y.il SUBPART...!., Fv-jRAGRAPH_77..iilc.)_12). 

QyARTERLY._REPORT 

OERIA.INIEED CORPORATION,. :-:...LAKE...CHA„RLES 

DECEMBER 1933 

DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS 

HOURS IN EXCESS 

OF EMISSION LIMITS 

01 

04 

05 

06 

07 

08 

09 

10 

1 1 

12 

13 

14 

15 

MO DATA 

o 

NO DATA 

u 

0 

o 

16 

1 "7 

18 

19 

20 

21 

24 

26 

(..) 

(.) 

0 

o 

0 

0 

0 

0 

0 

0 

0 

0 

(?) 

0 

o 

0 

31 (1 
P.27. 

•_ESJ;-iAi^...PAPT.^ 

QyABIiBLy....BiBQBI 

QLPIAINTEED CORPaRATIQN....~.J.AKE CHARLES._POLYMER...PLANT 

JANUARY 1984 

DATE 

01 

02 

O 3 

04 

05 

06 

07 

08 

09 

10 

11 

12 

13 

14 

HOURS IN EXCESS 

GF-EMISSION LIMITS 

M!J D M i A 

U 

(.) 

DATE 

17 

IS 

1 9 

20 

21 

24 

HOURS IN EXCESS 

OF EMISSION LIMITS 

MO DATA 

o 

o 

u 

o 

i.J 

u 

o 

o 

u 

(J 

o 

NO DATA 

u 
P.28 

..l~';::!•- ! A j- ' K1-1 PARK ! T I 

TABLE 6 

:.,..._Sy.BPART B__PARA6RAPH ZZ__i__li__ 

@y_BIiBLY._.REPORT 

£iBIAIb!Iii__CQRP^R-AJIQN._-....LAKE_^ 

FEBRUARY 1984 

DATE 

HOURS IN EXCESS 

OF EMISSION LIMITS DATE 

HOURS IN EXCESS 

DF EMISSION LIMITS 

01 16 (..j 

O-i:. 

1 7 

18 

(i 

O 

04 

05 

06 

07 

08 

(..) 

•I Q 

20 

(..) 

O 

o 

0 

0 

0 

ov 24 U 

10 

11 

12 

13 

14 

15 

(j 

U 

IBo 

MO DATA 

u 

u 

(..) 
P.29 

\5>0 +D.C) 

CertainTeed Corporation 

Pipe & Plastics Group 

P.O. Box 253 

Sulphur, LA 70663 

(318) 882-1441 

CertainTeed E3 

December 12, 1983 

CERTIFIED MAIL 

RETURN RECEIPT 

Mr. Gus Von Bod LingerProgram Adrn i n i st rat or 

Air Quality Division 

Department of Natual Resources 

P. O. Box 44066 

Baton Rouge, LA 70804 

Mr. Gus Von Bodunpens 

R

-C~/y E D 

''-Z,J 15 1383 

Al* QUALITY *-,,« _ 

CertainTeed Corporation is hereby submitting a quarterly report of 

vinyl chloride emissions as required for compliance with LESHAP Part 

IV, Subpart B, Paragraph 77.11(a) covering the period from September 

1, 1983 to November 30, 1983. 

Tables 1 throuyh Table 3 summarizes by month the daily weighted 

average vinyl chloride content in polyvinyl chloride polymer as 

required for compliance with Paragraph 77.11(c)(£). 

Tables 4 through 6 summarizes by month the daily records of emissions 

which are in excess of the prescribed limits as required for 

compliance with Paragraph 77.11(c)(1). 

Data on emissions from reactor openings as stated in Paragraph 

77.11(c)(3) is not provided separately because in the bulk 

polymerization process used by CertainTeed Corporation, reactor 

vessels are also stripper vessels. As can be seen from Tables 1 

through 3, all polymer produced is stripped of residual vinyl chloride 

to below 400 PPM by using a temperature and vacuum process. 

As indicated in paragraph 77.8(g) (5) (ii) an approximation of the VCM 

concentration remaining in the stripping vessel (autoclave) cari be 

calculated by using the initial VCM concentration and the principle of 

partial pressures for successive vacuum stripping operations. Where 

CO is the initial VCM concentration and PI is the absolute pressure 

01-90-0283 
P.30 

• . TABLE k 

LESHAP PART IV, SUBPART B, PARAGRAPH 77.11(C)(1) 

QUARTERLY REPORT 

CERTAINTEED CORPORATION - LAKE CHARLES POLYMER PLANT 

SEPTEMBER 1983 

' HOURS IN EXCESS '. HOURS IN EXCESS 

DATE OF EMISS ION LIMITS DATE OF EMISSION LIMITS 

01 0 ,16 1 

02 0 17 0 

03 1 18 0 

Ok 1 19 2 

05 1 20 4 

06 0 21 2 

07 1 22 0 

08 0 23 0 

09 0 2<-» 0 

10 0 25 0 

11 0 26 1 

12 b. 27 0 

13 12 " 28 3 

li, 8 29 1 

15 15 . 30 3 

31 

w n 

^{o 
P.31 

TABLE 5 

LESHAP PART IV, SUBPART B, PARAGRAPH 77-U(C)(l) 

QUARTERLY REPORT 

CERTAINTEED CORPORATION - LAKE CHARLES POLYMER PLANT 

OCTOBER 1983 

HOURS IN EXCESS HOURS IN EXCESS 

DATE OF EMISSION LIMITS DATE OF EMISSION LIMITS 

01 0 16 1 

02 0 17 0 

03 0 18 3 

Ok 0 19 1 • 

05 0 20 0 

06 2 21 3 

07 3 22 0 

08 7 23 0 

09 1 2k 3 . 

10 2 25 2 

11 2 26 0 

12 1 27 0 

13 3 28 1 

\k 1 29 1 

15

 2 30 0 

31 0 
P.32 

TABLE 6 

LESHAP PART IV, SUBPART B, PARAGRAPH 77.11(C)(1) 

QUARTERLY REPORT 

CERTAINTEED CORPORATION - LAKE CHARLES POLYMER PLANT 

NOVEMBER 1983 

HOURS IN EXCESS HOURS IN EXCESS 

DATE OF EMISSION LIMITS DATE OF EMISSION LIMITS 

01 0 16 0 

02 0 17 0 

03 0 18 0 

Ok 0 19 0 ' 

05 ° 20 0 

06 0 21 0 

07 ° 22 0 

08 ° 23 0 

09

 1 2k 0 

10 ° 25 0 

11 ° 26 0 

12 ° 27 0 

13 ° 28 0 

1*» ° 29 ' 0 

15 . ° 30 0 

31 

\ 
P.33 

CertainTeed Corporation 

Pipe & Plastics Group 

P.O. Box 253 

Sulphur, LA 70663 

(318) 882-1441 

CertainTeed HI 

December 7, 198? 

CERTIFIED MAIL 

RETURN RECEIPT 

Program Manager, Surveillance 

Department of Natural Resources 

P. 0. Box 44066 

Baton Rouge, LA 70804 

Dear Mr. Coerver; 

D EC

 1 2 !S83 

A

« OUA/j-ry o,-„;,JO„ 

0EA/Df«

 IJ '' 

In response to your letter on No vent be*- 8, 1983 concerning CertainTeed 

Corporation's report under Section 77.11 of Louisiana Emission 

Standard for Hazardous Air Pollutants (LESHAP), we nave reviewed the 

supporting infomation on our monitoring system and have obtained some 

import ant points,. 

On previous semi-annual reports submitted to USEPA, CertainTeed 

Corporation has reported days when no data was available due to 

equipment malfunctions with either the Areas Ambient Air Monitoring 

System or the DEC computer system. While some of the failures are 

beyond human control, CertainTeed has pursued an active and ongoing 

program to reduce failures to a very low level. 

The majority of days reported as having no data involved failures of 

the data reporting system (DEC computer) or data transfer between 

computers. The data 5§theri.nt3 system (Areas Air Monitoring System) 

was subject to only minor amounts of failure. As a result, effluent 

monitoring of the final control device continued uninterrupted with 

the result available on a real time basis. Since the data was not 

available in easily usable format for subsequent statistical 

purposes, it was reported as "No data" for the purposes of the 

USEPA's required ser"i-annual report. 

01-90-0283 
P.34 

Department of Natural Resources 

Page £ 

December 7, 1983 

When reviewing the raw data available from the gathering system (Areas Ambient 

Air Monitoring System), we have found a significant reduction in the number of 

hours with no data. The number of hours with no data during the third quarter 

(June, July, Aug«.ist 1983) were reduced from 356 hours to 100 hours. 

During preactive analysis of the fourth quarter (September, October, November 

1983) it has been found that there a.-re no hours without data. 

We hope that this dramatic improvement during this last quarter reporting will 

highlight to you our efforts in defining and reducing the number of hours with 

no data from our final control device montoring system. 

If you have any further questions, please contact Bruce Brocka at (318) 

882-1441. 

Best regards, 

C. A. Gellner 

Plant Manager 

dap 
P.35 

/ 

NDUSTRIES 

PPG INDUSTRIES, INC. INDUSTRIAL CHEMICAL DIVISION P. 0. BOX 1000 

i \ 

t •.%/' 

:

 •— f" 

LAKE CHARLES, LA. 70602 

v

'-s;c^ 

March 13, 1984 

Mr. Gus Von Bodungen 

Department of Environmental Quality 

Air Quality Division 

Office of Environmental Affairs 

P. O. Box 44066, Capitol Station 

Baton Rouge, LA 70804 

Dear Mr. Von Bodungen: 

RE: VCM LESHAP Quarterly Report 

In accordance with LESHAP Regulation 77.11, PPG Industries' Lake Charles 

Complex herein submits its quarterly report for the period of December 1 , 1983 

through February 29, 1984. 

A record of one-hour emissions in excess of the 10 ppm standard in the stack 

gases exiting each incinerator system is attached as Exhibit I. 

During this quarter approximately 576, pounds of VCM were released due to 

failure to incinerate vent gases. One such instance, as indicated below, 

exceeded fort y minutes in duration. 

Estimated Quantity 

Date Time/Duration Reason VCM Emitted 

2-8-84 1:06 - 2:06 PM Emergency maintenance 

on vent header to 

incinerators 

34 lbs, 

/ b h 

cc: Mr. Joe Withers 

Very trul y yours, 

£. uiychmc 

James E. Wyche, III 

Coordinator, Environmental Systems 
P.36 

EXHIBIT I 

IO-D«O*4_J 

5 - J <w ..._•••*. 

3 . } An__i 

Continuous Stack Emission Results 10 ppm VCM 

December 1 , 1983 - February 29, 1984 

Stack No. 1 (Incinerators #1 and #2 

Date 

« 12/4/83 

v 12/8/83 

Q 1/26/84 

Hour Ending 

5:00 p.m. 

2:00 p.m. 

3:00 p.m. 

Hourly Average 

11.24 

10.57 

172.51 

(pprr ) Comment 

Surge in vent flow to 

incinerator 

Vent isolation valve slow 

to close following incinerator 

trip 

Stack No. 2 (Incinerator #3) 

Date Hour Ending 

I 12/8/83 9:00 p.m. 

4 12/9/83 . 10:00 p.m. 

i 12/10/83 5:00 p.m. 

V 12/11/83 10:00 p.m. 

1 12/12/83 7:00 a.m. 

1 12/24/83 2:00 a.m. 

\ 12/31/83 9:00 p.m. 

»o 12/31/83 11:00 p.m. 

Q 1/29/84 4:00 p.m. 

Hourly Average (p 

43.19 

10.36 

19.81 

41.23 

43.12 

29.24 

165.30 

51.74 

27.91 

pm) Comment 

Incinerator tripped and 

restarted this hour 

Upset by liquid waste feed 

stream 

Incinerator tripped and 

restarted this hour 

Incinerator tripped and 

restarted this hour 

Upset by liquid waste feed 

stream 

Incinerator tripped and 

restarted this hour 

Incinerator tripped 

Upset of liquid waste feed 

stream 
P.37 

EXHIBIT I 

Continuous Stack Emission Results 10 ppm VCM 

Page 2 

Date Hour Ending Hourly Average (ppm) Comment 

Q> 1/29/84 5:00 p.m. 35.74 Incinerator tripped and 

restarted this hour 

2/6/84 10:00 p.m. 10.51 Upset in flows to 

incinerator 

2/7/84 7:00 a.m. 29.37 Upset in flows to 

incinerator 

2/7/84 8:00 a.m. 15.48 Upset in flows to 

incinerator 
P.38 

Syr, yv, A 

INDUSTRIES AM QUALITY Oh/,* 

•--A/DNR 

ir-zm ('« 

PPG INDUSTRIES, INC. INDUSTRIAL CHEMICAL DIVISION P. 0. BOX 1000 LAKE CHARLES, LA. 70602 

December 2, 1983 

Mr. Gus Von Bodungen 

Department of Natural Resources 

Air Quality Division 

Office of Environmental Affairs 

P.O. Box 44066, Capitol Station 

Baton Rouge, LA 70804 

Re: VCM LESHAP Quarterly Report 

Dear Mr. Von Bodungen: 

In accordance with LESHAP Regulation 77.11, PPG Industries', Lake Charles 

Complex herein submits its quarterly report for the period of September 1, 

1983 to December 1, 1983. This report addresses all of the units located 

at the Lake Charles Complex, which are governed by the VCM LESHAP regulations. 

This report includes: 

I. A record of those one-hour emissions in excess of the lOppm 

standard from the continuous VCM monitoring instruments 

from the stack gases exiting each incinerator system is 

attached as Exhibit I. 

II. During this reporting period, there was one release of 

vinyl chloride resulting from the accidental failure to 

incinerate vent gases. Exhibit II. 

III. During this period the Complex recorded no incidents where 

VCM bearing process wastewaters were co-mingled with nonVCM bearing wastewaters. 

(UVLf 

Philip S. Trew 

Environmental Control Specialist 

/bf 

cc: Mr. Joe Withers 

U.S. EPA, Region VI 

Air & Waste Management Division 
EXHIBIT I 

P.39 

Excursions lOppm VCM from Incinerator Stack Nos. 1, 2 & 3 

September 1, 1983 - November 30, 1983 

Stack No. 1 (Incinerators #1 and #2) 

Date Hour Ending Hourly Average (ppm) 

10/05/83 3:00p.m. 13.93 

Stack No. 2 (Incinerator #3) 

Date Hour Ending 

9/28/83 6:a.m. 

10/03/83 7:00a.m. 

10/03/83 8:00a.m. 

.10/06/83 12:00m.n. 

Stack No. 3 (Incinerator #4) 

Date 

9/23/83 

10/02/83 

Hour Ending 

10:00p.m. 

4:00p.m. 

Hourly Average (ppm) 

38.38 

49.59 

37.61 

41.84 

Hourly Average (ppm) 

10.7 

134.9 

Comment 

No reason found 

Comment 

No reason found 

Inc. down, possible Valve leak by. 

Inc. down, possible valve leak by. 

No reason found 

Comment 

No reason found 

No reason found 
P.40 

EXHIBIT II 

Non-Incineration of VCM Vents 

Estimated 

Date Time Reason , Quantity of VCM Emitted 

10/05/83 1:24a.m. - 2:27a.m. OHC Reactor at TE-II ex- ,is lbs* 

(1-hr 3 min) perienced an emergency (see below) 

shutdown. During the 

emergency the vents tripped out of the Incinerator. Operators working 

at securing the OHC area 

overlooked resetting of 

vents. 

* Method of Calculation: 

Assumed: . Molecular weight - 50 

VC wt % - 10% 

Known: Vent flow - 1300scfh 

Therefore: 1.05 hrs X 1300scf « 1365 scf 

PTr 

1365 scf X 1 mole = 3.6 mole 

379 scf 

3.6 mole X 50 X 0.1 lb - 18 lbs 

mole 
P.41 

PPG INDUSTRIESJNC. CHEMICALS P.O. BOX 1000 LAKE CHARLES, LA. 70602 

March 13 , 1985 

l\ I . rs Fn 

s \ •-,?.$ 

Gus Von Bodungen 

Department of Environmental Quality 

Air Quality Division 

Office of Environmental Affairs 

P. O. Box 44066, Capitol Station 

Baton Rouge, LA 70804 

AiR QUA! r*' r- • -

" ' ' ' -•-'••••i/Ofy 

RE: LESHAP VCM Quarterly Report 

Dear Mr. Von Bodungen: 

In accordance with §77.11 of the LESHAP regulations, PPG 

Industries' Lake Charles Complex herein submits its quarterly 

report for the period December 1, 1984 through February 28, 1985. 

A record of emissions in excess of 10 ppm (averaged on an hourly 

basis) in the stack gases exiting the incinerators is attached as 

Exhibit 1. There were five such incidents. Attached as Exhibit 

II is a record of emissions in excess of 10 ppm (averaged on an 

hourly basis) which resulted from temporary by-passes of 

incineration. An estimated 147 pounds of VCM were released as a 

result of these 34 incidents. 

Respectfully, 

Kenneth S. Kombroski 

KSK/bh 

Attachments 

cc: Joe Withers 

Fje "? v & 
P.42 

EXHIBIT I 

Continuous Stack Emission Results > 10 ppm VCM 

December 1, 1985 - February 28, 1985 

Date 

12/07/84 

01/08/85 

02/03/85 

02/03/85 

02/27/85 

Stack No. 

2 

1 

3 

3 

2 

Hour Ending 

0700 

1700 

0900 

1200 

1700 

Hourly Average 

(PP^) 

10.1 

19.2 

10.9 

11.3 

12.7 

Comment 

No apparent cause. 

No apparent cause. 

No apparent cause. 

No apparent cause. 

No apparent cause. 

Each of the above incidents was reviewed by appropriate unit supervision. 

Review included, as a minimum, reading the operations logbooks and checking 

operating data recorded on logsheets, stripcharts, etc. to determine 

possible causes. In each of the above incidents, no cause could be 

determined for the emission level recorded. 
P.43 

EXHIBIT II 

Non-Incineration of VCM Vents 

December 1, 1984 - February 28, 1985 

Date Time 

Estimated 

Sources Not Quantity VCM 

Incinerated Vented (lbs) 

12/03/84 1400 to 1415 ' VC-II, TE-II, CSS . 10.56 

12/06/84. 1644 to 1647 ': VC-II, TE-II, CSS 

12/16/84 0945 to 0949 

12/19/84 1121 to 1127 

12/19/84 1234 to 1245 

12/23/84 1505 to 1520 

12/25/84 0937 to 0942 

12/29/84 1525 to 1635 

VC-II 

TE-II, CSS 

TE-II, CSS 

TE-II 

TE-II 

L/ 

VC-II 

( 4j •»••£«•, ihfzs) 

01/16/85 0430 to 0507 ?', VC-II 

01/17/85 2042 to 2048 VC-II 

01/20/85 0800 to 0830 1 VC-II 

01/20/85 1200 to 1224 

01/21/85 0753 to 0808 

VC-II 

CSS 

1.67 

1.47 

1.08 

1.94 

1.00 

0.32 

23.25 

12.87 

2.06 

9.96 

7.97 

1.45 

Comment 

#2 Incinerator 

tripped. 

#2 Incinerator 

tripped. 

#4 Incinerator 

tripped. 

#2 Incinerator 

tripped. 

#2 Incinerator 

tripped. 

#2 Incinerator 

tripped. 

#1 Incinerator 

tripped. 

Power failure.. 

#1, #2, and #3 

Incinerator 

shut down. 

#4 Incinerator 

tripped. 

#4 Incinerator 

tripped. 

#4 Incinerator 

tripped. 

#4 Incinerator 

tripped. 

#1 Incinerator 

tripped. 
P.44 

EXHIBIT II 

Page 2 

Date Time 

01/21/85 0905 to 0910 

01/26/85 1334 to 1341 

01/30/85 1630 to 1641 

01/31/85 0715 to 0720 

01/31/85 0902 to 0908 

02/04/85 2021 to 2030 

02/05/85 0804 to 0810 

02/05/85 1500 to 1512 

02/09/85 0827 to 0830 

02/09/85 2010 to 2015 

02/15/85 0028 to 0037 

02/17/85 0345 to 0355 

Sources Not 

Incinerated 

CSS 

VC-II 

01/27/85 0059 to 0130 V' TE-II, CSS 

VC-II 

VC-II 

VC-II 

VC-II 

VC-II 

VC-II 

VC-II, CSS 

VC-II, CSS 

VC-II 

02/16/85 1350 to 1400 (,-r VC-II, CSS 

VC-II 

02/18/85 0030 to 0049 ff VC-II, CSS 

02/18/85 0930 to 0947 |7, VC-II, CSS 

Estimated 

Quantity VCM 

Vented (lbs) 

0.46 

2.55 

6.28 

3.73 

1.67 

1.68 

3.16 

2.09 

4.19 

1.34 

2.20 

2.9.1 

4.21 

4.34 

8.17 

7.07 

Comment 

#2 Incinerator 

tripped. 

#4 Incinerator 

tripped. 

#2 Incinerator 

tripped. 

#4 Incinerator 

tripped. 

#4 Incinerator 

tripped. 

#4 Incinerator 

tripped. 

#1 Incinerator 

tripped. 

#3 Incinerator 

tripped. 

#3 Incinerator 

tripped. 

#3 Incinerator 

tripped. 

#3 Incinerator 

tripped. 

#3 Incinerator 

tripped. 

#3 Incinerator 

tripped. 

#3 Incinerator 

tripped. 

#3 Incinerator 

tripped. 

#3 Incinerator 

tripped. 
P.45 

EXHIBIT II 

Page 3 

Date Time 

02/19/85 1728 to 1744 

02/22/85 1300 to 1335 

02/24/85 0945 to 1020 

02/27/85 1000 to 1030 

02/28/85 2244 to 2253 

Sources Not 

Incinerated 

VC-II 

CSS 

CSS 

CSS 

VC-II 

Estimated 

Quantity VCM 

Vented (lbs) 

4.42 

3.41 

3.42 

3.11 

1.42 

Comment 

#4 Incinerator 

tripped. 

#3 Incinerator 

tripped. 

#2 Incinerator 

tripped. 

#1 Incinerator 

tripped. 

#4 Incinerator 

tripped. 

Each of the above incidents was reviewed by appropriate unit supervision. 

Review included, as a minimum, reading the operations logbook and checking 

operating data recorded on logsheets, stripcharts, etc. to determine possible 

causes. In each of the above incidents, a cause was determined and further 

more detailed information has been retained in our files. 
P.46 

j / r- j, '-3^/0.^ 

INDUSTRIES 

PPG INDUSTRIES, INC. CHEMICAL DIVISION - U.S. P. 0. BOX 1000 LAKE CHARLES, LA. 70602 

September 13, 1983 

RECEIVED' 

Mr. Gus Von Bodungen ^/Zf / 

Department of Natural Resources ^^S^-/ ^ ^EP 1 5 J963 

Air Quality Division *" 

Office of Environmental Affairs /ft 

P.O. Box 44066 ^ 

Baton Rouge, LA 70804 • ' QZA/DNR 

Dear Mr. Von Bodungen: 

7//if *' R QUALITY DfV/S/dff 

RE: VCM LESHAP Regulation 77.11 

Quarterly Report 

PPG Industries, Inc., Lake Charles, LA 

In accordance with LESHAP Regulation 77.11, PPG Industries' Lake Charles 

Complex herein submits its quarterly report. The period of March 1 , 1983 

to September 1, 1983 is covered in this report due to the overlap between 

the Federal NESHAP program and the recently promulgated LESHAP program. 

This report addresses all of the units located at the Lake Charles Complex 

which are governed by the VCM LESHAP regulations. 

A record of those one-hour emissions in excess of the 10 ppm standard from 

the continuous VCM monitoring instruments from the stack gases exiting each 

of the incinerator systems is attached as Exhibit I. 

During this reporting period, there were five releases of vinyl chloride 

resulting from the accidental failure to incinerate vent gases. These five 

releases are enumerated in Exhibit II . 

Also during this reporting period, the Complex experienced six incidents 

where VCM-bearing process wastewater was comingled with non-VCM bearing 

streams prior to treatment and in which the hourly concentration of VCM in 

the VCM bearing stream was greater than 10 ppm (see Exhibit III). Each 

one of the six incidents were caused by the sudden unanticipated, surges of 
P.47 

VCM LESHAP Quarterly Report 

September 13, 1983 

Page two 

low pH aqueous material from the Tri-Ethane II OHC process. These sudden 

surges of low pH material can result in inadequate pH control and potential 

damage to downstream equipment. In order to control these surges that 

occur in the system, a level transmitter is presently being installed and 

should be operational by October 1 , 1983. $' 

Sincerely, 

Phifip S. Trew 

Environmental Control Specialist 

/ds 

xc: Mr. Joe Withers 

U.S. EPA, Region VI 

Air & Waste Management Division 
P.48 

EXHIBIT I 

EXCURSIONS 10 PPM VCM FROM INCINERATOR STACKS NOS. 

(March 1 , 1983 - September 1 , 1983) 

1, 2, &3 

Stack 

None 

Stack 

None 

Stack 

No. 1 (Incinerators #1 

No. 2 (Incinerator #3) 

No. 3 (Incinerator #4) 

and #2 

Date 

575783 

7/23/83 

7/23/83 

7/24/83 

7/24/83 

Hou 

5 

3 

4 

6 

r E 

00 

00 

00 

00 

nc 

P 

P 

P 

P 

ling 

m. 

m. 

m. 

m. 

7:00 p.m. 

.s>V 

Hourly Average 

13.9 ppm 

10.0 ppm 

21.0 ppm 

43.6 ppm 

20.9 ppm 

ry t ^ & 

Comment 

Error found in 

G.C. analysis. 

Readings believed 

to be in error on 

the high side. 
P.49 

EXHIBIT II 

NON-INCINERATION OF VCM VENTS 

Date 

3/12/83 

Time 

5:33 a.m. 6:16 p. 

(43 minutes) 

73. JU 

Reason 

Estimated Quantity 

of VCM Emitted 

m. Overflow of water from 24 lbs. 

a process vessel into y p , , M 

the VCM-11 vent header \)c fi ~ A '"' * 

caused the vents to 

divert to the emergency <? '^3^/33 

scrubbed. The overflow <^-*-" 1 I 

was caused by the mechanical JuAo£~ . 

failure" of a level control valve 

which has been corrected. 

3/28/83 

4/24/83 

6:22 a.m.-7:16 a.m. 

(54 minutes) 

Q n y 

11 :00 

(3 

—> 

p.m. 

hrs . 

°l\ 

-3:55 a.m 

55 min) 

.V 

5/14/83 1:40 p.m.-3:21 a.m. 

(1 hr. 40 min) 

/ , t>1 & 

8/13/83 8:39 p.m.-9:23 p.m. 

(44 minutes) 

1

 3

1 1 _-- J*-^ J? 

r, 9< 

Vents from the Tri-Ethane II 26 lbs. 

unit were tripped from the 

Incinerator and due to a 

mis-communication between 

operating areas the vents 

remained out of the incinerators 

for 54 minutes. 

This incident occurred when 

the rupture disc on the VC-I 

vent header blew prematurely. 

Due to the fact that the rupture 

disc relieves to a vent header 

common to other sources operations 

personnel were unable to determine 

that the rupture disc had blown. 

.OW2- w v 

Ir* 

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yy ,Mv--

Due to instruments problems 55 lbs 

in VC-II . The VC-II vents 

could not be reset to any of 

the incinerator after an 

unanticipated trip . Investigation 

into the control instrumentation 

could not uncover any mechanical 

problems. 

3/M/.J 3 

Lost of steam to the VCM-11 7 lbs. 

and OHC-111 areas caused an 

emergency shutdown of these 

areas. During this emergency, 

the No. 4 incinerator tripped off. 

Vents remained out of the Incinerator 

until the VCM-II/OHC-I II shutdowns 

were under control.. ^ 
P.50 

EXHIBIT III 

DIVERSIONS OF VCM PROCESS WASTEWATER 

Date 

3/2/83 

3/3/83 

5/4/83 

5/10/83 

6/3/83 

6/24/83 

Duration 

22 min. 

45 min. 

21 min. 

25 min. 

30 min. 

25 min. 

PH 

PH 

pH 

pH 

pH 

pH 

upset 

upset 

upset 

upset 

upset 

upset 

in 

in 

in 

in 

in 

in 

Re? 

OHCOHCOHCOHCOHCOHCEstimated Hourly 

Concentration of VCM 

Phase Separator 

Phase Separator 

Phase Separator 

Phase Separator 

Phase Separator 

Phase Separator 

10.6 

21.7 

10.1 

12.1 

14.5 

12.1 

7_ ,-£ V ,A£#L. 

/ -/^'~ 
P.51 

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Mr. Gus Von 

Administrate 

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March 13, 1985 

* •• 

Bodungen, P.E. 

>r, Air Quality Division 

Department of Environmental Quality 

Post Office 

Baton Rouge, 

Dear Mr. Vor 

Box 44066 

Louisiana 70804 

i Bodungen: 

Air! fy.--.-.. . 

Enclosed please find the sixth State Quarterly Report regarding the 

status with 

This report 

the LESHAP Regulations for Vulcan's ethylene dichloride 

is submitted in accordance with Subpart B, Section 17.11 

Louisiana Regulations for the emissions of hazardous air pollutants 

the time period from December 1, 1984 

Subpart B, Section 77.3(a) - Ethylene 

These vents 

to February 28, 1985 inclusive 

Dichloride Process Vents. 

were continuously incinerated as required except for the 

interruptions: 

Date and Time 

Vents Not Incinerated 

y 

*December 17 

09:15-15:51 

December 18 

14:38-14:59 

January 20, 

05:50-06:38 

1984 

(6 hrs. 36 min.) "^^ <*•'•" 

, 1984 

( 2 1 min. ) '•• i — 

1985 

(48 min.)

 l--H *-•* 

•January 21-22, 1985 

13:35-23:00 

•January 23, 

09:25-15:15 

January 28, 

08:00-08:14 

January 28, 

14:40-15:15 

(25 hrs. 25 min.) \'.\C~ -

1985 x, "~ . 

/ ;,; r... ^-:Ar- ) <-\,o ^ . 

1985 

(14 min.) 

1985 

(35 min.) 

P. O. Box 227 - Geismar, Louisiana 70734 • Telephone 504-389-9500 

Reason 

Incinerator shutdown due to 

manway on furnace 

Shutdown to change thermocoi 

Shutdown due to high steam p 

c Line from EDC to F-l frozen 

plugged due to cold 

u Line from D-118 and D-105 ir 

* -— L. 

.. • I'-.'o'-' 

' "-3 •-•:,'• 

'if "-.-Ve,.-

"<v!i-r_-u 

compliance 

(EDC) plant. 

, of the 

and covers 

following 

leaking 

pie 

iressure 

and 

EDC to 

"" vent header plugged 

Thermocouple giving incorrect indication 

Furnace shutdown to replace 

thermocouple 

A Division o Vulcan Materials Company 

faulty 

N-.*-

y> .'V 
P.52 

Mr. Gus Von Bodungen, P.E. -2- March 13, 1985 

Date and Time 

Vents Not Incinerated 

February 1, 1985 

14:54-15:27 (43 min.) 

"' *February 4, 1985 

16:32-21:20 (4 hrs. 48 min.) ^ 

'"" *February 5, 1985 

11:05-16:55 (5 hrs. 50 min.) 'AO 

February 16, 1985 

09:30-10:05 (35 min.) 

^•Februarv 16, 1985 

11:35-13:05 (-1 hr. 30 min.) <0 

Reason 

Shutdown for repairs to No. 1 burner 

Shutdown for repairs to No. 1 burner 

T-101 and T-106 in EDC down for 

maintenance 

Line pluggage in vent line caused 

pressure problems - blew line out 

T-103 in EDC pressure problems - line 

blown out 

•Reports previously submitted as required by 76.18(b) of LESHAP. In all cases 

maximum efforts were made to control the vents as quickly as possible. 

Subpart B, Section 77.3(b) - Ethylene Dichloride Oxychlorination Reactor Vents. 

The vents from the oxychlorination reactor were in compliance with the limits 

of Section 77.3(b) of LESHAP (one hour average, 2 pounds VnCl/10,000 pounds EDC) 

except for the following periods: 

Date, Time, and Duration 

December 10, 1984 

12:05-01:05 (1 hr.) 

January 30, 1985 

02:05-03:05 (1 hr.) 

February 21, 1985 

02:10-03:10 (1 hr.) 

lbs.-VnCl/ 

10,000 lbs. EDC 

2.2 

2.4 

2.3 

Reason 

Gas composition change 

Excess ethylene on reactor 

Gas composition change 

Standard operating procedures were followed during all the above exceptions. 

It should be noted that in all of these incidents, this vent was being incinerated 

in Vulcan's new oxy-vent incinerator (F-2) and the vinyl emissions were therefore 

essentially zero. 

Subpart B, Section 77.6 (B.9(i)) - Vinyl Chloride in Process Wastewater. 

Vulcan's vinyl chloride stripping tower (plant ID #T-106) used to meet the LESHAP 

performance standard for process wastewater was in service for the entire quarter 

and no exceptions are reported. 
P.53 

Mr. Gus Von Bodungen, P.E. -3- March 13, 1985 

Compliance was attained with all other applicable sections of Subpart B -

Emissions Standard for Vinyl Chloride. If you or your staff have any questions 

regarding this report, please contact me at 504/389-9500. 

RobertrE> Berg 

Environmental Eng 

REB:mrc 
Certified Mail: Return Receipt Requested #610 373 004 

P.54 

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December 13, 1984 r-r-

"•"••- J-> 1354 

Mr. Gus Von Bodungen, P.E. 

Administrator, Air Quality Division 

Department of Environmental Quality 

Post Office Box 44066 

Baton Rouge, Louisiana 70804 

Dear Mr. Von Bodungen: 

Enclosed please find the fifth State Quarterly Report regarding the compliance 

status with the LESHAP Regulations for Vulcan's ethylene dichloride (EDC) 

plant. This report is submitted in accordance with Subpart B, Section 17.11, 

of the Louisiana Regulations for the emissions of hazardous air pollutants 

and covers the time period from September 1, 1984 to November 30, 1984 

inclusive. 

Subpart B, Section 77.3(a) - Ethylene Dichloride Process Vents. 

These vents were continuously incinerated as required except for the following 

interruptions: 

Date and Time 

Vents Not Incinerated 

September 7, 1984 

18:30-18:40 (10 min.) 

•September 10, 1984 

08:07-15:30 (7 hrs. 29 min.) M-I«\ 

•September 11, 1984 

08:45-10:14 (1 hr. 29 min.) ^ 

September 12, 1984 

18:35-18:40 (5 min.) 

September 13, 1984 

11:02-11:10 (8 min.) 

September 16, 1984 

11:06-11:10 (4 min.) 

Reason 

Shutdown due to high boiler gas outlet 

temperature 

Replace natural gas valve on boiler 

Thermocouple failure shutdown furnace 

Shutdown due to high boiler gas outlet 

temperature 

Shutdown due to faulty high temperature 

alarm 

Lost #1 burner due to scanner failure 

P. O. Box 227 - Geismar. LA 70734 • Telephone 504-473-8641 

A Division ol Vulcan Materials Company 

. • 
P.55 

Mr. Gus Von Bodungen -2- December 13, 1984 

Date and Time 

Vents Not Incinerated Reason 

September 21, 1984 

20:48-21:17 (29 min.) 

•September 23, 1984 ^.- „^,r- *<. 

12:15-16:10 (3 hrs. 55 min.)'v' '->+•'( 

v> -"'d?TM* 

SP 

September 30, 1984 

00:30-00:35 (5 min.) 

September 30, 1984 

01:10-01:17 (7 min.) 

October 29, 1984 

08:40-09:15 (35 min.) 

Troubleshooting pressure problem on 

T-101 tower in EDC 

Line plugged on T-101 (al l other vents 

incinerated) 

Shutdown due to scanner problems 

Shutdown due to scanner problems 

Temporary power failur e 

Incinerator out of service due to 

•November 16-17, 1984 i o hs 

16:00 (16)-22:10 (17) (2Mirs . 10 min.) unanticipated refractory repairs 

|?7 0 

y<r •November 20-21, 1984 Shutdown due to thermocouple failur e 

•.*•**%. V 21:20-00:30 (3 hrs. 10 min.) i«io ^rl0A 

<z&'-^. ^'•Reports previously submitted as required by Section 76.18(b) of LESHAP. 

In al l cases maximum effort s were made to control the vents as quickly as 

possible. 

Subpart B, Section 77.3(b) - Ethylene Dichloride Oxychlorination Reactor Vents. 

The vents from the oxychlorination reactor were in compliance with the limit s 

of Section 77.3(b) of LESHAP (one hour average, 2 lbs . VnCl/10,000 lbs. EDC) 

except for the following periods: 

Date, Time, and Duration 

September 1, 1984 

00:05-01:05 (1 hr.) 

September 2, 1984 

11:40-12:40 (1 hr.) 

September 4, 1984 

07:55-08:55 (1 hr.) 

September 5, 1984 

07:30-08:30 (1 hr.) 

September 5, 1984 

14:30-15:30 (1 hr.) 

lbs . VnCl/ 

10,000 lbs . EDC 

2.5 

3.0 

2.8 

2.3 

2.6 

Reason 

Gas composition change 

Gas composition change 

Gas composition change 

Gas composition change 

Gas composition change 
P.56 

Mr. Gus Von Bodungen -3- December 13, 1984 

Date, Time, and Du 

September 18, 1984 

19:05-20:05 (1 hr.) 

September 22, 1984 

00:55-01:55 (1 hr.) 

September 27, 1984 

15:55-17:25 (1.5 hrs. 

October 12, 1984 

15:55-16:55 (1 hr.) 

October 28, 1984 

ration 

) 

10 

lbs. VnCl/ 

,000 lbs. EDC 

2.5 

2.2 

2.9 

2.9 

2.1 

Reason 

21:45-22:45 (1 hr.) 

October 29, 1984 

15:15-16:15 (1 hr.) 

October 29, 1984 

19:40-20:40 (1 hr.) 

November 16, 1984 

22:30-23:30 (1 hr.) 

2.5 

2.1 

2.8 

Startup reactor while perc 

plant upset 

Chlorine pressure problems 

Reactor startup and chlorine 

pressure problems 

Sharply cut rates 

Gas composition change and 

chlorine pressure problems 

Reactor startup 

Gas composition change 

Perc problems following 

startup 

Standard operating procedures were followed during the above exceptions in 

order to minimize vinyl emissions as much as possible. The number of 

exceptions is down significantl y over las t quarter and the majority of the 

exceptions thi s quarter occurred prior to a reactor catalyst change which was 

made in mid-September. As explained in the las t quarterly, this planned 

catalyst change was moved up so as to have two reactors with relativel y fresh 

catalyst to allow shutdown of the thir d reactor containing older, more 

sensitive catalyst. There were only four (4) exceptions during October and 

only one (1) in November. 

Subpart B, Section 77.6 (B.9(i)) - Vinyl Chloride in Process Wastewater. 

Vulcan's vinyl chloride stripping tower (plant ID #T-106) used to meet the 

LESHAP performance standard for process wastewater was in service for the 

entire quarter and no exceptions are reported. 

Compliance was attained with al l other applicable sections of Subpart B -

Emissions Standard for Vinyl Chloride. I f you or your staf f have any questions 

regarding thi s report, please contact me at 504/389-9500. 

REB:mrc 
P.57 

Certified Mail: Return Receipt Requested #610 372 983 Cpjj ^ l -

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AIR QWU7 / ^/iSJOri 

September 13, 1984 

Mr. Gus Von Bodungen, P.E. 

Administrator, Air Quality Division 

Department of Natural Resources 

Post Office Box 44066 

Baton Rouge, Louisiana 70804 

Dear Mr. Von Bodungen: 

Enclosed please find the fourth State Quarterly Report regarding the compliance 

status with the LESHAP Regulations for Vulcan's ethylene dichloride (EDC) plant. 

This report is submitted in accordance with Subpart B, Section 17.11, of the 

Louisiana Regulations for the emissions of hazardous air pollutants and covers 

the time period from June 1, 1984 to August 31, 1984 inclusive. 

Subpart B, Section 77.3(a) - Ethylene Dichloride Purification Process Vents. 

These vents were continuously incinerated as required except for the following 

interruption: 

Date and Time 

Vents Not Incinerated 

June 7, 1984 

13:04-13:25 (21 min.) 

June 24, 1984 

17:10-17:30 (20 min.) 

June 26, 1984* 

04:00-17:00 (13 hrs.) y%0 

June 28, 1984 

08:00-08:06 (6 min.) 

July 2, 1984 

15:50-15:55 (5 min.) 

Reason 

Broken thermocouple and thermowell 

Furnace momentarily shut down due to 

dirty scanners 

All vents blocked in at EDC during T-103 

shutdown (this is not standard operating 

procedure and this has been proceduraly 

addressed) 

Incinerator shut down when trying to put 

feed back in 

Lost main burners due to scanner 

problems 

P. O. Box 227 - Geismar, LA 70734 • Telephone 504-473-8641 

A Division ol Vulcan Materials Company 
P.58 

Mr. Gus Von Bodungen -2- September 13, 1984 

Date and Time 

Vents Not Incinerated Reason 

July 4, 1984 Lost No. 1 burner 

19:50-19:54 (4 min.) 

July 12, 1984 Incinerator shut down due to scanner 

16:50-16:58 (8 min.) problems 

17:07-17:20 (13 min.) 

July 14, 1984 Shut down due to high temperature of 

12:40-12:43 (3 min.) boiler outlet gas 

July 16, 1984 Lost No. 1 burner due to scanner 

10:25-10:32 (7 min.) failure 

August 18, 1984 Shut down due to high boiler outlet 

18:55-19:00 (5 min.) temperature 

August 29, 1984 Plantwide electrical outage 

.12:05-12:10 (5 min.) 

• Reports previously submitted as required by Section 76.18(b) of LESHAP. 

In all cases maximum efforts were made to control the vents as quickly as 

possible. The total amount of vinyl chloride released during all the minor 

(less than one (1) hour) outages during this quarter is calculated to be 

four (4) pounds. This amounts to an average of 0.36 pounds per release,^ ^J/^ue^^ ^ 

f which should not be expected to cause a significant negative impact on / 'jujjyi. 

^ambient air quality. g^"n 

Subpart B, Section 77.3(b) - Ethylene Dichloride Oxychlorination Reactor Vents 

The vents from the oxychlorination reactor were in compliance with the limits 

of Section 77.3(b) of LESHAP (one hour average, 2 lbs. VnCl/10,000 lbs. EDC) 

except for the following periods: 

Date, Time, and Duration 

June 4, 1984 

04:30-05:30 (1 hr.) 

June 5, 1984 

06:15-07:15 (1 hr.) 

June 12, 1984 

16:05-17:05 (1 hr.) 

June 13, 1984 

01:30-02:35 (1 hr. 5 min.) 

lbs . Vn 

10,000 lbs 

2.8 

2.7 

2.3 

3.5 

CI/ 

. EDC Reason 

Reactor startup 

Excess ethylene in reactor 

Gas composition change 

Raising rates 
P.59 

' Mr. Gus Von Bodungen -3- September 13, 1984 

Date, Time, and Duration 

June 14, 1984 

05:15-06:15 (1 hr.) 

June 16, 1984 

23:25-00:30 (1 hr. 5 min.) 

June 16, 1984 

12:50-14:10 (1 hr. 20 min.) 

June 23, 1984 

15:30-16:30 (1 hr. 

June 23, 1984 

19:45-20:45 (1 hr. 

June 27, 1984 

17:35-18:35 (1 hr. 

July 8, 1984 

10:15-11:15 (1 hr. 

July 8, 1984 

22:00-23:00 (1 hr. 

July 9, 1984 

08:00-09:00 (1 hr. 

July 13, 1984 

21:55-22:55 (1 hr. 

July 21, 1984 

16:55-17:55 (1 hr. 

July 23, 1984 

19:05-20:05 (1 hr. 

July 26, 1984 

00:55-01:55 (1 hr. 

July 26, 1984 

17:00-18:00 (1 hr. 

August 22, 1984 

01:05-03:05 (2 hrs.) 

August 30, 1984 

05:15-06:15 (1 hr. 

August 30, 1984 

15:00-16:30 (1 hr. 30 min.) 

August 30, 1984 

18:05-19:20 (1 hr. 15 min.) 

lbs. VnCl/ 

10,000 lbs. EDC 

2.4 

2.8 

2.9 

3.1 

2.3 

2.3 

2.3 

2.4 

2.4 

2.4 

2.5 

2.6 

3.2 

2.7 

2.7 

2.4 

3.1 

4.0 

Reason 

Gas composition change 

Reactor upset 

Lost light ends flow 

Starting up "C" reactor 

Excess gas composition change 

Starting up "C" reactor 

Starting up "C" reactor 

Chlorine pressure change 

Shut down of methanes plant 

Excess ethylene in reactors 

Reactor rate changes 

Excess ethylene in reactors 

HCI cutback to methanes 

Starting up "C" reactor 

Upset in perchloroethylene 

unit 

Upset in perchloroethylene 

unit due to change in feed 

material 

Propylene feed problems 

Excess ethylene in reactors 
P.60 

Mr. Gus Von Bodungen September 13, 1984 

Standard operating procedures were followed during the above exceptions in order 

to minimize vinyl emissions as much as possible. Several modifications in these 

operating procedures have been made in an effort to minimize vinyl chloride 

emissions and future changes will be made when necessary. It should be noted 

that the number, magnitude and duration of exceptions were all reduced during 

this quarter as a result of these changes in operation along with increased 

awareness among operations personnel of the need for compliance. Since the 

majority of the exceptions occurred during periods when "C" reactor was on line, 

a planned catalyst change for "B" reactor was moved up to mid-September so as to 

allow the shutdown of the "C" reactor. Additional operational changes made have 

also included lowering the set point on the vinyl alarm so as to alarm well before 

an exception occurs allowing time to rectify the problem before an exception 

occurs. Since it is felt that exceptions during operation of "C" reactor are due 

to the decreased activity that goes with extended catalyst life, Vulcan is 

committed to changing catalyst as necessary to avoid exceptions. We will attempt 

to maintain at least two reactors with relatively fresh catalyst at all times. 

The shutdown of "C" reactor along with the continued emphasis being placed on 

compliance with this section should significantly reduce future exceptions. 

The group of environmental, process engineering, and production personnel will 

continue to monitor the system closely. 

Subpart B, Section 77.6(B.9(i)) - Vinyl Chloride in Process Wastewater 

Vulcan's vinyl chloride stripping tower (plant ID #T-106) used to meet the 

LESHAP performance standard for process wastewater was in service for the 

entire quarter and no exceptions are reported. In addition the annual emission 

tests were run on this source in August under 77.8 and reported in a separate 

report. 

Compliance was attained with all other applicable sections of Subpart B -

Emissions Standard for Vinyl Chloride. If you or your staff have any questions 

or require further information regarding this report, please contact myself of 

Vance Gordon at 504/389-9500. 

REB:mrc 
P.61 

Certified Mail: Return Receipt Requested #610 372 954 

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June 14, 1984 

'/.; -

REyAyyfD 

**<• !—•* 

AIR QUALITY ry\>i~tr...f 

Mr. Gus Von Bodungen, P.E. 

Administrator, Air Quality Division 

Department of Environmental Quality 

Post Office Box 44066 

Baton Rouge, Louisiana 70804 

Dear Mr. Von Bodungen: 

Enclosed please find the third State Quarterly Report regarding the compliance 

status with the LESHAP Regulations for Vulcan's ethylene dichloride'(EDC) plant. 

This report is submitted in accordance with Subpart B, Section 17.11, of the 

Louisiana Regulations for the emissions of hazardous air pollutants and covers 

the time period from March 1, 1984 to May 31, 1984 inclusive. 

Subpart B, Section 77.3(a) - Ethylene Dichloride Purification Process Vents. 

These vents were continuously incinerated as required except for the following 

interruptions: 

Date and Time 

Vents Not Incinerated 

March 2, 1984* 

11:45-19:45 (8 hrs.) ^ ^ 

March 10, 1984 

20:10-20:13 (3 min.) 

March 16, 1984* 

10:08-12:30 (2 hrs., 42 min.) /_* 

April 1, 1984 - April 2, 1984* 

22:55-01:00 (2 hrs., 5 min.) /"*_" 

April 2, 1984* 

13:32-17:57 (4 hrs., 25 min.) ZA£ 

May 3, 1984* 

10:40-12:10 (1 hr., 30 min.) «o 

Reason 

Vents switched to atmosphere for removal 

of a plug in the vent feed line 

Furnace momentarily shut down from high 

temperature 

Incinerator shut down to repair a leaking 

block valve on the quench tower 

Incinerator shut down when a thermocouple 

failed 

Incinerator shut down to permanently 

replace the thermocouple failing April 1, 1984 

Incinerator shut down when the boiler flame 

was inadvertently extinguished, relighting 

problems 

P. O. Box 227 • Geismar, LA 70734 • Telephone 504-473-8641 

A Division ol Vulcan Materials Company 
P.62 

Mr. Gus Von Bodungen -2- June 14, 1984 

Date and Time 

Vents Not Incinerated Reason 

May 10, 1984* Vents switched to atmosphere when a leak 

11:00-14:50 (3 hrs., 50 min.) ~^o was discovered in the vent transfer line 

May 11, 1984* Vents switched to atmosphere to replace 

08:35-14:45 (6 hrs., 10 min.) 2~" leaking line discovered on May 10, 1984 

May 24, 1984* Incinerator shut down to clean the boiler 

08:40-23:30 (14 hrs., 50 min.) 71° - tubes 

•Reports previously submitted as required by Section 76.18(b) of LESHAP. 

In all cases maximum efforts were made to control the vents as quickly as 

possible. 

Subpart B, Section 77.3(b) - Ethylene Dichloride Oxychlorination Reactor Vents. 

Vulcan received final monitor certification from LESHAP for vinyl chloride 

monitors on April 23, 1984 by way of correspondence dated April 19, 1984. With 

this report Vulcan is reporting a number of relatively short exceptions to the 

vinyl chloride limits stated in Section 77.3(b) as detected by the certified 

analyzer. Several problems with the inputs to the microporcessor used to 

calculate the regulated parameters (pounds vinyl chloride/10,000 pounds EDC) 

have been discovered and corrected since the analyzer certification. These 

problems may have caused the analyzer to indicate more exceptions than actually 

occurred. We are nevertheless reporting all exceptions indicated by the analyzer 

system. Vulcan feels the correction of these detected problems along with 

modified operating procedures designed to minimize vinyl chloride production will 

significantly reduce future exceptions to the limits expressed in Section 77.3(b). 

The vents from the oxychlorination reactor were in compliance with the limits of 

Section 77.3(b) of LESHAP except for the following periods: 

lbs. VnCl/ 

Date, Time, and Duration 10,000 lbs . EDC Reason 

April 25, 1984 4.4 Ethylene change in HCI 

23:40-01:30 (1 hr., 50 min.) 

April 26, 1984 3.5 Reactor startup 

18:55-19:55 (1 hr.) 

April 30, 1984 5.2 E/cess ethylene in the reactors 

14:55-16:55 (2 hrs.) 

May 1, 1984 4.0 Gas rate change 

15:25-17:15 (1 hr. 50 min.) 

May 1, 1984 2.2 Excess ethylene in the reactors 

20:45-21:45 (1 hr.) 

May 1, 1984 2.7 Equipment failure 

23:15-00:15 (1 hr.) 
P.63 

Mr. Gus Von Bodungen -3- June 14, 1984 

Date, Time 

May 2, 1984 

03:55-06:10 ( 

May 2, 1984 

08:45-10:10 ( 

May 2, 1984 

20:20-21:20 ( 

May 3, 1984 

03:25-04:25 ( 

May 3, 1984 

04:50-05:50 ( 

May 3, 1984 

08:15-10:00 ( 

May 3, 1984 

13:45-15:10 ( 

May 3, 1984 

22:55-00:05 ( 

May 4, 1984 

09:05-10:05 ( 

May 4, 1984 

10:40-12:00 

May 4, 1984 

14:20-15:20 

May 5, 1984 

18:25-19:35 

May 6, 1984 

12:25-13:25 

May 7, 1984 

02:15-03:25 

May 7, 1984 

15:15-16:15 

May 7, 1984 

22:05-23:05 

•> 

2 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

n 

(i 

d 

(i 

(i 

and Duration 

hrs. , 15 min.) 

hr., 25 min.) 

hr.) 

hr.) 

hr.) 

hr. , 45 -min.) 

hr. , 25 min.) 

hr. , 10 min.) 

hr.) 

hr. , 20 min.) 

hr.) 

hr. , 10 min.) 

hr.) 

hr. , 10 min.) 

hr.) 

hr.) 

lbs. VnCl/ 

10,000 lbs . EDC 

2.9 

2.6 

3.5 

2.8 

2.2 

4.1 

4.3 

3.3 

4.4 

3.3 

2.7 

3.0 

3.0 

2.5 

2.1 

3.3 

Reason 

Excess ethylene in the reactors 

Ethylene change in HCI 

Ethylene change in HCI 

Ethylene change in HCI 

Ethylene change in HCI 

Excess ethylene in HCI 

Reactor startup 

Ethylene change in HCI 

Reactor rate change 

Excess ethylene in reactor 

Reactor rate change 

Reactor rate change 

Reactor rate change, ethylene change 

Excess ethylene 

Excess ethylene 

Excess ethylene change 
Mr. Gus Von Bodungen 

Date, Time, 

May 8, 1984 

03:25-04:25 (1 

May 8, 1984 

06:00-07:00 (1 

May 8, 1984 

16:20-17:30 (1 

May 9, 1984 

10:40-11:40 (1 

May 9, 1984 

12:40-13:50 (1 

May 9, 1984 

18:35-19:35 (1 

May 9, 1984 

20:50-21:50 (1 

May 10, 1984 

00:20-01:20 (1 

May 10, 1984 

01:45-02:45 (1 

May 10, 1984 

03:15-04:15 (1 

May 10, 1984 

05:10-06:10 (1 

May 10, 1984 

06:40-08:40 (2 

May 10, 1984 

16:15-17:15 (1 

May 22, 1984 

11:40-12:40 (1 

May 23, 1984 

11:00-12:00 (1 

May 24, 1984 

12:05-13:05 (1 

and Duration 

hr.) 

hr.) 

hr. , 10 min.) 

hr.) 

hr. , 10 min.) 

hr.) 

hr.) 

hr.) 

hr.) 

hr.) 

hr.) 

hrs.) 

hr.) 

hr.) . 

hr.) 

hr.) 

lbs. VnCl/ 

10,000 lbs . EDC 

2.3 

2.2 

2.9 

3.1 

3.7 

2.3 

2.4 

3.1 

3.3 

2.4 

3.0 

3.2 

2.6 

2.6 

2.2 

2.2 

June 14, 1984 

Reason 

Reactor temperature 

Ethyl 

Perc 

ene change in 

reactor upset 

change 

HCI 

ethylene change 

P.64 

Reactor startup 

Ethylene change in HCI 

Reactor rate change 

Ethylene change in HCI 

Excess ethylene in the reactor 

Excess ethylene in the reactor 

Excess ethylene in the reactor 

Reactor rate change 

Reactor rate change 

Reactor rate change 

Reactor startup 

Excess ethylene in the reactor 

Excess ethylene in the reactor 
P.65 

Mr. Gus Von Bodungen -5- June 14, 1984 

lbs. VnCl/ 

Date, Time, and Duration 10,000 lbs. EDC Reason 

May 24, 1984 2.6 Excess ethylene in the HCI 

23:20-00:20 (1 hr.) 

May 26, 1984 2.6 Ethylene change in the HCI 

08:10-09:10 (1 hr.) 

May 26, 1984 2.9 Ethylene change in the HCI 

13:25-14:35 (1 hr., 10 min.) 

May 27, 1984 2.8 Ethylene excess in the HCI 

16:30-17:55 (1 hr., 25 min.) 

May 28, 1984 2.3 Ethylene excess in the HCI 

09:35-10:35 (1 hr.) 

May 29, 1984 2.4 Reactor rate change 

12:05-13:05 (1 hr.) 

Standard operating procedures were followed during the above exceptions in order 

to minimize vinyl emissions as much as possible. As stated earlier, these 

operating procedures have been modified to help minimize vinyl chloride emissions 

and the importance of operating within the specified limits of this section has 

been strongly emphasized to the unit operating personnel. Vulcan feels the 

emphasis being placed on compliance with this section will significantly reduce 

future exceptions. 

Subpart B, Section 77.6 (B.9(i)) - Vinyl Chloride in Process Wastewater. 

Vulcan 's vinyl chloride stripping tower (plant ID #T-106) used to meet the 

LESHAP performance standard for process wastewater was in service for the entire 

quarter and no exceptions are reported. 

Compliance was attained with all other applicable sections of Subpart B -

Emissions Standard for Vinyl Chloride. If you or your staff have any questions 

or require further information regarding this report, please contact myself or 

Vance Gordon at 504/389-5900. 

Mery truly yours , 

J». i.e. 

G. L. Owen 

Environmental Chemist 

GL0:mrc 

cc: U. S. Environmental Protection Agency 

Air & Waste Management Division (6AW) 

1201 Elm Street 

Dallas, Texas 75270 
P.66 

Certified Mail: Return Receipt Requested #404 222 222 

i i 

\ \ ' i 

_5 r-

«ECFyf^ 

March 13, 1984 6

 1984 

Mr. Gus Von Bodungen, P.E. 

Administrator, Air Quality Division 

Department of Natural Resources 

Post Office Box 44066 

Baton Rouge, Louisiana 70804 

Dear Mr. Von Bodungen: 

I am enclosing our second State Quarterly Report regarding the status of 

our compliance with the LESHAP Regulations for Vulcan's ethylene 

dichloride (EDC) plant. This report is submitted in accordance with 

Subpart B, Section 77.11, of the Louisiana Regulations for the emissions 

of hazardous air pollutants and covers the time period from December 1, 1983 

to February 29, 1984 inclusive. 

Subpart B, Section 77.3(a) - Ethylene Dichloride Purification - Process 

Vents. These vents were continuously incinerated except for the following 

interruptions: 

O/V 

Date & Time Vents Not Incinerated 

December 25, 1983* 

02:30 - 09:35 (7 hrs , 5 min) <-\lC 

February 22, 1984 

08:15 - 08:23 (8 min) 

February 23, 1984 

08:00 - 08:C4 (4 min) 

February 24, 1984 

01:22 - 01:25 (4 min) 

February 24, 1984 

11 :00 - 11 :10 (10 min) 

February 25, 1984 

23:25 - 23:30 (5 min) 

Reason 

Furnace shutdown when high pressure switch 

malfunctioned due to freezing weather 

Furnace shutdown due to high pressure wet 

gas 

Furnace shutdown due to high boiler gas 

outlet temperature indicator malfunction 

Furnace shutdown due to high boiler gas 

outlet temperature indicator malfunction 

* 

Furnace shutdown due to high boiler gas 

outlet temperature indicator malfunction 

Furnace shutdown due to high boiler gas 

outlet temperature indicator malfunction 

• Report previously submitted, 

be 17.7 pounds. 

Vinyl chloride emissions were calculated to 

P. O. Box 227 • Geismar, Louisiana 70734 - Telephone 504-389-9500 

A Division ol Vulcan Materials Company 
P.67 

Mr. Gus Von Bodungen -2- March 13, 1984 

In al l cases, maximum effort was made to control the vents as soon as possible. 

The malfunction causing the four short interruptions between February 23 and 

February 25 has been corrected. 

Subpart B, Section 77.6 (B.9(i)) - Vinyl Chloride in Process Streams. 

Vulcan's vinyl chloride stripping tower (plant ID #T-106), which is used to 

meet the LESHAP performance standard for process wastewater, was in service 

for the entire quarter except for the following maintenance: 

Date & Time Tower Out Of Service Reason 

December 7, 1983 Tower down to repair flow orific e 

07:45 - 12:30 (4 hrs, 45 min) 

During this period, effluent lef t the production unit without passing through 

the vinyl chloride stripping tower. The stripper downtime was minimized to 

the greatest extent possible during thi s occurrence. 

Compliance was attained with al l other applicable sections of Subpart B. I f 

you or your staf f have any questions regarding this report, feel free to 

contact me at 504/389-9500. 

Sincerely, 

Si • *•&-

G. L. Owen 

Environmental Chemist 

GL0:mrc ; •K'ii*' 

\ •> j!V-

.'fl.l, ! 

cc: U.S. Environmental Protection Agency \ 0. w - •r'-L^' ^ 

Air and Waste Management Division (6AW) \ ' \ ^v^'' 7 \ 

1201 Elm Street / ' **

 v 

Dallas, Texas 75270 ' 
P.68 

L

i*r(^H 

Certified Mail: Return Receipt Requested #4715606 C6ZA<T _*• 

/ 

'•7/_V>7 

I 

•' ' ' 1 

, ' ! 1 

11 ! - 1 \ \ ! 

' 1 ' l i '' 

• ! r1 i .I V 

J j 1 i ! > 

" *_/ 

/ \ 

/ ) 

September 19, 1983

 /ff Q^/ r 

*•"; 1383 

0

^C^'°* 

Mr. Gus Von Bodungen, P. E. 

Administrator, Air Quality Division 

Department of Natural Resources 

Post Office Box 44066 

Baton Rouge, LA 70804 

Dear Mr. Von Bodungen: 

^ Z 

_-"> 

I am enclosing our thirteenth semi-annual report regarding the status of our 

compliance with the NESHAP (LESHAP) regulations for our ethylene dichloride 

(EDC) plant. This report is submitted in accordance with Subpart B, Section 

77.11 of the Air Quality LESHAP Regulations (40 CFR, Subpart F, Section 61.70) 

and covers the time period from March 16, 1983 to September 15, 1983 

inclusive. As required, this report will be submitted quarterly from this 

point forward. 

Subpart B, Section 77.3(a) -

Process vents. These vents 

the following interruptions: 

Date & Time 

Vents Not Incinerated 

June 9, 1983 

1325-1405 (40 min.) 

August 6, 1983 

0950-0955 (5 min.) 

August 13-1-47-1983:::^ 

0930-0430 (19 hours) ^ A->° 

August 197 1983 

2000-2005 (5 min.) 

September-l--;2;-1983 -—_•=; 

0020-1030 (34 hours, 10 min, 

September 13, 1983 

1253-1505 (2 hrs.,"12 min.) 

Ethylene Dichloride Purification -

were continuously incinerated except for 

Reason 

Furnace shutdown to repair leak on 

quench tower. 

Automatic furnace shutdown when 

quench tower temperature element 

position changed. 

Outage for major maintenance and 

quench tower replacement. 

« 

High level in knock-out drum, 

automatic feed trip-out. 

l^.iOlO p. 

IVL 

Electrical failure, acid spill on 

incinerator control box. 

Replacement of vent line in EDC 

unit. 

P. O. Box 227 • Geismar, Louisiana 70734 Telephone 504-389-9500 

A Division of Vulcan Materials Company N ^ 
P.69 

Mr. Gus Von Bodungen 

September 19, 1983 

Page 2 

In all cases, maximum effort was made to bring the incinerator back on line or 

restore the vent feed to the incinerator as soon as possible. 

Subpart B, Section 77.6 (B.9(i)) - Vinyl Chloride in Process Wastewater 

Streams. Vulcan's vinyl chloride stripping tower (plant ID T-106), which is 

used to meet the LESHAP (NESHAP) performance standard for process wastewater, 

is in continuous service except for required maintenance. The following 

summarizes the time periods that T-106 was out of service and explanations for 

this downtime: 

Date and Time 

Tower Out of Service 

July 22, 1983 

1100-1220 (1 hr., 20 min.) 

July 28, 1983 

0850-1100 (2 hrs., 10 min.) 

Reason 

Pump failure on stripping tower. 

Tower out of service to tie in 

additional source. 

During these periods, effluent left the production unit without passing 

through the vinyl chloride stripping tower. On all occasions, the stripping 

tower downtime was minimized to the greatest extent possible. 

Compliance was attained with all other applicable sections of Subpart B. If 

you or your staff have any further questions regarding this report, do not 

hesitate to contact me at 504/389-9500, extension 102. 

Very truly yours, 

bl 

/ John W. Bosky 

Environmental Engineer 

cc: U. S. Environmental Protection Agency 

Air and Waste Management Division (6AW) 

1201 Elm Street 

Dallas, Texas 75270 
•Certified Mail: Return Receipt Requested #404222190 

P.70 

/ 

-1 I 

J 

« » \ 

December 12, 1983 

Mr. Gus Von Bodungen, P.E. 

Administrator, Air Quality Division 

Department of Natural Resources 

Post Office Box 44066 

Baton Rouge, Louisiana 70804 

Dear Mr. Von Bodungen: 

I am enclosing our first State Quarterly Report regarding the status of our 

compliance with the LESHAP Regulations for Vulcan's ethylene dichloride (EDC) 

plant. This report is submitted in accordance with Subpart B, Section 77.11 

of the Louisiana Regulations for the emission of hazardous air pollutants and 

covers the time period from September 16, 1983 to November 30, 1983 inclusive. 

Subpart B, Section 77.3(a) - Ethylene Dichloride Purification - Process Vents. 

These vents were continuously incinerated except for the following interruptions 

Date & Time Vents Not Incinerated 

November 15, 1983* 

0830 - 1700 (8 hrs, 30 min) 510 

Reason 

Plugged check valve blocked vent line 

November 22, 1983 

1320 - 1420 (60 min) C=o 

Incinerator bypassed to repair flame 

arrestor and to flush vent line 

* Report submitted to State regarding this incident, 

one process tank. Vinyl chloride released was less 

Only affected vent 

than 0.5 pounds. 

from 

In both cases, maximum effort was made to control the vents as soon as 

possible. 

Subpart B, Section 77.6 (B.9(i)) - Vinyl Chloride in Process Streams. 

Vulcan's vinyl chloride stripping tower (Plant ID #T-106), which is used to 

meet the LESHAP performance standard for process wastewater, was not bypassed 

or out of service for any period during the last quarter. 

P. O. Box 227 Geismar, Louisiana 70734 • Telephone 504-389-9500 

A Division ol Vulcan Materials Company 
P.71 

Mr. Gus Von Bodungen, P.E. December 12, 1983 

In addition, compliance was attained with all other applicable sections of 

Subpart B. If you or your staff have any further questions regarding this 

report, do not hesitate to contact me at 504/389-9500, extension 102. 

Very truly yours , 

JWB:mrc 

John W. Bosky 

Environmental Engineer 

cc: U.S. Environmental Protection Agency 

Air and Waste Management Division (6 AW) 

1201 Elm Street 

Dallas, Texas 75270 
Goodrich 

The BFGoodrich Company 

Chemical Group 

P.O. Box 578 

Plaquemine. Louisiana 70765-0578 

504-387-3151 

CERTIFIED MAIL P 450 459 038 

RETURN RECEIPT REQUESTED 

September 11, 1984 

Mr. William H. Davis 

Chief, LESHAP Unit 

Louisiana Air Quality Division 

P. 0. Box 44066 

Baton Rouge, LA 70804-4066 

SUBJECT: LESHAP QUARTERLY REPORT 

Dear Mr. Davis: 

n r r> ~ M > r< *-N 

R n L, i \ y t D 

SEP 1.5 1334 

AIR QUALITY Oi VISION 

Pursuant to Section 77.11 of the Louisiana Emission Standard for Hazardous 

Air Pollutants, this serves as the quarterly report for the BFGoodrich Plaquemine Plant. This report covers the time period June 1, 1984 thru August 

31, 1984. 

During this time period, 2161 batches of PVC were produced by the bulk 

polymerization process. All batches were calculated to have zero reactor 

opening loss and therefore individual data, tables of zeros, is not included. 

The attached Table I, RESIDUAL VCM IN PVC - DAILY AVERAGES lists the 

weighted RVCM avearages for each day in this reporting period. 

During this time period, the vent gas incinerator operated 100% of the 

time. 

If you have any questions concerning this report, please contact Daniel P. 

Anderson, our Sr. Environmental Engineer at 387-3151 or 562-7402 (Convent). 

yours truly, 

Wrv), JL^J.' 

R. M. Sandfry 

Plant Manager 

#3-

RMS/vbp/WP0031A-015lB 
P.73 

Goodrich 

The BFGoodrich Company 

Chemical Group 

P.O. Box 578 

Plaquemine. Louisiana 70765-0578 

504-387-3151 

CERTIFIED MAIL # P 450 459 02A 

RETURN RECEIPT REQUESTED 

June 7, 1984 

Mr. William Newman, Chief 

Louisiana NESHAP Unit 

P. 0. Box 44066 

Baton Rouge, LA 70804 

SUBJECT: LESHAP QUARTERLY REPORT 

RECEIVED 

J UN 1 $ J9£4 

Dear Mr. Newman: 

Pursuant to Section 77.11 of the Louisiana Emission Standard for Hazardous 

Air Pollutants, this serves as the quarterly report for the BFGoodrich 

Plaquemine Plant. This report covers the time period March 1, 1984 thru 

May 31, 1984. 

During this time period, 2460 batches of PVC were produced by the bulk polymerization process. All batches were calculated to have zero reactor opening 

loss and therefore individual data, tables of zeros, is not included. 

The attached Table I, RESIDUAL VCM IN PVC - DAILY AVERAGES lists the weighted RVCM averages for each day in this reporting period. 

During this time period, the plant experienced no vent gas incinerator downtime, therefore individual data is not included. 

If you have any questions concerning this report, please contact Daniel P. 

Anderson, our Sr. Environmental Engineer at 387-3151 or 562-7402 (Convent). 

Yours truly, 

R. M. Sandfry 

Plant Manager 

RMS/vbp 
P.74 

z.v Goodrich 7 W-9 

The BFGoodrich Company 

Chemical Group 

P.O. Box 578 

Plaquemine, Louisiana 70765-0578 

504-387-3151 CERTIFIED # - P450 459 008 

RETURN RECEIPT REQUESTED 

Marc h 12 , 1984 

Mr. William Newman, Chief 

Louisiana NESHAP Unit 

P. 0. Box 44066 

Baton Rouge, LA 70804 

SUBJECT: LESHAP QUARTERLY REPORT 

Dear Mr. Newman: 

Pursuant to Section 77.11 of the Louisiana Emission 

Standard for Hazardous Air Pollutants, this serves 

as the quarterly report for the BFGoodrich Plaquemine 

Plant. This report covers the time period December 1, 1983 

thru February 29, 1984. 

During this time period, 1650 batches of PVC were 

produced by the bulk polymerization process. All batches 

were calculated to have zero reactor opening loss and 

therefore individual data, tables of zeros, is not 

included. 

The attached Table I, RESIDUAL VCM IN PVC - DAILY 

AVERAGES lists the weighted RVCM averages for each day 

in this reporting period. 

During this time period, the plant experienced no 

vent gas incinerator downtime, therefore individual data 

are not included. 

If you have any questions concerning this report, 

please contact Daniel P. Anderson, our Sr. Environmental 

Engineer at 387-3151 or 562-7402 (Convent). 

Yours truly, 

VT). 

RMS/vbp 

R. M. _5andfr5 

Plant Manager 
Goodrich O i I 

P.75 

The BFGoodrich Company 

Chemical Group 

P.O. Box 578 

Plaquemine, Louisiana 70765-0578 

504-387-3151 

CERTIFIED MAIL - P13 1353291 

RETURN RECEIPT REQUESTED 

RECEIVED 

January 19, 1984 -•': . im 

AIR QUALIir _.:;•;:'•-•.: 

OEA/DNR 

Mr. William T. Newman 

Acting Chief, NESHAP Unit -

Louisiana Air Quality Division 

P. 0. Box 44066 

Baton Rouge, LA 70804 

Dear Mr. Newman: 

Attached please find a table listing periods of incinerator downtime and the 

estimated amounts of VCM vented to atmosphere per occurrence. There are no flow 

measuring devices on this vent line and the values are estimated based upon 

operating conditions at those times. 

As discussed with Greg Gasperecz and Mary Wright during their November 

visit, we have completed revisions to our VCM Recovery System which will 

eliminate future venting to the atmosphere if the incinerator trips off line. 

If you have any further questions, please contact Daniel P. Anderson our Sr. 

Environmental Engineer at 387-3151 or at 562-7402 (Convent). 

Yours truly, 

ro 

R. M. Sandfry 

Plant Manager 

RMS/vbp/0017B 

ATTACHMENT 
P.76 

VENT GAS INCINERATOR DOWNTIME 

DATE 

09/01/83 

09/08/83 

09/21/83 

09/26/83 

09/30/83 

10/01/83 

10/05/83 

10/09/83 

10/21/83 

DURATION (HOURS) 

3.5 

0.08 

6.5 

0.75 

0.08 

0.08 

0.08 

3.08 

0.16 

ESTIMATED VINYL EMISSION (LBS) 

105.0 

2.4 

195.0 

22.5 

2.4 

2.4 

2.4 

92.4 

4.8 
P.77 

Goodrich 

The BFGoodrich Company 

Chemical Group 

P.O. Box 578 

Plaquemine. Louisiana 70765-0578 

504-387-3151 

CERTIFIED # - P13-135330 0 

RETURN RECEIPT REQUESTED 

Decembe r 15 , 1983 

Mr. Willia m Newman, Chie f 

Louisian a NESHAP Uni t 

P . 0 . Box 44066 

Bato n Rouge , LA 70804 

SUBJECT: LESHAP QUARTERLY REPORT 

Dea r Mr. Newman: 

RECEIVED 

LAzC; -• 

<• - 1983 

A

<* QUAury c/v ^

; 

°t/VDr"'' /S,C * 

Pursuant to Section 77.11 of the Louisiana Emission Standard 

for Hazardous Air Pollutants, this serves as the first quarterly 

report for the BFGoodrich Plaquemine Plant. This report covers 

the time period August 1, 1983 thru November 30, 1983. 

During this time period, 2332 batches of PVC were produced 

by the bulk polymerization process. All batches were calculated 

to have zero reactor opening loss and therefore individual data, 

tables of zeros, is not included. 

The attached Table I, RESIDUAL VCM IN PVC - DAILY AVERAGES 

lists the weighted RVCM averages for each day in this reporting 

period. 

The attached Table II, VENT GAS INCINERATOR DOWNTIME, 

lists periods when the incinerator was not operating because 

of equipment malfunction. 

If you have any questions concerning this report, please 

contact Daniel P. Anderson, our Sr. Environmental Engineer at 

387-3151 or 562-7402 (Convent). 

Yours truly, 

R. M. Sandtfr} 

Plant Manager 

RMS/vbp 
P.78 

Goodrich 

The BFGoodrich Company 

Chemical Group 

P.O. Box 578 

Plaquemine. Louisiana 70764 

504-387-3151 

jwr ft t C :- .' -j/r-

-^eo 

:>im 

Alp. Ci V-: .. 

^o'A^m 

August 24, 1983 " "^ 

Louisiana Department of Natural Resources 

Air Quality Division, NESHAP Unit 

P. 0. Box 44066 

Baton Rouge, LA 70804 

SUBJECT: NESHAP SEMI-ANNUAL REPORT 

Gentlemen: 

As required by 40 CFR 61.70, thi s serves as the Semi-Annual Report for 

BFQDodrich - Plaqusmine, Louisiana Plant for the time period February 1 , 1983 

through July 31 , 1983. 

The attached Table I , Residual VCM i n PVC-Daily averages list s the weighted RVCM 

averages fo r each day. 

The attached Table II , Reactor Opening Loss-Bulk Polymerization list s calculated 

reactor opening loss for each batch of PVC that exceeds 20 mg VCM/Kg PVC. 

The attached Table III , Vent Gas Incinerator Downtime list s periods when the 

incinerator was not i n operation due to equipment malfunctions. 

Yours truly, 

a~^ J 

R. M. Sandfry 

Plant Manager 

RMS/vbp 

cc: U.S. Environmental Protection Agency - Dallas, Texas 
P.79 

TABLE II 

VENT GAS INCINERATOR DOWN TIME 

The periods noted below were incidents of down time because of 

equipment malfunction. 

DATE 

09-01-83 

09-08-83 

09-21-83 

09-26-83 

09-30-83 

10-01-83 

10-05-83 

10-09-83 

10-21-83 

TIME DOWN 

0930 

0710 

0445 

1445 

2030 

0105 

1510 

1925 

1750 

TIME RE-STARTED 

1300 

0715 

1115 

1530 

2035 

0110 

1515 

2230 

1800 

TOTAL DOWN TIME 

3.5 

0.08 

6.5 

0.75 

0.08 

0.08 

0.08 

3.08 

0.16 

N-if /w 
P.80 

TABLE III 

VENT GAS INCINERATOR DOWN TIME 

The periods noted below were incidents of downtime because 

of equipment malfunction: 

DATE TIME DOWN 

8/4/82 0730 

8/14/82 1030 

8/22/82 1000 

TIME RE-STARTED 

0930 

1130 

1400 

TOTAL DOWNTIME 

2.0 hrs. 

1.0 

4.0 

TOTAL 7.0 hrs. 
P.81 

'OSrlH L'-S* a l>w, 

The BFGoodrich Company 

Chemical Group 

P.O. Box 578 

Plaquemine, Louisiano 70764 

504-387-3151 

<i>9f>A 

March 14, 1983 

Mr. Dick Whittington 

Regional Administrator 

U.S.E.P.A. 

Region VI 

First International Building 

1201 Elm Street 

Dallas, TX 75270 

SUBJECT: NESHAP SEMI-ANNUAL REPORT 

Dear Mr. Whittington: 

As required by 40CFR 61.70, this serves as the semiannual report for the BFGoodrich Plaquemine Louisiana Plant 

for the time period August 1, 1982 through January 31, 1983. 

The attached Table I, RESIDUAL VCM IN PVC - DAILY AVERAGES, 

lists the weighted RVCM averages for each day. 

The attached Table II, REACTOR OPENING LOSS - BULK 

POLYMERIZATION, lists calculated reactor opening loss for each 

batch of PVC that exceeds 20 mg VCM/kg PVC. 

The attached Table III, VENT GAS INCINERATOR DOWNTIME, lists 

periods when the incinerator was not in operation due to 

equipment malfunctions. 

The attached Table IV, VENT GAS INCINERATOR MONITOR DATA 

LOGGER DOWNTIME, lists periods when data was not recorded due 

to equipment malfunctions. 

Yours truly, 

__*WJ M 

R. M. Sandfr? 

Plant Manager 

RMS/vbp 

RECEIVED 

MAR2 31S83 

RECEIVED 

MAR 2 3 1983 

SAW* 
P.82 

TABLE III 

VENT GAS INCINERATOR DOWN TIME 

The periods noted below were incidents of downtime 

because of equipment malfunction. 

Date Time Down 

6-17-83 10:00 

7-17-83 05:30 

7-18-83 09:00 

Time Re-Started 

11 

10 

• 12 

30 

30 

00 

Total Down Time 

1.5 

5.0 

3.0 

TOTAL 9.5 
P.83 

TABLE IV 

VENT GAS INCINERATOR MONITOR DATA LOGGER DOWN TIME 

The vent gas incinerator data logger was not operational 

from October 11, 1982 through December 17, 1982. However, 

during this time period, the monitor functioned 100% of the 

time. Operating data indicated normal operation of the incinerator 

and routine observation of the incinerator monitor revealed no 

exceedances of the 10 PPM emission limit. 
P.84 

LESHAP SECTION 77.11 c(l) 

EMISSION CONTROL DEVICE BY-PASS 

DURATION LESS THAN ONE HOUR 

DATE 

12-5-84 

12-12-84 

12-12-84 

12-13-84 

12-13-84 

12-16-84 

12-16-84 

12-16-84 

12-16-84 

12-16-84 

12-20-84 

12-20-84 

12-21-84 

12-21-84 

12-21-84 

12-22-84 

12-22-84 

12-22-84 

12-22-84 

12-22-84 

12-23-84 

12-25-84 

12-25-84 

12-25-84 

12-25-84 

12-26-84 

12-27-84 

12-27-84 

TIME 

START 

1640 

0850 

0852 

0130 

0140 

0345 

1730 

1743 

1745 

1757 

1030 

1910 

1200 

1206 

1335 

08051 

0813'; 

0915 3 

1130 

1145 

2115 

0100 

0128 

1435 

1445 

1615 

1520 

1530 

END 

*» 1700 

1 0851 

*~> 0939 

M 0134 

s 0145 

c 0350 

*-• 1734 

^ 1745 

i 1747 

-L 1759 

^ 1113 

-o 1930 

f 1205 

s* 1304 

•L 1337 

-i 0812 

-> 0820 

*<< 0930 

c 1135 

< 1150 

•» 2122 

-> 010 7 

2. 0130 

i- 1437 

1 1446 

S 1620 

x 1522 

z. 1532 

CAUSE 

Oxy unit start-up; oxy vent only -

Liquid in vent header 1 

Liquid in vent header '• 

High temperature •*, 

Switched vent from secondary to primary •/ 

Liquid in vent header ? 

Liquid in vent header 1 • 

Switched vent from secondary to primary ' 

Liquid in vent header '. 

Switched vent from secondary to primary -

/ 

Sandblast crew blasted the air supply line on 

fuel valve 

Liquid in vent header "•" 

Water in vent line 

Water in vent line 

Switched vents from secondary to primary

 y 

Unknown ; 

Unknown / 

Unknown j 

Water in vent line 

Water in vent line "-. 

Problem with fuel gas valve 

Flame sensors 

Switched vents from secondary to primary A 

Heavy venting V,. 

Switched vents from secondary to primary

 y 

High level in vent knock out pot 7 

High temperature 

Switched vents from secondary to primary A 

juda -

v

" r~-^ -

1 

' 1 ' i- • \ "-* — ' ° 

LBS. VCM 

BUTTED 

3 

6 

282 

24 

30 

30 

24 

12 

12 

12 

258 

120 

30 

348 

12 

42 

42 

90 

30 

30 

42 

42 

12 

12 

6 

30 

12 

\2^ 

r<*°^ 

r 
P.85 

BORDEN CHEMICAL 

DIVISION OF BORDEN INC 

March 15, 1985 

CERTIFIED MAIL P 404 220 933 

RETURN RECEIPT REQUESTED 

Mr. William H. Davis 

Chief, NESHAP Unit 

Department of Environmental Quality 

P. 0. Box 44066 

Baton Rouge, Louisiana 70804 

Dear Mr. Davis: 

In accordance with Louisiana Air Quality Regulations, Section 77.11, 

Borden herewith submits its quarterly report for the quarter ending 

February 28, 1985. 

Should you have any questions concerning this report, please contact 

David T. McLemore or me. 

Sincerely yours, 

G. T. Hennings 

Complex II Manager 

GTH:al y 

Attachment 

CC: 0. 

-^0 . 

M. 

D. 

W. 

W. 

H. 

N. 

C. 

F. 

Di 

A. Sandberg 

C. Lunn, Jr. 

W. Dietzel 

T. McLemore 

P. Leonard 

B. Barton 

A. Rosenzweig 

M. Lattimore 

C. Jones 

R. Swavely 

rector - Enforcement Division 

EPA, Region VI 

1201 Elm Street 

Dallas. Texas 75270 

POST OFFICE BOX 427 « GEISMAR, LOUISIANA • TELEPHONES: (504) 673-6121 (504) 387-5101 
P.86 

LESHAP SECTION 77.11 c(l) 

EMISSION CONTROL DEVICE BY-PASS 

DURATION LESS -THAN ONE HOUR 

. DATE 

1-3-85 

1-3-85 

1-7-85 

1-10-85 

1-12-85 

1-12-85 

1-12-85 

1-13-85 

1-13-85 

1-13-85 

1-13-85 

1-16-85 

1-18-85 

1-18-85 

1-19-85 

1-20-85 

1-20-85 

TIME 

START 

2045 

2115 

1530 

1320 

1450 

1520 

1700 

1055 

1109 

1245 

1329 

1940 

0325 

0520 

2130 

0748 

1000 

END 

^2110 

s 2120 

i* 1545 

''-1336 ": 

i 1453 -' 

i 1523 

T- 1702 y 

3 1058 '[ 

' m o '-• 

z 1248

 7 

i 1330 v 

^2014 < 

£'0416

 7 

^'0605

 7 

222152 ? 

5^0840 1" 

moio ^f 

~y\ 

CAUSE 

Blower tripped (oxy vent only) 

Unknown (oxy vent only) 

High vent pressure, no incinerator trip-out, 

diverted utility vent only 

Pluggage in vent line ? 

High temperature high vent flow (partial by-pass 

only) 

Refractory thermocouple failed (partial by-pass 

only) 

Switched vents from sec to pri (partial by-pass 

only) 

Liquid in vent header (partial by-pass only)

 n 

Switched vent from sec to pri (partial by-pass 

only) 

Liquid in vent header (partial by-pass only) 

Switched vents from sec to pri (partial by-pass 

only) 

High.vent flow from N2 purge caused flame failure' 

(PVC vent only) 

Liquid in vent line (PVC only) 

Liquid in vent line (PVC only) 

High level in seperator (PVC only) 

Flame sensor (PVC and VCM-A vent) 

Flame sensor (Fluctuation in vent flow and draft 

caused varying flame patterns that kept tripping 

incinerator. The flame sensors were repositioned 

to compensate. 

LBS. VCM 

EMITTED 

3.7 

0.7 

7.4 

96 

9 

9 

6 

9 

3 

9 

3 

30 

45 

40 

19 

185 

44 

-^ 

's* .% 
P.87 

LESHAP SECTION 77.11 c(l) 

EMISSION CONTROL DEVICE BY-PASS 

DURATION LESS THAN ONE HOUR 

DATE 

1-20-85 

1-20-85 

1-20-85 

1-20-85 

1-20-85 

1-20-85 

1-20-85 

1-20-85 

1-20-85 

1-20-85 

1-20-85 

1-21-85 

1-2.1-85 

1-21-85 

1-21-85 

1-21-85 

1-.21-85 

1-21-85 

1-21-85 

1-21-85 

TIME 

START 

1020 

1042 

1116 

1134 

1250 

1428 

1500 

1825 

1925 

2005 

2040 

0925 

0942 

1012 

1033 

1056 

1144 

1251 

1312 

1545 

END 

-o 1030 ,' 

•? 1047 ;. 

<=* 11257 

3^1208 ";' 

'O1300 ;•' 

f 1435 , 

•-o 1540 

7*1845 -•'. 

• S 1940 . 

i 

•£ 2020 '. 

H 2055 ', 

" 0936 7;' 

> 0948 

it 1024 '. 

'i 1051

 L 

3*1128 

2?1222 

'~>1308 

^3 1355 7 

^1600 '•/ 

2W 

CAUSE 

Flame sensor ) 

Flame sensor ) 

) Fluctuation in, vent flow and 

Flame sensor ) draft caused varying flame 

) patterns that kept tripping 

Flame sensor ) incinerator. The flame sensor 

) were repositioned to compensat 

Flame sensor ) 

Flame sensor (PVC only) 

Flame sensor (PVC only) 

Flame sensor (PVC only) 

High vent pressure (PVC only) 

High vent pressure (PVC only) 

High vent pressure (PVC only) 

Flame failure (PVC and VCM-A) 

Flame failure (PVC and VCM-A) 

Flame failure (PVC and VCM-A) 

Flame failure (PVC and VCM-A) 

Pressure controller on boiler (PVC and VCM-A)l 

Pressure controller on boiler (PVC and VCM-A) . . 

IVPressure controller on boiler (PVC and VCM-A)': 

Flame failure (PVC and VCM-A)

 / 

Flame failure (PVC and VCM-A) 

LBS. VCM 

EMITTED 

44 

22 

39 

5 149 

44 

6 

35 

18 

13 

13 

13 

39 

21 

43 

64 

114 

y 135 

60 

153 

53 

UN 

l

u 
LESHAP SECTION 77.11 c(l) 

EMISSION CONTROL DEVICE BY-PASS 

DURATION LESS THAN ONE HOUR 

DATE 

TIME 

START END CAUSE 

LBS. VCM 

EMITTED 

1-27-85 

1-27-85 

1-27-85 

1-27-85 

1-27-85 

1-27-85 

1-28-85 

1-30-85 

1-31-85 

0907 

1335 

1455 

1551 

1926 

2155 

1605 

0455 

0215 

? 0915 

f 1340 

i 1456 

I 1552 

l 1927 

I 2156 

/01615 

I 0456 

rU)227-

uQ 

Incinerator tripped while instrument personnel 

was working on the programmable computer (partial 

by-pass only PVC) 

Secondary incinerator, tripped - cause unknown 

(partial by-pass only PVC) 

Secondary incinerator tripped - cause unknown 

(partial by-pass only PVC) 

Secondary incinerator tripped - cause unknown 

(partial by-pass only PVC) 

Secondary incinerator tripped. Flame sensor 

problem - (partial by-pass only PVC) 

Secondary incinerator tripped. Flame sensor 

problem - (partial by-pass only PVC) 

Secondary incinerator tripped. Flame sensor 

problem. 

Primary incinerator tripped - cause unknown 

High vent flow (oxy vent only) 

1.1 

0.7 

0.14 

0.14 

0.14 

0.14 

60 

6 

1.8 

^ 

-?O.I b 

•Primary 

Secondary 

und secondary inci lerators down for turnaround from 1-14-85. VCR only operating. 

start-u3 1-27-85, Primary start-up 1-29-85. 
P.89 

LESHAP SECTION 77.11 c(l) 

EMISSION CONTROL DEVICE BY-PASS 

DURATION LESS THAN ONE HOUR 

DATE 

2-2-85 

2-2-85 

2-2-85 

2-2-85 

2-3-85 

2-4-85 

2-4-85 

2-4-85 

2-4-85 

2-4-85 

2-4-85 

2-4-85 

2-4-85 

2-4-85 

2-5-85 

2-5-85 

2-5-85 

2-5-85 

2-5-85 

2-11-85 

TIME 

START 

1120 

1145 

1235 

2055 

0550 

0055 

0150 

0800 

0930 

1325 

1337 

1758 

2245 

2345 

0025 

0306 

1045 

1405 

2145 

2230 

END 

1124

 v 

122 0 •• 

1237 C2130 V 

0610 

0110 

0152 •-

0802 >, 

0950 '•• 

1335 ;•• 

1355 •/ 

1803 — 

2250 -/ 

2347 •-' 

0027 

0307 >' 

1050 ,... 

1410 v 

2147 -., 

2251 -• 

CAUSE 

High vent flow (partial by-pass only) 

High vent flow (partial by-pass only) 

Switched vents from s.ec to pri (partial by-pass 

only) 

High vent flow 

High vent flow and pressure-oxy start-up 

High vent flow 

Switched vents from pri to sec to repair leak on 

vent header to pri 

Shut down pri for maintenance V.WlJ- '* ru<*»-*,~-* \ 

High vent flow 

High vent flow 

High vent flow 

Low quench water flow 

High vent flow 

Switched vents from sec to pri 

Blower seal failure 

High vent flow 

Switched vents from sec to pri 

Shutdown pri for maintenance -{*w ~/~^ 

Switched vents from sec to pri 

Low quench water flow 

LBS. VCM 

EMITTED 

. 12 

105 

6 

210 

120 

90 

12 

12 

120 

60 

108 

30 

30 

12 

12 

6 

30 

30 

12 

126 
P.90 

LESHAP SECTION 77.11 c(l) 

EMISSION CONTROL DEVICE BY-PASS 

DURATION LESS THAN ONE HOUR 

DATE 

2-11-85 

2-11-85 

2-11-85 

2-12-85 

2-12-85 

2-12-85 

2-12-85 

2-13-85 

2-14-85 

2-18-85 

2-18-85 

( 

2-23-85 

2-23-85 

2-23-85 

2-24-85 

2-24-85 

2-25-85 

2-25-85 

TIME 

START 

2256 

2328 

2350 

0230 

0245 

0615 

0635 

0045 

2015 

0015 

0030 

1015 

1135 

2135 

1105 

1420 

1335 

1431 

END 

2320 — 

2345 

0032 

0240

 /\ 

0304 { 

0630 '• 

0645 ••'. 

0100 

2030 / 

0025 ;•' 

0035 ,.' 

1016 -.' 

1145 

2220 

1115 '?( 

1421 

1430 

1440 

CAUSE 

• Unknown y-'O'*•+*-••'« sv~;-.«-«v--'_; 

Low temperature trip 

Outlet thermocouple failure 

Liquid in the vent header 

Liquid in the vent header 

Liquid in the vent header 

Liquid in the vent header 

Computer outage resulted in ratio problems in oxy 

High vent flow due to plant upset 

High vent flow 

High vent flow 

High vent flow 

Waste liquid line plugged . 

Electrical short (wiring in conduit) 

High vent flow 

Power dip 

Blown fuse on control panel on pri 

Fire on.burner unit of VCR 

LBS. VCM 

EMITTED 

144 

102 

252 

60 

114 

90 

60 

90 

90 

60 

, 30 

6 

60 

270 

60 

6 

330 

54 

r 
P.91 

LESHAP SECTION 77.11 c(l) 

EXCEEDANCE OF 10 PPM AVERAGE PER HOUR 

FOR EMISSION CONTROL DEVICE VENT 

DATE 

TIME 

START CAUSE 

12-6-84 

12-12-84 

12-20-84 

12-21-84 

12-22-84 

12-25-84 

12-26-84 

12-27-84 

1500 

0900 

10000 

1030 

1905 

1205 

1130 

2120 

0100 

1400 

1620 

1530 

VCM in scrubbing water -' no problem with incinerators. 

Liquid in the vent header 

Liquid in the vent header 

Primary incinerator tripped - broken air supply line to the fuel 

valve. 

Primary incinerator tripped - water in the vent header. 

Primary incinerator tripped - water in the vent header. 

Primary incinerator tripped - water in the vent header. 

Primary incinerator tripped - failure of fuel gas valve. 

Primary incinerator tripped - cause unknown. 

Primary incinerator tripped - heavy venting. 

Primary incinerator tripped - high level in vent knock-out pot. 

Primary incinerator tripped - high temperature. 
NJ 

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P.93 

2-15-85 

2-16-85 

0030 

0800 

0900 

1000 

1100 

1200 

1300 

1400 

1500 

1600 

1700 

1800 

1900 

2000 

2100 

2200 

2300 

0000 

0100 

0200 

0300 

0400 

0500 

0600 

0700 

0800 

1425 

1525 

LESHAP SECTION 77.11 c(l) 

EXCEEDANCE OF 10 PPM AVERAGE PER HOUR 

FOR EMISSION CONTROL DEVICE VENT 

2-

2-

_.-

2-

DATE 

-11-85 

-12-85 

-13-85 

-14-85 

TIME 

START 

2245 

2345 

0045 

0145 

0245 

0345 

0445 

. 0545 

0050 

1710 

2030 

2130 

2230 

2330 

CAUSE 

Primary incinerator tripped -

Primary incinerator tripped -

Liquid in vent header 

Liquid in vent header 

Primary incinerator tripped -

Primary incinerator tripped -

Liquid in vent header 

Liquid in vent header 

Primary incinerator tripped -

problems in oxy 

VCM contamination of absorber 

Primary incinerator tripped -

Ditto 

Ditto 

Ditto 

low quench water flow 

low temperature 

liquid in the vent header 

liquid in the vent header 

computer outage resulted in 

water 

heavy vent flow due to plant upset 

Ditto 

VCM contamination of the absorber water 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Unknown 

Unknown 
P.94 

LESHAP SECTION 77.11 c(l) 

EXCEEDANCE OF 10 PPM AVERAGE PER HOUR 

FOR EMISSION CONTROL DEVICE VENT 

DATE CAUSE 

2-17-85 

2-18-85 

2-24-85 

2-25-85 

2-28-85 

VCM contamination in absorber water 

Primary incinerator tripped - high vent flow 

High vent flow 

Ditto 

Ditto 

Ditto 

Primary incinerator tripped - power failure 

Primary incinerator tripped - blown fuse 

Ditto 

High vent flow 

VCM contamination of the absorber water 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

2-1-85 1525 

1625 

VCR VENT 

Cleared HCI export line to the VCR 1st absorber 

Ditto 
P.95 

LESHAP SECTION 77.11 c(l) 

EXCEEDANCE OF 10 PPM AVERAGE PER HOUR 

FOR EMISSION CONTROL DEVICE VENT 

DATE 

TIME 

START CAUSE 

1-3-85 

1-12-85 

1-13-85 

1-14-85 

1-15-85 

1-26-85 

.1-27-85 

2055 

1530 

1740 

0635 

0735 

1100 

1300 

1600 

0300 

0400 

0500 

0600 

0700 

0800 

0900 

1000 

1100 

1200 

1300 

1400 

1500 

1600 

1700 

1800 

2000 

2100 

2200 

2300 

2400 

0100 

1800 

1900 

2000 

0045 

0145 

0245 

0345 

0445 

0545 

0645 

Primary incinerator blower tripped 

Primary incinerator tripped - refractory thermocouple failed 

Ditto 

Clearing equipment for turnaround 

Ditto 

Primary incinerator tripped - liquid in the vent header 

Clearing equipment for turnaround 

Ditto 

VCM in the absorber water from equipment wash 

Water, clearing for turnaround 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto . 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

VCM contamination of absorber water 

Ditto 

Ditto 

VCM contamination in absorber water 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 
P.96 

1-29-85 

LESHAP SECTION 77.11 c(l) 

EXCEEDANCE OF 10 PPM AVERAGE PER HOUR 

FOR EMISSION CONTROL DEVICE VENT 

DATE 

1-27-85 

1-28-85 

TIME 

START 

0745 

0845 

0545 

1045 

1145 

1245 

1345 

1445 

1545 

1645 

1745 

1845 

1945 

2045 

2145 

2245 

2345 

0045 

0145 

CAUSE 

VCM contamination in absorber 

Ditto 

water 

VCR incinerator tripped - instrument problem 

Ditto 

Ditto 

Ditto 

Secondary 

Secondary 

Secondary 

Ditto 

Ditto 

Ditto 

Secondary 

Ditto 

Secondary 

Ditto 

Ditto 

incinerator tripped 

incinerator tripped 

incinerator tripped 

incinerator tripped 

incinerator tripped 

VCM contamination of absorber 

Ditto 

- cause unknown 

- cause unknown 

- cause unknown 

- flame sensor problem 

- flame sensor problem 

water 

0245 

0345 

0445 

0545 

0645 

0745 

0845 

0945 

1700 

2100 

2200 

0230 

0350 

0430 

0530 

0630 

0730 

0830 

0930 

1030 

1130 

1230 

1330 

1430 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Secondary incinerator tripped - flame sensor problem 

VCM contamination of the absorber water 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 
1-31-85 

LESHAP SECTION 77.11 c(l) 

EXCEEDANCE OF 10 PPM AVERAGE PER HOUR 

FOR EMISSION CONTROL DEVICE VENT 

DATE 

1-29-85 

1-30-85 

TIME 

START 

1530 

1630 

1730 

1830 

1930 

2030 

2130 

2230 

2350 

0030 

0130 

0230 

0330 

0430 

0530 

0630 

0730 ' 

1500 

CAUSE 

VCM contamination of the absorber water 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

1610 

1710 

1810 

1910 

2010 

2230 

2330 

0030 

0130 

0230 

0330 

0430 

0530 

0630 

0730 

0830 

0930 

1030 

1130 

1230 

1330 

1430 

1530 

1630 

Ditto 

Primary incinerator tripped - cause unknown 

VCM contamination of absorber water 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 

Ditto 
P.98 

LESHAP SECTION 77.11 c(l) 

EXCEEDANCE OF 10 PPM AVERAGE PER HOUR 

FOR EMISSION CONTROL DEVICE VENT 

DATE 

TIME 

START CAUSE 

1-14-85 

1-15-85 

1-17-85 

2200 

1200 

0100 

0200 

V

CR VENT 

Cleared the HCI storage tank to the VCR 1st absorber. 

Ditto 

Cleared the VCM-A HCI export line to the VCR 1st absorber 

Ditto 
P.99 

A VZy?/-7

-

BORDEN CHEMICAL 

DIVISION OF BORDEN INC [BORDEN] 

March 15, 1984 

CERTIFIED MAIL P404 221 264 

RETURN RECEIPT REQUESTED 

Mr. Gustave Von Bodungen 

Department of Natural Resources 

Office of Environmental Affairs 

Air Quality Division 

P. 0. Box 44066 

Baton Rouge, LA 70804 

Dear Sir: 

Rt £ U_ i y £ £) 

W 16 B34 

A

" " "-.r^'•.-... : , L\"/:£;''J IM 

In accordance with Louisiana Air Quality Regulations, Section 77.11, 

Borden herewith submits its quarterly report for the quarter ending 

February 29, 1984. 

1

 1 

-VSection 77.11 c(l) 

Date 

12/08/83 

vSl^^Jp-"- *J 

12/09/83 

12/10/83 

Cause of Emission 

There were 14 reportable emissions in excess of the emission 

limit. The primary incinerator tripped at 0650 due to a 

problem with a flame sensor. The sensor was cleaned and the 

incinerator was restarted in 15 minutes. It tripped again 

at 0745, ex_acj^_c_aus_e_is_unkjio\ij and was restarted in 10 

minutes. It tripped again at 1500 due to loss of quench 

water supply. The problem was corrected and it was restarted. 

There were 13 reportable emissions in excess of the emission 

limit. Investigation did not reveal any problem with the 

incinerator before 1300. The scrubbing water was found to 

contain some VCM, probably from the incinerator problems 

the previous day. Between 1300 and 1600, the primary tripped 

5 times. Each time it was immediately restarted. 

There were 19 reportable emissions in excess of the emission 

limit. The scrubbing water was found to contain some VCM. 

Also, the primary incinerator tripped several times. It 

could be re-lit but a stable operation could not be maintained. 

An instrument technician and an electrician were called out 

and found a short in the flame sensor. This was repaired. 

POST OFFICE BOX 427 • GEISMAR. LOUISIANA 70734 • TELEPHONES (504) 673-6121 (504) 387-5101 
Mr. Gustave Von Bodungen 

March 15, 1984 

Page 2 

p.1 

•1> 

*-.->'' 

Date 

12/11/83 

12/12/83 

12/13/83 

12/14/83 

12/15/83 

. 12/16/83 

12/17/83 

li 

/yC> 

12/21/83 

12/26/83 

Cause of Emission 

There were 10 reportable emissions in excess of emission 

limit. The scrubbing water contained some VCM. There was 

no problem with the incinerator. 

There were 9 reportable emissions in excess of emission limit. 

The scrubbing water contained some VCM. Also, the temperature 

on the primary incinerator had to be adjusted a couple of 

times. The secondary incinerator was started to help burn 

the vents. 

There were 3 reportable emissions in excess of emission limit. 

The problem from 12/12 continued into 12/13. As the secondary 

reached temperature, the alarms ceased. 

There were 5 reportable emissions in excess of emission limit. 

The scrubbing water contained some VCM. 

There were 10 reportable emissions in excess of emission limit. 

The scrubbing water contained some VCM. At 1450, the secondary 

incinerator tripped and the vents were switched back to the 

primary. 

There were 17 reportable emissions in excess of emission limit. 

The scrubbing water contained some VCM. The primary incinerator 

was shut down for maintenance to install a sample connection. 

About 3 hours after it was restarted, it tripped due to low 

flow of scrubbing water and was restarted in 15 minutes. 

There were 8 reportable emissions in excess of emission limit. 

The scrubbing water contained some VCM. The vents were 

switched from the primary to the secondary and the primary 

was shut down to replace a bad thermo-couple. It was restarted 

in 30 minutes. 

There were 6 reportable emissions in excess of emission limit. 

The scrubbing water contained some VCM. The vents were 

switched from the primary to the secondary for maintenance 

on the primary quench pot. 

There were 10 reportable emissions in excess of emission limit. 

The primary incinerator tripped due to an air blower electrical 

failure. The secondary incinerator and VCR were still down 

due to freezing weather. An emission control by-pass report 

was submitted on this incident. 

NOTE: The primary source of the VCM contamination of the incinerator vent 

scrubbing water occurs when the incinerator trips and the unburned vents 

are being water scrubbed. 
P.2 

- t ^ 

4.L 

Mr. Gustave Von Bodungen 

March 15, 19S4 

Page 5 

Date Cause of Emission 

12/27/83 

12/28/83 

12/29/83 

12/30/83 

01/04/84 

01/05/84 

01/06/84 

fr * 

01/07/84 

01/11/84 

i". 

< 

There were 17 reportable emissions in excess of emission 

limit. The scrubbing water contained some VCM. The primary 

incinerator tripped due to an instrument problem. 

There were 4 reportable emissions in excess of emission 

limit. The primary incinerator tripped and was restarted. 

Also, the oxy-chlorination section was shut down, resulting 

in some heavy venting. 

There were 2 reportable emissions in excess of emission 

limit. The primary incinerator tripped and was restarted. 

There were 4 reportable emissions in excess of emission 

limit. The primary incinerator was shut down for maintenance. 

The vents were switched to the secondary incinerator. 

There were 2 reportable emissions in excess of emission 

limit. The scrubbing water contained some VCM. 

There were 6 reportable emissions in excess of emission limit. 

The scrubbing water contained some VCM. 

There were 20 reportable emissions in excess of emission limit. 

The scrubbing water contained some VCM. 

There were 22 reportable emissions in excess of emission limit. 

The scrubbing water contained some VCM. 

There were 16 reportable emissions in excess of emission limit. 

The primary incinerator tripped due to a broken coupling on 

the blower. The secondary incinerator was operating but 

would not accept the total vent stream because of high back 

pressure. An emission control by-pass report was submitted. 

The by-pass resulted in the scrubbing water being contaminated 

with VCM. 

01/16/84 There were 2 reportable emission's in excess of emission limit. 

The primary incinerator was shut down for maintenance' and 

the vents were switched to the secondary incinerator. Later 

the secondary incinerator tripped and the vents were switched 

to VCR. 

NOTE: The primary source of the VCM contamination of the incinerator vent 

scrubbing water occurs when the incinerator trips and the unburned vents 

are being water scrubbed. 
P.3 

Mr. Gustave Von Bodungen 

March 15, 1984 

Page 4 

V 

Date Cause of Emission 

01/17/84 There were 4 reportable emissions in excess of the emission 

limit. The air control valve stuck causing insufficient air 

for complete incineration. 

01/18/84 

%\ 

01/25/84 

There were 4 reportable emissions in excess of the emission 

limit. The venting was heavy due to purging rail cars. 

There were 3 reportable emissions in excess of the emission 

limit. The scrubbing water contained some VCM. 

02/03/84 

—' o *i 

02/10/84 

There were 4 reportable emissions in excess of the emission 

limit. The scrubbing water contained some VCM. 

There were 4 reportable emissions in excess of the emission 

limit. The primary incinerator tripped due to a malfunction 

in the flame sensor. The flame sensor was cleaned and the 

incinerator was restarted. The temperature of the incinerator 

was increased and the air was increased and the emision was 

reduced. 

02/11/84 There was 1 reportable emission in excess of the emission limit. 

The primary incinerator tripped due to low boiler level. It 

was restarted in 10 minutes. 

02/12/84 There were 3 reportable emissions in excess of the emission 

limit. The primary incinerator tripped due to a power failure. 

The vents were switched to the secondary incinerator. 

02/15/84 There were 20 reportable emissions in excess of the emission 

limit. The scrubbing water contained some VCM. 

02/16/84 There were 2 reportable emissions in excess of the emission 

limit. The scrubbing water contained some VCM. 

® 

02/17/84 

V* 

02/27/84 

There was 1 reportable emission in excess of the emission limit. 

The scrubbing water contained some VCM. 

There was 1 reportable emission in excess of the emission limit. 

The primary incinerator tripped due to a faulty boiler level • 

controller. The incinerator was restarted in 20 minutes. 

02/28/84 There were 9 reportable emissions in excess of the emission 

limit. The scrubbing water contained some VCM. The primary 

incinerator tripped due to low quench column flow. Also the 

venting was heavy due to purging the driers. 

NOTE: The primary source of the VCM contamination of the incinerator vent 

scrubbing water occurs when the incinerator trips and the unburned vents 

are being water scrubbed. 
P.4 

/ ' 

BORDEN CHEMICAL 

DIVISION OF BORDEN INC [BORDEN 

December 14, 1983 

CERTIFIED MAIL P 404 222 075 

Return Receipt Requested 

Mr. Gustave Von Bodungen 

Department of Natural Resources 

Office of Environmental Affairs 

Air Quality Division 

P. 0. Box 44066 

Baton Rouge, La. 70804 

Dear Sir: 

^ « 

1983 

m QAy' :w.S10* 

OCH/Ij^'ti 

In accordance with Louisiana Air Quality Regulations section 77.11, 

Borden herewith submits its quarterly report for the quarter ending 

November 30, 1983. 

Section 77.11 c(l) 

There were no recorded emissions in excess of the emission limits 

for the incinerator vent scrubber during this time period. 

There were two recorded emissions in excess of the emission limits 

for the VCR incinerator vent. 

Date Cause of the Emission 

10-24-83 The HCI line to the VCM-A unit was being 

10-25-83 evacuated to the VCR incinerator. A misalignment of the valves caused the 

evacuation to by-pass the incinerator 

portion and vent from the stack. 

POST OFFICE BOX 427 • GEISMAR, LOUISIANA 70734 • TELEPHONES (504) 673-6121 (504) 387-5101 
P.5 

/iBORDEN CHEMICAL 

DIVISION OF BORDEN INC 

/I 

s ... 

October 3, 1983 

BORDEN 

RECF i/pp 

CERTIFIED MAIL P136523726 

RETURN RECEIPT REQUESTED 

Mr. Gustave Von Bodungen 

Department of Natural Resources 

Office of Environmental Affairs 

Air Quality Division 

P. 0. Box 44066 

Baton Rouge, LA 70804 

Dear Sir: 

007 05198$ 

A,R QS,4— 

In accordance with 40 CFR Part 61.70, regarding VCM emissions, Borden 

herewith submits its semi-annual report as of September 15, 1983. 

Date 

3/18/83 

3/21/83 

3/22/83 

3/31/83 

4/14/83 

4/23/83 

4/24/83 

4/25/83 

Cause of Emission 

The primary incinerator tripped due to a problem with the 

refractory thermocouple. 

Starting up the primary incinerator switched vents from the 

secondary to the primary. 

Clearing VCM reflux pump for maintenance repair. 

The primary and secondary incinerator tripped due to a power 

dip. The incinerators were down approximately twenty-five . 

(25) minutes. 

The rupture disk on the VCM-A waste liquid tank blew putting 

waste liquid into the vent line. This material was then 

purged out of the line under control conditions. The rupture 

disk discharge was removed from the vent header. 

The furnace quench accumulator was deinventoried to the wash 

system. This caused a high vent header flow to the incinerator. 

The temperature was raised on the incinerator to compensate. 

A plant emergency shut-down resulted in a high vent rate to 

the incinerator. 

The emission occurred while switching the vents from the 

primary to the secondary incinerator. 

POST OFFICE BOX 427 • GEISMAR, LOUISIANA • TELEPHONES: (504) 673-6121 (504) 387-5101 
Mr. Gustave Von Bodungen 

October 3, 1983 

Page 2 

P.6 

Date 

4/30/83 

5/4/83 

5/16/83 

5/19/83 

5/20/83 

5/21/83 

5/22/83 

5/22/83 

5/23/83 

5/23/83 

5/24/83 

5/24/83 

6/5/83 

Cause of Emission 

Both incinerators tripped out when the electric sump pump 

was shut down while switching to the turbine pump. These 

pumps supply water for the incinerator quench and vent 

scrubbers. 

Emergency venting caused high vent header pressure to the 

incinerator. 

The steam stripper was down causing a higher concentration 

of VCM in the water in the absorber pond. The VCM was then 

being stripped out of the absorber water in the incinerator 

vent scrubber. There was no problem with the incinerator. 

The primary incinerator tripped due to a flame sensor malfunction. The sensor was cleaned and the incinerator was 

restarted. The downtime was approximately thirty (30) 

minutes. 

The primary incinerator tripped due to high temperature 

caused by a high utility vent flow. The incinerator downtime 

was five (5) minutes. 

The primary incinerator tripped. The exact cause in unknown. 

The incinerator downtime was fifteen (15) minutes. 

The primary incinerator tripped. The exact cause is unknown. 

A second emission occurred on this day and an exact cause 

could not be determined. 

A power failure, caused by a pipeline crew causing a tree to 

hit a line at the Geismar substation, shut down the unit. 

The incinerator downtime was approximately one (1) hour. 

A second emission occurred on this day due to restarting the 

unit after the power failure. 

Pluggage problems occurred in the waste liquid line while 

feeding the secondary incinerator. There was no incinerator 

downtime. 

High vent header pressure caused both incinerators to trip. 

The primary incinerator tripped. The exact cause is unknown. 

The downtime was approximately forty-five (45) minutes. 

'•^ 
P.7 

Mr. Gustave Von Bodungen 

October 3, 1983 

Page 3 

Date Cause of Emission 

6/6/83 The primary incinerator tripped.. The exact cause is unknown. 

The downtime was approximately fifteen (15) minutes. 

6/10/83 The emission occurred while burning waste liquids. 

6/11/83 The primary incinerator tripped. The exact cause is unknown. 

The downtime-was approximately seven (7) minutes. 

6/11/83 The emission occurred while burning waste liquids. 

6/12/83 The secondary incinerator tripped due. to the waste liquid 

line plugging. The downtime was approximately twenty (20) 

minutes. 

6/12/83 The secondary incinerator tripped due to the Maxon valve 

sticking. 

6/12/83 The secondary incinerator tripped. The exact cause is unknown. 

6/12/83 The primary and secondary incinerators.tripped. The exact 

cause is unknown. The downtime was approximately ten (10) 

minutes. 

For the twenty-four (24) hour period from 7:00 P.M. on 6/15/83 to 7:00 P.M. on 

6/16/83, there were fourteen (14) emissions. The exact cause of this is unknown. 

Both the primary and secondary incinerators tripped several times. They were 

generally re-lit within ten (10) minutes. The temperature on the incinerators 

was increased and vents were removed one at a time to see if a particular vent 

was causing the problem. No change could be distinguished. 

6/17/83 There were five (5) emissions during the day. The primary 

incinerator tripped once and the secondary incinerator tripped 

twice. The exact cause is unknown. 

6/18/83 There were six (6) emissions on this date. The primary 

incinerator tripped once. The ex*act cause is unknown. 

6/19/83 There was only one (1) emission on this date, however, the 

primary incinerator tripped twice during this time. The exact 

cause is unknown. 

6/20/83 There were five (5) emissions due to high VCM content in the 

absorber water. The VCM was being stripped from the water in 

the vent scrubber. There was no problem with the incinerators.