## 1

MEMORANDUM

TO: Jodi Howard, US EPA/OAQPS/SPPD/RCG

FROM: Eastern Research Group, Inc.

DATE: January 11, 2012

SUBJECT: Potential to Emit Calculations for OxyVinyls

– Deer Park, TX

Permitted emission rates for the OxyVinyls

– Deer Park facility can be found in TX State

Air Permit, 4673B, issued July 13, 2009, which is included as an attachment to a separate

memorandum 1



## .

In response to the August 21, 2009 section 114 request, OxyVinyls

– Deer Park provided

test results for the flow and HAP concentrations to the inlet of their LaPorte t hermal oxidizer (C301A). The test results are provided as Attachment A to this memorandum. OxyViny ls indicated

that the oxidizer only controlled process vent streams for the polyvinyl chloride (PVC) process unit during testing.

Although the results of outlet testing in response to the August 21, 2009 section 114 have

been excluded from the Maximum Achievable Control Technology (MACT) floor analysis for

PVC production facilities (as described in a separate memorandum 2 

## ), the reported inlet data were

used to determine the facility’s potential to emit (PTE) prior to control. The inlet stream to the

LaPorte thermal oxidizer was not diluted by abnormally high volumes of natural gas . To

determine the mass of vinyl chloride (VC) in the stream that was sent from the PVC process unit

at the Deer Park facility to the LaPorte thermal oxidizer, the reported stream characteristics

(volumetric flow rate, temperature, etc.) were used to convert the VC concentration t o mass. Details of those calculations are provided below.

Table 1 is a summary of the vinyl chloride (VC) concentration and stream character istics

for the inlet stream to the thermal oxidizer as reported in response to the required test ing under

EPA’s August 21, 2009 section 114 request

.

Table 1. Summary of OxyVinyls

– Deer Park Thermal Oxidizer Inlet Data

– Vinyl

Chloride

Run Vinyl Chloride

Concentration (ppmvd) Inlet Oxygen

Concentration (%) Inlet Flow Rate

(DSCMM)

1 489,780 9.25 0.600

2 489,780 9.25 0.600

3 489,780 9.25 0.600

Average 489,780 9.25 0.600

## 2 ppmvd

– parts per million on a dry volume basis, corrected to 3 percent oxygen

% - percent

DSCMM

–

Dry standard cubic meters per minute

Equation 1 was used to calculate the PTE in pounds per hour for VC for the OxyVinyls

– Deer Park facility.



# hr min 60 V MW

385.3ft mol lb1

m 0.028 ft1

3 20.9 O 20.9

10 1 C

hr lb

i 3 3 3

2

6 i 

# 6 V M

3 1

0 3 O 2

1 C & (Eq. 1)

where:

lb/hr = mass flow rate in pounds per hour,

C i 

## = pollutant concentration in ppmvd at 3 percent oxygen,

O 2 

## = average oxygen concentration of all pollutant three run tests,

385.3 ft 3 

## = volume, in cubic feet, of 1 pound mole of ideal gas at 20 ° C

(68 ° F) and 1 atmosphere of pressure,

MW i 

## = molecular weight of the pollutant in pounds per pound mole (62.5 for

VC), and



# V & = volumetric flow rate of the exhaust gas in dry standard cubic meters per

minute.

Assuming an operating time of 8,400 hours per year, the calculated PTE prior to control

for the OxyVinyls

–

Deer Park facility is 279 tons per year of VC.

## 3

References

1. “Generally Available Control Technology (GACT) Analysi s for Area Sources in the

Polyvinyl Chloride and Copolymers (PVC) Production Source Category.” Memorandum

from Eastern Research Group, Inc. To Jodi Howard, U.S. E nvironmental Protection

Agency. February 2012.

2. “Revised Maximum Achievable Control Technology (MACT) Flo or Analysis for the

Polyvinyl chloride and Copolymers (PVC) Production Source C ategory.” Memorandum

from Eastern Research Group, Inc. To Jodi Howard, U.S. E nvironmental Protection

Agency. February 2012.

## Attachments

Attachment A: OxyVinyls

– Deer Park Inlet Testing Data Response to the August 21, 2009

Section 114

4

## Attachment A

OxyVinyls

–

Deer Park Inlet Testing Data Response to the August 21, 2009 Section 114

5******	


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