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 

memorandum1. 

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 thermal oxidizer (C301A). The test results are provided as Attachment A to this memorandum. OxyVinyls 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 memorandum2), 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 to mass. 

Details of those calculations are provided below. 

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

for the inlet stream to the thermal oxidizer as reported in response to the required testing 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

60 min MW V

385.3ft

lb1 mol

0.028 m

ft1

20.9 3

20.9 O

10

1

C

hr

lb

3 3 i

3

2

i 6

6 M V

3

1

3 0

2 O

1

C &

 (Eq. 1)

where: 

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

Ci = pollutant concentration in ppmvd at 3 percent oxygen, 

 O2 = average oxygen concentration of all pollutant three run tests, 

 385.3 ft3 = volume, in cubic feet, of 1 pound mole of ideal gas at 20 °C 

(68 °F) and 1 atmosphere of pressure, 

MWi = 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) Analysis for Area Sources in the 

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

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

Agency. February 2012. 

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

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

from Eastern Research Group, Inc. To Jodi Howard, U.S. Environmental 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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