P.1 

OAR Box 1107 

Prepped by Ollie Stewart 

Document Number: 

24) VI-B-3 

Docket Number: 

A-81-21 

Printed 4/11/2008 3:03:45 PM Sheet 24 of 90 
P.2 

BFGoodrich 

The BFGoodrich Company 

Geon Vinyl Division 

6100 Oak Tree Boulevard 

Cleveland, Ohio 44131 

216-447-6000 APR 1 ?.« 

EPA AIR DOCKET, 

/?-•?/-<*/ 

1/1-8-1 

March 6. 1987 

Certified Mail No. P 338 741 020 

Ms. Karen K. Fidler 

Radian Corporation 

Progress Center 

3200 E. Chapel Hill Road 

Nelson Highway 

P.O. Box 13000 

Research Triangle Park. NC 

Dear Karen: 

27709 

Enclosed is our written response to your letter dated February 

24. 1987. The enclosure contains the written confirmation of 

our March 5. 1987 telephone conversations. The response is 

organized to respond to the questions contained in Attachment 1 

of your letter. 

If you have any further questions concerning our response, 

please call me at (216) 447-7979. 

Sincerely. 

THE BFGOODRICH COMPANY 

Geon Vinyl Division 

James W. Lewis. P.E. 

Manager. Safety. Health 

and Environment 

JWL/kp 

0385j 

Enclosure 

cc: W. C. Holbrook 
P.3 

ATTACHMENT 1 

REQUESTED INFORMATION 

Vinvl Chloride Emission Estimates 

For estimates based on physical measurements: 

1. What compound(s) was measured (i.e. vinyl chloride, 

total hydrocarbons, etc.)? 

Answer - vinyl chloride. 

2. What method of sampling and analysis was used (i.e. 

portable hydrocarbon analyzer, bag sample with GC 

analysis, etc.)? 

Answer - Method 107 for wastewater contained in the 

NESHAP VCM standard was used to determine the VCM 

concentration in the water layer above the stored 

liquid in the two open top tanks. 

3. Where were measurements taken (i.e.. vapor space, 

stored liquid)? 

Answer - The water layer above the stored liquid in 

the two open top tanks was sampled, taken to the 

laboratory and analyzed. 

4. How were VC emissions calculated from measurements? 

Answer - The average molecular weight of the vapors 

over the water layer and the true vapor pressure was 

calculated using the concentration of VC in water and 

the ideal gas laws. These values were then 

incorporated with the other operational data to 

calculate emissions utilizing the equations for 

storage tank emissions in AP-42. 

For estimates not based on physical measurements (if any): 

1. What assumptions were made in estimating vinyl 

chloride emissions? 

Answer - For the four fixed roof tanks, we assumed 

the water layer over the stored liquid was saturated 

with VC. 
P.4 

- 2 

For the two floating roof tanks and the Catoxid feed 

tank, we assumed the composition of the individual 

liquid streams was the same as the liquid from the 

preceding pieces of process equipment. An average 

molecular weight was then calculated for the combined 

liquid stored in the tanks. 

Replacement of Six Tanks 

For each of the existing tanks that would need to be replaced: 

1. What is the tank pressure and vacuum rating? Over 

what range of pressures are the tanks currently 

operated? 

..' _ 'r • 

Answer - The six tanks are rated at 2.5 inch W.G. and 

no vacuum. They are presently operated at ambient 

conditions, essentially zero pressure. 

2. Is the tank equipped with a conservation vent? If 

so. what are the pressure settings? 

Answer - The tanks are not equipped with conservation 

vents. 

Provide a very brief description of the vapor recovery system 

that would be installed including the following information: 

1. Would the tanks be vented to a single manifold header 

going to the incinerator? Or would each tank be 

vented separately to the incinerator? 

Answer - The tanks would vent to the incinerator via 

a single manifold header. 

2. At what pressure settings would the vapor recovery 

system be activated? 

Answer - Appropriately located two stage blower(s) 

will be used to move the vapors from the tanks to the 

incinerator. The first stage is activated at 2 

inches W.G. and the second stage at 4 inches W.G. 

3. What would be the pressure and vacuum rating of the 

new tanks? 

Answer - The new tanks are designed for 6.5 inches 

W.G. pressure and 1 ounce per square inch vacuum. 

0385j/kp 

3/9/87