1
Memorandum.
Brown,
H.
and
Norwood,
P.
EC/
R
Incorporated,
to
Rosario,
I.,
EPA/
OAQPS/
ESD/
MG.
Summary
of
the
June
3,
2003
Meeting
Between
the
EPA
and
the
Chlorine
Institute
to
Discuss
Issues
Associated
with
the
Mercury
Cell
Chlor­
Alkali
Plan
NESHAP.
June
30,
2003.

1
MEMORANDUM
Date:
August
5,
2003
Subject:
Background
Information
on
Occidental
Chemical
­
Delaware
City,
Delaware
Mercury
Emission
Estimates
From:
Phil
Norwood,
EC/
R
Incorporated
To:
Iliam
Rosario,
EPA/
OAQPS/
ESD/
MG
The
Mercury
Cell
Chlor­
Alkali
Plant
NESHAP
was
proposed
on
July
3,
2002
(
67
FR
44672).
This
proposal
contained
an
emission
limitation
for
total
mercury
emissions
from
both
the
by­
product
hydrogen
stream
and
the
end­
box
ventilation
system
vents
that
was
based
on
the
lowest
emitting
facility.
However,
since
this
lowest
emitting
facility
had
closed
at
the
time
of
proposal
and
since
the
technology
used
at
that
facility
was
no
longer
commercially
available,
the
EPA
requested
comment
on
the
proposed
limit
and
indicated
that
if
this
lowest
emitting
facility
was
not
used
as
the
basis,
the
final
rule
would
be
based
on
the
next
lowest
emitting
facility
(
Occidental
Chemical
in
Delaware
City,
Delaware).

Commenters
objected
to
establishing
the
limit
based
on
the
closed
plant,
but
also
expressed
concerns
about
the
ability
to
continuously
meet
a
limit
based
on
the
Occidental­
Delaware
City
reported
emissions.
This
concern
was
also
raised
in
a
June
3,
2003
conference
call
between
the
industry
and
the
EPA.
1
This
limit
was
0.076
grams
mercury
emitted
per
Megagram
of
chlorine
produced.

In
response
to
these
concerns,
I
contacted
Richard
Timmons
of
Occidental­
Delaware
City
facility
to
confirm
the
basis
for
the
original
emission
estimates
and
to
discuss
whether
this
facility
could
achieve
compliance
with
this
limit
on
a
longer
term
basis.
Telephone
conversations
were
held
with
Mr.
Timmons
on
May
22
and
June
11,
2003.
Following
is
a
summary
of
the
relevant
aspects
of
these
conversations.
2
"
Hazardous
Air
Pollutant
Emissions
from
Mercury
Cell
Chlor­
Alkali
Plants
­
Background
Information
for
Proposed
Standards.
EPA­
453/
R­
02­
007.
U.
S.
Environmental
Protection
Agency,
Research
Triangle
Park,
NC.
February
2002.
Page
7­
13.

2
At
the
Occidental­
Delaware
City
facility,
they
take
samples
from
the
by­
product
stream
and
end­
box
ventilation
system
vents
weekly.
Actually,
there
are
multiple
carbon
adsorbers
that
control
the
mercury
emissions
and
they
take
samples
from
all
of
them.
The
test
method
is
a
nonisokinetic
method
that
is
based
on
EPA
Reference
Methods
101A
and
102.

The
annual
1998
mercury
emissions
that
formed
the
basis
for
the
0.076
g/
Mg
limit
were
calculated
by
taking
the
average
concentration
measurements
from
all
tests
conducted
during
the
year
and
multiplying
it
by
the
flow
rate.
For
the
hydrogen
stream,
there
were
weekly
concentration
measurements
made
and
the
flow
rate
used
was
the
annual
production
of
hydrogen
(
which
is
measured
as
a
volume).
They
only
did
monthly
tests
on
the
end­
box
ventilation
system
in
1998,
and
the
annual
calculation
was
based
on
the
average
of
these
values.
The
flow
rate
used
was
based
on
fan
performance
values.
The
annual
mercury
emissions,
which
were
adjusted
maximum
production
capacity,
were
1.2
lbs/
year
from
the
by­
product
hydrogen
and
21
lbs/
year
from
the
end­
box
ventilation
system.
Since
the
emissions
were
adjusted
for
maximum
production,
the
annual
emissions
were
divided
by
the
chlorine
production
capacity
to
obtain
the
0.076
ratio
(
This
is
the
same
as
dividing
actual
emissions
by
actual
chlorine
production,
which
is
what
is
required
by
the
rule).

In
a
follow­
up
email
(
see
Attachment),
Mr.
Timmons
provided
the
test
methods
and
more
information
on
future
years.
The
EPA's
Emission
Standards
Division
had
already
determined
that
the
non­
isokinetic
methods
like
those
used
by
Oxychem
provided
results
appropriate
to
be
used
in
establishing
MACT.
2
Mr.
Timmons
reported
that
the
2001
mercury
emission
rate
was
0.0455
g/
ton
(
0.05
g/
Mg)
and
in
2002
it
was
0.0369
grams/
ton
(
0.041
g/
Mg).
Both
years
the
plant
would
have
been
in
compliance
with
the
standard.
ATTACHMENT:
EMAIL
FROM
DICK
TIMMONS,
OCCIDENTAL
CHEMICAL
Date:
Mon,
16
Jun
2003
14:
28:
27
­
0400
To:
norwood.
phil@
ecrweb.
com
From:
<
Richard_
L._
Timmons@
oxy.
com>
Subject:
FW:
EPA
Data
Request
Phil,
outlined
below
is
the
data
you
requested.
The
non­
iso
kinetic
methods
are
also
attached,
per
your
request.

Submitted
data
1998:
(
note
numbers
adjusted
to
146,000
s­
tons/
yr
cl2
production,
or
plant
capacity
as
we
discussed)
H2
Emissions
1.2
lbs/
year
(
based
on
1/
week
lab
numbers,
average
the
results,
times
annual
production)
Endbox
vent
21
lbs/
year
(
based
on
quarterly
samples,
fan
performance
flow
number)
Total
Hg
emissions
0.0690
grams/
s­
ton
cl2
2001
data
H2
emissions
0.4041
lbs/
year
(
based
on
1/
week
lab
numbers,
average
the
results,
times
annual
production)
Endbox
vent
10.07
lbs/
year
(
based
on
1/
week
lab
numbers,
average
the
results,
times
fan
performance
flow
number)
Total
Hg
emissions
0.0455
grams/
s­
ton
2002
data
H2
emissions
0.3478
lbs/
year
(
based
on
1/
week
lab
numbers,
average
the
results,
times
annual
production)
Endbox
vent
9.15
lbs/
year
(
based
on
1/
week
lab
numbers,
average
the
results,
times
fan
performance
flow
number)
Total
hg
emissions
0.0369
grams/
s­
ton
As
we
discussed,
production
volumes
are
significantly
different
versus
the
base
year
reported
to
EPA.
Production
data:
1997
volume
93
%
plant
capacity
2001
71.5
%
plant
capacity
2002
80
%
plant
capacity
Please
forward
any
comments.
Dick
Timmons
302­
834­
3942
