From: Thomas Andersen [mailto:tandersen@shin-tech.com]  
Sent: Tuesday, May 06, 2014 6:08 PM 
To: Howard, Jodi 
Subject: Methane Concerns Regarding PVC Stack Testing and 2010 Plaquemine THC data.

Jodi,


Here is the second e-mail that  has the Shintech  Plaquemine THC data and the diagrams I spoke 
about.  Below is a written  explanation of the diagrams.  Tim and I would like to discuss further once 
you and Jason have had a chance to review the data.

Thanks Jodi!  Have a nice evening.


Thomas S. Andersen
Environmental Manager
Shintech, Inc.
5618 East Hwy 332
Freeport, TX 77541
979 233 7861 ext 398
979 236 5641 (c)
 


From: Tim Gilder  
Sent: Monday, May 05, 2014 2:03 PM 
To: Thomas Andersen 
Cc: David Wise; aeguchi@shin-tech.com 
Subject: RE: Methane Concerns Regarding PVC Stack Testing

Tom,
Per our conversation before lunch,
Here is two sets of drawings for our discussion. Both are identical, but one set has some Color to 
better distinguish between liquids and gasses, as well as temperatures (ranges). This will be important 
to better understand the Heat Duty of the SCR Heater. 

In both sets, a simplified PVC-Only Vent Gas incinerator, Typical VCM/PVC Vent Gas incinerator, and 
the Shintech GTO’s are represented. 

In the course of destroying the process vents, our Destruction Furnace allows for a residence time of 
more than 2-seconds at greater than 1650F. While at this temperature, or even after some heat 
recovery, it is impractical to reduce any NOx until the chlorides have first been removed. It is in the 
process of removing the chlorides that the temperatures decline and require heating for NOx control. 
The duration the fuel gas (natural gas) is at flame temperature would be measured in nano-seconds 
and the bulk vapor temperature is well below the methane destruction temperature. It was only 
designed only to heat the flue gas, not destroy methane; hence, uncombusted methane can escape 
the flame tips in the heater duct. 

I hope the EPA can see how either sampling upstream of the SCR for balanced compliance, or allowing 
methane to be removed from the analysis is a more balanced and prudent compliance metric.

Tim H. Gilder
VCM Production Manager
Shintech Louisiana, LLC
tgilder@shin-tech.com
(225) 687 - 2105 (x5619)



From: Howard, Jodi [mailto:Howard.Jodi@epa.gov]  
Sent: Monday, May 05, 2014 8:07 AM 
To: Thomas Andersen 
Subject: Methane Concerns Regarding PVC Stack Testing

Tom,

Could you tell the specific concern that you have regarding the THC testing as it relates to methane?

Thanks.


Jodi L. Howard
US EPA
OAR/OAQPS/SPPD/RCG
E143-01
Research Triangle Park, NC 27711
(919) 541-4607

