December 2018
MEMORANDUM
TO:		Docket ID: EPA-HQ-OAR-2018-0417
FROM:	Nathan Topham, Environmental Engineer, U.S. EPA
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SUBJECT:	Industry Characterization for the Hydrochloric Acid Production NESHAP Residual Risk and Technology Review Proposal
	This memo describes the hydrochloric acid production source category. The following sections cover the manufacturing process, emission points, and uses of the end product. 
       
1. Hydrochloric Acid Production Industry

1.1 Product and Manufacturing Overview 
	
	Hydrochloric acid is produced largely as an intermediate chemical used in the manufacturing of other chemicals. A gaseous stream enters an absorption tower in which the HCl is absorbed into water or dilute HCl to produce concentrated HCl. Concentrated aqueous HCl is then used on-site for other processes or transported off-site. 

1.2 Characterization of the Hydrochloric Acid Production Industry

   The hydrochloric acid production source category includes 19 facilities, a decline since the 2003 final rule was promulgated. At that time, there were over sixty facilities in the source category. The EPA collected facility and emissions data for this rulemaking from EPA databases such as the 2014 National Emissions Inventory (NEI), Enforcement and Compliance History Online (ECHO), and state title V permit databases. 
   
Table 1: HCl Production Facility List
Facility Name
FRS ID
Address
Arkema Inc.
110000380061
4444 Industrial Pkwy, Calvert City, KY 42029
BASF Corp.
110043972207
2525 S. Kensington Rd., Kankakee, IL 60901
BASF Corp.  -  Geismar Site
110000597364
8404 River Rd. (Highway 75), Geismar, LA 70734
BASF Corporation
110000605051
1379 Ciba Road, Mcintosh, AL, 36553
Cabot Corp
110040961965
700 E. US Highway 36, Tuscola, IL, 61953
Dow Chemical Company
110000602544
901 Loveridge Road, Pittsburg, CA, 94565
Dow Texas Operations Freeport
110008170237
2301 N. Brazosport Blvd., Clute, TX 77541
Blue Cube Operations (Olin)
110001244724
21255 Hwy 1, Plaquemine, LA 70765
The Dow Chemical Company U.S.A., Midland
110027360629
1790 Building, Midland, MI 48674
Dupont Washington Works
110000586081
Route 892, Washington, WV 26181
E.I. du Pont de Nemours & Co.
110040920242
4200 Camp Ground Rd., Louisville, KY 40216
Evonik Corporation
110017408296
4201 Evonik Road, Theodore, AL 36582
Hexion Inc.  -  Norco Facility
110013662009
16122 River Rd. Lot 3, Norco, LA 70079
Honeywell International Inc.  -  Baton Rouge Plant
110003266849
Lupine & Ontario, Baton Rouge, LA 70821
Honeywell International Inc.  -  Geismar Plant
110012818745
5525 Hwy 3115, Geismar, LA 70734
Momentive Performance Materials
110000324435
260 Hudson River Rd., Waterford, NY 12188
Polymer Additives Inc.
110000582003
US Rt 130 South, Bridgeport, NJ 08014
PPG  -  South Plant
110041418338
PPG Industries, Inc., Barberton, OH 44203
Rubicon LLC  -  Geismar Plant
110000597373
9156 Hwy 75, Geismar, LA 70734


2.0 Hydrochloric Acid Production Manufacturing Process

2.1 Overview of Process

	The HCl production process involves the absorption of gaseous HCl into water or aqueous HCl, associated material transfer and loading operations, HCl storage tanks, and other equipment to move the HCl between these points in the process. The process covered by the HCl production NESHAP begins at the point that gaseous HCl enters and absorber and ends at the point where the liquid HCl product produced in the HCl production unit is loaded into a tank truck, rail car, ship, or barge, at the point the HCl product enters another process on the plant site, or at the point the HCl product leaves the plant site via pipeline. 

2.2 Process Description: This section describes each of the principle processing steps in the hydrochloric acid production process: HCl absorption and HCl storage and transfer operations. 

2.2.1 HCl Absorber. The source category begins at the point that a gaseous HCl stream enters an absorber. There are numerous types of processes that produce a gaseous stream containing HCl that is the starting point for an HCl facility (including fume silica production). However, the NESHAP is blind to the type of process that generates the HCl, as the HCl production facility begins at the point where the stream containing HCl enters the absorber. The gaseous HCl stream enters the absorption tower and is absorbed into water or aqueous HCl. The gaseous stream leaving the absorption column contains HCl that was not absorbed into the liquid in the tower and any Cl2 present in the inlet stream. This outlet stream may be routed (or recycled) to another process, in which case it is no longer part of the HCl production affected source. However, if the outlet stream is directly discharged to the atmosphere or if it is routed through other recovery/control devices before being discharged to the atmosphere, it is considered an HCl process vent from an HCl production facility.  

2.2.2 HCl Storage, Transfer, and Loading. If the liquid HCl leaving the absorption tower is routed to an HCl storage tank, there is the potential for HCl emissions from the tank. There is also the potential for emissions when HCl is loaded from a storage tank to a tank truck, rail car, ship, or barge. Plants often reduce HCl emissions from HCl storage tanks and HCl transfer operations by using a scrubber.

3.0 REFERENCES

 EPA's Enforcement and Compliance History Online (ECHO) database. Accessed at: 
https://echo.epa.gov/
 Various state environmental air agency websites for Title V permit.
 EPA's Multisystem Search System. Accessed at: https://www3.epa.gov/enviro/facts/multisystem.html
 Original NESHAP Support Documents, available at regulations.gov, docket ID: EPA-HQ-OAR-2002-0057.


