ENVIRONMENTAL PROTECTION AGENCY OFFICE OF ENFORCEMENT EPA 330/2-76-010 REPORT ON State Implementation Plan Air Pollution Inspection Witco Chemical-Witfield Division LOS ANGELES COUNTY, CALIFORNIA NATIONAL ENFORCEMENT INVESTIGATIONS CENTER DENVER, COLORADO AND REGION IX, SAN FRANCISCO, CALIFORNIA £ 2 \ FEBRUARY 1976 ------- ENVIRONMENTAL PROTECTION AGENCY Office of Enforcement STATE IMPLEMENTATION PLAN INSPECTION OF W1TCO CHEMICAL CORPORATION Witfield Division P.O. Box 1243 - 2100 East 223rd Street Carson, California 90744 213/830-4353 November 5, 1975 February 1976 NATIONAL ENFORCEMENT INVESTIGATIONS CENTER - Denver, Colorado and Region IX - Son Francisco, California ------- CONTENTS Introduction 1 Process Description 2 Potential Sources of Air Pollution Emissions and Related Control Equipment ... 8 Emissions Data 11 Summary of Violations 12 Inspection Summary 13 Appendix A LAAPCD Rules B Pressure Relief Valve Maintenance Schedule C Storage Tank Listing ------- INTRODUCTION Background The Witfield Division of Witco Chemical Corporation (Witco) op- erates an organic chemicals synthesis plant at this location. Products from these operations include linear alkylbenzene (Dodane-S alkylate), "hard" alkylbenzene (Dodane-H alkylate), a high boiling point detergent bottoms product which is used for lube oil additives (Synthogene), sodium isethionate, and muriatic acid (31% hydrochloric acid solution). Witco employs about 29 people and operates three 8-hour shifts per day, seven days a week, year around. On November 5, 1975, a process inspection was conducted at this facility be NEIC personnel. The inspection was preceded by a letter to the Company on September 8, 1975, announcing NEIC's intention to inspect the facility and requesting substantial amounts of process information. Subsequent to the inspection, Witco personnel transmitted the requested information via mail. During the inspection, an examination was made of the manufacturing equipment, potential air pollution sources, and air pollution control equipment. The purpose of this inspection was to evaluate the degree of compliance of this facility with the requirements of the Federally ap- proved State Implementation Plan as required by Section 110 of the Clean Air Act, as amended. Company personnel were very cooperative throughout this inspection. They supplied all EPA requested information during the inspection in- terview or by subsequent letter. ------- Inspection Participants Mr. John Corinth-Ass1t. General Manager, Witfield Chemical Div., Witco Mr. Edmond Art Powell-Los Angeles County Air Pollution Control District (LAAPCD) Mr. David L. Brooman-USEPA, NEIC Applicable Regulations The following rules contained in the Rules and Regulations of the Los Angeles County Air Pollution Control District (LAAPCD) [detailed in Appendix A] are applicable to this facility: Rule 50. Ringelmann Chart Rule 51. Nuisance Rule 59. Effluent Oil/Water Separators Rule 62. Sulfur Content of Fuels Rule 66c. Organic Solvents Rule 68. Fuel Burning Equipment - Combustion Contaminants Rule 69. Vacuum Producing devices or Systems Rule 71. Carbon Monoxide Rule 72. Pumps and Compressors Rule 73. Safety Pressure Relief Valves PROCESS DESCRIPTION There are three distinct manufacturing processes at this facility: 1) the Dodane-S process, 2) the Dodane-H process, and 3) the sodium isethionate process. Muriatic acid and Synthogene the other two pro- ducts, are byproducts from these processes. Dodane-S Process Figure 1 is a simplified process flow diagram for the Dodane-S process. A brief description of the process follows. ------- Patdf firt d ¦t d u B 3 E Mould u O Ol C N Chlorine U U. •H C. u > u Complex Settler To waste HC1 to Muriatic AcilT Recycle Benzene bo urier Plant Complex Storage To Misc H>drocarbon Storcce Cnlorination Reactor HC1 to Muriatic Acid Plant In-line Mixer Recycle Paraffin to Drier Off-test Product Powdered Slurry Hix Tank Aluninun Detergent Alkylate To Storage & Spert Acid to Tankage Synthogene to Storage FIGURE 1. SIMPLIFIED DODANE-S PROCESS FLOW DIAGRAM - WITCO CHEMICAL CORPORATION, CARSON, CALIFORNIA CO ------- 4 Paraffin is received from the nearby Texaco refinery by tank t~uck. After the paraffin is dried, it is purified in a carbon tower and filter system before being introduced into the chlorine reactor. Liquid chlorine, received by tank truck, is vaporized before being mixed with the paraffin. These two materials are mixed together with an in-line mixer and introduced into the chlorine reactor tubes. In the chlorine reactor, the mixture of paraffin and chlorine passes through quartz glass tubes while being exposed to ultraviolet light. The resulting product is passed through coolers and into a flash drum. Here unreacted chlorine is flashed off to the muriatic acid plant described later. The bottoms from the flash drum are routed to a benzene absorber unit where they are mixed with benzene from the alkylation reactor which follows in the process. Excess chlorine is again vented from this unit to the muriatic acid plant. The bottoms from the benzene absorber unit are preheated and introduced into the alkylation reactor. Benzene, received by pipeline from the nearby ARCO refinery, is dried and introduced directly into the alkylation reactor. A portion of the dried benzene is mixed with powdered aluminum in a slurry mix tank; the resultant slurry is also introduced into the alkylation reactor. Off-test product is dried and also reintroduced into the alkylation reactor. The reaction products from the alkylation reactor are routed to a "complex" settling unit. Overheads from this unit are neutralized with ammonia, then water-washed, and passed through a salt tower and filters before entering a benzene stripper unit. Benzene stripped from the product stream is recycled to the process. Bottoms front the stripper column constitute the product stream which is ready for purification. ------- 5 The product stream is introduced into the paraffin recycle frac- tionation column. Overhead vapors from this column contain paraffins which are recycled back to the paraffin drier and reintroduced into the process. The bottoms from this column consist of "heart" alkylate. The "heart" alkylate is introduced into the "heart" akylate frac- tionation column. Overhead vapors from this column are collected, mixed with sulfuric acid in an in-line mixer unit, separated from the spent sulfuric acid in a recipitator unit, and filtered through clay drum filters before being sent to storage as detergent alkylate. Bottoms from the "heart" alkylate fractionator consist of Synthogene which is sent to product storage. The Dodane-S plant can produce 18.2 x 10^ kg (40 x 10^ lb)/yr of 3 linear alkylbenzene. It has a nominal capacity of b7 m (420 bbl )/day of this material. It also produces approximately 1'! m (70 bbl )/day of Synthogene. Dodane-H Process Figure 2 is a simplified process flow diagram for the Dodane-H pro- cess. A brief description of the process follows. Benzene is dried and contacted with hydrochloric acid before being introduced into the reactor unit. A portion of the dried benzene is mixed with aluminum chloride and the resulting slurry is introduced into the reactor unit. Olefin materials and off-test product are dried and also introduced into the reactor unit. Products from the reactor are routed to a "complex" settler. Overheads from the settler are neutralized with ammonia, water-washed, and passed through a salt tower before being introduced into the benzene stripper tower. ------- HC1 to Muriatic Olefin Acid Plant Complex Settler Off-test Product To Waste Complex Storage To Hydrolysis Drum Benzene-HCl Contactor Slurry Lt. Alkylate to Storage Tank Hard Alkylate to Treater Aluminum Chloride FIGURE Hvy. Alkylate SIMPLIFIED DODANE-H PROCESS FLOW DIAGRAM WITCO CHEMICAL CORPORATION, CARSON, CALIFORNIA to Storage ------- 7 Overhead vapors from the benzene stripper column consist of benzene, which is recycled to the benzene drier and reintroduced into the process. Bottoms from the benzene stripper are used as feed stock to the light alkylate fractionation column. Overhead vapors from the light alkylate fractionation column consist of light alkylate which is collected and piped to storage. Bottoms from this column consist of heavy alkylate, a portion of which is routed to storage. The remainder is used as feed stock for the hard alkylate fractionation column. Overhead vapors from the hard alkylate fractionation column consist of hard alkylate which is collected and piped to storage. The bottoms from this column are heavy alkylate which is also sent to storage. 6 6 The Dodane-H plant can produce approximately 6.8 x 10 kg (15 x 10 lb)/yr of hard alkylate. It has a rated capacity of 38 m3 (240 bbl)/day. Witco has only operated this plant for 6 weeks since it was completed in early 1975. The market demand for hard alkylate has dropped severely. Witco has no plans to operate this unit in the near future. Sodium Isethionate Process Deionized water, 50% strength sodium hydroxide (NaOH), ethylene oxide (CH2CH20), and sulfur dioxide are mixed together in a reactor. Sodium isethionate (NaSO-jC^Ch^OH) is produced by the following reactions. so2 + h2o + h2so3 H2S03 + 2 NaOH -* Na2S03 + 2 H20 Na2S03 + H2S03 -v 2 NaHS03 NaHS03 + CH2 CH20 -> Na S03 CH2 CH2 OH The sodium isethionate is filtered, stored, and ultimately shipped for sale via tank truck. ------- 8 Witco has a nominal sodium isethionate production capacity of 46 to 57 tn^ (12,000 to 15,000 gal)/week. Muriatic Acid Production Off-gases from the chlorinator reactor flash drum and the benzene absorber, both part of the Dodane-S system, contain considerable quan- tities of chlorine and/or hydrogen chloride gas. These off-gases are collected and scrubbed with water in a Karbate absorption tower. The resulting hydrochloric acid is collected, skimmed of trace hydrocarbons, passed through filters and sent to muriatic acid storage tanks. Witco has a muriatic acid production capacity of 68 m (18,000 gal)/day of 31% acid. POTENTIAL SOURCES OF AIR POLLUTION EMISSIONS AND RELATED CONTROL EQUIPMENT One process heater, product storage tanks, product loading racks, vent gases from the processes, and unit pressure relief valves constitute the main potential emission sources at this facility. Process Heater There is one process heater at this facility wii:h a rated capacity of 0.5 x 10^ kg cal (2 x 10^ Btu)/hr. The heater is fired with 8,900 3 3 kg cal/m (1,000 Btu/ft ) natural gas for approximately 99% of the time. The remainder of the time it is fueled with No. 2 diesel fuel. The heater exhausts through a 24 m (80 ft) high stack 26 cm (10.4 in) in diameter. The stack has no emission control devices nor is it equipped with any stack gas opacity detectors. ------- 9 Incinerators There are no incinerators at this facility per se. The process heater described above does receive some blowdown from the benzene stripper unit and gases from an overhead vent on the effluent surge drum at the Dodane-S plant. Blowdown Systems All of the major process units have pressure relief valves. The majority of these relief valves vent directly to the atmosphere. Sev- eral of the units vent to piping which connects to surge drums in the process. There are no flare units utilized at this facility. Witco has a pressure relief valve maintenance schedule which com- plies with the requirements of LAAPCD Rule 73. A copy of the pressure relief valve schedule for this facility is attached in Appendix B. Storage Tanks 3 There are 46 tanks at this facility ranging in size from 32 to 400 (200 to 2500 bbl). These tanks all have fixed roofs and the majority are vented directly to the atmosphere. All tanks which contain benzene or have a chance of containing benzene have pressure/vacuum relief valves set at + 1.3 cm (+ 1/2 in) water. The tanks which store muriatic acid are connected via a common piping manifold to a water fume scrubber. A listing of the tanks at this facility, the materials stored within them, and their configuration is presented iri Appendix C. ------- 10 Wastewater Treatment r> Witco's total wastewater flow amounts to approximately 160 nr (42,000 gal)/day. Sources contributory to this wastewater flow are the neutralization drum drainage at 14 m (3,800 gal)/day, "complex" wash- 3 water at 95 m (25,000 gal)/day, and miscellaneous sources such as plant and tank drains, condensate, wash racks, and firehoses at 48 m (13,000 gal)/day. All wastewater is routed by plant sewers to a sump. From here it is pumped to a closed tank where the phases are allowed to separate. The hydrocarbon phase is routinely drawn off and pumped to the off-test product tank where it is stored until it is reprocessed. The water phase from the wastewater tank flows by sewer to sand and grease traps. After passing through these traps, the wastewater is pH adjusted by automatic acid addition and ultimately discharged to the Los Angeles County Sanitation District sewer system. The hydrocarbon/water phase separation tank is a closed tank with a pressure/vacuum relief valve set at + 1.3 cm (+ 1/2 in) water. Vacuum Jets Both the Dodane-S and Dodane-H processes utilize vacuum jets on the overhead collection systems for the various fractionation columns. These vacuum jets discharge to surface condensers which ultimately discharge to the atmosphere. Loading Racks There are no vapor recovery systems on any of the hydrocarbon loading ------- 11 racks at this facility, since all materials which are loaded have >193 °C (380 °F) initial boiling point and <0.007 kg/cm^ (<0.1 psi) va- por pressure. Benzene is transported to Witco by pipeline from the adjacent ARC0 refinery. Off-gases from the tank truck and rail car loading of muriatic acid are collected via vacuum piping and routed to water scrubber units. There are tank car unloading facilities for ethylene oxide and liquid sulfur dioxide. These materials are transferred under pressure from the tank cars to Witco's pressure storage vessels. The transfer pipes are purged before and after the filling operations to a caustic scrubber unit. EMISSIONS DATA Source Test Data NEIC personnel requested that Witco supply copies of all stack tests conducted at this facility since 1972. The LAAPCD was requested to do likewise. No source test data was received from either group; hence, it is assumed that no tests have been conducted at the facility since 1972. Computed Emission Rates Except for the single process heater and the hydrocarbon storage tanks, there are no published EPA emission factors for the processes employed at this facility. Emissions from the storage tanks have not ------- 12 been calculated for this report; rather, they will be included in a separate report being prepared by NEIC which will summarize storage tank emissions from all refineries and several organic chemical pro- ducing facilities in Los Angeles County. Emissions from the single process heater at this facility can be calculated from Table 9.1-1 of the EPA publication AP-42 Compilation of Air Pollutant Emission Factors, Second Edition (Second printing with Supplements 1-4). Based on a rated heat input of 5.0 x 10 kg cal ft O (2x10 Btu)/hr and a natural gas heat content of 8,900 kg cal/m 3 (1,000 Btu/ft ) the following emission rates were calculated: Emitted Pollutant (kg/hr) (lb/hr) Particulate Matter 0.02 0.04 Sulfur Oxides Neg. Neg. Carbon Monoxide Neg. Neg. Hydrocarbons 0.03 0.06 Nitrogen Oxides as NO2 0.21 0.46 Aldehydes 0.003 0.006 Ammonia Neg. Neg. It is obvious from these figures that this unit is not a major con- tributor of air pollutants. SUMMARY OF PAST VIOLATIONS The LAAPCD was requested to supply a summary of the court history of Rule violations issued to Witco. The LAAPCD reported that they have no record of violation notices having been issued to the Company. ------- 13 All units, except for the equipment associated with the new Dodane-H process, are operating under a valid LAAPCD permit. An author- ity to construct (ATC) for the Dodane-H plant has been issued to Witco by the LAAPCD. The process has not been operated for sufficient time to ensure compliance with the rules, so no operating permits have been issued for the equipment. INSPECTION SUMMARY At the time of this inspection, none of the major processes were in operation. The Dodane-H process has not been operated in past months due to a lack or market demand for the product. The Dodane-S process was down for routine clean-out of the chlorine reactor glass tubes. The sodium isethionate production run had been completed earlier in the day. All process units, storage vessels, potential emission sources and pollution control devices at this facility were observed during the in- spection. General housekeeping at this facility appeared to be very good. The main process areas were neat and had no noticeable spill areas or leaks. No violations of the LAACPD rules and regulations were noted during this inspection. ------- APPENDIX A Select LAAPCD Rules ------- Ccunty of Los Angeles Air Pollution Control District ------- Prohibitions ------- Rule 50. Ringelmann Chart. (Effective January 6, 1972 for any source not completed and put into service. Effective for all sources on January 1, 1973.) A person shall not discharge into the atmosphere from any single source of emission whatsoever any air contaminant for a period or periods aggregating more than three minutes in any one hour which is a. As dark or darker in shade as that designated No. 1 on the Ringel- mann Chart, as published by the United States Bureau of Mines, or b. Of such opacity as to obscure an observer's view to a degree equal to or greater than does smoke described in subsection (a) of this Rule. This amendment shall be effective on the date of its adoption for any source of emission not then completed and put into service. As to all other sources of emission this amendment shall be effective on January 1, 1973. Rule 51. Nuisance. A person shall not discharge from any source whatsoever such quanti- ties of air contaminants or other material which cause injury, detriment, nuisance or annoyance to any considerable number of persons or to the public or which endanger the comfort, repose, health or safety of any such persons or the public or which cause or have a natural tendency to cause injury or damage to business or property. Rule 52.. Particulate Matter - Concentration. (Effective January 6, 1972 for any equipment not completed and put into service. Effective for all equipment on January 1, 1973.) A person shall not discharge into the atmosphere from any source par- ticulate matter in excess of the concentration shown in the following table: (See Rule 52 Table) Where the volume discharged falls between figures listed in the table, the exact concentration permitted to be discharged shall be determined by linear interpolation. The provisions of this rule shall not apply to emissions resulting from the combustion of liquid or gaseous fuels in steam generators or gas turbines. For the purposes of this rule "particulate matter" includes any material which would become particulate matter if cooled to standard conditions. This amendment shall be effective on the date of its adoption for any ------- Rule 59. Effluent Oil Water Separators. (Effective June 29, 1971 for any equipment not completed and put into service. Effective for all equipment after July 1, 1972) A person shall not use any compartment of any vessel or device operat- ed for the recovery of oil from effluent water which recovers 200 cjallons a day or more of any petroleum products from any equipment which proc- esses, refines, stores or handles hydrocarbons with a Reid vapor pressure of 0.5 pound or greater, unless such compartment is equipped with one of the following vapor loss control devices, except when gauging or sampling is taking place a. A solid cover with alt openings sealed and totally enclosing the liquid contents of that compartment. b. A floating pontoon or double-deck type cover, equipped with closure seals to enclose any space between the cover's edye and compartment wall. c. A vapor recovery system, which reduces the emission of all hydrocarbon vapors and gases into the atmosphere by at least 90 per cent by weight. d. Other equipment of an efficiency equal to or greater than a, b, or c, if approved by the Air Pollution Control Officer. This rule shall not apply to any oil-effluent water separator used ex- clusively in conjunction with the production of crude oil, if the water fraction of the oil-water effluent entering the separator contains less than 5 parts per million hydrogen sulfide, organic sulfides, or a combination thereof. This amendment shall be effective at the date of its adoption for any equipment not then completed and put into service. As to all other equip- ment this amendment shall be effective on July 1, 1972. ------- vapor pressure of 1.5 psia or greater under actual loading conditions at a facility from which at least 20,000 gallons of such organic liquids are loaded in any one day. "Loading facility", for the purpose of this rule, shaiI mean any aggre- gation or combination of organic liquid loading equipment which is both (1) possessed by one person, and (2) located so that all the organic liquid loading outlets for such aggregation or combination of loading equipment can be encompassed within any circle of 300 feet in diameter This amendment shall be effective at the date of it-; adoption for any equipment not then completed and put into service. As to all other equip- ment this amendment shall be effective on July 1, 1972. Rule 62. Sulfur Contents of Fuels. A person shall not burn within the Los Angeles Basin at any time be- tween May 1 and September 30, both dates inclusive, during the calendar year 195S, and each year thereafter between April 15 and November 15, both inclusive, of the same calendar year, any gaseous fuel containing sulfur compounds in excess of 50 grains per 100 cubic feet of gaseous fuel, calcu- lated as hydrogen sulfide at standard conditions, or any liquid fuel or solid fuel having a sulfur content in excess of 0.5 per cent by weight The provisions of this rule shall ncit apply to. a. The burning of sulfur, hydrogen sulfide, acid sludge or other sulfur-compounds in the manufacturing of sulfur or sulfur compounds. b. The incinerating of waste gases provided that the gross heat- ing value of such gases is less than 300 British Thermal Units per cubic foot at standard conditions and the fuel used to incinerate such waste gases does not contain sulfur or sulfur compounds in excess of the a- mount specified in this rule. ------- c. The use of solid fuels in any metallurgical process. d. The use of fuels where the gaseous products of combustion are used as raw materials for other processes e. The use of liquid or solid fuel to propel or test any vehicle, aircraft, missile, locomotive, boat or ship. f. The use of liquid fuel whenever the supply of gaseous fuel, the burning of which is permitted by this rule, is not physically avail- able to the user due to accident, act of God, act of war, act of the public enemy, or failure of the supplier. Rule 62.1 Sulfur Contents of Fuels. a. A person shall not burn within the Los Angeles Basin at any time between the days of November 16 of any year and April 14 of the next succeeding calendar year, both dates inclusive, any fuel described in the first paragraph of Rule 62 of these Rules and Regulation;;. b. The provisions of this Rule do not apply to: 1. Any use of fuel described in Subsections a,b,c,d,e, and f of said Rule 62 under the conditions and for the uses set forth in said Subsections. 2. The use of liquid fuel dunng a period for which the supplier of gaseous fuel, the burning of which is not prohibited by this Rule, interrupts the delivery of gaseous fuel to the user. c. Every holder of, and every applicant for a permit to operate fuel- burning equipment under these Rules and Regulations shall notify the Air Pollution Control Officer in the manner and form prescribed by him, of each interruption in and resumption of delivery of gaseous fuel to his equipment. Rule 62.2 Sulfur Contents of Fuels. Notwithstanding the provisions of Section (f) of Rule 62 or 3ny pro- ------- vision of said section as incorporated into Rule 62.1 or any provision of Subsection (2) of Section b of Rule 62.1, a person shdll net burn within the Los Angeles Basin any liquid fuel or solid fuel having a sulfur content in ex- cess of 0.5 per cent by weight. It shall not be a violation of this rule to burn such fuel for a period of not to exceed three calendar days (and in addition for that period of time necessary for the Hearing Board to render a decision, provided that an ap- plication for a variance is promptly filed] when other fuel which complies with this Rule is not used due to acciden., strike, sabotage, or act of God. Rule 63. Gasoline Specifications. a. A person shall not, after June 30, 1960, sell or supply for use within the District as a fuel for motor vehicles as defined by the Vehicle Code of the State of California, gasoline having a degree of unsaturat.on greater than that indicated by a Bromine Number of 30 bs determined by ASTM Method D1159-57T modified by omission of the mercuric chloride catalyst. b. For the purpose of this rule, the term "gasoline" means any pe- troleum distillate having a Reid vapor pressure of more than four pounds. Rule 64. Reduction of Animal Matter. A person shall not operate or ur.e any article, machine, equipment or other contrivance for the reduction of animal matter unless all gases, vapors and gas-entrained effluents from such an article, machine, equipment or other contrivance are. a. Incinerated at temperatures of not less than 1200 degrees Fahrenheit for a period of not less than 0.3 second, or b. Processed in such a manner determined by the Air Pollution ------- apply for a permit to operate such tank before January 1, 1965 The provi- sions of Rule 40 shall not apply during the period between the dole of adop- tion of this rule and January 1, 1965, to any gasoline tank installed prior to the date of adoption of this rule provided an application for permit to oper- ate is filed before January 1, 1965. A person shall not install any gasoline tank with a capacity of 250 gal- lons or more unless such tank is equipped as described in the first paragraph of this rule. For the purpose of this rule, the term "gasoline" i<. defined as any pe- troleum distillate having a Reid vapor pressure of 4 pounds or greater For the purpose of this rule, the term "submerged fill pipe" is defined as any fill pipe the discharge opening of which is entirely submerged when the liquid level is 6 inches above the bottom of the tank. "Submerged fill pipe" when applied to a tank which is loaded from the side is defined as any fill pipe the discharge opening of which is entirely submerged when the liq- uid level is 18 inches above the bottom of the tank. The provisions of this rule do not apply to any stationary tank which is used primarily for the fueling of implements of husbandry, as such vehicles are defined in Division 16 (Section 36000, et seq.) of the Vehicle Code Rule 66. Organic Solvents. a. 'A person shall not discharge into the atmosphere more than 15 pounds of organic materials in any one day, nor more than 3 pounds tn any one hour, from any article, machine, equipment or other contrivance, in which any organic solvent or any material containing organic solvent comes into contact with flame or is baked, heat-cured or heat-polymerized, in the presence of oxygen, unless said discharge has been reduced by at least 85 per cent. Those portions of any series of articles, machines, equipment or other ------- contrivances designed for processing a continuous web, strip or wire which emit organic materials and using operations described in this section shall be collectively subject to compliance with this section. b. A person shall not discharge into the atmosphere more than 40 pounds of organic materials in any one day, nor more than 8 pounds in any one hour, from any article, machine, equipment or other contrivance used under conditions other than described in section (a), for employing or ap- plying, any photocheinically reactive solvent, as defined in section (k), or material containing such photochemically reactive solvent, unless said dis- charge has been reduced by at least 85 per cent. Emissions of organic ma- terials into the atmosphere resulting from air or heated drying of products for the first 12 hours after their removal from any article, machine, equip- ment, or other contrivance described in this section shall be included in de- termining compliance with this section. Emissions resulting from baking, heat-curing, or heat-polymerizing as described in section (a) shall be exclud- ed from determination of compliance with this section. Those portions of any series of articles, machines, equipment or other contrivances designed for processing a continuous web, strip or wire which emit organic materials and using operations described in this section shall be collectively subject to compliance with this section. c. A person shall not, after August 31, 1974, discharge into the at- mosphere more than 3,000 pounds of organic materials in any one day, nor more than 450 pounds in any one hour, from any article, machine, equip- ment or other contrivance in which any non-photochemically reactive organ- ic solvent or any material containing such solvent is employed or applied, unless said discharge has been reduced by at least 85 per cent. Emissions of organic materials into the atmosphere resulting from air or heated drying of pfoducts for the first 12 hours after their removal from any article, machine, ------- equipment, or other contrivance described in this section shall bn included in detcimining compliance with this section. Emissions resulting from bak- ing, heat-curing, or heat-polyrnerizing as described in section (a) shall be ex- cluded from determination of compliance with this section. Those portions of any series of articles, machines, equipment or other contrivances designed for processing a continuous web, strip or wire which emit organic materials and using operations described in this section shall be collectively subject to compliance with this section. d. Fmissions of organic materials to the atmosphere from the clean- up with photochemically reactive solvent, as defined ,n section (k), of any article, machine, equipment or other contrivance described in sections (a), (b) or (c), shall be included with the other emissions of organic materials from that article, machine, equipment or other contrivance for determining compliance with this rule. f. Emissions of organic materials into the atmosphere required to be controlled by sections (a), (b) or (c), shall be reduced bv 1. Incineration, provided that 90 per cent or more of the car- bon in the organic material being incinerated is oxidized to carbon dioxide, or 2. Adsorption, or 3. Processing in a manner determined bv the Air Pollution Con- trol Officer to be not less effective than (1) or (2) above. g. A person incinerating, adsorbing, or otherwise processing organic materials pursuant to this rule shall provide, properly install and maintain in calibration, in good working order and in operation, cevices as specified in the authority to construct or the permit to operate, or as specified by the Air Pollution Control Officer, for indicating temperatures, pressures, rates of flow or other operating conditions necessary to determine the degree and ------- effectiveness of air pollution control. h. Any person using organic solvents or any materials containing or- ganic solvents shall supply the Air Pollution Control Officer, upon request and in the mannei and form prescribed by him, written evidence of the chemical composition, physical properties and amount consumed for each organic solvent used. i. The provisions of this rule shall not apply to: 1. The manufacture of organic solvents, or the transport or storage of organic solvents or materials containing organic solvents. 2. The use of equipment for which other tequirements are specified by Rules 56, 59, 61 or 65 or which are exempt from air pollution control requirements by said rules. 3. The spraying or other employment of insecticides, pesticides or herbicides. 4. The employment, application, evaporation or drying of satu- rated halogenated hydrocaibons or perchlorosthylene. 5. The use of any material, in any article, machine, equipment or other contrivance described in sections (al, (b), (c) or (d), if: (i) . the volatile content of such material consists only of water and organic solvents, and (ii) the organic solvents comprise not more than 20 per cent of said volatile content, and (iii) the volatile content is not photochemically reactive as defined in section (k). j. For the purposes of this rule, organic solvents include diluents and thinners and are defined as organic materials which are liquids at standard ------- conditions and which are used as dissolvcrs, viscosity reducers or claming agents, except that such materials which exhibit a boiling point hnjlic-i ili.m 220°F at 0.5 millimeter mercury absolute pressure or having an eriuivjluni vapor pressure shall not be considered to be solvents unless exposed to turn peratures exceeding 220°F. k. For the purposes of this rule, a photochemically reactive solvent is any solvent witfi an aggregate of more than 20 pei cent of its total volume composed of the chemical compounds classified below or which exceeds any of the following individual percentage composition limitations, refeired to the total volume of solvent 1. A combination of hydrocarbons, alcohols, aldehydes, esters, ethers or ketones having an olefinic or cyclo-olefinic type of unsaturation: 5 per cent, 2. A combination of aromatic compounds with eight or more carbon atoms to the molecule except ethylbenzene 8 per cent; 3. A combination of ethylbenzene, ketones having branched hydrocarbon structures, trichloroethylene or toluene 20 per cent. Whenever any organic solvent or any constituent of an organic solvent may be classified from its chemical structure into more than one of the above groups of organic compounds, it shall be considered as a member of the most reactive chemical group, that is, that group having the least allowable per cent of the total volume of solvents. I. For the purposes of this rule, organic materials are defined as chemical compounds of carbon excluding carbon monoxidi?, carbon dioxide, carbonic acid, metallic carbides, metallic carbonates and ammonium carbon- ate. ------- Rule fiS.1 Fuel Burning Equipment - Combustion Contaminants. A person shall not discharge into the atmosphere combustion contami- nants exceeding in concentration at the point of dischaige, 0 3 grain per cubic foot of gas calculated to 12 per cent of carbon dioxide (CO2) at standard conditions. Rule 69. Vacuum Producing Devices or Systems. A person shall not dischaige into the atmosphere more than 3 pounds of organic materials in any one hour from any vacuum producing devices or systems including hot wells and accumulators, unless said discharge has been reduced by at least 90 per cent. This rule shall be effective at the date of its adoption for any equip- ment not then completed and put into service. As to ail other equipment this rule shall be effective on July 1, 1972. Rule 70. Asphalt Air Blowing. A person shall not operate or use any article, machine, equipment or Other contrivance for the air blowing of asphalt unless all gases, vapors and gas-enlrained effluents from such an article, machine, equipment or other contrivance are a. Incinerated at temperatures of not less than 1400 degrees Fahrenheit for a period of not less than 0 3 second, or b. Processed in such a manner determined by the Air Pollution Control Officer to be equally, or more, effective for the purpose of air pollution control than (a) above. This rule shall be effective at the date of its adoption for any equip- ment not then completed and put into service As to all other equipment this rule shall be effective on July 1, 1972. Rule 71. Carbon Monoxide. A person shall not, after December 31, 1971, discharge into the atmos- phere carbon monoxide (CO) in concentrations exceeding 0.2 per cent by volume measured on a dry basis. The provisions of this rule shall not apply to emissions from internal ------- / combustion engines Rule 72. Pumps and Compressors. A person shall not, after July 1, 1973, use any pump or compressor handling organic materials having a Reid Vapor Pressure of 1 5 pounds or greater unless such pump or compressor is equipped with a mechanical seal or other device of equal or greater efficiency approved by the Air Pollution Control Officer The provisions of this rule shall not apply to any pump or compressor which has a driver of less than one (1) horsepower motor or equivalent rated energy or to any pump or compressor operating at temperatures in A person shall not, after July 1, 1973, use any safety pressure relief valve on any equipment handling organic materials above 15 pounds per square inch absolute pressure unless the safety pressure relief valve is vented to a vspor recovery or disposal system, protected by a rupture disc, or is maintained by an inspection system approved by the Air Pollution Control Officer The provisions of this rule shall not apply to any safety pressure relief valve of one (1) inch pipe size or less / s/' excess of 500°F Rule 73. Safety Pressure Relief Valves. ------- APPFNDIX B Pressure Relief Valve Maintenance Schedule ------- ¦g&'&W d. A. UNIT REL|J ^VALVES "Soft" a i;o. _i— - ¦ LOCATION ANO SERVICE SIZE SETTING R.D.SET. UCIJT TO PROD. j REI1ARKS i Tnermal Relief Paraffin Cord, ICC Atmos h2o ¦} " " 1ns t.Air Cooler H 11 1 1 1 1 j i 3 11 " Uti 1 i ty Ai r Cooler II (1 11 1 1 I 1 k i) ii II (1 11 1 t ( 1 3 11 " Spare 6 " 11 Benzene Rec'y Cooicr 1J II 1 1 1 1 I 1 7 11 " D.A.O.H. Condenser II If i: 1 1 1 I S 11 " Hydrolysis Cooler II II i. 1 t 1 1 3 " " Spore 10 j " " O.A. Bottoms Cooler II II 11 1 1 1 1 11 " " Bcnz. Stripper OH Cond. II II 11 i 1 1 1 12 II 11 1 t II 11 1 1 1 1 \k Off test Feed Oner 2x3 55 1 1 Off test 1 5 Dcnzcne Feed Drier 2*3 60 Recovery Benzene ]£> DQV.cne Teed Drici' 2x3 60 Rccove ry Dcnzcne 17 Alky lotion Reoctor 4x6 5't Recovery HCL . _ i 8 Effluent Surge Drum (Stripper Feed Surge) 6x8 HO Atmos Fuel Gas 19 So ere i 20 jj-jocnzcnc Stripper Tower 3x4 | 30 1 'Umos Benzene 21 jCo"plex ftec'y pump 3 Ax! 125 Atmos Ccno lex 22 jipsrc 23 Lpcre t 2^ v-l-'eort A' k> To'.'er (3, A. Tower) 3x4 IS rttd'OS D.A.O.H. 7? ir rn«;n Ac i a nunra f I renter Feed) 3/4x1 100 ilccove ry 2-3-A Fresh Ac i a puwp (ireater feed) j 3/^xl 100 Recovery h2so)i 26 5& :rc 27 '"jet fiediu.,1 Suroc Dri.n | 3x4 60 j Atrvos Heat f'.cc. ?8 'Caustic Cooler 3/^xi 100 j j At.', cs h2o 3C X|Ciov To.'cr (Norlh) j ^*6 55 j | Afics D.A.O.H. "> I . - i i i :v Air Rccr'vc: i W > 135 | j At.TiQS A, r ------- 0. A, UN'IT RELl'^, VALVES "Soft" h! NO. LOCATION AND SERVICE SIZE SETTING R, D.SET. VENT TO PROD. REIIARKS 33 Instrument Air Receiver 3/Ax3/A 115 i Atmos Ai r Spare 35 Sparc 36 Utility Air Compressor 3/Ax3/A 100 Atiros H,0 37 Instrument Air Compressor Djtcharge lxl 135 Atmos Ai r 30 Spore 39 Alky Feed Preheater 3/Axl 60 Atmos Paraff i n 39-A Alky Feed Preheater Ixl* 60 At.T.OS Paraffin AO E1ecLric Precipita tor 1x2 60 Atmos D,A.O.H. AI Complex Pump-ouL punp 1 X 1 2 Al Atmos Stconi Kl Spare \ A3 Foon Tank (South) 3xA 150 Aimos Foam(Fire 1 i ghs 11 ng) -* AA rocm Tank (North) il 150 Atmos Foam (Fire ( ightincj) L-5 Instrument Air Oriei (West) JX 115 Atmos Ai r A6 Instrument Air Oner (East) %>'• 1 15 Atmos Ai r • A7 1 Tner.ra 1 Re 1 i ef ylkx3/4 i 00 AUnos H,0 - AG Spare -> 51 Tner'-a 1 Re 11 ef 3/kx3/A 100 Atmos h2o ' 33 Sulfuric Acid unloading rack 3/Axi AO Atmos Ai r 55 T.ie rrc l Relief rieat Mea i lti (Elect.) 3/Ax 3/A 100 Atmos H„0 57 V Paraffin Tower Ax6 50 Atmos Pcraf fin 5o Cnlonne Vooonzer 1x2 lAO Reccverv Ch 1 orine 5S-A C'n ion r.c Vapor i zcr 1x2 i';0 Recovery Ch1 or i re - - 53 \'?orrff i n Recycle Drier li <3 AO Recovery Paraf f > n i 60 [Spare 6i vtnlorinc Reactor 2x3 35 Yes Recovery Paraf f i n -- 61-A i ^phlorine Rjactor 2x3 35 Yes Recovery Paraf f i n 1 1 I - • ' ' ------- D. A. UNIT REL VALVES "Soft1' ¦1 NO. LOCATION AND SERVICE SIZE SETT 1 KG R.D.SET. VEtIT TO PROO. REI1ARKS 62 >: Cniorinci Reactor Effluent Flash Drun 2x3 5G 1 XHSX Recov HCL £•3 Y Benzene Absorber 3xh 55 * " | HCL 6u Spore 66 X Benzene Stripper Preheater 3xk 1.0 Atmos Alci y 1 otc 67 Chlorine Vaporizer (Stecm) 1 jx2t 60 Atmos Steam 67-A Chlorine Vaporizer (Steam) !tx2u 288 60 Atmos Stcan 63 Tnermal relief Heat iledium pump (Spare) 3/^x3/^ 100 Atmos H?0 63 Thermal relief West Heat Iledium pump 3/'i*3A 100 Atmos H?0 70 Tnc-rnta 1 relief Instrument Air Compressor l/k&k 100 Atmos h2o 73 \ /I.Tit-onia Storage Drum 1 h 291 Aimos Ai*n,on 1 a Co 11 t1 11 l£ 291 1 1 I 1 81 11 11 11 'iT 291 1 i 1 I G2 11 n 11 291 1 1 1 J 93 \ | Salt To\.cr i»x6 75 Atmos A1j ate 30 y Chlorine Control Cho-.iber (North) 1tv2 273 Yes Recovery Chlorine i 37 \ 11 11 11 (South) 1 Vx2 275 Yes Recovery Ch1 or 1ne yS " SUrge Tank (Uorth) 1U2 27 3 Yes Recovery Ch1 or 1ne 39 1 11 11 n (South) 1 Vs2 275 ! Yes Recovery Ch i or 1 no j !C0 ! Ami, on 1 a Vaporizer \<] 200 Atmos Amnion 1 a 101 \ Tcnk 20 L'rS, 1" 'Jacoi 1" Vccuuhi Atmos Benzene 10?. \ 11 -jq hx » 1 I 1 Benzene 10 3 38 L\x. 1 1 1 1 Benzene in' ! " 11 U 1 1 1 I Benzene iftC \ ' 1 77 k-. 1 1 >1 Genz^pc I "" 1 f I —1 1 1 ! 1 — 3 ------- "HARD" 0.A. UNIT RELIEF VALVES '\l Nn. LOCATION AND SERVICE S !ZE SETTING PROD. 1 VENT TO 1 1 131 Olefin Drier 2x3 55 PS 1G HC L1qu1( Atmos. ~ 1 182 m \ Ot ttest Drier 2x3 5S PS 1G M'' L1qu11 HC L ijGLM' HC Vapor " - Benzene Drier 3x*4 55 PS 1G D-lOU D-m 1 Alky Reactor 5Li PS 1G "1" ¦' 1S5_ 186 A R Coo 1 e r 6x8 100 PS 1G Water Atmos ^ i Benzene Surge (Feec Surge) 30 PS 1G HC Vapor Atn:os 1 ! 187 HCL Compressor 3/^xl 200 PS 1G HC Vapor D- 1 \b / 138 Focm Tank 3x3 150 PS 1 G V/ater Atmos CO vo / Complex Settler Ux6 70 PS 1G HC Vapor IJorth Pi t Atmos ,r 4. O C *"v 6 2 So Salt Tower 3 W. 60 PLIG HCVapor 281 Benzene Stripper Prcheater 4x6 UO PS 1G HC Vapor Atmos <,. 282 * 283 Benzene Stripper Tower Benzene Recycle Surge Drum 2x3 80 PS 1 G 100 PS 1G HC Vapor V/ a ter Atmos A (.mos ^ — 1 Z. w .J ' ;¦ 0 t- — _ . :s.o5 28U Benzene Recycle Surge Drum 100 PS 1 G Water Atmos /. • ^ 0 <3 ~"" 2C5 Benzene Stripper O.H, Condenser JXJ 100 PS 1 G | \/'a ter A tnos z_ 286 , | Light Alky Tower 2x3 15 PS 1G J HC Vapor Atmos cj __ 287 Light Alley O.H. Condenser 2x3 100 PS 1G | './ater 30 PS 1G J HC Vapor Atmos Atmos _ 238 D.A. Tov.sr 229 D.A. BTI1S Cooler 3/'-x 1 lOO PS1G | V/ater Atrnos -- 230 D.A. Overhead Condenser 3/^xl 100 PS IG j l.'ater Atmos 291 Jet Condenser 3/^xl 100 PS 1 G j i.'atcr Atmos 190 hCL Contactor 1 jx 1 y 100 PS 1G |HC Vapor D-l 1^ . t 2 bO Tank 5' 3" ~07\~2 1 r^oj nC Vapcr " JHC Vapor Atmos ALmos \ t 331 Tank 52 3" ___382_ 38 i Tank ^5 3" " |HC "apor A Lir.05 1 1 - - — Tcnk ^ 3" " |HC Vapor Atmos _3_3i, 29 Tank h2 I 3" " i HC VAPOR Atmos i So'-tn Clay Tower '1x6 55 PSIG j hC L i.quj i A tires I 1 31 "l9l Electric Precipitator 3xU 60 PSIG HC L1qu1 j Atmos 1 1 Vest Complex puT>p to Hard Unit A. Reactor 3/'txl 100 PSIG HC L1qu1 J Atmos 1 ------- "HARD" D.A. UNIT RCLIEF VALVES ./ ::o. LOCATION AND SERVICE SIZE SETTING PROD. VENT TO Light Alky Tower Btms. pufp 3/^x3/^ 100 PS;G Water Atmos . 50 Lignt Alky Tower Btms. pump 3A*3/i+ 100 PS IG WATER Atmos i 1 1 , * • | - • 1 i ' 1 i 1 1 ¦ r ------- N 1 S RELIEF VALVES R.V. -V VESSEL i t/or SERVICE SIZE l-lOl-A F-101 Sulfur Dioxide (East) 2x3 CD 1 O 1 F-101 Sulfur Dioxide (West) 2x3 3- 101-C F- 10 1 Sulfur Dioxide (South) 1x2 4-101-D F-101 Sulfur Dioxide (North) 1x2 5-102 G- 102 Caustic Transfer Pump Punpx 1 i; 6- 103-A 0 1 u_ \ Ethylene Oxide 6x3 7- 103-3 *F-!03 Ethylene Oxide 6x8 3- 10'i-A G- 103 E.O. Unloading Pump, Disc. 3Axl 9- 104-B G-104 E.O, Transfer Pump, Suet. 3 Ax! 10-106 )c r-106 E.O. Gauge Tank 4x6 1 i - 10 7 - A c-106 E.O, Gauce Tank 3 Ax I 12-107-3 F-106 E.O. Gauge Tank 3Axl CO 0 1 c> X D-I0I Reactor 6x8 14- 109 M- 10 1 Filter 3/^.1 15-110 F-108 1 nstn.-nent Ai r Rec. lxAtmos. 16-111 E-101 Cooling Water (Reactor Cooler) 3A-OA 17-112 E- 102 Cooling (Inst. Air Aft. Cooler) 3/^x3/4 13-113 C- 102 Cooling Water (Inst. Air Comp) 3Ax3A 19- 1 K A-101 Cooling Water (Reactor Agit.) 3Ax3A 20-115 Utility Water 3A<3A 21-116 E-102 Instrument Air (Inst. Air Aft. Clr.) £x3A 22- 117-A K- 10 4 Inst. Air Drier (South) j-xAtros. 23-117-3 V- 104 1 ast. Air Drier (North) i^Atros. 2\-l 18 C - 10 1 Sulfur Dio.-.ide Comp. 3/^.i PS I G 0PER. R. D. SCTTING PRESS. SETTING MANUFACTURE 135 75 150 C rosby 1 35 75 150 C rosby 1 10 75 125 Crosby 1 10 75 125 C rosby 20 20 Viking 65 60 75 C rosby 65 60 75 C rcsby iOO 55 C rosby 100 55 Crosby 65 60 75 C rosbv 100 60 Crosby 100 60 C rosby 70 :o 95 Crosby 75 72 CrcsDy • 15 1 10 Kingston 75 48 Ash ton 75 » «*l -f U A - U ^ i .j . t - ^ ¦ i 75 48 Ash ton 75 43 «sb ton 100 75 Ash; on 125 110 Conso1ioated 150 1 10 Jayco 150 1IC Jayco 250 iOO Z^stian BlessingCi . .'CO C,,"_ . "".. ; ' r* ,r c C.VoO., P O L.OV v '!L" tr- ¦ '\- r ^ ------- APPENDIX C Storage Tank Listing ------- V ^ rxeo vCherrrti eal STORAGE TANK SUMMARY Hard Alkylate Tank fcarm TK# (3) Cap. bbls (4) Dim. , ft &(5) h Vent (14) Commodity (15) (lb/gal) V.P. Reid (17)lbs Flash °F ** ThruDut (18)bbl/da 40 2000 24 25 open Dodane 7.25 0.0 290 60 41 2000 24 25 open Dodane 7.25 0.0 290 60 42 500 15 16 ¦k Waste Water -- -- 150 43 1000 19 20 open Synthogene 7.41 0.0 380 30 44 1000 19 20 * Red Oil 7.66 1.4 12 10 46 600 16 18 open Dodane 7.25 0.0 290 50 47 600 16 18 open Dodane 7.25 0.0 290 50 48 600 16 18 open Lt. Alky. 6.66 0.2 150 20 49 600 16 18 vV Off-Test 7.25 0.0 290 unknown 50 2000 24 25 open Tetramer 6.46 0.1 170 220 51 800 18 18 •k Benzen^ 7.36 1.4 12 40 52 800 18 18 it Benzene 7.36 1.4 12 40 * 3" relief valves with \ oz x h" H2O setting (on Benzene tanks and all tanks that could conceivably contain some benzene.) ** Estimated maximum at 220 b/d total Dodane production; plant has not been on stream long enough to establish 'average1 data. All tanks are: (6) cylindrical, (7) steel, (8) light tan, (9) good condi- tion, (10) new construction, (11) have fixed roof, and (16) contain material at 45 to 85 °F. J. Corinth Ass't. Gen. Mgr. JC/bj WiIlo Chemical Corporation Witfiekl Division — Carson, P O Box 1243, Wilmington, Calif 90744 Area Code 213 Telephone 830-4353 ------- TABLE I - EXPLICATION OF SY? SOLA U'iED "w TATiV: LO-S"i^ SH'OIAHY .SxjjJKL' COUBiN rO: _ .COLUMN.jE/JHJ'G So US CL Use classification codia (see Table II) 7 XT Tank type oode (sre Talkie II) 8 TANK NO, Tank identification nuinDer 15 pr CD Product code (see Table II) ]6 KETD V.P. Reid Vapor Pressure (oiP-it, not required) 29 t>TR IMP Average product storage temperature, °P 02 TRUE V.P. True vapor pressure at storage temperaturej psia 25 TANK DIA. Tank diameter, feet 29 DNSTY Density oC condensed vapors, Ib/bbl 32 OT FC Outage factor (height of vapor space above liquid, ft) 3I; AV TC Average daily umbient temperature change, °P 36 POT FaC Paint factor for tank (kp in API Bull 2517 > Fp m API Bu±l 2518) jq THRU PUT Average thruput, bbl/day H TURN FAC Turnover factor for fixed-roof tanks (k-^ m API Bull. 2518) ^7 S.T. aJDJ Factor for bniall fuced-roof tanks (C m APT Bull 2>Lt) 50 C.O. FAC. B Breathing loss factor for crude 031 m fi::ea-roof tanks (similar to kc m aPI Bull 25l8) 53 C.O. FAC. F Working loss factor for crude oil in fu-cea-roof tanks (API Bull 2518); or evaporation loss factor ior cruae oil in floating roof tank3 (kc m API Bull 2517) 56 T. T. FAC Tank type factor for floating roof tanks (kt m API Bull 2517) 59 WIND VEL Average v.md velocity 62 SEaL FAC Seal factor for floating roof tanks (lcs in API Bull. 2517) 65 CLIJG FAC Clmgage factor for floating roof tanks (C m API Bull 2517) 68 CAP. BBL Capacity of storage tank, 100'a of bblo 72 GRID S<* Area location code (APCD use only) 1 ko Month ±n which data ua3 recorded or corrected 3 YR Year m winch data was recorded or corrected 6011706 ------- TABLE II - COD''1. NUI3KRS A. USE CLASSIFICATION CODE **» ~ - t* 0 - Petrochemical plant 1 - Refinery distillate 2 - Refinery ciuds 3 - Marketing 4 - Harms terminal crude 5 - Ma.rD.n3 ternmal distillate 6 - Pipeline terminal crude 7 - Pipeline terminal distillate 8 - Oil well tanks B. TANK TYPE CODE Pnjced roof 2 - Floating roof 3 - Fixed roof control ^.4 - Pressure F Q C. PRODUCT CODE Organic ch.snu.calc 1/. P. gases Gasoline Aviation gasoline Petroleum distillates greater than 1.5 psia (true vapor pressure) Crude oil Turbine fuel PeLi-oleum distillates less than 1.5 psia (true vapor pressure) Bnpty ------- P RE^_/WE O. 06/13 A73, ,u t- A PC D / \ t ,~r pv-^ iJLi . CO 8-*^-* 15 / /' UST C CS'i 8 0 RE 10 STR TRUE TANK V .P . TUP V .P . D 1 A . 1 6 f 1 9 ¦> <" 2 2*3 2 5 « ¦ '«• w w V ' . (\r / dn- or av CTY FC TC 29-f32*34 Oi« i DtcfKm 1 0 o~*"i " >. 2 "0" 0 -* * 1 rl fe 0 0" 1 " 7 0 n ' 1 SyN-~ 8" 0 q~ i Perfctu 1 1 c QZ* 1 12 0 C 1 fiiWA 1 5 0 C - 1 PcU*- 16 0 Q i Sy 19 Q /\ Br.nz, 20 0 .Pi' -1. 21 1 o ¦> «¦ l CP, ~f. 24 c C " /I S-cnx 25 3 o** i $yt ; i %hP_n° Zi O o 70 0.0 '21.3 210 0 1 5 "0 .0" 7 0 0.0 ' 21.3 "2 10 8 1 5 o. c 7 0 _0.0_ J_21 .3 210 8 1 5 0 .0 7 0 0.0 '21.3 210 8 15 0.0 70 0.0" "21.3 210 8 1 5 0 .0 70 0.0 v^3 0 .0 210 e 1 5 0 .0 70 0.0 1 '3 5 '.5 2 1 0 8 1 3 0.0 70 " 0.1 i '30 :o 2 10 8 1 5 0 .0 70 0.1 ^30 .0 2 i 0 0 1 5 o O 70 0.0 21.3 210 8 15 0 .0 " " 70 "1.41, 20.5 210 8 15 •?i O ' j 7 0 _0 .1 /_2J_. 3_ 2 _1_0_ 8 _1 5 0 . c 7 0 0 .0 1 21 .3 210 8 15 U . 0 70 1 ."4 20 .5 210 0 15 1 O O 70 0.0 12 1.3 2 10 8 1 5 C .0 70 0.0 i 12 .5 210 8 1 5 0 .0 7 0 0.0 •12.5 2 10 8 1 5 0 .0 7 0 0.0 21.3 2 1 0 0 1 5 0 .0 70 0.0 / 2 1.3 2 10 8 15 -- 60 21.2 y .u 210 20 1 5 - 70 . .. ?•?__ *\ " I' JO , ( i(? 0 (t tt I' 1 AN K PNT FAC . 36 -=> 1 . 20 1 . 20 1 .20 1 . 20 1 . 20 1 . 20 1 . 20 1 . 20 1 .20 1 . 20 1 . 20 1 . 20 1 . 20 1 . 20 1 . 20 1 . 20 1 . 20 1 . 20 1 . 2'J 1 . 20 LOSSES SUMMARY SHEET \iix THRU TURN ' S.T. t . D. PUT FAC. ADJ. FAC.5 39,. s.o 47 5 0 - U/lTF I ELD Cil-Efl I C At oO 60 60 60 20 _ 6C 60 110 110 20 75 11 0 2 75 20 1 80 1 UO 1 00 1 SO 14 / b ± I 1.00 .87 1.00 1.00 .87 1 .0 0' 1 .00 .87 1 .00 1.00 .87 1.00 1.00 .87 1.00 1 .00 1 .00_ 1 .00 1 .00 1.00 ,1 .00 1 .00 1.00 .1 .00 1 .CO 1.00 '1 .00 1 .00 1 .00 1.00 1 .00 1 .00 1.00 .37 .37 _.6 0 .60 i .00 . 8 7 1.00 i .65 1.00 _.8 7_ "] .00 1 .87 1 . C 0 .85 1.00 .87 1.00 .62 1.00 .62 1.00 .87 l.C'O . E 7 1.00 .45 i.OO C . 0. FAC .F _5 3~=> i .00 1 .00 1 .00 1 .00 1 . 00 1 .00 1 . 00 1 .00 1 . 00 1 .00 1 . 00 1 .00 1 .00 1 .00 1 .00 1 .00 1 .00 1 . 00 1 .00 1 . CO CAP,. GP, 1J KL VR P8L SQ. 6o 12--* M,* YY 10 4G18 10 A G 1 S 10 4 018 10 4018 10 G 1 8 20 401H 25 4018 20 4018 20 4010 10 4018 9 401 8 _10 4018 10 4 018 9 4018 10 4018 4 4 018 4 4013 10 4 C 1 0 i 0 4 0 i c 5 4 C 11 1 1/ 71 11/71 11/71 _ 11/71 1 j/71" 13/ 7 i 1 i/ 71 11/71 11/71 1 l/7i 1 1/ 71 1 1/71 1 1/ 71 1 ./ 7 l 11/ n 1 1/ 71 i 1/ 71 1_1/ 71 11/71 • ./ 7i 1 " z ''ft 1*'^ -'y /v " I 7 ------- WITCO CHEMICAL CORPORATION Witfield Division Carson, California SUMMARY AND CONCLUSIONS The Witfield Division of Witco Chemical Corporation (Witco) operates an organic chemicals synthesis plant in Carson, a suburb of Los Angeles, California. Witco produces linear alkylbenzene, "hard" alkylbenzene, Synthogene (a high boiling point detergent bottoms product which is used for lube oil additives), sodium isethionate, and muriatic acid. An air pollution related inspection of these facilities was conducted by NEIC personnel or, November 5, 1975. Substantial amounts of process and air pollution control related information were requested of, and received from, Witco. The Los Angeles County Air Pollution Control District (LAAPCD) was requested to supply information pertaining to stack testing conducted at this facility and any violation notices issued to Witco. The following conclusions were derived from the inspection and in- formation obtained: 1. All units at this facility, currently being operated, have a valid LAAPCD permit. The "hard" alkylbenzene plant (Dodane- H) is not permitted. This plant was completed in early 1975 under a LAAPCD authority to construct (ATC), but it has only been operated for approximately six weeks due to lack of demand for the product. It is not currently being operated, nor does Witco plan to operate it in the near future. It has not been operated for a sufficient length of time to determine if it complies with all LAAPCD rules, hence, operating permits have not been issued for it. ------- 2. No violations of the LAAPCD rules were noted during this inspection. Unfortunately none of the processes were opera- ting during this inspection. As noted, the Dodane-H plant has not been operated since early 1975. The linear alkylbenzene plant (Dodane-S) was down for maintenance. The sodium isethio- nate process runs only briefly, early in the day. Muriatic acid and Syntliogene production are tied to the Dodane-S process. 3. Housekeeping at this facility appeared to be very good. There were no noticeable spill areas or process 'leaks. 4. No stack tests have been conducted at this facility according to LAAPCD records. 5. No violation notices have been issued to Witco by the LAAPCD. RECOMMENDATION Another inspection should be scheduled for this facility to observe all of the processes in operation and verify compliance with the appli- cable LAAPCD Rules and Regulations. The inspection should be scheduled with Witco personnel to insure that all processes are operating. ------- |