Crompton Corporation (Formerly Witco Corporation)

Witco Letter to EPA: Thermal Oxidizer Startup Problems and Performance Test Extension

Witco Corporation
OrganoSilicones Group
Sistersville Plant
3500 South State Route 2
Friendly, WV 20146
(304)652-8000

June 10, 1998

Mr. Tad Radzinski (3HW70)
US EPA Region III
841 Chestnut Street
Philadelphia, PA 19107

Re: Thermal Oxidizer Startup Problems and Performance Test Extension

Dear Tad:

This information is being submitted by the request of the United States Environmental Protection Agency Region III (EPA) as your Agency considers our request for an extension of the time to complete the performance test on the thermal oxidizer, which was installed as part of our Project XL agreement. As you know, due to various startup difficulties we have not yet completed the performance test. As you also know, we have requested and received a 60-day extension of the performance test deadline from the West Virginia Office of Air Quality, as regards our Consent Order and Regulation 13 Permit. We are requesting a similar 60-day extension from EPA for our proposed site-specific rule. This document contains information on the problems surrounding the design, installation, and testing of this unit.

Witco is committed to meeting the goals and deadlines associated with our XL project. Unfortunately, there have been issues beyond our control on the startup of the oxidizer and as a result, we were unable to complete the performance test in the time period (60 days after startup) specified in the FPA. As EPA is aware, the 60 day agreement for completing the performance test was an aggressive schedule (180 days is typically allowed under the HON for units of this type) and was agreed to based on the assumption of a relatively problem free startup. Since the initial startup of the oxidizer, we have spend -- all anticipated: numerous consultant and vendor hours; over 200 Witco maintenance hours; many more uncounted hours by Witco personnel in engineering, production, environmental protection, and research and development; and over $30,000 in expenses for material and maintenance labor directly attributable to Oxidizer startup. a summary of events related to startup is below.

Since April 1 (our commitment date to have the oxidizer running) the Capper Unit has not operated unless the Thermal Oxidizer was operating, except as provided under the Start-up, Shutdown, and Malfunction provisions of our permit, state consent order, and proposed federal rule. Therefore, we have met the requirements of the XL agreement in terms of reducing, to the maximum extent possible, the organic air emissions from the Capper Unit since April 1.

Methyl Capper Thermal Oxidizer Startup Summary -- 1998

January 1998 Installation process begun (steel support work, piping, etc.).

January-March Installed Oxidizer, instruments, piping, etc.

March 23-26 Various checkouts of instruments after installation.

March 26 Lit natural gas briefly and experienced instrumentation problems.

March 30 Lit natural gas briefly to check controls.

April 1 Shut down Capper Unit production (until April 14; shutdown was unplanned).

April 1 Lit Oxidizer and began heatup and "baking" of refractory (thus meeting the April 1 FPA deadline for startup). 2300-2400 F is required for the baking.

April 3 to 6 Attempted to get temperature above 1600 F with no success.

April 7 Concluded a bigger burner was needed and it was ordered.

April 8 Removed burner and found that wrong burner had been installed at factory.

April 10 Reinstalled modified burner after also making modifications to refractory at burner opening.

April 11-13 Lit burner and began to maintain temperatures above 1600 F. (1600 F is the minimum operating temperature required by the FPA). Additional checkouts and minor adjustments.

April 14 Capper Unit began operation with Oxidizer running.

April 17 Capper Unit shut down due to water leaks that developed from the Oxidizer quench (at flange between transition elbow and quench itself, hereafter referred to as water lead from quench); control sensitivity concerns raised; between Capper product runs, did some maintenance.

April 19-29 Oxidizer running; 2 Capper product campaigns completed; Oxidizer and Capper run - 9 days.

April 30 Capper Unit down; Oxidizer going down to prepare for maintenance.

May 1 Removed refractory lined elbow to repair leak from quench and discovered refractory was seriously eroded due to water impinging up into the elbow. Elbow is sent off-site to be re-lined with a different type of refractory.

May 4 Action and modification plan developed to prevent further erosion of refractory lined elbow. Actions planned to remove bits of refractory out of quench and scrubber water lines.

May 7 Re-lined elbow received on-site.

May 8 - 15 Elbow is replaced; sleeve installed into elbow and quench in effort to prevent recurrence of refractory erosion and to stop water leak from quench; refractory cleared out of water lines; several other miscellaneous mechanical items completed.

May 15- 20 Oxidizer re-lit; heating to cure new refractory; further maintenance on water lines and water leak from quench.

May 21 Oxidizer at temperature and Capper Unit restarted.

May 21 -31 Oxidizer running; Capper Unit running; water leak from quench continues; Oxidizer and Capper run ~ 11 days.

May 21 Witco via telephone notifies both West Virginia Office of Air Quality (WVOAQ) (Jonathan McClung) and Region III EPA (Beth Termini) that we could not meet the 5/31 deadline for performance test, and that Witco requests a 60 day extension to the deadline. Witco's questions are: will this be acceptable, and how to carry out an extension? Witco learns from EPA that final site specific rule had not yet been sent for publication, therefore no federal regulatory deadline currently exists.

May 26 WVOAQ via telephone conceptually agrees to extension and asks Witco to propose language for the written agreement to modify the existing Consent Order. Witco notifies EPA via email of this process.

May 27 Witco provides to WVOAQ draft language for agreement.

May 27 Water leak from quench continues but at a lesser rate; Vendor contacted to develop solution.

May 29 WVOAQ issues to Witco a letter for the Reg 13 permit and a signed agreement for the Consent Order. Each allows the deadline for performance test to be extended by 60 days. Witco notifies EPA via email of this action.

June 1-5 Capper down for maintenance on Capper Unit; Oxidizer running on standby; water lead from quench continues.

June 4 EPA via telephone tells Witco of its decision on how to handle performance test deadline extension and requests explanation for Witco's request to serve as basis for the extension.

June 6-7 Oxidizer running; Capper Unit running; water lead from quench continues; Oxidizer and Capper run ~2 days.

June 8 Oxidizer and Capper Unit down, due to need to repair water leak from quench.

June 9 Oxidizer contractor on-site for discussions of plans for repair.

Prior to May 21st, when we requested the performance test extension, the Oxidizer and Capper Unit had run only sporadically, for a total of about 11 days. As of today the units have run about 24 days. That has not been enough time to "shake-down" the equipment, and be prepared for the performance test.

As you can see, there have been many unexpected difficulties with this startup. Our vendor has not encountered problems such as these in prior startups, and in fact one of the reasons for their selection was their previous experience with design and installation of thermal oxidizers. However, OSi Specialties has encountered design, construction, and operational problems with this Oxidizer. Due to our commitments in Project XL, and the need to satisfy customer demand for our products, we have moved as expeditiously as possible to resolve problems as they have been encountered.

If you have any questions please call me at 304-652-8131.

Sincerely,

Okey Tucker
Environmental Technology Manager

cc: Jonathan McClung - WVOAQ
D.R. Heintzman
A.J. Vandenberg
J. Nortz
file

January 1998	Installation process begun (steel support work, piping, etc.).
January-March	Installed Oxidizer, instruments, piping, etc.
March 23-26	Various checkouts of instruments after installation.
March 26	Lit natural gas briefly and experienced instrumentation problems.
March 30	Lit natural gas briefly to check controls.
April 1	Shut down Capper Unit production (until April 14; shutdown was unplanned).
April 1	Lit Oxidizer and began heatup and "baking" of refractory (thus meeting the April 1 FPA deadline for startup). 2300-2400 F is required for the baking.
April 3 to 6	Attempted to get temperature above 1600 F with no success.
April 7	Concluded a bigger burner was needed and it was ordered.
April 8	Removed burner and found that wrong burner had been installed at factory.
April 10	Reinstalled modified burner after also making modifications to refractory at burner opening.
April 11-13	Lit burner and began to maintain temperatures above 1600 F. (1600 F is the minimum operating temperature required by the FPA). Additional checkouts and minor adjustments.
April 14	Capper Unit began operation with Oxidizer running.
April 17	Capper Unit shut down due to water leaks that developed from the Oxidizer quench (at flange between transition elbow and quench itself, hereafter referred to as water lead from quench); control sensitivity concerns raised; between Capper product runs, did some maintenance.
April 19-29	Oxidizer running; 2 Capper product campaigns completed; Oxidizer and Capper run - 9 days.
April 30	Capper Unit down; Oxidizer going down to prepare for maintenance.
May 1	Removed refractory lined elbow to repair leak from quench and discovered refractory was seriously eroded due to water impinging up into the elbow. Elbow is sent off-site to be re-lined with a different type of refractory.
May 4	Action and modification plan developed to prevent further erosion of refractory lined elbow. Actions planned to remove bits of refractory out of quench and scrubber water lines.
May 7	Re-lined elbow received on-site.
May 8 - 15	Elbow is replaced; sleeve installed into elbow and quench in effort to prevent recurrence of refractory erosion and to stop water leak from quench; refractory cleared out of water lines; several other miscellaneous mechanical items completed.
May 15- 20	Oxidizer re-lit; heating to cure new refractory; further maintenance on water lines and water leak from quench.
May 21	Oxidizer at temperature and Capper Unit restarted.
May 21 -31	Oxidizer running; Capper Unit running; water leak from quench continues; Oxidizer and Capper run ~ 11 days.
May 21	Witco via telephone notifies both West Virginia Office of Air Quality (WVOAQ) (Jonathan McClung) and Region III EPA (Beth Termini) that we could not meet the 5/31 deadline for performance test, and that Witco requests a 60 day extension to the deadline. Witco's questions are: will this be acceptable, and how to carry out an extension? Witco learns from EPA that final site specific rule had not yet been sent for publication, therefore no federal regulatory deadline currently exists.
May 26	WVOAQ via telephone conceptually agrees to extension and asks Witco to propose language for the written agreement to modify the existing Consent Order. Witco notifies EPA via email of this process.
May 27	Witco provides to WVOAQ draft language for agreement.
May 27	Water leak from quench continues but at a lesser rate; Vendor contacted to develop solution.
May 29	WVOAQ issues to Witco a letter for the Reg 13 permit and a signed agreement for the Consent Order. Each allows the deadline for performance test to be extended by 60 days. Witco notifies EPA via email of this action.
June 1-5	Capper down for maintenance on Capper Unit; Oxidizer running on standby; water lead from quench continues.
June 4	EPA via telephone tells Witco of its decision on how to handle performance test deadline extension and requests explanation for Witco's request to serve as basis for the extension.
June 6-7	Oxidizer running; Capper Unit running; water lead from quench continues; Oxidizer and Capper run ~2 days.
June 8	Oxidizer and Capper Unit down, due to need to repair water leak from quench.
June 9	Oxidizer contractor on-site for discussions of plans for repair.

Crompton Corporation (Formerly Witco Corporation)

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