DEVROHTEEPAKTm November 4, 1998 Mr. Doug Bell Organic Chemicals Group Emissions Standards Div. (MD-13) USEPA OAQPS Research Triangle Park, NC 27711 Dear Mr. Bell: Enclosed please find the "Clarifications of Devro-Teepak Section 114 Survey Response" that was requested in your September 3, 1998 correspondence. Devro-Teepak considers much of this information to be highly confidential and expects the EPA to treat it appropriately. A copy is enclosed with all confidential information removed. Sincerely, 96ia)azi hohn W. Webster Manager, Regulatory Affairs JWW/jsg Enclosure Registered Devro-Teepak, Inc., 915 N. Michigan, Danville, IL 61832 Tel: 217.446.6460 Fax: 217.442.2617
Transcript
DEVROHTEEPAKTm
November 4, 1998
Mr. Doug Bell Organic Chemicals Group Emissions Standards Div. (MD-13) USEPA OAQPS Research Triangle Park, NC 27711
Dear Mr. Bell:
Enclosed please find the "Clarifications of Devro-Teepak Section 114 Survey Response" that was requested in your September 3, 1998 correspondence. Devro-Teepak considers much of this information to be highly confidential and expects the EPA to treat it appropriately. A copy is enclosed with all confidential information removed.
Sincerely,
96ia)azi hohn W. Webster Manager, Regulatory Affairs
JWW/jsg
Enclosure
Registered
Devro-Teepak, Inc., 915 N. Michigan, Danville, IL 61832 Tel: 217.446.6460 Fax: 217.442.2617
Enclosure 1
Clarifications of Devro-Teepak Section 114 Survey Response
1. Please provide the annual quantity of cellulose fiber used to produce viscose.
2. Please provide a diagram of the gas flow system associated with extrusion, coagulation, regeneration and washing of the cellulose food. casings (i.e., the extrusion machines, starting with extrusion of the viscose through washing of the cellulose food casings with water and prior to drying of the food casings). Please identify the following: (a) each separate enclosure (cab"); (b) fans used to motivate air to and from each cab (include fan speed); (c) ductwork diameter and type (e.g., 12-inch fiber-reinforced plastic piping), starting with the first ductwork that leaves each cab; (d) cab size and material of construction (e.g., 30 feet high, 20 feet wide, 20 feet long, made of plexiglass); (e) estimated gas flow rate from each cab; and (f) estimated CS2 concentrations in the gas stream immediately exiting from each cab.
Please clarify emissions for process machines 8 through 10 for the Flat Goods process. Do scrubbed emissions from extrusion/regeneration go to Stack S-4 and unscrubbed emissions from washing go to Stack S-3? Also, please provide total CS2 emissions from the plant.
Please provide the following information regarding the acid recovery area at your plant-(a) total flow rate (gpm) of liquid sent to the acid recovery area; (b) concentration (ppm). of CS2 in the liquids entering the acid recovery area; (c) flow rate of liquid exiting the acid recovery area that is recycled to the plant and the concentration of CS2 in that stream; and (d) the flow rate of liquid exiting the acid plant that is sent to wastewater treatment and the concentration of CS2 in that stream.
5 Please provide the gas flow rate (acfm) and CS2 concentration (ppm) from each process vent in the acid recovery area, starting at the earliest release of the gas from each piece of equipment.
Please provide an estimate of the reduction in CS2 emissions that have been the direct result of a source reduction measure (e.g., process/equipment change) implemented at your plant since 1990. For each source reduction measure: (a) describe the process/ equipment change; (b) indicate when the change was implemented (year); (c) specify how the reduction in CS2 emissions is measured (e.g., reduction in the ratio of CS2 to cellulose added in the reactors, decrease in the amount of viscose used per foot or cubic foot of product, etc.); and (d) quantify the emission reduction using the format described in (c).
7 Please provide the overall. plant-wide control efficiency resulting from both pollution reduction measures (e.g., control devices) and source reduction measures (e.g., process/equipment changes) at the plant.
8 Is sodium sulfate (Na2SO4) added to the process? If yes, where is it added?
NOTE: Please use 1997 as the basis for all of your estimates.
Clarification of Devro-Teepak Section 114 Survey Response
1. pounds of cellulose fiber were used to produce viscose in 1997. Devro-Teepak uses either Buckeye V5 or Rayonier Ultranier J pulp. The EPA needs to remember that, as presented by Mr. Kapoor on 7/28/98, the different industries identified as Miscellaneous Cellulose Manufacturing Industry use different varieties of cellulose which come from different sources, e.g. softwood vs. hardwood. Food casings use the highest quality wood pulp made with approximately 98% alpha cellulose. This is needed to achieve the necessary casing strength. Other industries use significantly lower purity pulp. They do not need the higher strength and stretch characteristics required by the stuffing operations of meatpackers. The lower purity material allows them to dissolve it with less carbon disulfide.
2. We have attempted to answer the information requested under item 2 by using Attachment 1, Generic Ventilation System and Attachments 2-9, which are Tables 1-8.
As you will recall from your site visit at Devro-Teepak, each line of Wienie-Pake and Deli-Pak@ casings is produced by extruding viscose through a die and around a mandrel in its own "B" tank. The extrusion area is enclosed above the "B" tanks on each machine and across the carryover rolls. This area is referred to as the extrusion cab.
The tubing is directed to a series of acid tanks and then water tanks, where the regeneration is completed and the casing is washed free of contaminants. The tanks are side by side and are contained in a single enclosure with access available at each tank. This enclosure is also referred to as a cab. Machine 7 is the newest machine and has individual enclosures over each acid or wash tank.
With Process Machines 9 and 10 producing Fibrous products, viscose is extruded on the inside and outside of a cylinder of hemp fiber paper. There are two "B" tanks on each machine. The acid and wash tanks are contained in a single enclosure.
Cab sizes and material of construction are included in Attachment 2, Table 1.
Ventilation of the equipment is primarily handled by the stack fans. We have four stacks, with each having two 73 inch fans powered by 200 horsepower motors. One fan operates while the other is in reserve. Each machine also has a 20 horsepower booster fan which is located on the vapor discharge side of the hydrogen sulfide scrubber. The booster fans are not presently used on any of the Wienie-Pak machines. They are
JWW-EPA2.doc 1
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being used on PM's 8, 9 and 10 to allow Stack S-3 to ventilate other parts of the operation.
Each Wienie-Pak extrusion cab is ventilated through the top of its enclosure and the vapors are scrubbed.
Process Machine 8 uses two ducts to ventilate its cab.
The B tanks on Machines 9 and 10 have sill vents on the north and south sides of each tank, with duct work on each end of the sill vents.
Each acid and wash tank on each machine is ventilated through sill vents which are located on opposite sides of the tanks just above the liquid levels. Most are on the east and west s.ides, although some are on the north and south sides because of retrofit considerations. Vapors from the first three tanks are collected and scrubbed. On Machine 7, the first six tanks are scrubbed. Vapors from the remaining tanks in the process machines are manifolded together, and since they contain no significant amount of hydrogen sulfide, they bypass the scrubbers and join the trunk line to the stack.
We have provided, in Attachment 3, data for vapor streams into the scrubbers (E and B in Attachment 1), and the unscrubbed trunk lines (D in Attachment 1) for Process Machines 4, 5, and 6. We cannot safely get to similar lines on the other machines. However, we believe these concentrations and flows to be representative of other machines.
All ductwork for the process machines is constructed of Quagor Furan FR 1200 Resin. Ductwork sizes from the machine enclosures to the roof ventilation fans are:
Scrubbed (F) Inches Unscrubbed (D) Inches
42 36 42 36 42 36 48 42 42 42 42 42 42 42
All of the data regarding gas flow rates and CS2 concentrations presented in this response are based on limited sample results. While it is the best information we have at this time, there is a low confidence level that it is a valid representation of the individual airstream.
PM
1 2 3 7 a 9
10
JWW-EPA2.doc 2
Attachment 3 specifically provides information requested in Item 2 c, e, and f; however, we believe that the EPA is really interested in concentrations leaving individual wash tank areas. We have provided, in Attachments 4 through 9, specific concentration and flow data for the risers from the individual process tanks (K and "C" in Attachment 1). While the general setup and ventilation is similar on the process machines, there are some specific differences based on machine age, and the ventilation design and installation requirements after the decision was made to switch to sill vents after a fire in 1987.
Attachment 4, Table 3, provides information which we consider to be representative of Process Machines 1, 3, and 4.
Attachment 5, Table 4, provides information on Process Machine 2. This machine is primarily ventilated from only the east side.
Attachment 6, Table 5, provides information for Process Machines 5 and 6. Samples representing emissions from individual tanks are not able to be obtained.
Attachment 7, Table 6, provides information for Process Machine 7. This is our newest machine and is unique.
Attachment 8, Table 7, provides information for Process Machine 8. This machine is also unique.
Attachment 9, Table 8, provides data representative of Process Machines 9 and 10, our Fibrous machines.
3. The scrubbed emissions from Process Machines 8, 9, and 10 go to stack S-3. The unscrubbed emissions from 8, 9 and 10 go to stack S-4. The total CS2 emissions from the plant in 1997 as identified in our 114(a) survey response was 3,838,951 pounds in air and 35,780 pounds transferred to POTW via waste water.
4. Please refer to Attachment 10, Acid Recovery Flows — General, for information requested in Item 4. Attachment 11 identifies the individual equipment indicated as Acid Recovery in Attachment 10.
Water and sodium sulfate are continually being produced from the neutralization of the sodium hydroxide in the viscose during extrusion and regeneration. Since the acid and salt concentrations are important to the coagulation/regeneration reactions, steps must be taken to control them. Concentrated sulfuric acid is continually added to one of the acid
JWW-EPA2.doc 3
circulation tanks in the basement and slip streams from the recirculated acids are sent to the crystallizers and the evaporators. Water is removed by evaporation; sodium sulfate is removed by crystallization, isolated, and sold. Solutions with reduced water and with reduced sodium sulfate are circulated back to the basement acid systems.
We do not have a lot of information regarding CS2 concentrations in these streams. What data we have were obtained when preparing our Title V application. They do not show significant CS2 emissions from this operation, as we expected.
5. Our understanding of process vent is the point where the process vents to the atmosphere. We have provided that information in the initial 114(a) Survey. The process vents from the entire plant were identified as B-1, B-2, Ripening, S-1, S-2, S-3, S-4, LA-1 and LA-2. As identified in Attachment 10, the Cooling Towers could also be considered as a process vent. Carbon disulfide concentrations are non-detectable at this point.
The question seems to be addressing vapor streams leaving every single _ piece of equipment even though many are manifolded together. We do not have this information, and in most cases, we are not able to obtain it. Ventilation duct work was not installed in a way that would allow the correct sampling of the vapor streams. Based upon our experience we do not believe that significant concentrations would be found in the acid recovery area, if we could obtain the samples.
6. This item asked for an estimate of the reduction in CS2 emissions from source reduction measures. This is not as easy a question as with some production processes. There are two different production processes (Fibrous and Wienie-Pak). Different size products can run at different speeds. The larger the diameter of the casing, the more viscose is used, and the more total CS2 emissions are geherated. Considering these confoUnders we can provide the following information:
In 1997, in batches...of viscose were used for Wienie-Pak and Deli-Pak production, and MN batches were used for Fibrous. Emissions of CS2 are directly proportional to the amount of viscose extruded.
a) Source Reduction — Reduced Cellulose
In 1991, a project was implemented to reduce the amount of viscose used to produce Fibrous casings. The total amount of viscose used was reduced by 20% resulting in a 20% reduction in the amount of CS2 emitted from the production of Fibrous casing
JWW-EPA2.doc 4
when measured on a per unit length of product basis. This was a legitimate reduction; however, it was offset by an increase in speed of production so that there was no net decrease in overall plant emissions.
Using the 1997 viscose usage fi9yres without the reduction, Fibrous production would have required batches of viscose to produce the same amount of casing.
b. Source Reduction — CS2 Reduction
In 1996, a process change was made that reduced by :;lipounds the amount of carbon disulfide used in each batch of viscose that was produced. Since viscose is used in Fibrous, Wienie-Pak, and Deli-Pak, this approximately NI reduction has yielded a proportional reduction in CS2 emissions based on the viscose used. This was not reflected in plant total emissions, however, because the reduction was offset by production rate increases.
Without the CS2 reduction the amount of CS2 emission in 1997 would have been
c. Source Reduction — Stretched Casing
In 1997, we started the implementation of a project to stretch Wienie-Pak casings. Patents have been applied for around the world.
After the casing has been extruded and before it enters the dryer, the casing is stretched, primarily longitudinally. This orients the casing and provides beneficial properties over unstretched casing. When stretched longitudinally, it also yields more meters of casing per batch of viscose extruded.
This project is continuing. The increased tension during stretching has caused some operational problems that are still being addressed. Although new problems have arisen, they have more than been compensated by the improvements from the stretching operation.
The effect in 1997 of the stretching has been estimated to equal batches of viscose used for the Wienie-Pak production.
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d. Source Reduction — Nitrogen Tank Car Unloading
In 1997, a bulk nitrogen system was installed to allow the switch from water unloading to nitrogen unloading of carbon disulfide tank cars. Previous to the change, water was added to the top of the tank car and CS2 was forced out the bottom and into the storage tank. When the tank car was empty of CS2, the water would then be drained from the tank car.
The Handbook of Chemistry and Physics identifies the solubility of CS2 in water at .22 grams per 100 ml of water at 22°C. The change has produced a reduction in CS2 emissions, but we have not attempted to quantify the amount, because of the varying temperature conditions and inability to determine if equilibrium is reached.
Based on the 1997 production data and determining the effect of (a), (b), and (c) above, an estimate of the reduction in CS2 emissions as a result of source reduction can be shown by the following table:
Batches Used 1997
Needed Without (a) Reduced Cellulose
Needed Without (c) Stretched
Casino
1997 Effect of (b) Production CS2 w/o (a) & (c) Reduction
PM 1 — 8 PM 9 & 10
Total
Based upon 1997 production, CS2 emissions were approximately /0 less than what they would have been without the three source reduction projects.
7. Overall, Plant-Wide Control Efficiency
An estimate of CS2 reduction from three source reduction projects was discussed in Item 6. There have been no other attempts to control CS2 emissions because of the costs associated with any control techniques needed for the dilute streams. While reviewing our operation and taking additional sampling data for the MACT determination process, we have found that the results show some reduction of CS2 across the scrubbers. Supplier information shows that carbon disulfide will react with aqueous sodium hydroxide or sodium sulfide to form sodium trithiocarbonates. We
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have been unsuccessful so far in identifying these materials in the scrubber liquid.
We are continuing to look into this situation to confirm this reduction and to quantify it. We expect to be able to supply EPA additional information on this subject by December 10, 1998.
Devro-Teepak has determined through measuring the efficiency if its hydrogen sulfide scrubbers and comparing that to its production rates that approximately 30 pounds of hydrogen sulfide is produced per batch of viscose extruded, and a minimum of 90% of it is controlled in the scrubber. The 30 pounds represents about of the CS2 charged to the process.
8. Sodium sulfate is not added to the process. It is formed in the process when sodium hydroxide reacts with sulfuric acid, and is removed from the process through crystallization, dehydration, and drying and then sold.
9. As indicated in previous discussions, the domestic Cellulose Food Casing-Industry finds itself in a situation of expanding foreign competition and decreasing prices and profit margins. This situation must be thoroughly considered whenever the economic analysis required as part of the MACT determination process is completed. Illustrative of this situation is Attachment 12. This is a copy of an internal Devro-Teepak report generated from Bureau of Census data.
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TABLE 1
Machine Dimensions
Reference Generic Ventilation System
A. Extrusion Cabs
Material of Construction - Quacior Furan Resin FR1200 Windows - Plexiglas
B. Wash Enclosure
Material of Construction - Qua:for Furan Resin FR1200 Windows - Plexiglas
*Only machine with eighteen individual tank enclosures.
Extrusion Cab (E)
Duct Size
PM WI
4 36
5 26
6 26
CS, (ppmV)
Rate (acfm)
100 7,775
105 10,784
105 11,384
TABLE 2
Cab Flows and Concentrations
Reference Generic Diagram of PM
Wash
Duct Size Lirù
Scrubbed Enclosure
CS, (ppmV)
Section of (B)
Rate
Wash
Duct Size firA
Unscrubbed Enclosure
CS, ippmV)
Section of (D)
Rate acUrn
36 160 10,072 36 195 8,129
36 135 7,069 30 190 10,677
36 200 8,129 30 210 9,572
NOTE: All ductwork - Quacior Furan Resin FR1200
-; scot, tricow
TABLE 3
PM #1
Date: 09/17/98
Process Tank
Diameter act)
East Side Riser
CS2 Avg. Flow fppmV) • ‘fLiii
West Side Riser
Diameter CS2 Avg. Flow fial (opmV) fmf._ im
B-tanks 16 300 942 16 250 698
1 16 150 2,268 16 100 2,599
2 14 300 1,949 14 • 200 1,842
3 14 400 1,135 14 180 • 1,121
4 14 390 1,292 • 14 200 947
5 14 200 1,175 14 100 1,295
6 14 100 1,015 14 60 1,121
7 14 22 748 14 5 748
I "S
TABLE 4
PM #2
Date: 09/17/98
East Side Riser West Side Riser
Process Tank
Diameter •
CS, DpmV)
Avg. Row Diameter (p_dL)n (jn)
CS2 ippmV)
Avg. Flow jgcf_Lin
B-tanks 18 200 2,605
1/2 16 250 2,618
2/3 12 200 1,806 14 125 2,243
3/4 14 300 2,456
4/5 14 250 2,376
5/6 14 250 3,151
6/7 14 50 2,163
7/8 14 100 2,002
TrA m -1-(,
TABLE 5
PM #5
Date: 09/17/98
Process Tank
1,2,3 Trunkline
4,5,6,7 Trunkline
3,4,5,6,7 Trunkline
5/6
CS, Avg. Flow Size ippmV) Os.f_jm
16" 100 7,136
25 1/2"
17 1/2" 150 7,812
27 1/2"
13 1/2" 100 5,621
•25 1/2"
West Side Riser
CS, Avg. Flow Size (ppmV)
East Side Riser
47rAci 4 in EAir 7
TABLE 6
PM #7
Date: 09/17/98
East Side Riser West Side Riser
Process Diameter CS2 Avg. Flow Diameter CS2 Avg. Flow Tank (ppmV) fggfr_01 firl) fpomV)
Notes: (1) Information obtained from the Bureau of the Census (Artificial Guts o( Cellulose Plastic Material (3917101000)) (2) Conversion based on a theoretical code mix (B) Actuel invoiced meters for 1994 were 217,948,504 or 96.7% of the calculated value.
