DEQ-CFW_00086649

RSU Process Fugitive Emission Determination
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Fugitive and Equipment Emissions Determination (Non -point Source):
Fugitive (FE) and Equipment Emissions (EE) are a function of the number of emission points in the
plant (valves, flanges, pump seals). The inventory shown below is conservative and based on plant
and process diagrams. Note that the calculations below include equipment emissions inside
as well as equipment emissions outside (fugitive emissions).
A. Equipment emissions from SU Reactor, Rearranger, RSU Still and RSU Hold Tank:
Emissions are vented from equipment located inside the RSU barricade and -are vented to a vent
Barricade:
Valve emissions: 250 valves x 0.00036 Ib/hr/valve = 0.090 Ib/hr EE
Flange emissions: 550 flanges x 0.00018 Ib/hr/flange = 0.045 Ib/hr EE
Total equipment emission rate = 0.135 Ib/hr EE
Days of operation = 117
On average 0.13 Ibs of HF are produced for every 1 lb of RSU, SU or PAF.
VOC: 0.135 Ib/hr EE
x 24 hours/day
x 117 days/year
= 378.1 Ib/yr VOC from EE
HF: 0.135 Ib/hr EE
x 24 hours/day
x 117 days/year
x 0.13 lb HF per lb VOC
49.1 Ib/yr HF from EE
B. Fugitive Emissions From S03 Storage Tank and Vaporizer
This equipment is not inside a building, therefore emissions are true Fugitive Emissions
Valve emissions: 85 valves x 0.00036 Ib/hr/valve = 0.031 Ib/hr FE
Flange emissions: 180 flanges x 0.00018 Ib/hr/flange = 0.032 Ib/hr FE
Total fugitive emission rate = 0.063 Ib/hr FE
S03: 0.063 lb. FE/hr H2SO4: 0.063 lb. FE/hr
x 24 hours/day x 24 hours/day
x 117 days/year x 117 days/year
176.9 Ib/yr S03 from EE x 1.225 lb H2SO4 per lb S03
= 216.7 Ib/yr H2SO4 from FE
C. Fugitive Emissions From EDC Tank
This equipment is not inside a building, therefore emissions are true Fugitive Emissions
Valve emissions: 20 valves x 0.00036 Ib/hr/valve = 0.007 Ib/hr FE
Flange emissions: 10 flanges x 0,00018 Ib/hr/flange = 0.002 Ib/hr FE
Total fugitive emission rate = 0.009 ib/hr FE
VOC: 0.009 Ib/hr FE HF: 0
x 24 hours/day
x 117 days/year
25.3 Ib/yr VOC from FE
DEQ-CFW 00086649

RSU Process
Fugitive Emission Determination
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D. Total RSU Plant Non -Point Source Emissions
Equipment
Emissions
Fugitive
Emissions
VOC
Ibfyr
HF
Ib/yr
VOC
Ib/yr
S03
Ib/yr
H2SO4
Ib/yr
Emission Source
A. Equipment Emissions from SU Reactor,
Rearran er, Still and Hold Tank
378.1
49.1
0
0
0
B. Fugitive Emissions From S03 Storage
Tank and Vaporizer
0
0
0
176.9
216.7
C. Fugitive Emissions From EDC Tank
0
0
25.3
0
0
Total for 2007
378.1
49.1
25.3
176.9 1
216.7
E. VOC Emission by Source Type
'a
® C
C
U) Y
C v
O r
N
d
2
tll
d C
> 2
cc
r
C 0
N
C
O
o 0
N f/i
E
0 R .Q
w tl/
o
cv
:.
�, ...
�c
I ,�
z
v
0
w,-
ww
w
a
w
TFE
3856.0
375.6
0
0
4231.E
PAF
10.7
1.0
0
0
11.7
RSU
3.6
0.4
0
462.0
466.0
SU
10.7
1.0
0
0
11.7
EDC 1
0
0
25.3
0
25.3
Total 1
3880.9
378.1
25.3
462.0
4746.2
Note: Speciated equipment emissions were estimated by assuming that each
compound's equipment emission concentration was equal to that compound's
stack emission fraction of the total stack emission.
Example: The TFE equipment emissions were determined by the ratio of the
TFE stack emission (1,997.9 ib) divided by the total stack emission (2,010.8 ib),
multiplied by the total equipment emissions (229.4 lb).
Specifically:. 3856.0 378.1 = 375.6 lb. TFE
3880.9
DEQ-CFW 00086650