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Enron Mail |
The MTBE plant, located on 70 acres of land in Morgan's Point, can produce=
=20 17,000 barrels per day of MTBE. Feedstocks to the plant to produce the MTBE= =20 are methanol from Enron's methanol plant and normal butane from the Mt.=20 Belvieu underground storage facility. The emission sources at this facility= =20 are authorized under Texas Natural Resource Conservation Commission (TNRCC)= =20 air permits and authorizations (e.g., Standard Exemptions) and are not=20 "grandfathered" emission sources. Grandfathered emissions sources are sourc= es=20 installed in Texas before September, 1971 (that predate the Texas Clean Air= =20 Act) and are often uncontrolled. The major sources of NOx emissions at this plant are two boilers, an olefle= x=20 heater, and three hot oil heaters. All are currently controlled with low NO= x=20 burners, but will require more combustion controls and Selective Catalytic= =20 Reduction (SCR) to attain the strict limits in the proposed Houston=20 non-attainment regulations. The proposed limits are 0.01 pounds of NOx per= =20 MMbtu for the two boilers and oleflex heater, and 0.015 pounds of NOx per= =20 MMbtu for the smaller hot oil heaters. One third of the reductions must be= =20 attained by the end of 2002, two thirds by the end of 2003, and all=20 reductions must be completed (or emission credits purchased) by December 31= ,=20 2004. Major Volatile Organic Compound (VOC) emission sources at this facility=20 include storage tanks (controlled with floating roofs) and loading faciliti= es. The methanol plant, located on 20 acres in Pasadena, can produce 125,000,00= 0=20 gallons of methanol per year. Feedstocks to the plant to produce methanol a= re=20 natural gas and oxygen. Most of the emission sources at this facility are= =20 authorized under TNRCC air permits and Standard Exemptions, but some predat= e=20 the Texas Clean Air Act and are grandfathered. The major sources of NOx emissions at this plant are a reformer (heater) an= d=20 three natural gas-fired reciprocating engines. The reformer is currently=20 controlled with low NOx burners, but will require more combustion controls= =20 and Selective Catalytic Reduction (SCR) to attain the strict limit of 0.01= =20 pounds of NOx per MMbtu in the proposed Houston non-attainment regulations.= =20 The proposed limit for the engines (currently uncontrolled) is 0.017 grams= =20 per horsepower-hour. Although combustion controls and SCR are possible=20 control methods to attain this strict limit, they are unproven on engines,= =20 and it is likely that the engines will need to be replaced with electric=20 motors. One third of the reductions must be attained by the end of 2002, tw= o=20 thirds by the end of 2003, and all reductions must be completed (or credits= =20 purchased) by December 31, 2004. Major VOC emissions sources at this facility include storage tanks=20 (controlled with scrubbers) and loading facilities. The Bammel gas storage facility is located on Kuykendahl Road in north=20 Houston and is used for the underground storage of natural gas. The 15=20 natural gas-fired engines at this facility were replaced with electric moto= rs=20 in 1999. The estimated reductions of emissions by the replacements at this= =20 facility were 1,254 tons/year of NOx and 42 tons per year of VOC. Most of t= he=20 NOx credits have been sold to other companies under TNRCC=01,s current trad= ing=20 program, which is not a cap and trade program.=20 The remaining minimal emissions at this site are from the glycol dehydrator= s=20 (NOx and VOC), and storage tanks (VOC). The VOC emissions from the=20 dehydrators are already controlled with incinerators under current TNRCC=20 regulations. The 1999 emissions from the chemical plants as indicated in Enron=01,s EH&S= =20 Annual Report are 2,822 tons per year of NOx, 823.7 tons per year of VOC, a= nd=20 195 tons per year of Carbon Monoxide. Most of the NOx emissions are from th= e=20 uncontrolled engines at the methanol plant. The Cost Estimate for the installation of combustion controls and SCR, and= =20 replacement of the engines at the chemical plants is $30 to $40 million.
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