A Major Expansion of a Texas Chemical Plant

Water Reuse, Approaching Minimal or

No Discharge, Water Conservation, and

Environmental Control

prepared by

Davis L. Ford, Ph.D., P.E., National Academy of Engineering

Davis L. Ford & Associates

November 16-17, 2015

AIChE-ISWS Workshop: Water Efficiency in Downstream Refinery,

Petrochemical and Chemical Processing

Acknowledgments:

• Operations & Management Staff, Formosa Plastics

• Plummer & Associates, Austin

• Jim Blackburn

Section I. Table of Contents

• Section I. Table of Contents

• Section II. Introduction, Background, and Expansion Scope

• Section III. Chronology of Permitting and Implementation

Process

• Section IV. Treatment Plant Description (2015)

• Section V. Proposed Flow Diagrams and Candidates for

Expansion Water Demands

• Section VI. Current NPDES (TPDES) Discharge Permit

Limitations

• Section VII. References

Appendix A: Formosa Plastics Corporation Texas

Industrial Wastewater Treatment Plant (1992)

Section II. Introduction, Background,

and Expansion Scope

Formosa Plastics (Formosa Plastics Corporation, Texas)

has publicly announced a 5.5 billion dollar expansion to its Point

Comfort plant, following an increased demand for many of their

products (olefins, PVC, SPVC, LDPE, HDPE, caustic/chlorine, etc.).

The initial construction for this expansion commenced in late 2014

and is scheduled for completion in the next three to four years.

A primary focus of the company management planning

and utility support is directed toward the increase of freshwater

demand as well as associated infrastructure such as allocation

restrictions (Lavaca-Navidad River Authority, LNRA) combined

with new freshwater sources, such as proximate Formosa-owned

wells (Bell Wells), reuse of existing organic/inorganic wastewater

streams (current effluent from 101-organic streams currently

treated through the existing 3-train wastewater treatment system),

and combined with the inorganic wastewater stream (201),

resulting in the 001 permitted stream (001) discharged to Lavaca

Bay through an extended submerged pipeline with an end-of-pipe

disposal system and continual effluent monitoring program.

A total of approximately 12 to 13 million gallons per day

(MGD) of additional freshwater is required for this expansion.

Through the joint efforts of the FPCT management and technical

staff, the consulting firms of Plummer & Associates, Arcadis, the

author (Davis L. Ford & Assoc.), and advisor-attorney Jim

Blackburn, the engineering and planning is currently being

implemented. It is the intent of this technical paper to outline the

initial engineering reverse osmosis reuse possibilities and overall

planning to approach zero or reduction in plant effluent flow to

Lavaca Bay and production of high quality water to meet the

expansion water demands.

The Texas Department of Water Resources (TDWR) along

with the Environmental Protection Agency (EPA) drew regulatory

attention from the public and private sectors. Environmental

protection, regulatory controls, economics, water quantity and

quality, and health concerns were the dominant issues in the

region.

Multiple lawsuits were filed by public and private interest

groups objecting to the plant expansion. In 1992, extensive public

hearings were held in Austin, in which the author participated

representing Formosa interests and commitments. A discharge

permit with strict guidelines and commitments was issued to

Formosa. An extensive treatment complex was constructed in the

early 1990s at a cost of approx. 80 million dollars. This was the

highest cost per MGD capacity of any wastewater treatment

known by the author at that time.

Table III-1

Chronology of Permitting process

A Case History: Olefins

Formosa Plastics, Pt. Comfort, TX

1983 Original plant constructed

1986 Preparation of preliminary drawings and specifications

for major expansion

1986-87 Preliminary draft of permit applications submitted.

Extensive discussions with State/EPA/stakeholders

1988 Announces major expansion (over 700% of original production

1987-92 Extensive environmentally related technical reports,

EIS, air emission/water quality, hazardous waste

disposal issues

1992 Permit hearings

1993 Litigation issues settled

1993-94 Plant becomes operational

1998 Second major expansion announced

2000 Expanded plant, valued in excess of 3.5 billion dollars

2000-

2014 Continues process upgrades, recycle enhancement, capacity upgrades

and selective pretreatment based on production unit discharges to the

treatment complex. Permit compliance is under continuous surveillance

and correction measures are implemented as required. An “Industrial

Water Quality Control Environmental Report Card” is shown in Figure III-1.

As the aforementioned 5.5 billion dollar expansion is

currently underway, there is a possibility based on current and

planned water reuse technologies, treatability studies and

extensive technical oversight, that total water reuse and

reconfiguration, zero or minimal wastewater discharge is a

technical reality.

Section VII. References

• Ford, Davis L., Current Environmental Engineering and

Science Technologies, Eckenfelder Lecture Series, Forty Acres

Press, Austin (2012)

• Eckenfelder, W.W., Ford, Davis L., Englande, A.J., Industrial

Water Quality, 4th Edition, McGraw-Hill, Water Environment

Federation (2009)

• Formosa Plastics Corporation, Texas, “Industrial Water

Treatment Plant, Water for Recreation and Industry---A Story of

Progress” (1992)

• Blackburn, Jim, The Book of Texas Bays, A&M Press (2004)

Industrial Water Quality Control Environmental Report Card

(Ford, D., 2009)