Document 10dy71z1zgn0qyxYpVLJqmBYK
R&S 028865
November 17, 1983
Sherrie Arnold Fred Hoerger Ron Taylor Charlie Royalty Paul Rozas Ken West
REVISION OF VCM STANDARD MEETING OF VINYL INSTITUTE AND EPA
On November 15, 1983, a meeting of the Manufacturing Practices Committee of the Vinyl Institute and EPA was held in Durham, North Carolina. The meeting had two purposes -- to discuss the proposal by the Vinyl Institute to institute a numerical quantity limitation in the relief valve provision of the standard and to determine what work the contractor Radian was
to do for EPA.
Attendance at the meeting was as follows:
EPA Fred Dimmick
Leslie Evans
Bob Rosensteel
Gil Wood
(
Susan W-oe-d Yo
Radian
Clint Burklin
Karen Fidler Reese Howe 3ohn Spelling
Vinyl Institute of SPI
Roy T. Gottesman
Borden
W. Bailey Barton
Conoco
Doe Ledvina
B.F. Goodrich
W. C. Holbrook
Tenneco Polymers
3im Kachtick
Dow Bob Oubre
R&S 028866
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Numerical Limitation - ERA agreed that this was a viable approach, that is, the idea of allowing a set quantity limit of VCM released through relief valves per million pounds of production. They were concerned, however, that certain folks (Environmentalists) might regard this as backing off from the "zero" allowable which they have interpreted in the present standard. The Vinyl Institute's original proposal was 50 pounds per million pounds production for PVC plants and 25 pounds per million production for VCM plants.
The numerical values were to be based on a 12 month rolling average, that is, the total relief valve discharge pounds for the previous 12 months divided by the millions of pounds of produc tion for the same period. The numbers would be updated each month by dropping one month and adding the new month. Attach ment A shows the data in this form as compiled by the Vinyl Institute. The company names were omitted for confidentiality. I have marked our two plants which were submitted.
EPA's main concern in a calculated relief valve discharge was the uncertainty in the duration of release. They asked us to explore the possibility of some timing device for valve opening. We indicated that it was very unlikely something could be developed which would be reliable but we would think about it. They (EPA) suggested that one number which could be used that had no subjectivity was number of releases per 1000 batches of PVC or per million pounds of production. The problem with that (which everyone recognized) was the quantity per release could vary significantly. A combination of the two ideas might be an acceptable approach, that is, if the release were of a long enough duration that the time could accurately be measured by instrument charts, the quantity would be calculated, and if too short a duration it would not be calculated. The standard might then be based on a VCM pound limit and a number of discharges limit. EPA requested we gather additional data so that they could determine if acceptable limits could be established. We agreed to furnish the data as listed in Attachment B. Vinyl Institute will tabulate the numbers which will then be forwarded to EPA without company identification.
EPA had accumulated the relief valve data from Region VI which includes all our plants. The data is Attachment C.
The Radian folks then outlined their work under EPA's contract. They plan to visit a number of plants, mostly the new plants and plants with low VCM release history to determine how those plants are preventing the releases. The plants they presently plan to
R&S 028867
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visit are Goodrich at Peririckstown, New Jersey, Shintech at Freeport, Formosa at Point Comfort, Tenneco at Pasadena, and Borden at Illiopolis, Illinois. The subject of secrecy agree ments then came up and EPA revealed that their legal staff had advised that EPA's contractors not sign secrecy agreements with companies. Instead, a "Memorandum of Understanding" had been drafted by EPA's legal staff to cover confidentiality issues. The spokesmen for Goodrich and Borden, two of the plants to be visited, both objected and said secrecy agreements signed by Radian would be required. The subject remained at stalemate for the time being. A copy of the EPA proposed agreement is in Attachment D.
The timing of Radian's work is as follows:
Visit of plants complete by mid-December, 1983 for finding out release reduction techniques.
Put a package together for review by EPA by February, 1984.
Invite Vinyl Institute to review and comment by March or April, 1984.
Have revisions ready to go into Federal Register by end of 1984.
I will keep you informed of the status as it becomes available.
Robert R. Oubre pm VCM Technology Center
ATTACHMENT A
TWELVE MONTH ROLLING f^^GE INDEX*n
POUNDS VCM RELEASED PER MILLION POUNDS PVC PRODUCTION
PVC Plants
A 8 C D E F G H 1 J K L M N. 0 P 9 R S
Aug.
0.65 2.4 85 93.7 0 11 84 2 6.1 3.6 1.38 0.03 328.1 2.4 18 0.03 0 40.6 202
Sept.
0 2.3 84 93.0 0 10 0 0.3 6.5 0 1.38 0.03 289.8 2.1 17 0.03 0 38.1 208
1982 Oct.
Nov.
Dec.
Jan.
Feb.
Mar.
Apr.
1983 May
June
Jul y
Aug.
0 1.0 4.9 177.0 0 10 0 0.2 6.9 0 2.66 0.03 125.5 1.4 15 0.03 0 38.3 199
0 .7
4.8 176.0
0 10 0.006 0.2 0 0 3.53 0.03 146.6
1.4 15 0.03 0 37.5 198
0 .7
4.8 191 .0
0 8 0.008 0.2 0 0 4.87 0.03 151.4 1.3 14 0.03 0 36.5 1 15
0 5.0 2.5 225.0 0 8 0.008 0.2 47.7 0 14.5 0.03 150.4 1.4 14 0.03 0 35.5 122
00
4.9 4.9
2.9 2.9
219.0
219.0
0 3.2
87
0.008 0.008
00
47.8
47.4
00
Plant Closed
0.03
0.03
97.7
207.4
1.0 1.0
13 3
0.03
0.03
00
34.9
34.4
117 1 13
0 4.6 2.9 210.2 3.2 12 0.008 0 48.2 0 0.03 284.7 1.7 0 0 0 33.9 1 10
0 4.5 2.9 158.2 3.1 11 0.008 0 48.2 0 0.03 287.8 1.4 0 0 0 33.5 106
0.5 4.1 2.9 160.9 3.1 16 0.02 0 46.3 0 -
0.03 275.1
1 .4 0 0 0 34.1 103
0.5 4.0 2.9 147.3 3.2 10 0.02 0.2 44.6 0 0.16 279.9 1.3 0 0 0 39.8 8
0.5 10.3
1.6 146.9
7.4 10 0.02
3.0 44.8
0 1.2 255.0 1 .4 0.06 0 0 8.2 8
Mi 1 1 Ion Pounds Productlon*^*
260.6 265.2
265.2
262.5
272.5
279.3
278.6
284.0
280.4
284.2
288.9
295.6 298
* * * Each month Iy Index entry = The sum of all relief valve, rupture disc, and manual vent VCM releases for the previous I 2 mont hs dIv!ded by the sum of alI PVC production at the plant for the previous 12 months.
*2* Each monthly entry represents the sum of the previous 12 months PVC production for plants A through S divided by 12,
Source - The Vinyl Institute November 1983.
898820 S9U
TWELVE MONTH ROLL 1 ERAGE INDEX(,) POUNDS VCM RELEASED PER MILLION POUNDS VCM PRODUCTION
t
P Aj % ki i
VCM Plants
A B C OCP D E F G VCM I - LAH 1
Aug.
4.8 2 6.6 0.4 23.34 123 3.4 2.60 0.40
Sept.
4.7 0.2 6.5 0.13 26.98 124 3.4 2.61 0.37
1982 Oct.
Nov.
2.3 0,2 6.3 0.13 26.96 123 24.3 2.58 0.35
2.3 0.2 18.8 0.13 26.82 122 23.2 2.71 0.33
Dec.
2.3 0 16.3 0.13 4.11 58 23.9 2.87 0.31
Jan.
2.3 0 18.0 0.12 4.03 59 23.4 2.81 0.31
Feb.
2.3 0 17.8 0.12 4.05 59 23.5 2.90 0.85
Mar.
Apr.
2.5 0 17.8 0.13 6.65 61 23.5 2.94 0.78
2.9 6 . 16.7 0.12 7.53 64 32.9 0 0.47
1983 May
June
July
Aug.
5.8 6 15.6 0.12 7.37 62 34.0 0 37.92
5.6 6 15.5 0 7.08 0 34.2 0 37.38
3.1 5 1 5.0 0 6.91 0 34.3 0 36.57
3.1 5 10.6 0 7.50
.04 31.1
0 36.57
Ml 11 Ion Pounds Production**^
355.5 360.8
370.5
374.4
375.3
379.6
375
370.1
364.8 376.6
375.3
382.1 387
**> Each monthly Index entry = The sum of all relief valve, rupture disc, and manual vent VCM releasesfor theprevious 12 months divided by the sum of all VCM production at the plant for the previous 12 months.
*2) Each monthly entry represents the sum of the previous 12 months VCM production for plants A throughI divided by 12.
Source - The Vinyl Institute November 1983.
698820 SSU
n n, M r IDENTiAL'
ATTACHMENT B
^88Zo
PVC PLANTS
TWO-YEAR DATA ON A MONTHLY BASIS
August 1981 - August 1983
Plant
No. of releases/10^ PVC/mo. Lbs. released/10^ PVC/mo. No. of releases (<10,000 gal.)/10^ PVC/mo. No. of releases (>10,000 gal.)/10^ PVC/mo, Lbs. released (<10,000 gal.)/10*j PVC/mo. Lbs, released (>10,000 gal.)/10 PVC/mo. No. of releases (<10,000 gal,)/1000 batch N^^of releases (>10,000 gal.)/1000 batch Lq^P released (<10,000 gal.)/1000 batch
Lbs. released (>10,000 gal.)/1000 batch No. releases/mo. Lbs. released/mo.
Susp.
Process Disp. Mass
Non Reactor
Other Latex Source
VCM PLANTS
TWO-YEAR DATA ON A MONTHLY BASIS (All 61.65(a ) Sources)
August 1981 - August 1983
No. releases/10^ VCM/mo. Pounds VCM released/10^ VCM/mo. No. releases/mo. Pounds released/mo.
ATTACHMENT C
IE6IM VI VCH/WA MU SUfUlART - II YEAH
totem LACAI1DK
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U8830 SVU
OfitJ.. Jisdx , Cr~ JtA
'dt
REASON
OPERATOR ERROR PREMATURE RELEASE INSTRUMENT MALFUNCTION POWER FAILURE EQUIPMENT FAILURE UPSET CONDITIONS INCORRECT SRV SETTING UNKNOWN/NOT AVAILABLE
TOTAL OF DISCHARGES
BREAKDOWN OF RVDS 1977 - 1982
CONTROL
EDC/VCM PLANTS
PERCENT PERCENT
BY BY
NUMBER
WEIGHT
PVC PLANTS PERCENT PERCENT
BY BY NUMBER WEIGHT
OPERATOR TRAINING/SOP MAINTENANCE PROGRAM Q/A MAINTENANCE/REDUNDANT INSTR. BACK-UP POWER
/
I
i
43,8 6,1
21.5 3.8 6,9 8.5 3.1 6.2
45.2 4.3
19.6 11.0 10.6
4,2 3.2 1.8
30.5 9.0
26.9 1.2
20.3 6.0 0 6,0
42,2 32.5 18.5
1.4 1.8 0.6 0 2.9
130 213,000 lbs 167 366,000 lbs
ATTACHMENT D
MEMORANDUM ON CONFIDENTIAL TREATMENT OF CERTAIN INFORMATION FOR USE WITH SITE VISITS BY EPA AUTHORIZED CONTRACTOR REPRESENTATIVES UNDER
AUTHORITY OF SECTION 114 OF THE CLEAN AIR ACT 1. Pursuant to the provisions of Section 114 of the Clean Air Act, as amended, (source) (hereinafter "the source") will provide, or^give access to, information requested by the Environmental Protection Agency (EPA) in the course of carrying out its responsibilities. Such information and such access will be provided to EPA and to its duly authorized repre sentative (contractor) (hereinafter "the contractor") designated by EPA to assist EPA in carrying out such responsibilities pursuant to Contract No. with EPA. The information requested may be either documentary (e.g., records, photographs or charts) or non-documentary (e.g., oral communications, taking of photographs, or visual observations). EPA and the contractor recognize that the source may consider the informa tion so provided, or some part of it, to be confidential within the meaning of Section 114 and 18 U.S.C. 1905. The source may assert a claim of confidentiality under the procedures established in Part 2 of Title 40 of the Code of Federal Regulations (40 CFR Part 2) by noting such claim on documentary material provided to the contractor or to EPA. The contractor will note such claim when submitting the information to EPA. The EPA will note such claim when submitting such information to the contractor. Moreover, the source may notify the contractor or EPA that it considers the non documentary information provided to EPA or to the contractor to be confidential. The contractor will note said claim of confidentiality in any reports or documents submitted to EPA which utilize such non-documentary information. The EPA will note said claim of confidentiality in any reports or documents submitted to the contractor which utilizes such non-documentary information. Any material
R&S 028873
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R&S 028874
or information claimed as confidential will be treated by the contractor
as confidential in accordance with its contract and will be'treated by EPA
in accordance with the provisions of 40 CFR Part 2. Any material or
information for which a claim of confidentiality is not made may be made
available to the public by EPA without notice to the source.
2. The provisions in the contractor's contract with EPA concerning
the use and disclosure of confidential information are included therein
for the benefit of, and shall be enforceable by, both EPA and the source.
The provisions of Contract No. `
between EPA and
the contractor provide:
a. The contractor and its employees will: (i) use the
information claimed to be confidential only for purposes
of carrying out the work required by the contract; (ii)
not disclose the information to anyone other than EPA
employees without the prior written approval of the
Assistant General Counsel for Contracts and General
Administration; and (iii) return to the EPA Contracting
officer all copies of the information, and any abstracts
or excerpts therefrom, upon request by the Contracting
Office, whenever the information is no longer required
by the contractor for the performance of the work or
upon completion of the contract.
b. The contractor will obtain a written agreement to honor
the provisions of paragraph 2(a) from each of its employees
who will have access to the information, before the employee
is allowed access.
R&S 028875
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c. The contractor.will not use any information claimed to be confidential to compete with the source.
d. Before entering into any subcontract that will involve either the disclosure to a subcontractor by the contractor of informa tion claimed to be confidential, or the collection of information by a subcontractor, the contractor will obtain the written consent of the EPA Contracting Officer, after a written determination by the appropriate EPA program office.
3. Any subcontractor who will have access to the information is subject to the restrictions set forth in this memorandum.
4. It is intended that this memorandum be consistent with and not exceed the provisions of 40 CFR Part 2 and the provisions of Contract No. This memorandum does not address information not obtained from the source. Nothing in this memorandum relieves the contractor of any liability it may independently have to the source as a matter of statutory or common law from injury to the source arising from the contractor's release of information in a manner which exceeds its authority under 40 CFR Part 2 and its contract with EPA.
U.S. Environmental Protection Agency
By: ___________________________________ Date: ____________________
Company
By: Date:
Contractor
By: Date: