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HOMO MONO
Dr. Hasmukh C. Shah Director Biomedical and Environmental
Special Programs Chemical Manufacturers Association 2501 M Street/ N.W. Washington, D.C. 20037
Dear Has;
I am enclosing a copy of proposed emission standards for vinyl chloride, which should be of interest to the EDC Panel.
Sincerely,
A) t,s *-------------
W. Caffey Norman, III
Enclosure
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Federal Register / Vol 50. No. 0 / Wednesday. January 9. 1965 / Propooed Rales
ENVIRONMENTAL PMOTlCTfON AGENCY
40 CFR Part Cl
[AD-FRL-2707-4]
National Emlaalon Standards for Hazardous Air Pollutants; Vinyl Chloride
aocncy; Envoronmental Protection Agency (EPA).
action; Propoaed rule and notice of public hearing.
summary: The current emiaaion standard for vinyl chloride (VC) waa promulgated under Section 112 of the Clean Air Act in 1978. A review of the technological basis and administrative aspects of the standard has been completed, and the conclusions of the review are presented in this notice The conclusions are the basis for this action which (1) proposes administrative and clarifying revisions la the standard and (2)"announces decisions pertaining to other aspects of the current standard. This notice also withdraws proposed revisions to the current standard which were published in the Federal Register on (une 2.1977 (42 FR 28154).
If requested, a public hearing will be held to provide interested persons an opportunity for ora) presentations of data, views, or arguments concerning the proposed revisions to the current standard.
Oates: Comments. Comments must be received on or before March 26,1906.
Public Hearing. If anyone contacts die EPA requesting to speak at a public hearing by January 30 IMS, a public hearing wih be held on February 20. 1985 beginning at 9:00 a.m. Persona interested fea attending the hewing should call Ms. Shelby Joumigan at (910) 541-5578 to verify that a hearing will occur.
Request to Speak at Hearing. Persona wishing to present oral testimony must contact EPA by January 3a IMS.
Incorporation by Reference. Dm incorporation by refsrenon gf certain publications in these staadjMrwill be approved by the Director ofthe Federal Register as of the datn at the Had rule.
snoRMttsfc Comments. Comments should be submitted (In duplicate If possible) to: Central Docket Section (A130), Attention Docket Number A-61-21. U.S. Environmental Protection Agency. 401M Street S.W.. Washington. D.C 20460.
Public Hearing. If anyone contacts the EPA requesting to speak at a public hearing by January 30.1985. the public hearing will be held at EPA Auditorium.
corner of Highway 54 and Alexander Drive. Research Triangle Park, North Carolina. Persons interested in attending the hearing should call Ms. Shelby Joumigan at (919) 541-5578 to verify that a hearing will occur. Persons wishing to present oral testimony should notify Ms. Shelby Joumigan. Standards Development Branch (MD-13). U.S. Enviromental Protection Agency. Research Triangle Park. North Carolina 27711, telephone number (919) 541-557*.
Background Information Document The general findings of the review study are documented in "Vinyl Chloride--A Review of National Emission Standards". EPA-450/3-82-003 (NTISPB 84-114354), available from this National Technical Information Service, 5285 Port Royal Road. Springfield, Virginia 22101. The major technical analysis for the review study is contained in a separate document which may be obtained from the U.S. RPA Library (MD-35), Research Triangle Park. North Carolina 27711, telephone number (919) 541-2777. Please refer to "Vinyl Chloride: Relief Valve Discharge Standard.'- EPA-450/3-85-002. Cor the
technical document Docket Docket No. A-81-21.
containing supporting information used in developing the proposed standard, is available for public inspection and copying between 8.-00 a.m. and 4.-00 pjnMonday throu^ Friday, at EPA's Central Docket Section. West Tower Lobby. Gallery 1. Waterside Mafl. 401M Street 5W.. Washington. D.C. 20400. A reasonable fee may be charged far copying.
eon suther information contact Mr. Robert E. Rosensteel or Mr. Leslie B. Evan*. (919) 541-5871. concerning technical aspects of the industry and control technologies, and Mr. Fred Dimndcfc or hfr. Gilbert H. Wood, (919) 541-5576, concerning regulatory decisions. The address for these contacts is Emission Standards sind Engineering Division (MD-13), U.S. Environmental Protection Agency, Research Triangle Park, North Caroline 27711.
aUFFLIMINTARY tNFORMATKMC
Summary of Revisions to Current Standard
Revisions. Several administrative changes are being proposed as a twdl of a review of the national emiaaion standard for VC. No major revisions are being proposed to the standard As with the current standard for VC <ha revisions araiwing established radar ` Section 112 of the Clean Air Act The significant administrative revhdone include: (1) Reformatting the Mission
limit /or relief valve discharges, (2}
providing a compliance test procsdwu
and a specific emission limit for
^
operators who perform stripping
operations in reactors, and (3) spedfytoy
requirements for leak detection and
repair programs for certain equipment in
VC service. Additional minor
administrative changes to the standard
are being proposed and are explained ^ later in this pramable.
Summary of Health, Environmental
Energy, and Economic Impacts. Since a
major revisions to the standard are
being proposed, the impacts resulting
horn the current standard remain
generally unchanged. In 1975, it was wtimeAsd that emissions of VC from
plants producing ethylene dichloride
(EDC), VC monomer and polyvinyl
diloride (PVC) would be reduced from
98.000 Mg/yr to 4,910 Mg/yr under the
current standard, representing an
amission reduction of 91.000 Mg/yr of
VC (or 95 percent of VC emissions).
Emissions of volatile organic compounds
(YOC) and EDC are also reduced under
the standard.
i
The eatimated risks attributed to *
exposure to VC from EDC/VC and PVC
plants in operation prior to the current
standard ware U cases per year for
Ever angiosarcoma and 11 cases per
year for all cancer* The risks attributed
to exposure to VC from sources under
the current standard have been
estimated to be 0.28 cases per year for.
Ever ragiosercoma and 055 cases per
year far all cancers.
In 1975. the estimated capital cost for
existing plants to meet the VC standard
was S198 million, of which $15 million
was for EDC and VC monomer plants
and $183 million was for PVC plants.
The EPA estimated that the annualized
cost (including capital amortization, etc.)
to these plants to maintain the required
emission levels would be $70 million per
year.
lackground
The VC standard was proposed on December 24.1973 (40 Fr 59532). and promulgated on October 21.1978 (41 Fr 40559). It ia applicable to plants producing EDC by the reaction of oxygen and hydrogen chloride with ethylene, plants producing VC by any process, and plants producting one or more polymers containing any fraction, of VC These plants are subject to different requirements at numerous VC mission points in the manufacturing process. These requirements include suMMrtcel emission limits, equipment specifications, and work practices.
The standard was designed to minimize the health risks associated
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F*d*cai Register / Vol. 5ft Na 6 / Wednesday, January 9, 1985 / Proposed Rule*
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with VC by requiring reasonable control measure*. As stated in the preamble to the proposed standard (40 Fr 58532. December 24.1975), then 1* no known threshold level of effect* for VC Therefore, the only approach that would
eliminate health risks associated with VC would ban its production and use. This approach was not selected. Rather,
an approach was selected to minimize the health risks associated with VC by use of ressonable control measure.
On November 19.1978, the Environmental Defense Fund (EDF) petitioned the United States Court of Appeals for the District of Columbia Circuit to review the standard. On March 24,1977. the EDF and the EPA moved to dismiss the proceedings on the basis of a settlement agreement requiring the EPA to propose amendments which would require increased efficiency of existing control
equipment require more stringent control of new sources, and prohibit increases in emissions within the vicinity of an existing source due to new construction. The preamble to the
proposed amendments was to state that the EPA'a policy for regulating carcinogens under Section 112 of the Clean Air Act would include a general
goal of eliminating emissions of carcinogens and that the EPA would initiate a review of the VC standard 3 years after the promulgation of the amendments.
On fun# 2.1977. the amendments were
proposed (42 FR 28154). Many comments pertaining to policy, technological feasibility, and procedural aspects of the
proposed amendments were received. Review of these comments indicated that additional technical data and cost information were required before the proposed amendments, or revisions of the proposed amendments, could be
promulgated-
Meanwhile, the EDF filed a petition with the EPA requesting the establishment of a comprehensive program for regulating airborne carcinogens under SectiOB lU Of the
Clean Air Act The aapegifof tha EDFs petition concerning the development of standards under Section 112 ware similar to those proposed in tha funs 2, 1977, amendments to fan VC standard. Baaed on the sfcntfaiiiy of the proposed amendments and the IDf^t reqnastad comprehensive program far regulating
airborne i sn lnnpnns tha EPA believed that it should not take fatal aefam on the proposed VC amendments until after it had acted on the EDFa petition,T
On October IB, 1879 (44 FR MM2), the
EPA proposed "Policy and Procedures for Identifying Aaaesain* and - <
Regulating Airborne Substances Posing
a Risk of Cancer." This proposal addressed several issues which were central to the proposed VC
amendments. It also articulated the EPA's conclusion that Section 112 does not express an intent to eliminate totally all risks from emissions of airborne
carcinogens. The EPA's selection Of the level of control for a hazardous air pollutant emission standard would not
be based on a policy that requires zero emissions of carcinogens. This policy is consistent with the basis for other recent actions under Section 112. For example, standards for benzent from coke ovens and leaks from equipment components in benzene service are not based on a zero emissions policy but rather on a reasonable level of control, which considers emissions and, health risks.
The EPA believee it Is not appropriate to leave the proposed amendments to the VC standard in effect or to promulgate amendments based on the proposed amendments. Therefore, the June 2,1977, proposal is withdrawn. As described in tha following section of this notice, the EPA began a review study to obtain additional technical data and coat information and to determie whether other amendments to the standard are needed. New amendments developed as a result of the review
study are proposed in thi> notice.
Review of VC Standard
Early in 1980 tha EPA began a review of the VC standard. The primary purpose of the review was to investigate the adequacy and appropriateness of the standard in light of policy decisions, health studies, control technology developments, and enforcement and compliance experience which have occurred since tha standard was first promulgated. The review consisted of a screening study of: (1) Existing and new control technologies, (2) source* not regulated by the standard, and (3) enforcement and compliance experience since1 promulgation of the standard. Information and data evaluated during this study were obtained through literature searches, plant visits, and interviews with industrial representative* and EPA regional personnel involved in enforcement and surveillance of the VC-emitting industries. Tha information and data are presented in a document that may be obtained as described in the Aoorasaa* section of thia preamble, decision* basad on this review are summarized in the next two section* of this preamble.
A* another aspect of the review of tha VC standard, the EPA's Carcinogen
Assessment Croup reviewed new health studies that have become available since the standard was promulgated. This review included a study of the estimated carcinogenic strength of VC (the VC unit nsk number) and focused on whether this number should be changed to reflect new informaton. Since the current standard was promulgated, new occupational studies have confirmed qualitatively that liver and brain cancer incidence are asociated with population exposure to atmospheric VC However, none of these new studies have sufficient exposure informetion to warrant a refinement of the quantitative cancer risk estimate.
Findings end Conclusion* of fas Review Study
Tha findings and conclusions of tha VC review study are presented in the following subsections. The first subsection discusses fat need and basis for the current standard. The second subsection addresses the level of control required by the current standard. The third subsection identifies source categories not covered by the current standard and evaluates tha appropriateness of regulating these sources.
(1) Need and Batit for Current Standard
The current VC standard waa established based on judgments concerning the coets end benefits of th standard to society. The standard is not designed to eliminate VC exposure risk entirely. Rather, it strikes a balance between public health protection and ' the cost of that protection. Data (avaluated before the currant standard was established) strongly indicate that VC causes or contributes to the development of angiosarcoma, other cancers, and various noncaroinogenic disorder* in people with occupational exposure and in animals with experimental exposure to VC Although no doe*-response data are available at the concentrations of VC found in the ambient air, tha EPA concluded when the standard was established that any atmospheric concentration of VC poses soma public heath risk. To eliminate tha risk of VC exposure entirely, a complete prohibition of all VC amissions would be necessary. This would require the cloture of the entire industry and result in serious, adverse economic impacts. Furthermore, th* EPA concluded at th* time tha current standard waa established that a complete prohibition of all VC emissions would not be desirable or necessary. The EPA
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Federal Rsgfator / Vol. 50. No. 6 / Wednesday, January 9. 1965 / Proposed Rufaa
andudsd this in view of (IT the beneficial mu ol VC products far which desirable substitutes are not readily available (2) the potential adverse health and environmental Impacts associated with W substitutes that have not been throughly studied: (3) the number of employees, particularly in fabrication industries, who would become at least temporarily _ unemployed: and ffl the availability of control technology that is capable of substantially reducing emissions of VC into the atmosphere.
Although all EOC VC and PVC plants have now incorporated VC emisaion controls, the maintenance of a Federal standard for VC is still considered necessary. Tin standard contains requirements for the proper operation and asaintoeanoe ef central devices and the proper implemcntatien of week practices. These requirements refind an approprifao balance between the need to mirrimria health tfafcs and dm avoidants of rnneaaenaMe economic and conmaaity impacts which would result from standards designed ta reduce risks to aero. Relative to the initial control costs, (he additional cost of maintaining and implementing the Federal VC standard is small. Nevertheless, if the Federal standard ia discontinued, these small costs may be sufficient In provide the industry with an economic inceptive far discontinuing the use of proper control measures. Thus, the continued maintenance at Federal standards tar the control of VC is.necessary to ensure a' continuation of the current level at control Additionally, th standard is aqw4ant for the control of VC emissions from plants built in the ,"t***t The consequence of not maintaining a 'Federal standard would be ta increase the carcinogenic risk fa large segments of the population, (fa VB% whan the standard was origriiahy proposed, approximately 4J reMan paapfa Bred
FVC plantaj Acndadfafihr^Mftk has
conducted that Ifaa arefcsfammwsfthe
revision of \
of Contra/ ^ u
This saheertine describes the statue of the tsrhasloBf baaed level ofoontrs! for sources oovread by faacmreot standard. The preaantatafas tM emissioi current VC etii is pnaanfad fa Table 1.
Tsmg i. Status of cumnott Emwskm law ELS FfSOM SOUttCES COVEDCO BT TXe VWYL Chlosuoc NESHAP T Efl**+crrn taeMOtetf* (pnor io *97$ (CWTfiffi EiiMtarit frvti i rfaoo* 000 ifag/yr EDG/VC taaMy
lOppmv Standard. Emission sources covered by this standard include H3C purification and VC monomer formation and purification equipment, monomer recovery systems and other equipment at PVC plants, and vents from fugitive emission capture systems. The standard is based primarily on the control of these emissions by incineration or other primary control devices and tpvcifies an emission limit of 10 parts per million by volume (ppmv) of VC averaged over a 3hour period. Tire 10 ppmv standard applies to control device bypass streams.
One of the swwndmante proposed fa 1077 would have required reduction of the amission limit from 10 fa I ppaev. The goal af the proposed 5 ppmv Hmit was to anaaro that the standard continued to approach a "aero antisafaa goal" by requiring owners and operators both to wsvinAs the effectiveness of existing control systems and to daat^ Improved new control systems at tho time of construction. The f ppmv (fad! was not baaed on data to control technology different from that analysed
------------------------------ ---
at the time of Ufa prmmJgatkmV the 10
ppmv limit
Comments received on the proposed 1977 amendments stated that in order to meet a limit of S ppmv. a control device
would have to be capable of control at a level even lower than 5 ppmv to offset emission fluctuations. Commenters also stated that a change from 10 to 5 ppmv would result in Httle redaction in mass emissions of VC Finaly, commenters questioned the rationale of the "zero
emisaion goal" policy.
Because the proposed S ppmv emisaion limit waa not based on data from a control technology different from that analyzed for the current standard and because 10 ppmv represents the lowest level of control which has bean
consistently achieved, fas EPA withdraws the proposed S ppmv limit and affirms the original 10 ppmv limit If such a technology had bean identified, it could have been the basis at a revised standard. Howeverduring the review
study no more advanced technology was identified, even though additional data an incinerators, carbon adsorbers.'aad
solvent absorption control systems aw existing plants were obtained Although these data indicate fast incinerators arecapable at reducing amiaaiona below 10 ppmv, 10 ppaav represent* fas lowest
level of control whiph has bean consistently adhievtd Based oa this information, fas EPA has concluded that there is u> improved ernew control
technology that has been demonstrated to significant!? and consistently reduce emissions fa a level below that required
by the current standard. Therefore, nofurther rwhiwihujMl investigation of the 10 ppnrv standard is planned
Oxyohionnatiom Vant Standard--OJ
g/kg EDC. The current oxychlorination vent standard of Ol g of VC pw kg of EDC does not require an add-on control device, lastend. fas Until can be achieved at dost ftTM*r by controlling operating conditions and at the
remaining plants through process modifications. At fas time the original standard wu written, incineration of oxychlorination vent emissions wu
investigated Becauea of expected Ugh energy oosts associated with. supplemental faai requirements for mnihuefilm mrinwetfan rrai determined net to bo a reasonable method of control fartfas source.
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pacified a level af S ppm far the oxychlarination vunL The proposed requiretnmri was based on installation .
ofan oxygen had agate* with an incinaroWr or eqeipmt central device. The use ofaxygee toad in the EDC *
oxychlorinaton process decreases the
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/ Vot 50. N - 6 / Wednesday, January 9, 1985 / Propped Roles
1185
volume of inert substances is the vent stream and. consequently. tfce cost for supplemental fuel requiredfog
incineration. Comments reoeived on this
proposed amendment focused primarily on the high expense and large energy requirements associated with the production of oxygen.
The review study identified no control technology for oxychlorinetion vents at
EDC/VC plants that had not been considered during the development of the original standard. Additionally, the
EPA reevaluated the coat of retrofit incinerator controls snd reached the same conclusion drawn hr the
development of the original standard. As before, the Ugh coat associated with
incinerating oxychlorinatiaa vents at existing EDC/VC plants makes this level of control unreasonable. Thus, the
current standard of 02 g/kg EDC is considered still to be the most
reasonable level of control for existing
oxychlorinetion vents. In addition, the review study concluded that significant new construction or modification of
EDC/VC plants is not expected. At this time, only one new EDC/VC facility is reportedly planned. (BF Goodrich has plans to construct an EDC/VC facility in
Convent Louisiana.) Oxychlorinetion vents at new EDC/VC plants will be
regulated by the proposed standards of performance for air oxidation processes (40 CFR Part 80 Subpart 01) or by the
BACT or LAQt requirements of new source review regulations applicable in specific locations to s level comparehie
to that achievable through the use of incineration. Because the technologically achievable level of control is assured through the current requirements, the EPA concluded that investigation of additional control (i.e* incineration) was not required for oxychlorination vents.
Reactor Opening--0,02 g/kg PVC
Product The current VC standard restricts emissions during
polymerization reactor openings. The standard was based an reactor purging and on a reduction In the Hsrimyaf reactor openings. An inassayleral of control was not proposed In me isyy
amendments. (The level of oosmul provided by the Current standard. 0.02 g/kg ofPVC product reduces VC emissions to about 138 Mg per year fa a model PVC plant) During the review .
of the standard, no technology wee identified that would provide additional VC reductions beyona the level of the current standard. Therefore, the EPA la -not investigating farther the'control of
reactor openings. Combined Souraee After Renin
Stripping. The sources of VC emissions covered under the current standard
include blend tanks, dryers, centrifuges, storage silos, bagging operations, and any sources following the stripper. Control of these emissions is based on either stripping the PVC resin to a
specified (based on resin type) residual VC level (i.e.. 400 ppm for suspension, bulk, solution, and latex resins; and
2,000 ppm for dispersion resins) or controlling the emissions from all sources following the stripper with a control device. The 1877 proposed
amendments would have required "new resins" to be stripped to lower levels (i.e,, 100 ppm for suspension, bulk, solution, end latex resins: and 500 ppm for dispersion resins). When the
amendments were proposed, the EPA believed that some resins could meet the proposed limits; whereas, for other
resins the manufacturer would have been required to develop unproved
stripping technology or not to produce the resin.
Industry comments stated that most dispersion, copolymer, and bulk resins would suffer degradation if more stringent emission limits were imposed. Additionally, the commentere noted the inherent difficulties in defining a "new resin." Information submitted by
commentere indicated that minor adjustments to resin compositions are
made routinely, end completely new resins ere rarely, if ever, made. As s result of these comments, the EPA
concluded that it is impossible in many cases to distinguish between new and existing resins snd still have any resins covered by the propoaad amendments. Further, the proposed amendments did not address whet levels of control could be achieved by improved stripping technology. Far these reasons, the EPA
chose to evaluate whether higher levels of control are achievable for ell resins, or only for some special classes of resins.
Hm review study found that resin tripping technology has improved tinea the current standard was promulgated, and that some processors can achieve lowerresin residual VC levels than those required in the original standard. In certain cases, some resins can meet the more stringent levels specified in the previously proposed amendments. However, other processors manufacturing resins of differing grades and characteristics can only marginally comply with the original standard. Because of the wide variation in resin grades snd characteristics, it cannot be
concluded that, even though a particular reain made by one company can meat a particular level, any other resin or similar resins produced by another company could also meet that levsL Furthermore, in tome cases these
processors meeting the more stringent limits proposed previously are stripping these resins to this low level to offset emissions from those resins which are more difficult to strip. Without this ability to average the emissions and reductions among resins, these
processors might not achieve the current
standard. Exempting resin grades known to be difficult to atrip is not
feasible because these resins cannot readily be defined. For the foregoing reasons, the EPA has concluded that there is no demonstrated level of control which could significantly and consistently reduce residual VC levels in resins to levels below that required by the current standard. Therefore, the EPA is not investigating further the control of the combined sources after
stripping.
Equipment Leake. Bacause little wee known about leak detection and elimination programs for control of equipment leeks from components in VC service, specific requirements for theeg programs were not included in tho f current standard. InatemL each plant t waa required to institute and implement a formalized leak detection end elimination program incorporating both
a fixad-point monitor and portable monitor. Plant-specific programs were subject to approval by the Administrator. Consaquentiy, due to site-spedfic difference* among plants, ss well as variations in lsak definitions end monitoring practices, differences in
control of equipment leeks among the plants have resulted. Since the standard was promulgated, the EPA has obtained more information pertaining to tho control of equipment leaks from components in VC service. With the information obtained form the development of other standards, an effective leak detection and repair program baaed on use of a portable monitor can now be specified for equipment covered by this program. The specific leek detection and repair requirements are discussed in the Administrative Revision* section of this preamble.
Relief Valve Diecharge Standard. Sources of VC emissions covered by this standard inchide discharge* from relief
valves on pressure vessels, transfer lines, snd other equipment In EDC/VC end PVC plants. The standard la based on emission control by s combination of equipment end process modifications, and operational procedures, found in plants during development of the standard. An exact combination of modifications and operational procedures was not specified. Instead, s performance standard (La., an emission
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Federal Register/ Vol. 50, No. 6 / Wednesday, January 9. 1985 / Proposed Rules
standard) was established because it
was believed that different combinations could be equally effective in controlling relief valve discharges. The current format of the standard prohibits all relief valve discharges except emergency discharges. Emergency discharges are described as those which could not have been avoided by taking measures to prevent the discharge (i.e.. those that are "nonpreventable"). Sines the standard was promulgated, all plants have experienced some releasee. Many of these releases are considered preventable by the EPA. Based on visits to plants with good compliance histories, the EPA concluded that a level of performance reflecting compliance with the current format of the standard through the combined effects of equipment, process modifications and operational procedures remains reasonable, during the review, no technological level of control was found that would provide for e more stringent standard. Therefore, the standard is still considered to reflect the appropriate level of control for these sources. However, as discussed in the Administrative Revisions section of the preamble, the EPA is proposing to revise the standard by setting limits for relief valve discharges in a different format-
Administrative Aspects of the Standard. Even though the EPA decided not to revise the level of control associated with the current VC
standard, the EPA identified revisions to several administrative aspects of the standard. These revisions as well as those identified above, are discussed in the Administrative Revisions section of the preamble.
(3) Review of Sources Not Previously Covered
This subsection discusses the status of VC sources not covered by the current standard that were identified in the review study. For these sources, the EPA assessed whether s Federal standard was warranted. The EPA's assessment of these sourest was based primarily on a quantitative analysis of VC emissions from these combined with a qualitative analysis of risks associated with expoeure to VC from these sources. The EPA considers these analyses to be adequate in place of a thorough quantitative risk . assessment for purposes of determining whether e Federal standard la
warranted for these sources. Because ' these sources are already relatively
well-controlled and the quantity at VC emission, and consequently, the risks associated with exposure to VC from these sources, are small in comparison
to sources covered by the VC standard, the EPA concluded that none of the additional sources identified in the review study warrant a Federal
standard.
Miscellaneous Sources of VC Emissions. Miscellaneous sources are
plants other than PVC and EDC/VC plants that use VC as a raw material or produce VC as an intermediate or by product. The EPA has identified four such plants, two of these plants produce 1,1.1-trichloroethane, one produces perchloroethylene and trichloroethylene and the fourth plant produces pesticides.
(An additional 1.1.1-trichloroethane unit waa constructed at a fourth location but has reportedly never operated. Thera are no plans to operate in the furture.) Review of VC emission sources at the identified plants showed them to be well controlled. Emissions of VC from these plants are primarily from fugitive sources and range from leaa than 1 Mg/ yr to 14 Mg/yr per plant In general, the VC NESHAP requirements for process vents and equipment in VC service arebeing met at the miscellaneous source* due to company policy considerations and State and local regulatory requirements. In addition, many of the equipment components in VC service would be covered by standards of performance for new sources and standards for sources in nonattairunent areas. Based on the investigation of these sources, the EPA concluded that they are already relatively wellcontrolled and do not contribute significantly to VC exposure. For these reasons, additional requirements for
miscellaneous sources of VC are not being proposed at this time.
PVC Fabrication Plants. There are about 8,000 fabrication plants which take the resin produced by PVC plants and fashion it into intermediate or final products. Emission* from these plants are estimated to be about 0.0035 Mg/yr per plant In comparison to VC production plsnts (which typically emit about 92 Mg/yr), PVC fabrication planta are small emitter* of VC. If standards were developed for this category they would not result in reduced emission! because the best control for these plants is to reduce the VC levels in the resins being processed by the fabricators. Resin stripping beyond the level that process economics would dictate it already being done as s result of the EPA's current standard and OSHA's VC
standard, based on the EPA's assessment of these sources, the EPA concluded that they do not contribute significantly to VC exposure. Therefore, the EPA believes that the evaluation of controls for PVC fabrication planta is
unnecessary and that the current level of control resulting from the EPA's standard and OSHA's standard is still reasonable.
Landfills. Off-specification resins containing VC has been taken to landfills where the gaseous VC can be released. However, the current EPA standard intends that all resins, including off-specification resins, be stripped to reduce the VC emissions from sources downstream from the stripper. In order to clarify that stripping requirements also apply to the offspecification resins before removal of landfills, these requirements are being restated to explicity address offspecification resins. The EPA believes that the level of control resulting from the stripping requirements is reasonable: thus, VC emission requirements for landfills are not being proposed todays However, the EPA recognises that VC may be emitted from hazardous waste landfills and is evaluating and may regulate under the Resource Conservation and Recovery Act (RCRA) volatile emissions (including VC) from landfills at hazardous waste disposal" facilities. The EPA also recognizes that VC has been detected in municipal landfills. Therefore, in addition to assessing VC emissions from hazardous waste disposal faculties, a (RCRA) Subtitle D TASK FuRCE hes been formed which will assess all environmental releases including air emissions from Subtitle D facilities (a category which includes municipal landfills).
Administrative Revisions
As discussed in the Findings and Conclusions of the Review Study section of this preamble, the EPA identified several administrative revisions that are appropriate as a result of the review study. The rationale for the proposed administrative revisions is presented in this section of the preamble. These revisions include: (1) Reformatting the emission limit for relief valve discharges, (2) providing a compliance test procedure and a specific emission limit for operators who strip in the reactors. (3) specifying requirements for leak detection and repair program for equipment components in VC sendee; and (4) miscellaneous revisions-
Relief Valve Discharges
Background. The current format of the standard for relief valve dischups allows only "emergency" discharges (i.e., discharges that could not be avoided by taking preventive measures|. The standard applies to all pressure relief devices on pressure vessels.
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^ 1117
transfer lines, and other equipment la EDC/VC and PVC plants. The control
techniques considered as the basis of the standard involve a combination of equipment modifications, process
modifications, snd operational procedures. An exact combination of modifications and operational procedures was not specified in the current standard: rather, a performance standard (i.e., an emission standard) was established because different combinations of the modifications and procedures were expected to be equally effective in controlling relief valve discharges.
Based on 0 yean of anforcement and compliance experience, the EPA hae concluded that tha relief discharge
standard has resulted in: (1) Significant reductions in the frequency and quantity
of VC discharges from relief valves, (2) significant use of agency resources to evaluate individual discharges for
preventabiiity. and (3) uncertainty on the part of producers regarding whether
they comply with the standard. Additionally, the EPA teamed some of VC and PVC believe that this part of the current standard applies only to discharges through safety relief valves and that discharges through other pressure relief devices, such as rupture disks or manual or automatic vent valves, are not covered. This interpretation is not compatible with the intent behind the current standard. To provide more efficient enforcement by
decreasing tbe burden of individual preventabiiity'assessments on the EPA. and to provide a better understanding to plant operators of the goal of the standard, the EPA is proposing to reformat the standard for relief valve discharges and to define the emission points covered by this standard to include appropriately ell pressure relief devices. As discussed more completely in the following sections, the EPA is proposing to change tbe format of the numerical limit* in tha standard to reflect the number of itiacharres that occur from those plants sUMfisi with the format of tha currentagudard.
The EPA found in the review study that efforts by ail HJC/VC and PVC producers to comply with the standard are reflected in (half pratemance (in terms of six* and frequency of discharges) since the standard went into effect In general, a reduction in the reported frequency end six* of relief valve dischargee by PVC pmducan has occurred sine* 197* A further decrease in relief valve discharges by the PVC
industry occurred between MM end 1981. Performance by tbe EDC/VC industry exhibited e lea* marked trend
of decreased discharge* over the compliance period. Following an initial drop in relief valve discharges sfter the standard want into effect the frequency and quantity of relief valve discharges by EDC/VC plant* have decreased slightly or remained relatively constant.
General Basis for Numerical Limits,
In selecting the proposed numerical limits. EPA first evaluated in detail tha recent performance (1961 to 1983] of five
PVC plants and one EDC/VC plant These plants were chosen based on discussions with EPA Regional Office personnel and industry and were intended to represent plants with good relief valve discharge records. In general, the EPA's evaluation of these plants indicates that each has adopted
the combination of equipment, operational procedure* and attitude toward prevention of relief discharges intended by the current standard, and that their resulting performance is consistent with compliance with the current standard. The EPA'a evaluation found that a few discharges may continue to occur from some plants that comply with the standard. This observation is consistent with the
expectation held by the EPA when the standard was written.
In order to revise the standard in term* of numerical limits representing compliance with the current format of the standard, this evaluation separated PVC and EDC/VC plants. For plants, relief valve discharge performance data
were further separated by source (reactor vs. nonreactor) and by reain type The EPA then reviewed the performance of 25 additional PVC plants and 12 additional EDC/VC plants. The EPA reviewed this large sat of plants to ensure that tha level of performance demonstrated by tha evaluated plants could be achieved by all PVC and EDC/
VC plants. Tbe numerical limits presented in the
Findings section of this preamble ere based on an evaluation of the number of
dischargee representing the demonstrated performance level
associated with compliance with the provisions of the existing standard.
Format for Numerical Limits. The
EPA visited the five PVC plants evaluated in detail. As expected, the
EPA found differences in tha combinations of hardware end operational procedures associated with control of relief valve discharges of each of the plants. Furthermore, no exact relationship was found between tha effectiveness at specific hardware items end operational procedures end prevention of dischargee. In the SPA's judgment the various combinations of
hardware and operational procedures implemented by each of tha plants along with the attitudes adopted toward preventing relief valve discharges represent the types of control measures that the standard intended. In particular, the EPA concluded that the low frequency of discharges by the visited plants was indicative of their degree of effort to prevent relief valve discharges. Consistent with the goal of this proposed revision, the EPA decided that an alternative numerical emission limit
based on performance resulting under the current standard could be revised in a format that would be easier to understand by enforcement and industry personnel.
The EPA investigated two basic ways of expressing relief valve discharge performance for PVC plant* One format is based on mass amission*, for example, the pounde of VC discharged per million pounds ofJVC produced (lb VC/MM lb PVC). Baaed on a review of methods used by industry to determine the amount of VC discharged from relief valve*, die EPA wee unable to identify e
sufficiently accurate method for measuring discharge quantities from relief valve*. At present, producers are
required only to estimate discharge quantities for reporting purpoaa* Demonstration of compliance with e lb
VC/MM lb PVC Ifimti would require producer* to measure the amount of VC discharged during an incident Because a suitable measurement method wes not
identified the EPA decided not to redefine relief valve discharge performance by PVC plants in a lb VC/ MM lb PVC format
Another format is based on tbe frequency (i.e,, number per unit time) of discharge from occurrences. No method for measuring the amount of VC discharged from relief valves is needed because only the occurrence of s release is required for this format The occurrence of a discharge can be determined by monitoring process parameters as well as inspecting relief valve performance reports. Thus, of the two bails ways of expressing relief valve performance that were considered the EPA selected e format based on tbe frequency of discharges.
Based on this decision, the EPA then considered how tha format would be applied to PVC and EDC/VC plants. At PVC plant* the frequency of discharge*
from polymerisation reactor* and associated proces* equipment may be related to the fact that a batch process is used to produce moat types of PVC For batch PVC production procetse* the opportunity for discharges is related to the number of times a new
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Federal Register / VoL 50. No. 8 / Wednesday. January 9. 1985 / Proposed Rules
polymerization batch is initiated
Expressing relief salve discharge performance for these plants with a discharge-per-batch format aamunts for
variations among plants In fly number of batches produced The EPftselected 100 polymerization batches as a convenient basis for expressing relief valve discharge performance by PVC plants with batch production processes
in e discharge frequency format Further, the EPA noted that the ability
of batch PVC producers to limit the discharge frequency may be different for reactor and nonreactor discharges and that reactor discharges may vary by resin type at any plant Consequently, relief valve discharges by individual PVC plants (except for continuous solution process plants) were classified according to type of discharge (i.e.. reactor vs. nonreactor) and the reactor
discharges were separated by resin type. Nonreactor discharge sources at PVC plants include blowdown tanks, transfer lines, and storage vessels. Because usage of this equipment 1s also related to some extent to the frequency of batch polymerization operations, the relief valve discharge performance by nonreactor sources in PVC plants with batch production processes was also examined on the basis of number of
discharges/100 batches. Unlike the batch process used to
produce other PVC resin types, the solution PVC process is continuous. Thus relief valve discharge performance for the solution PVC process cannot be expressed on a frequency per batch
basis. Instead, the relief valve discharge performance associated with the solution production process can only be expressed in terms of the total number of discharges (reactor and nonreactor) per year.
Similarly, the QJC/VC production process is not a batch process, but Is continuous. Thus, relief valve discharge performance by EDC/VC plants alio cannot be expressed on e frequency per batch basia. Moreover, the EPA was unable to detect a direct relationship between discharge frequencyand VC production at EDC/VC plantar Thus, the EPA decided to define nirfwt:
discharge performance for B8C/VC plants on the basis of a total number of annual dischargee.
Finding,c. PVC Reactor Discharges. Suspension resins account for the highest percentage of total PVC production. The remaining PVC production is In the form of bulk, dispersion and solution resins. (A small
amount of latex resin is produced by a process closely related to the dispersion process.) Examination of relief valve discharge performance associated with
production of suspension and bulk resins indicates that reactor discharge frequency generally is either less then 0-035 discharges/100 batches or is much
greater. (Recent reactor discharge frequencies for suspension resin plants with poorer performance levels ranged
between 0.059 and 0101 discharges/100 batches.) Further examination of relief valve discharge performance by suspension resin producers indicates that only one plant experienced more than 4 dischargee per year during the period from 1981 to 1983. Performance by this plant also exceeded 0.035 discharges/100 batches.
The reactor discharge frequency associated with dispersion and latex production is typically zero. However, for a typical dispersion or latex resin process with a low production rate (Le^ number of polymerization batches per year), a single emergency reactor discharge in a given year would be equivalent to a discharge frequency of
about 0.035 discharges/100 batches. Nonreactor Discharges. Nonreector
discharge frequencies by PVC plants typically were either leu than 0.025
discharges/100 batches or were much greater. (Recent nonreactor discharge frequencies reflecting poorer performance than the 0.025 level ranged between 0.048 and 0.223 discharges/100 batches.) Furthermore, with the exception of two producers, no more
than three discharges per year were reported from nonreactor sources in PVC plants during the period from 1981 to 1983.
Each of the five PVC plants that the EPA evaluated in detail was among thou achieving 0.035 discharges/100
batches or less in each of the reactor discharge categories and 0.025 discharges/100 batches or less in the nonreactor discharge category. The EPA examined individual discharge incidents
for the PVC producers whose recent performance hu exceeded 0.035 discharges/100 batches in one or more of the reactor discharge categories or who exceeded 0-025 discharges/10O batches and 3 discharges per year from nonreactor sources. In every case, the
EPA identified one or more discharges that were preventable. Elimination of these preventable discharges indicates that these producers should have achieved discharge frequencies comparable to the five PVC plants that tha EPA evaluated in detail. .
Solution PVC Process. Discharge
frequency from both reactor and nonreactor sources by the single plant producing PVC by the solution pracau was zero during tile period 1981 to 1983. Previously, this plant experienced u many as two discharges in a l2*month
period Recant performance suggests that preventable*discharges have been eliminated et this plant With the exception of a potential emergency discharge occurrence, future discharges at this plant are not anticipated.
EDC/VC Discharges. During the review study, the EPA evaluated performance by one EDC/VC plant in detail. This plant experienced about four discharges that could be considered emergencies. Recent (1961 to 1983) relief valve discharge performance data for other EDC/VC producers indicates an industry range of 0 to 7 discharges/yr. Information obtained from plants during the review indicated that, where applicable, similar types of equipment, process modifications and operational procedures used to control relief valve discharges from PVC plants also are used at EDC/VC pants. The EPA examined discharges by the EDC/VC producers who exceeded four discharges in one or more years since 1981 and found that one or more of the discharges et each plant were preventable. Elimination of the preventable discharges would allow each of these plants to reduce their annual discharge frequency to four or fewer.
Summary ofNumerical Limits. Based on the study of current relief valve discharge performance by PVC and EDC/VC plants, the EPA is proposing that the following numerical limits for relief valve discharges be added to the standard. Each discharge causing an exceedence of any numerical limit presented below would be considered a violation without regard to whether any individual discharge was preventable.
Compliance Provieione. The EPA recognizes that all plants may experience an unavoidable relief valve discharge incident at some time. Examination of relief valve discharge performance by PVC plants with low
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11#
discharge frequencies indicated that plants with the lowest polymerization
batch frequencies typically experience about one discharge in 112-month period. The EPA concluded that for most plants a 12-month reporting period
(rolling every 6-months) was both suitable and appropriate for determining compliance with the proposed numerical limits. For plants producing only a small amount of a particular resin (Le,, low number of polymerization batches), an apparent violation of the standard may result from a single discharge occurrence during a 12-month compliance period as described below.
For a PVC plant producing a single resin type to meet the numerical limit for reactor discharges (i-e- 0.033 discharges/100 batches), it must experience and average of no more than one discharge per 2,853 polymerization batches over the preceding 12-month period. An average reactor discharge frequency exceeding one discharge per 2,858 batches would be a violation of the standard. However, if the plant made less than 2358 polymerization batches over the 12-month compliance period, a single discharge occurrence would be an apparent violation of the standard (i.e..
the discharge frequency per 100 batches would exceed 0.035). Because insufficient batches were made, the reported discharge frequency per 100 batches would not correctly reflect the
performance by that plant in comparison to other plants complying with the standard. In rectifying the undue
compliance burden posed on plants with small numbers of batches by the discharge/100 batch format and the selected 12-month compliance period the EPA is proposing to add additional provisions affecting the number of batches used to calculate the discharge frequency. For PVC plants producing less than 2,858 batches of e particular resin, the minimum number of 2,838 batches will be used when determining compliance with the numerical limits.
. PVC plants producing mors than one resin type must demons**te compliance separately for reactor discharge* occurring from different resin production processes. Only the relief valve discharges and polymerization batches specific to each resin type are considered for determining compliance. However, for determining compliance with the standard for nonreactor discharges, tbs total number of polymerization batches (regardless of
resin type] ere counted. To determine the number of
polymerization batches produced for purposes of assessing compliance, the following guidelines apply- A
"polymerization batch" consists of each sequence of charging VC and other materials to the reactor, heating reactor, contents, polymerization of reactor
contents, and removal (i.e.. blowdown) of reactor contents. Any batch that is
aborted following charging of VC to the reactor is nonetheless counted as a polymerization batch in assessing compliance. For PVC plants producing bulk resin, s single "polymerization
batch" includes both prepolymerization and postpolymerization reactor operations.
Discharge frequency can be recorded in two ways. Discharge frequency can be recorded on the basis of discharge events (involving discharges from one or
more relief valves) or on individual relief valve discharges. In most cases, plants currently report discharges individually when they occur from relief valves on separate equipment However, certain equipment such ss
polymerization reactors that are equipped with multiple relief valves may experience discharges simultaneously from more than one relief valve. Most plants currently report such multiple discharges from a single piece of
equipment as a single discharge. Thus, the performance levels serving as the
basis for the numerical limits represent individual discharges and not multiple discharge events except when they occur from a single piece of equipment For determining compliance with the numerical limits, discharge frequency is to be recorded on the basis of individual discharges except when simultaneous discharges occur from relief valves on the same piece of equipment
A relief valve discharge in considered to be any venting through a pressure
relief device to prevent or relieve an overpressure condition from equipment in VC service that results in emissions of VC directly or indirectly to the atmosphere. In determining whether or not a relief valve discharge results in emissions to the atmosphere, the controlling factor is the ultimate disposition of the gases. Venting to a manifold or header system thet ultimately discharges to the etomsphere constitutes a relief valve discharge, ff the manifold or header discharges gases through e control device meeting the 10 ppmv VC emission limit the venting does not constitute e relief valve discharge.
For purposes of reporting compliance status with the limits, plants will be required to calculate their discharge per batch frequencies with sufficient precision to demonstrate thet performance is either equal to. below of in excess of the limits. Based on
operating history, relief velve discharge performance by certain plants is expected to be much better than the respective limits. For example, some new suspension resin PVC plants produce about 5,000 batches during a
12-month compliance period. One and two discharges st one of these plants
during s compliance period would result in a discharge performance of 0.02 and 0.05 discharges per 100 batches, respectively. The second discharge during the compliance period would be a violation of the proposed 0.033
discharges per 100 batches limit despite the fact that the first discharge would result in performance well below the limit These types of plants were considered in selecting the proposed limits and reporting procedures for relief valve dischargee. The result that plants of this type must perform well below the limits in the standard in order to be in compliance is consistent with the proposed limits, which were selected to represent an upper boundary on the number of allowable discharges intended by the standard. The ERA expects that plants using the be*#' technology and procedures should be able to perform better than the proposed limits.
Reporting Requirements. The current standard for relief valve discharges requires producers to report discharges within 10 days of the incident The EPA is proposing to eliminate the 10 day reporting requirements end to require reporting of ell discharges on a quarterly
basis. Although compliance it to be determined on a semiannual basis, quarterly reporting of discharges is appropriate because violations of the standard may occur well before the end of the 8-month period. Quarterly reporting notifies enforcement personnel of potential violations and violations that have already occurred prior to the end of the compliance period so that corrective actions can take place sooner following the end of the compliance period. Information to be included in the semiannual report for individual relief valve discharges is to be reduced to include only the date, time, source, cause and estimated amount of each discharge occurrence. The semiannual report will also tnlcude information on
compliance status.
In addition, plants will now be required to maintain relief valve discharge records for 3 years, because of the potentially significant increase hi the time period between a discharge occurrence and reporting of the
discharge. Effective Date of Revision. The
current standard as written will remain
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Federal Boglrtr / Vol. 50, No. 6 / Wednesday, January fl. 1985 / Propo--d Bui--.
in effect for relief valve discharges until
the proposed revisions are promulgated The propoeed administrative revisions do not change the standard^ original intent and are intended only to set limits to facilitate compliance and enforcement effort*. Thus, the current standard will continue to be enforced until the revisions are promulgated
Stn'pping-in-Reactor Compliance Teat Procedure
The test method for measuring reactor
opening losses was developed for resin
stripping operations that take place in
vessels separate from the reactor. Some
PVC plants, including all bulk resin
manufacturers, however, do not use
separate strippers to remove residual
VC from the resin produced Instead
these plants strip VC from the product
resin in the reactor (postpolymerization
reactor in the case of bulk resin
producers). For plants with reactor reaia
stripping operations, the concentration
of VC in the reactor vapor space, as measured in accordance with the
current standard exceeds the 0.02g/kg of PVC requirement The high
concentrations result form VC monomer
diffusing from the resin into the vapor
space during the period following
completion of the stripping operation
(normally occurring under a vacuum that
must be broken before the reactor can
be emptied) and before the reactor is
completely emptied of PVC resin.
According to the Federal Register notice
of promulgation of the current VC
standard (40 FR 40563. October 211970).
any VC escaping from the resin after it
has been stripped to acceptable levels is
not intended to be counted as part of the
reactor opening loss. However, the
current standard did not include in the
measurement method an acceptable
method for determining what part of the
VC in the vapor space has escaped from
the resin after stripping is completed
The current standard allows bulk
resin producers to calculate reactor
opening lose emissions from the
postpolymerizatioa reactor based on the
number of reactor evacuatfrHBtthe
vacuum invlovad and the vmfaas ofgee in the reactor*. For noobnikrasia
produces with raector main stripping operations, calmlstian of reactor opening loss emissions is more
complicated due to the pieseuro of
water vapor to the reactnr vapor specs.
Currently, waivers of testing or
producers with
resin stripping
operations in the raector havs bean .
granted od ansae by case basis by the
EPA Regions^ typically with the
provision the! residue! VC sample^ are
nlaysed on sack belch. A variety of-,
calculation methods are then used to establish the reactor opening loss.
Based on experience of the EPA Regional offices, a method for determining the reactor opening loss that accounts for stripping in the reactor has been developed for use by all nonbulk resin producers with reactor resin stripping operations and is included in the proposed revisions to the current VC standard. Limitations for resin residual and reactor opening loae are added together to give e total allowable VC content from these two sources. The measured resin residual VC and the calculated reactor opening loss would then be added together, and averaged over a 24-hour period according to resin type. If the 24-hour average meets the combined standard, the plant would be considered to be in compliance with both the stripping and the reactor opening loss requirements.
Leak Detection and Repair
Background. The current standard
requires implementation of a formalized
program for detection of leaks from
equipment in VC service and
elimination of these leaks. The
formalized program includes a
multipoint VC detector and a portable
volatile organic compound (VOC)
analyzer. The fixed-point monitoring
system continuously monitors VC
concentrations in the work area around
equipment in VC service and sounds an
alarm when concentrations exceed
prescribed leveL The portable monitor is
used independently to screen individual
equipment components for leaks. Rather
than specifying the number of points to
be monitored, the sensitivities of the
multipoint detector, the VC
concentration that indicates a leak, and
the actions to be taken to repair leaks,
the current etanderd requires each plant
owner or operator to prepare a program
plan containing these specifications and
to submit the plan to the EPA for
approved. Plant owners or operators are
required to submit data on background
concentrations of VC in different areas
of the plant to use in determining the VC
concentration that should be designated
as indicating a leak. Plane, therefore,
were tailored by each plant and
reviewed by the the EPA Regional
Offices.
The EPA found in the review study
that differences in leak detection and
elimination programs exist among PVC
and EDC/VC production plants end
miscellaneous sources and that sUe-
differences
variations in
leak definitions and monitoring
practices. The definition end monitoring
practices, along with repair practices,
are primary influences on the control
effectiveness of leek detection and repair programs. Some plants
implemented rigorous programs and
others implemented programs lacking
specific procedures or requirements.
Accordingly, the effectiveness of lesk
detection and elimination programs
varies among the plants.
Since the current standard was
promulgated, the EPA has obtained
more information pertaining to the
control of emission from equipment
leaks- Based on this information and the review of the leak detection and
elimination plans being implemented to
control emissions of VC, the EPA
decided to specify leak detection and
repair requirements for certain
equipment components in VC Sendee.
Although Information obtained from
development of other standards
indicates that a routine leak detection ^
and repair program with a portable ^
monitor can be an effective emission
reduction technique without the
requirement of a fixed point monitmtng
system, the EPA concluded that fixe*.
point monitoring systems already in 1 ,
place have usee that Justify their retention in the current standard. In - -
particular, fixed-point monitors allow . for quick detection of certain large VC. *
leaks that might otherwise go
>.*
undetected until thf next routine ref
portable monitor screening. The EPA
recognizes that existing fixed-point,
monitoring plans will need to be
reviewed in light of the leak def and repair requirement* being <. at this time. The complexity of exiettog*
fixed-point monitoring plans, in tame number and distribution of monitoring
points, varies greatly among plant* Consequently, some plant owners operator* may want to alter the m-- of points that are monitored and the
distribution of monitoring locatio better complement the specified portable monitoring requirements,
changes to i*ing fixed-point
monitoring plans will be allowed providing they do not alter the plnw*
ability to detect large VC leak*
The propoeed revision* are p* intended to standardise control to emissions from equipment leak*
doing this, the EPA to cooceffl*'
existing affective plane eot be
inappropriately diaapd. The
revisions
provide^-'
plants with existing effective
periodically demonstrate the
effectiveneea of their pto* additionali
the EPA requetta <
industry represent specific effects at verifying
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Federal Bgbtr / y0|. aq No. > / Wednesday, January 9. 1983 / Proposed Rule- -- vee^-
detection and repair requirement* on effective existihg plans.
Leak Detection and Repair Requirements. The EPA established leak detection and repair requirement* (40 CFR Part 61 Subpart V) for certain
equipment in volatile hazardous air pollutant (VHAP) service on fun* 6, 1984. These requirement* were established in conjunction with the final standard for benzene equipment leaks. The requirement* of Subpart V generally apply to pump*, compressor*, pressure relief devices, sampling connection systems, open-ended valves or lines, valves, flange* and other connectors, and product accumulator vessels. These requirements reflect the level of control
that the EPA considers reasonable for
equipment coveted by developing standards for VHAP. The EPA is therefore proposing to add VC to the list of substances covered by Subpart V.
Subpart V would substantively affect only valves and flanges in VC service within this industry. All other equipment
in VC service ere already required by the VC standard to comply with equipment end work practice standards consistent with those in Subpart V, For
example, pumps and compressors meeting the dual mechanical seal requirements of the current VC standard will be in compliance with the Subpart V requirements. In addition, the
sampling connection systems requirements of Subpart V are
essentially the same as the current
standard. The use of rapture discs for controlling leaks from pressure relief devices, as required by the VC standard, is consistent with the "no detectable emissions'* requirement included in
Subpart V. Requirements for controlling leaks from pressure relief devices are described in more detail later in this section. Thus. Subpart V will affect primarily valve* and flanges in VC service by requiring a specific monitoring schedule, leek definition end repair provisions.
Compliance with the provisions of
Subpart V will be used to^lAvn&M compliance with the portable monitor leek detection and eUsdnathm requirements in the current VC standard
(40 CFR 01AS(bMKaiI. and therefore, the currant standard la being revised to reflect this chugs However, process units within VC and PVC plants la which the percentage ofleaking valves
Is equal to or less than 2J> percent era considered by the EPA to bo effectively rjnittnlliiig VC awlaahwa front leaking -
valves. For these process anils. As existing leek detection end elimination program will continue to bo allowed while the percentage of leaking valve* is
2JO percent or less. Any process unit in which the percentage of leaking valves is round to exceed 2.0 percent will be required to comply with the provisions
of Subpart V. The Subpart V requirements for
valves are based on a teak detection and repair program that requires (1) monthly monitoring for valves in gas/ vapor and light liquid service, (2) an initial attempt at repairing these valves within 5 days after detection of e leak, (3) repair of leaking valves within 19 days after detection of the leak unless repair would require a process unit shutdown, and (4) repair of valves during the next process unit shutdown
after repair is delayed until a process unit shutdown. Valves found not to leak for 2 successive months can be
monitored quarterly until leaks are detected Monitoring of equipment to detect leaks ia conducted in accordance with Method 21 and a leak is defined at a measured organic concentration equal to or greater than 10,000 parts per million by volume (ppvm). For a complete description of the leak detection and repair requirements, see Subpart V (49 FR 23498. June 8.1984).
In addition. Subpart V contains
standards for other types of equipment (e.g. flanges, and open ended valves or lines). Standards for flanges indud*
monitoring with a portable instrument under prescribed procedure* within 9 days of observing evidence of s potential leak by visual, audible or other means. Open-ended valves or lines ere required to be capped, blinded or fitted with a second valve. These provisions are not expected to significantly affect producers with these types of equipment
in VC service. The equipment and procedures employed as normal practice by these producers or as e result of the current VC standard ere expected generally to ensure compliance with Subpart V.
Pressure ReliefDevices. The EPA proposed and promulgated the work practices, equipment design and operational standards in the current standard before explicit legal authority existed in Section lit These requirements are found hi 16145(b). In August of 1977. Congress amended Section 112 to allow the use of these requirements. Section 112 of the Clean Air Act require* that an emission standard (Le- a performance standard)
be established for control of e hazardous air pollutant unless. In the (udgment of the EPA, II Is not feasible to prescribe or enforce such a standard. An emission standard allows for some flexibility in complying with the standard, since any control technique
that achieves that standard may be applied. Section 112(e)(2) defines the following conditions under which it is not feadible to prescribe or enforce an emission standard: (l) If the pollutants cannot be emitted through a conveyance
designed and constructed to emit or capture the pollutant; or (2) if the application of measurement
methodology ia not practicable due to technological or economic limitations. Section 112(e)(1) allows that if an emission standard ia not feasible to prescribe or endorce. then the EPA may istead promulgate a design, equipment,
work practice, or operational standard, or combination thereof
The EPA has reviewed the design, equipment, work practice and
operational requirements contained in the current VC standard. The only sources covered by the current standard with one of the requirements for which a performance standard (Le,, an emission standard) is feasible are pressure relkd devices. As discussed below, the ERA is
setting a "no detectable emissions'*IMt for these sources. For the other souzpse. the EPA is reinstating those requirements as set forth in the current
standard.
The EPA selected the use of rapture
disks as tha basis for the currant standard for pressure relief devices. When the integrity of rupture* disks is maintained, equipment leaks through the relief device are eliminated. Rupture disks normally maintain their integrity unless an overpressure occurs. After the occurrence of ea overpressure, replacement of the rapture disk once again eliminates equipment leaks of VC through the pressure relief device.
For emission control techniques that
eliminate equipment leaks, such as tha use of rapture disks, s "no detectable emissions" limit is feasible. An instrument reading of less than 500 parts per million by volume (ppmv) above a background concentration based on Reference Method 21 can be used to indicate whether equipment leaks have been eliminated; that is, that the equipment has Sto detectable emissions."
The "no detectable emission" limit would not apply to discharges throtigh the pressure relief device during overpressure relief. (These releases are covered under || 81.84(a) and WJRt).) The standard would specify, however, that the relief device be returned to e
state of "no detectable amissions" within 9 days after such a discharge. The standard would further require an annual test to verify the "no detectable emissions" status of the pressure reEaf devices and a test after each over
SI- 067108
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pressure relief. This adminletrative change implements 8m besie of this standard consistent with the requirements of Section 113(a).
Miscellaneous Revisions'-
Based on discussions with the EPA regional personnel regarding their experience in administering the current VC standard, the EPA is proposing several additional administrative revisions that would facilitate compliance and enforcement efforts associated with the current standard. These revisions represent minor changes to the standard. A brief description of these administrative revisions and the basis for making them follows.
Definition ofLeak. Exhaust Gas and Relief Valve Discharge. Functional definitions of "leak", "exhaust gas'* and "relief valve discharge" are being added to the standard to clarify the applicability of the standard to each of
these types of VC emissions. Dining their review of enforcement and compliance experience since the standard was promulgated, the EPA discovered several cases of confusion over the intended meaning of 'Teak", "exhaust gas" and "relief valve discharge." These three distinct categories of VC emissions are being defined in the revised standard to provide compliance and industry personnel with e dear understanding of wtvdi part of the standard applies to
any given discharge of VC emissions to the atomoaphera.
Definition of EDC and VC Purification, far tha past some plants have nusinterprented which equipment components are included in EDC purification and VC purification
processes with the result that emissions from certain equipment intended to be covered by the standard may not have been controlled. The definitions of "QIC purification" and "VC purification" are being revised to darify that all purification equipment following EDC and VC formation wore subject to regulation under the arrant standard.
10 ppmv Standard. Tmanhnlfjlni revisions are baing nidtfSriB ppmv regulations to improve Mpraraeilliw of the applicability of this pgrt of the standard. First, altheugb *a test method for determining companion with the 10 ppmv standard specifies that the average results from three 1-hour sampling runs be used, this 3-hoor averaging period in not specified in the
10 ppmv requirements. Specifying that emissions may not exceed 10 ppmv over
3-hour averaging period clarifies that instantaneous compliance with tin 10 ppmv standard is not an intamUd
requirement Moreover; specification of
the 3-hour averaging period is intended to darify that tha 10 ppmv standard applies to VC emissions in all exhaust gas streams covered by the 10 ppmv requirements, including any control device bypass streams. Requirements for calculating the VC content in
bypassed emissions for purposes of reporting VC emissions in excess of the 10 ppmv standard are being added to the regulation. Tha EPA may use these calculations along with continuous emission monitoring results as indications of noacomplianca if they show dearly that emissions in excess of
the 10 ppmv requirements occurred.
The second clarifying revision to the 10 ppmv standard involves the specification that the 10 ppmv requirements apply to each exhaust gaa
stream from the covered equipment The purpose of this revision is to dearly
prohibit plants from using dilution with other exhaust gaa streams as a
technique for meeting the 10 ppmv requirement This revision is not intended to prohibit tha common practice of combining two or mote exhaust gas streams in common header leading to a control device. According to me revised 10 ppmv requirements, combining an exhaust gaa stream containing more than 10 ppmv VC with another exhaust gas stream containing lest than 10 ppmv VC is allowed only when the combined stream
s ducted to the control device.
Relief Valve Definition. Tha current standard for reliaf valve discharges was intended to apply not only to safety relief valves but to all typist of pressure relief devices. A definition of "relief valve" fa being proposed under the revised standard to clarify that tha current relief valve discharge standard also applied to rupture discs, manual vents and other pressure relief devices that vent to the atmosphere to protect process equipment from unsafe overpressure conditions. The definition of relief valve in the proposed standard is not intended to include pressure control valves used to control flow to an incinerator or other control device. However, the currant relief valve discharge standard did cover emissions from pressure control valves. Also not included in the definition of reliaf valve are pressure control systems such aa polymerisation reaction shortstop
systems or refrigerated water systems which act to reduce pressure by means other than venting.
Reactor Opening Lott Requirements for Bulk PVCResin Producers. Bulk PVC resin production differs from production of other types of PVC resin in that the polymerization reaction is
carried out hi two aaperetn raa--HTtW reaction is initiated hr the `prepolymerization" reactor and the reactor contents are then transferred to the "postpolymerization'' reactor where the reaction is completed. Stripping of residual VC in bulk resin is performed following the postpolymerization step in the reactor vesaet The
postpolymerization reactor generally i> opened after every batch and must
comply with tha reactor opening low limits specified in the standard. Because the prepolymerization reactor is opened less frequently and because determination of vow product (for reactor opening low estimation) is difficult the EPA has allowed plants to meet the equipment requirements for minimising VC
emissions from polymerisation reactor openings. The reactor opening low requirements are being revised et this time to specifically exdude prepolymerization reactors. Accordingly. VC emissions from aU opening of prepolymerization reactors will be subject to dm equipment owning requirements. This revision is intended to clarify and improve the oonsistsalcy of the eqnirements of the revised * standard aa they apply to bulk PVC resin producers in light of actual industry practice. No reduction in VC
emission control stringency will result from the change in requirements for
prepoiyroerizatioo reactors.
Inprocess Wastewater Requirements for Gasholder Soak. Under the current standards, the VC content of inprocess wastewater must be reduced to lew than 10 ppm exposure of the wastewater to the atmoephere. In the case of gasholder water seels, the VC content in the exposed water seel may exceed 10 ppm during normal operation of tha gasholder. Experience since the standard waa promulgated indicates that compliance with the atrooapheric exposure limit is not practicable for this particular inprocess wastewater source.
Consequently, tha definition of inprocew wastewater is being revised to exclude the expoeed water seel of gasholders. The inproass wastewater stripping requirements will continue to apply to wastewater alter removal from the gasholder seal.
Elimination ofJO-Doy Limit on EquivalencyRequests. The current
standard epndfiw a 30-day limit tarexisting sourew to submit requests for use of equivalent methods. Becauw such a limit poaw e restriction on initiative by industry to develop alternative, and potentially mom affective, control measures, the 30-day limitation is being eliminated. - - - ,r
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Other. In addition to the nviiiaa described above. a review of tha recordkeeping and reporting requirements of the crorent standard was performed to identify ways to eaae recordkeeping and reporting burden on plants and to identify any additional recordkeeping and/or reporting needs. The EPA identified two areas where the reporting burden on plants could be reduced. He current reporting requirements far residual VC monomer specifications and reactor opening measurements require that results of all compliance tests be reported in semiannual reports. The EPA is proposing to allow plants to report only test results that simw exceedances of tha respective standards If an
exceedances occur, plants will ba required to indicate fm* in tha
semiannual report. This type of exception reporting is currently allowed for demonstration of npHn with the 10 ppmv standard for process vents. Tha second area, la tha requirement to report relief valve discharges within 10 days of their occurrence. The B*A is proposing to allow plants to report relief
valve discharge occurences on a quarterly basis rather than within 10 days of their occurrence. Furthermore, the reporting requirements far relief valve discharges have been streamlined by dropping the need to repost actions taken and implemented preventive measuree for each discharge. Information on the data. time, source, cause and estimated amount of individual relief valve discharge will be included with the semiannual reports along with information on compliance status.
Additional semiannual reporting requirements being added for PVC producers ate tha number of reactor openings and tha design capacity number of polymerization batches far each resin type. Ibis requirement will provide general information to facilitate review of industry-wide status during past repotting (unhide
Specific racotdkoeolHBud reporting requirements are teolnd|Ras pert of this revisions to the leak dstmhkm and mpali mpiliaeuoli Thai--iBeaiilng requirements include preparation of an initial log to record aqalpiaeat component identification. physical
tagging of sqaipmant earngonantewhfah leak, and maintaining a raeaad el equipment leaks and mpair action.
Included in
, the repair states e/SKSgeemponaotn.
Depending osi thepertiselar leek detection end repair pro-am in piece. these requirements mar represent an
increase or decrease in tha overall recordkeeping and reporting currently practiced by individual plants.
The EPA concluded that the current recordkeeping requirements, as specified in 40 CFTl 61.71, are still
appropriate. However, the EPA it proposing to extend the current
recordkeeping requirements for all reporting activities bom 2 to 3 years.
The net impact of tha revised recordkeeping and reporting # requirements proposed by the EPA is estimated to be a decrease in a paperwork burden of about 2Jt personyears.
It should be noted that all Comprehensive Environmental Response. Compensation, and Liability Act (CERCLA) Section 101(14) hazardous substances such as vinyl chloride are subject to reporting requirement! under Section 103(a) of CERCLA. CERCLA requires that persons in charge of vessels or facilities bom which hazardous aubatances have been released in quantities (RQs) immediately notify the National Response Center (NRC) at the release. The toil-bee 24-hour telephone number of the NRC is 600-424-6802 and in Washington, D.C metropolitan area it is (202) 426-2673. (Sot CERCLA Section
108 and 4S PR 23552, May 25,1963.) Vinyl rhlnrifU wan assigned a
statutory 1 pound reportable quantity under Section 101(14) until adjusted by regulation and la presently undergoing assessment far both chronic toxicity and carcinogenicity. Its RQ will be adjusted pending the outcome of these reviews by the Office of Emergency and Remedial Response. Federally permitted releases under CERCLA (See CERCLA Section
101(1) and 48 FR 23552) are not subject to CERLA notification requirements or liabilities. However, releases of hazardous substances that are not subject to a permit or control regulation must be reported.
Regulatory FiaxibiUty Analysis
The Regulatory Flexibility Act of I960 requires that adverse affects of all Federal regulations upon small businesses be Identified. According to tha current guidelines of tha mall Business Administration [SBA). a small business that produces or processes VC
is one that has 500 employees or less. Currently, none at the evleting
producers or processors that are affected by the standard are estimated to be small by this definition. Since non# of the companies meeta the SBA definition of small business, no regulatory flexibility analysis is required. Even if an analysis were required, the proposed administrative
revisions do not increase the coat of compliance with the standard.
Public Hearing
If requested, a public hearing will be held to discuss the proposed revisions to the VC standard in accordance with sections 112(b)(1)(B) and 307(d)(5) of the Clean Air Act Persons wishing to make oral presentations on the proposed revisions should contact tha EPA at the address given in the a&OMttn section of this preamble. Oral presentations will be limited to 15 minutes each. Any member of the public may file a written statement before, during, or within 30 days after tha hearing. Written statements should be addressed to the Central Docket Section address given in tha Aoomsaae section of this preamble.
A verbatim transcript of the hearing and written statements will be available for public inspection and copying during normal working hours at the Q>A't Central Docket Section in Washington. D.C (aee WOSUU1 section of this preamble).
Dodtat
The docket is an organized and complete file of all the information submitted to or otherwise considered by the EPA in the development of this proporod rulemaking. The principal purposes of the docket are: (1) To allow interested parties to identify and locate documents so that they can effectively participate in the rulemaking process, and (2) to serve as the record in case of judicial review (except for interagency review materials [| 307(d)(7(A)|).
Miscellaneous
In accordance with section 117 of the Act publication of this proposal was preceded by consultation with appropriate advisory committees, independent experts, and Federal departments and agencies: Tha Administrator will welcome comments on all aspects of the proposed regulation. Including health, and economic and technological issues.
The information collection requirements in this prop sed rate have been submitted for approval to the Office of Management and Budgst (OMB) under tha Paperwork Reduction Act of I960.44 U.S.C. 3501 et seq. Comments on these requirements should be submitted to the Office of Informedon and Regulatory Affairs of OMB. marked "Attention: Desk Officer for EPA". as wait as to the EPA docket described above. The final rule will respond to any OMB or public comments on tha information collection requirements.
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Under Executive Order 12391. the EPA must judge whether a regulation is "major" and therefore subject to the requirement of a Regulatory fcbect Analysis. This regulation is net major because: (1) The national annualized compliance costs, including capital charges resulting horn the standards total less than $100 million: (2) the standards do not cause a major increase in prices or production costs; and (3) the standards do not cause significant adverse effect* on domestic competition, employment, investment, productivity, innovation or competition in foreign markets.
This regulation was submitted to the Office of Management and Budget for review as required by Executive Order 12291. Any comments from OMB to EPA and any EPA response to those comments are included in Docket Number A-81-21. The docket is available for public inspection at EPA'a Central Docket Section. West Tower Lobby, Gallery 1, Waterside Mall. 401M Street, SW,, Washington, D.C. 20460.
Pursuant to the provisions of 5 UJS.G 005(b), I hereby certify that this rule, if promulgated, will not have a significant economic impact on a substantial number of small entities because no small entities are affected.
list of Subjects in 40 CFR Part 11
Air pollution control. Asbestos, Beryllium. Hazardous materials. Mercury, Vinyl chloride.
Osted: Dated December 31,1964. Alvin L Aim,
Acting Administrator.
PART 61--(AMENDED 1
It is proposed to amend 40 CFR Part 61 as follows:
1. The proposed changes to 40 CFR Part 61 proposed at 42 FR 28154, June 2. 1977 are withdrawn.
2. By revising the definitions in existing 16l.Bl(j), (I), (o) and (p) for "In process wastewater", "In vinyl chloride service", "ethylene dichlaridt purification" and "vinyl chltotft purification" and by addtomjlgfaltions for the terms "relief valuerfllifef. "exhaust gas", "relief valve discharge and "3-hour period" in new paragraphs (v). (wj. (x), (y) and (x).
16141 DefMMone. A**.**
U) "Inprocess wastarwater" means any water which, during manufacturing or processing, coma* into direct contact with vinyl chloride or polyvinyl chloride or results from the production or use of any raw material, intermediate product finished product by-product or waste
product containing vinyl chloride or polyvinyl chloride but which hat not
been discharged to e wastewater treatment process or discharged
untreated as wastewater. Gas-holder seal water is not inprocess wastewater until it is removed from the gasholder. ta*
(1) "In vinyl chloride service" means
that a piece of equipment either contains
or contacts a liquid that it at least 10
percent vinyl chloride by weight or a gas
that is at least 10 percent by volume
vinyl chloride as determined according
to the provisions of | 61.67(h). The
provisions of f 61.67(h) also specify how
to determine that a piece of equipment it
not in vinyl chloride service. This
definition must be used in place of the
definition of "VHAP service" in Subpart
V of this part
9
**
(o) "Ethylene dichloride purification" includes any part of the process of ethylene dichloride production which follows ethylene dichloride formation.
(p) "Vinyl chloride purification"
includes any part of the process of vinyl chloride production which follows vinyl chloride formation.
* **
(v) "Relief valve" means each pressure relief device including pressure
relief valves, rupture disks, manual vents and other pressure relief systems used to protect process components from overpressure conditions. "Relief valve" does not include control valves used to control flow to an incinerator or other air pollution control device.
(w) "Leak" means any of several events that indicate interruption of confinement of vinyl chloride within process equipment Leaks include events regulated under Subpart V of this part such as: (l) An instrument feeding of 10,000ppm or greater (2) indications of liquid dripping: (3) a sensor detection of failure of e seal system, failure of e barrier fluid system, or bath: and (4) detectable emissions as indicated by an Instrument reading of greater thanr 500 ppm above background. Leaks also Include events regulated under | Sl.68(b)(8](i) of detection of ambient concentrations in excess of background concentration. Emissions of vinyl chloride not regulated under | BUJl (a) and (b): 161.63(a): 181.64 (a), (b). (c),
(d), (e) and (I); and 161.85 (a) and (b)(1). (b)(2), (b)(3), (b)(4). (b)(5), (bM (bK7) and (b)(9) shall be considered a leak. A relief valve discharge la not f leak.
(x) "Exhaust gas" means any offgas discharged directly or ultimately to the atmosphere that was initially contained in or was In direct contact with the equipment for which 10 ppm emission
, * im* *
limits are prescribed in 161.62 (a) and (b); | 61.83(a): 61.64 (a)(1). (a)(2). (br ie) and (d): I 61.65 (b)(l)(ii), (b)(2). (b)(5). (b)(6)(ii) and (b)(9)(H). A leak as defined in paragraph (w) of this section is not an exhaust gas.
(y) "Relief valve discharge" means any nonleak discharge through a relief valve.
(z) "3-hour period" means any three consecutive 1-hour periods (each hour commencing on the hour).
3. By changing " all exhaust gases" to "each exhaust gas stream" and making other minor clarifying revisions in I 61.62(a), { 61.63(a), and 161.64 (a)(1), (b). (c) and (d) as follows:
11143 cimoon vmva for oovywnv dteNoride ptanto.
(a) Ethylene dichloride purification: The concentration of vinyl chloride in each exhaust gas stream from any equipment used in ethylene dichloride purification is not to exceed 10 ppm (average for 3-hour period or as determined In accordance with' 161.87(g)(1)), except aa provided in i 161.65(a). This requirement does not A preclude combining of exhaust gas * streams provided tot combined steam is ducted through control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm, or Apifvalent as provided in 161.66, lids requirement does not apply to equipment that has been opened, is ont of operation, and met the requirement in 16145(b)(6)(i) before being opened.
***
} 61.63 Emission standard tor vinyl chloride plants.
An owner or operator of a vinyl chloride plant shall comply with tha requirements of this section end f 0146
(a) Vinyl chloride formation and purifiestiotb The concentration of vinyl chloride in each exhaust gas stream from any equipment used In vinyl chloride formation and/or purification is not to exceed 10 ppm [average for 3-hour period or as dstarmined in accordance with 161.67(g)(1)), except ss provided in 161.85(a). This requirement does not preclude combining of exhaust gas streams provided toe combined steam is ducted through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm, or equivalent as provided In 161.66. ibis requirement does not apply to equipment that has been opened, is out of operation, and met the requirement in 161.65(b)(6)(l) before being opened. f $
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1396.
J4144 CmMm stand** far polyvinyl tWortdi ptalfc
Aa owner or operatarof polyvinyl chloride plant shall comply with the requirements of this section and 181.85.
(a) Reactor. The following requirements apply to reactors;
(1) The concentration of vinyl chloride in each exhaust gas stream from each reactor is not to exceed 10 ppm (avenge for 3-hour period or as determined in accordance with 16147(g)(1)), except as provided in paragraph (a)(2) of this section and 16143(a). 66
(b) Stripper. The concentration of vinyl chloride in each exhaust gas stream from each stripper is not to excsid 10 ppm (average for 3-hour period or aa determined in accordance with f 61.67tgXl)l. except as provided in f 01.63(a). Thia requirement does not apply to equipment that has been opened, is out of operation, and met the requirement in f 61.6S(bH6Hl) before being opened.
(c) Mixing, weighing, and holding container*. The concentration of vinyl chloride in each exhaust gaa stream Grom each mixing, weighing, or holding container in vinyl chloride service which precedes the stripper (or the reactor if the plant has no stripper) in the plant process flow is not to exceed 10 ppm' (average for 3-hour period or as determined in accordance with f 61.67(g)(1)). except as provided in I 6146(a). This requirement does not apply to equipment that has been opened, is out of operation, end met the requirement in 16143(b)(6)(f) before being opened.
(d) Monomer recovery system. The concentration of vinyl chloride in each exahust gaa stream from each monomer recovery system is not to exceed 10 ppm (average for 3-hour period or aa determined in accordance with .. { 61.67(g)(1)). except ea provided in I 61.63(a). This requirement dost not apply to equipment that has bean opened, la out of operatina.lnd ant the requirement in 16148(b)(6)0lhefoce being opened.
4. By revising existing parapaphs ! 6l.64(aX2) and by removing (e)(3) aa follows:
|614 gnariowatandwdterpolyvinyl U-*B*U- M*UV- po-m-Si
An owner or operator of a polyvinyl chloride plant shall comply with the requirements of this section and 161.68b
(a) Reactor. The following requirements apply to reactor*
(2) The reactor opening loss from each reactor is not to exceed 042 g vinyl chloride/kg (040002 lb vinyl chloride/lb) of poly vinyl chloride product except as provided in paragraphs (f)(1) and (f)(2) of this section, with the product determined on a dry solids basis. This requirement does not apply to prepolymerization reactors in the bulk process. This requirement does apply to postpoiymerization reactors in the bulk process, where the product means the gross product of prepolymerisation and postpoiymerization. 4
3. By revising paragraph (a) introductory text and adding paragraph (e)(3) to 18146 as follows:
161.64 Emission standard for polyvinyl cmoncM pvniik
*
(a) Sources following the stripparfs). The following requirements apply to emissions of vinyl chloride to the atmosphere from the combination of all sources following the stripperfs) [or the reactorfs) is the plant haa no stripperft)] in the plant process flow including but not limited to. centrifuges, concentrators, blend tanks, filters, dryers, conveyor air discharges, baggers, storage containers, and inprocess wastewater, except as provided in paragraph (f) of thia section:
(3) The provisions of this paragraph apply at all times including when offspecification or other types of resins ate made.
6. By adding paragraph (f) to V 81.64 as follows:
16144 Emiaaton standard for potyvlnyt
*
(f) Reactor used as stripper. When s nonbulk resin reactor Is used as a stripper this paragraph may be applied in lieu of 101.64 (a)(2) and (e)(1):
(1) The weighted average emissions of vinyl chlarida from reactor opening loss and all sources following the reactor used as a stripper from all grades of polyvinyl chloride resin stripped in the reactor on ench calendar day may not exceed:
(1) 202 g/kg (040202 Ib/lb) of polyvinyl chloride product for dispersion polyvinyl chloride resins, excluding latex resins, with the product determined on a dry solids basis.
(U) 0.42 g/kg (0-00042 Ib/lb) of polyvinyl chloride product for all other polyvinyl chloride resins, including latex resins, with the product determined on a dry solids basis.
7. By revising paragraph (a) to 16146 as follows:
} 61.45 Emission standard for ethylene dlchioritie, vinyl chloride and polyvinyl chloride plants
An owner or operator of an ethylene dichloride, vinyl chloride, and/or polyvinyl chloride plant shall comply with the requirements of this section.
(a) Relief ra/ve discharges. (1) Polyvinyl chloride plants (suspension, dispersion, latex and bulk processes).
(1) Reactor. The number of discharges to the atmosphere from relief valves on polyvinyl chloride reactors in vinyl chloride service is not to exceed the following limits except es provided in paragraph (a)(l](iii) of this section. For all reactors producing suspension resins within a PVC plant, the number of relief valve discharges la not to exceed 0436 discharges par 100 polymerization batches nor 4 discharges par year.For all reactors producing dispersion and latex resins within a PVC plant the number of relief valve discharge* fo not to exceed 0438 discharges par 100 polymerization batch**. For all reactors including prepolymerization and postpoiymerization reactors, producing bulk resins withift a PVC plant th* number of relief valva discharges is not to exceed 0435 discharges per 100 polymerization batches.
(ii) The number of discharges to the atmosphere from relief valves on equipment (excluding polyvinyl chloride reactors) in vinyl chloride service is not to exceed 0.023 discharges per 100 polymerization batches nor 3 discharges per year except as provided in paragarph (a)(l)(iii] of this section,
(iii) The limits specified in paragraphs (a)(l)(i) and (a)(1)(H) of this section may be exceeded when only one relief valve discharge to the atmosphere occurs during the 12-month period preceding the close of the 6-month reporting period.
(2) Polyvinyl chloride plants (solution and other continuous PVC production processes). The number of discharges to th* atmosphere from relief valves on ail equipment in vinyl chloride service is not to exceed 1 discharge per year.
(3) Ethylene dichioride and vinyl chloride plants. Th# number of discharges to the atmosphere from relief valves on equipment in vinyl chloride service is not to exceed 4 dischargee par year.
(4) Bach relief valve discharge that contributes to a relief valve discharge frequency tat excess of any limit prescribed in paragarphs (a)(1). (a)(2) and (a)(3) of this paragraph constitutes
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an individual violation of the respective limit.
(5) For every relief valve discharge to
the atmosphere, the owner of operator shall record the identity of the source, the date and time of the discharge, the cause of the discharge, the approximate total vinyl chloride loss during the discharge, and the method used for determining the vinyl chloride loss. This information shall be submitted in writing to the Administrator as part of the reporting requirements of paragraph 9 61.70. This information shall be retained and made available for inspection by the Administrator for a minimum of 3 years.
a By revising paragraphs (b)(3), (b)(8)(i), (b)(8)(iii), (b)(8)(iv) and (b)(aj(vi) to | 81.65 as follows:
9 61.65 Emission standard tor ethylene dichloride. vinyl cMorldo and polyvinyl chloride plants.
An owner or operator of an ethylene dichloride, vinyl chloride, and/or polyvinyl chloride plant shall comply with the requirements of this section.
(a) * * * (b) Fugitive emission sources
(1) * * * * (2) * * * (3) Leakage from pump, compressor, and agitator seals: (i) Rotating pumps. Vinyl chloride emissions from seals on all rotating pumps in vinyl chloride service are to be minimized by installing sealless pumps, pumps wi.th double mechanical seals or equivalent as provided in 9 61.06. If double mechanical seals are used, vinyl chloride emissions from the seals are to be minimized by maintaining the pressure between the two seals so that any leak that occurs is into the pump; by ducting any vinyl chloride between the two seals through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm; or equivalent as provided in 9 81.06. (ii) Reciprocating pumps. Vinyl chloride emissions from seals on all reciprocating pumps in vinwLchloride service are to be mlnliiiliaiTnj iwiaHing double outboard seals, or sf^inlunt aa provided in 9 01.06, If double ootboerd seals are used vinyl chloride emissions from the seels art to bo minimised by maintaining the pressure between the two seels so that any leek that occur* is into the pump; by ducting any vinyl chloride between the two seals through > control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm: or equivalent as provided in 161.86. (iii) Rotating compressor. Vinyl chloride emissions from seels on ell
rotating compressors in vinyl chloride service are to be minimized by installing compressors with double mechanical seals, or equivalent as provided in 9 01.66. If double mechanical seals are used, vinyl chloride emissions from the seals are to be minimized by maintaining the pressure between the two seals so that any leak that occurs is into the compressor by ducting any vinyl chloride between the two seals through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm: or equivalent as provided in 9 01.88.
(iv) Reciprocating compressors. Vinyl chloride emissions from seals on all reciprocating compressors in vinyl chloride service are to be minimized by installing double outboard seals, or equivalent as provided in 9 61.06, If double outboard seals are used, vinyl chloride emissions from the seals are to be minimized by maintaining the pressure between the two seals so that any leak that occurs is into the compressor, by ducting any vinyl chloride between the two seals through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm; or equivalent as provided in 161.66
(v) Agitator. Vinyl chloride emissions from seals on all agitators in vinyl chloride service ere to be minimized by installing agitators with double mechanical seala, or equivalent as provided in 9 61.66. If double mechanical seals .are used, vinyl chloride emissions from the seals are to be minimized by maintaining the pressure between the two seals so that any leak that occurs is into the agitated vessel: by ducting any vinyl chloride between the two seals through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm: or equivalent as provided in 9 61.66. #* 6 *
(6) Leak detection and elimination.
(i) It includes t reliable and accurate vinyl chloride monitoring system for detection of major leaks and identification of the general area of the plant where a leak is located. A vinyl chloride monitoring system means is device which obtains sir samples from one or more points on e continuous sequential basis and analyzes the samples with gas chromatography or, if the owner or operator assumes that all hydrocarbons measured are vinyl chloride, with infrared spectrophotometry, flame ion detection, or an equivalent or alternative method. * ft
{iii) It provide* for an acceptable calibration and maintenance schedule for the vinyl chloride monitoring system and portable hydrocarbon detector. For the vinyl chloride monitoring system, a daily span check is to be conducted with a concentration of vinyl chloride equal to the concentration defined as a leak according to paragraph (b)(6)(vi) of this section. The calibration is to be done
with either
(A) A calibration gas mixture prepared from the gases specified in sections 5.2.1 and 5X2 of Test Method 106 and in accordance with section 7.1 of test Method 106, or
(B) A calibration gas cylinder standard containing the appropriate concentration of vinyl chloride. The gas composition of the calibration gas cylinder standard la to have been certified by the manufacturer. The manufacturer must hava recommended a maximum shelf life for each cylinder so that the concentration does not change greater than 5 percent from the certified value. Ilia data of gas cylinder preparation, certified vinyl chloride concentration and recommended
maximum shelf life mutt have been affixed to the cylinder before shipment from the manufacturer to the buyer. If a gas chromatograph is used as the vinyl chloride monitoring system, these gee mixtures may be dinctly used to prepare a chromatograph calibration curve aa described in section 7J of Test Method 106. The requirements in section 5X3.1 and 5X3J of Teat Method 106 for certification of cylinder standards tnd for establishment and verification of calibration standards are to be followed.
[iv] The location and number of points to be monitored and the frequency of monitoring provided for in the program are acceptable when they era compared with the number of pieces of equipment in vinyl chloride sendee end the size and physical layout of the plant
ft* ft
(vi) It contains a definition of leak which ie acceptable when compand with the background concentrations of vinyl chloride in the areas of the plant to be monitored by the vinyl chloride monitoring system. Measurements of background concentrations of vinyl chloride in the areas of the plant to be monitored by the vinyl chloride monitoring system are to be included with the description of the program. The definition of leak for e given plant may very among the different erase within the plant snrfls also to change over time as beckpound concentrations in the plant are reduced. *66*6
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9. By revising paragraph (bM) l* i 61.65 as follows:
*41.66 Cmteatan atamter* ter eteytene
aicMorMa. vtnyt cMorMe ana palyvtnyt chloride p<ants .
(b) Fugitive emission sources. * * a*
(4) fecks /rom re/se/ valves. Vinyl chloride amliaiona due to leaks from each relief valve on equipment in vinyl chloride service shall comply with I 61.242-4 of Subpart V of this pert
a
10. By revising paragraph (b)(7) of I 61.65 as follows:
|6i*6 Ejnteaton standard tar ethylene onwra^ vwryi yfvonov vw pOVyVWlyl cfwnov-*-*-----a-a- p---iwita. *****
(b) Fugitive emission sources. *****
(7) Samples. Unused portions of samples containing at least 10 percent by weight vinyl chloride are to be returned to the process or destroyed in a control device from which the concentration of vinyl chloride in the exhaust gas does not exceed 10 ppm. -v Sampling techniques are to be such that sample containers in vinyl chloride are purged into a dosed process system.
11. By revising paragraphs (b)(8) introductory text (b)(8)(H). and (b)(B)(v) to ) 61*5 as follows:
t|Ve1eSWf mUM-- H_ B_ V--1 WIQW- -- -* s Ia*--* V,iDtVya M- -n-i
wwoOnOi, wiyi craonot |no polyvinyl-** --X- *-----I -j- - ------- a -*-*-----*
- -u -a ------ *------- ------ *
MOW KM pWiA-- - - j- ~_ _*.
***
(b) Fugitive emission sources
*
**
*
(8) Leak detection and elimination..
Vinyl chloride emissions due to leaks from equipment in vinyl chloride service are to be minimised by instituting and implementing a lead detection and repair program consistent with the provisions of Subpart V of this part The program is to be Implemented within 90 days of the effective date atthus regulations, unless a waiver of compliance is granted under 181.11. Approval of a program will bo wanted
by the Administrator provided m finds:
0) * * *
(U) It indudes a reliable and secants portable hydrocarbon detector to bo used consistent with the provisions of Subpart V of this part An owner or operator is exempt from 181-242-l(d). II 61*42-7 (). (b) and (c), 161*4* and 161*47 of Subpart V of mis part for any procaaa unit in which the percentage of leaking valve* is demonstrated to be equal to or less than Z.0 percent as
determined In accordanc* with the following:
(A) A performance teat as specified in paragraph (b)(B)(ii)(C) of this section shall be conducted initially within 90 days of the effective date of these regulations, annuity and at times requested by the Administrator.
(B) For each performance test a minimum of 200 or 90 percent of the total valves in VOC service (as defined in 160.461 of Subpart W of Part 60) within the process unit shall, be randomly selected and monitored within 1 week by the methods specified in | 61245(d) of Subpart V of this part If an instrument reading of 10,000 ppm or greater ia measured, a leak is detected. The leak percentage shall be determined by dividing the number of valves in VOC service for which leaks are detected by the number of tested valves in VOC service.
(C) If a leak ia detected, it shall be repaired in accordance with 161.242-7 (d) and (e) of Subpart V of this part.
(D) The results of ths performance test shall be submitted in writing to the Administrator in the first semiannual report following the performance teat as part of the reporting requirements of 161.70.
(E) Any process unit in which the percentage of leaking valves fa found to be greater than 10 percent must comply with all provisions of Subpart V of this part within 90 days. *****
(v) It contains a plan of action to be taken when a leak is detected consistent with Subpart V of this part
12. By revising { 61.66 as follows;
|61*6 Equivalent equipment and
Upon written application from an owner or operator, the Administrator may spprovs use of equipment or procedures which have been demonstrated to his satisfaction to be equivalent in terms of reducing vinyl chloride emissions to the atmosphere to those prescribed for compliance with specific paragraph of this subpart.
13. By revising paragraph (f) of 161*7 as follows:
161*7 imlsilsn teste.
(0 The owner or operator shell retain at the pleat and make available* upon request for Inspection by the Administrator, for a minimum of 3 yeah, records of emission test results and other date needed to determine emissions.
14. By revising paragraphs (g)(3) introductory text (g)(3)(i), and (g)(3)(iii) of i 61.67 as follows:
f 41.67 Emission testa. *****
(8) * * *
(3) When a stripping operation ia used to attain the emission limits in 161.84 (e) and (f). emissions are to be
determined using Test Method 107 as follows:
(i) The number of strippers (or reactors using as strippers) and samples and the types and grades of resin to be sampled are to be determined by the Administrator for each individual plant at the time of ths test based on the plant's operation.
(ii) * *
(iii) The corresponding quantity of
material processed by each stripper (or
reactor used as a stripper) is to be
determined on a dry solids basis and by
a method submitted to and approved by
the Administrator.
....................................
A
%
15. By revising paragraph (g)(5)
introductory text end adding paragraph
(g)(6) to | 61.67 as follows:
|61*7 Emission taste. * * *^
(8) * * * (5) The reactor opening loss for which
an emiaalon limit ia prescribed in
161.64(a)(2) is to be determined. The
number of reactors for which the determination is to be specified by the Administrator for each individual plant at the time of the determination baaed on the plant's operation. *****
(8) For a reactor that is used as e stripper, the emissions of vinyl chloride from reactor opening loss and ail sources following the reactor used as a stripper for which an emission limit ia prescribed in f 61*4(f) are to be determined. The number of reactors for which the determination ia to be made ia to be specified by the Administrator for each Individual plant at the time of the determination based on the plant'* operation.
(i) For each batch stripped in th* reactor, the following measurements are to be made:
(A) The concentration (ppm) of vinyl chloride in resin after stripping, measured according to paragraph (g)(3). of this section;
(B) The reactor vacuum (mm Hg) at end of strip from plant Instrument and
(C) The reactor temperature (*C) atend of strip from plant instrument
067U* Si
1198
Federal Register / Vol. 50, No. 8 / Wednesday. January 9. 1985 / Proposed Rules
(ii) For each batch stripped in the reactor, the following information is to be determined:
(A) The vapor pressure (nan Hg) of water in the reactor at end ofitrfp from the following table:
*par Ml fQ
vapor
**mn {turn
Raacfcs aaa fO
HfO MW
Hsaaar
Swro
HfO vapor ON-
(fit* **
40 56.3 41 90.3 4* 1,3 * 144 44 0L3 41 71* m 734 47 714 40 0.7 40 NO SO 923 51 72 52 1Qt 53 1072 54 112.3 56 11*4 56 1234 57 12&I 9 1301
so 142-6 eo 140.4
1 ISM
* 163,0 a 1714 04 1713
mm 1074 tflflLf
07 2064
m zvu m 2237
70 2*7
ft71 2414 2544 TO 3*7 74 2774 75 2*1
n 3014 n 3*4.1
n 3274
70 3074
m 3S61 9% 300.7
3044 03 400.0 M 4104 99 4364 M 450 0 7 4*7 0 407.1 60 3001 0 3254 01 5*0
m 074
n 3*0
0* 0104 00 0334
*70
7 *1
m 7074 m nu
100 7*0
(B) The partial pressure (mm Hg) of vinyl chloride in reactor at end of strip from the following equation:
PPVA - 780 - RV - VPW
Where: PPVC- partial pressure sf vinyl cMoride, in
nun Hg 700=atmospheric pressure at O'C in mm Hg RV--absolute valet of reactor vacuum, la
sun Hg VPW-vapor pressure of water, to mmHg
(C) The reactor vapor apace volume (m*) at end of strip from the following equation:
v*v-nc-wv- ---------
where:
RV5Va reactor vapor apace vekM.fi RC--reactor capacity, kaf WV . volume of wstre hi reactor Im recipe.
in m*
PVCW-diy wetghl atfpeiyvteyf cMoride to reactor fruairedpe. to kg
*33 ** typical danaity of polyvinyl chloride in kg/m*
(Ui) For ooch bntch stripped in the
reactor, the combined reactor opening
lose and emiseione from ell tourcee
following the reectoe need aa a stripper
is to be determined using the foQowk*
equation:
,.
(PPVC](RVSV)(1.002)
c*(ppwvcxi<r*)+ -----------------------
IPVCW)(273 + RT)
where:
Cg vinyl chloride/kg poiyvmyi chlonde product
PPMVC--concentration of vinyl chloride in resin after stripping. In ppm
10"'=conversion factor for ppm PPVC--partial pressure of vinyl chlonde
determined according to paragraph (sH&HdXB) of this section, to mm Hg RVSV - reactor vapor space volume determined according to paragraph (8)(0)(u)(C) of this section, in m' 1,002--ideal gat constant in g--*K/mm Hg-- m* for vinyl chloride PVCW--dry weight of polyvinyl chloride in reactor from reaps. in kg 273 - conversion factor tor *C to *K RT- reactor temperature, in 'C
18. By adding paragraph (h) to { 81.67 as follows: *
(h)(1) Each piece of equipment within e process unit that can reasonably contain equipmmjt m vinyl chloride service is presumed to be in vinyl chloride service unless aa owner or operator demonstrates that the piece of equipment is not in vinyl chloride service. For e piece of equipment to be considered not in vinyl chloride service, it must be determined that the percent vinyl chloride content can be reesonably expected not to exceed 10 percent by weight for liquid streams and 10 percent by volume for gas streams. For purposes of determining the percent vinyl chloride content of the process fluid that is contained in at contacts equipment, procedures that conform to the methods described in ASTM Method D-22S7 (incorporated by reference es specified in 181.18) shall be used.
<3Xi) An owner or operator may use engineering fudgment rather than the procedures in paragraph (h)(1) of this section to demonstrate that the percent vinyl chloride content does not exceed 10 percent by weight for liquid streama and 10 percent by volume for gee streams, provided that the engineering judgment demonstrates that the vinyl chloride content dearly does not exceed 10 percent When an owner or operator and the Administrator do not agree on whether a pieca of equipment is not in vinyl chloride service, however, the procedures in paragraph (hHD of this section shall be used to resolve the disagreesMnt.
(ii) If an owner or operator determines that a piece of equipment is in vinyl chloride service, the determination ceo
be revised only after following the procedures in paragraph (h)(1) of this section.
(3) Samples used in determining the percent vinyl chloride content shall be representative of the process fluid that Is contained in or contacts the equipment
17. By adding paragraphs (d), (e) and (0 to f 61.88 as follows:
f 61.68 Emission monitoring.
4 *
(d) When exhaust gas{es)i having emission limits that an subject to the requirement of paragraph (a) of this section, are emitted to the atmosphere around the control system and required vinyl chloride monitoring system, the? vinyl chloride content of the emission shall be calculated (in units of each applicable emission limit) by best practical engineering judgment based on the discharge duration and known VC concentrations in the affected equipment as determined in accordance with 161.67(h) or other acceptable method.
(e) For each 3-hour period, the vinyl chloride content of emissions subject to the requirements of paragraphs (a) and (d) of this section shall be averaged (weighted according to the proportion of time that emissions wen continuously monitored and that emissions bypassed the continuous monitor) for purposes of reporting excess emissions under f 81.70(c)(1).
(f) each vinyl chloride emimion to the atmosphere determined in accordance with paragraph (e) of this section to be in excess of the applicable emission limits, tbs owner or operator shall record the identity of the aotneefob the date, time, end duration of the excess emission, the cause of the emission, the approximate total vinyl chloride loss during the excess emission, and ths method nsed for determining the vinyl chloride loot. This information shall be retained and mads available for inspection by the Administrate* as required by 161.71(e).
10. By eWwwgtwg the title from "Semiannual report" to "Reporting'* end by revising psravepb (a) of 18L70 ee follows:
SL 067115
/ VoL ML Nol / Wednesday. (anuary . 1968 / Proposed Kale*
lift*
f #1.70 Reporting.
(a)(1) The owner or opmaimef say source to which this subpart afpUe* shall submit to the Administrator on September 15 end March 15 of eoch year a report in writing containing the information required in paragraphs, (cl. (d) and (e) of this section and on December IS and Juno IS of each year a report in writing containing the information required in paragraph (e) of thia section, except as provided In paragraph (a)(2).
(2) In the case of an existing source that submits semiannual reports on an approved fixed schedule other than September 15 end March 15, tha approved semiannual reporting schedule shall be used to report the information required in paragrapha (c), (d) and (e) of this section. In addition, the information required in paragraph (e) of thia section will be reported exactly 3 months following the semiannual reporting dates.
(3) The first report is to be submitted following the first full 3 month reporting period after the initial report f> submitted.
19. By revising paragraph (c)(1) of } 61.70 as follows:
$ 61.70 Reporting. ****
(c)* * * (1) The owner or operator shall include in the report a record of the vinyl chloride content of emissions for each 3-hour period during which average emissions are in excess of the emission limits in S 61.62 (a) or (b), I 61.63(a). or ! 61.64 (a)(1), (b). (c). or (d). or during which average emissions are in excess of the emission limits specified for any control system to which reactor emissions are required to be ducted in 161.64(a)(2) or to which fugitive emissions are required to be ducted in S 61.65 (b)(i)(U). (b)(2), (b)(5), (b)(6)(ii). or (b] (9)(ii). If emissiona in excees of the emission limits are not detected, the report shall contain a statement that no excess emissions have bees detected. The emissions ere to bo determined in accordance with 101.M(eL 20. By revising panpaph (cX*)_ introductory text removing paragrapha (c) (2)(iv), revising paragraph (cM2KiU)
and revising (c)(2)(v) and (cX2K*<) introductory text to i 61.70 as follow*:
(61.70 inputting.
*****
(c) * * * (2) In polyvinyl chlorid# plants for . which a stripping operation Is used to attain the emission level prescribed in 161.64(e). the owner or operator shall include in the report a record of the
etapl ehloride corneal in the polyvinyl dtlortde resin.
(ili) The vinyl chloride content in each tumple is to be determined by Test Method 107 as prescribed in | 61.67(g)(3).
(iv) (Reserved} . (v) The report to the Administrator by the owner or operator is to include a record of any 24-hour average resin
vinyl chloride concentration, as determined in this paragraph, in excess of the limits prescribed in f 61.64(e). The vinyl chloride content found in each sample required by paragraphs (cl(2)(i) and (c)(2](ii) of this section shall be averaged separately for each type of resin, over each calendar day and weighted according to the quantity of each grade of resin processed by the stripperfs) that calendar day, according to the following equation:
2p-lP'(M0t+p'iM't+ . . .
Ar, 9Z "
^
where:
A-24-hour average concentration of type. T, resin in ppm (dry weight basis).
Q--Total production of type 7i rosin over the 24-hour period, in kg.
Ti--Type of resin: /--1.2, . . m when m is total number of resin types produced dunng tha 24-hour period.
A/ Concentration of vinyl chloride in one sample of grade G rosin, in ppm.
P= Production of grade G resin represented by the sample, in kg.
C.-Grade of resin: e.g~ G,. G* and G* n -Total number of grades of resin produced
during the 24-hour period.
If no 24-hour average resin vinyl chloride concentredona in excess at the limits prescribed in 1 61.64(e) are measured, the report shall state that no excess resin vinyl chloride concentrations were measured.
(vi) The owner or operator shall retain at the source and make available for inspection by the Administrator for a minimum of 3 years records of all data needed to furnish the information required by paragraph (c)(2)(v) of this section. The records are to contain the following information:
(A) * * * () f t
21. By revising paragraph (c)(3) of 161.70 as follows:
161.7* Reporting. t *
(C)* * * (3) The owner or operator shall Include in the report record of any emissions from each reactor opening in excess of the emission limits prescribed in 161.64(a)(2). Emissions are to be determined in accordance with| 61.67(g)(5), except that emissiona for each reactor are to be determined. If emissions in txcess of the emission limits are not detected, the report shall
include s statement that excess
emissions have not been detected.
*
22. By adding paragraph (c)(4) to { 61.70 as follows:
*61.70 Reporting
e
t
(C) * * * (4) In polyvinyl chloride plants foowhich stripping in the reactor is used to attain the emission level prescribed In 161.64(f), the owner or operator shell
include in the repqpt a record of the vinyl chloride emissions from reactor opening loss and all sources following the reactor used as a stripper.
(i) One representative sample of
polyvinyl chloride resin is to be taken from each batch of each grade of resin immediately following the completion of the stripping operation, and identified by resin type and grade and the date and time the batch is completed. The corresponding quantity of material processed in each stripper batch ia to be recorded and identified by resin type and grade and the date and time the batch is completed.
(ii) The vinyl chloride content in each sample is to be determined by Test Method 107 as prescribed in
f 61.67(g)(3). (iii) The combined emission from
reactor opening lots and all sources following the reactor used as a stripper are to be determined for each batch stripped in a reactor according to the procedure prescribed in 161.67(g)(6).
(iv) The report to the Administrator by
the owner or operator is to include e record of any 24-hour average combined reactor opening toes and emissiona from all soareas following the reactor used as a stripper as determined In thia paragraph. In excesa of the limits prescribed in 161.64(f)- The combined reactor opening loss and emissions from
SL 067116
1200
Federal Ragfatae / Vol. 50. No. 8 / Wednesday. January 9. 1985 / Proposed Rules
all sources following the reactor used as
a stripper associated with sad) batch are to be averaged separata^far each, type of resin, over each caMSMar day and weighted according to the quantity
of each grade of resin stripped in reactors that calendar day as follows:
For each type of resin (suspension, dispersion, latex, bulk, other), the following calculation is to be performed:
n E PG ^G -1----1-- ----B-1---b--1-
PS1CG1 4- PG2 CG2
4- PG CG
nn
Where:
A = 24-hour average combined reactor opening lose and emissions from all sources following the reactor need as e stnpper. in g vinyl chloride/kg product (dry weight baeia).
Q-Total production of resin in batches for which stripping is coupietsd during tbs 24-hour period, tn kg.
C--Average combined reactor opening lost __ and amissions from all sources following
the reactor usad as a stripper of all batches of grade Gi resin for which tripping is completed during the 24-hour period in g vinyl chloride/kg product (dry weight basis) (determinad according to procedure prescribed in | SUI7(gJ(6)). P-Production of grade Gi resin in tha batches for which C is determinad. in kg Gi-Grade of resin; e-g. Gi. Gm. and G. n* Total number of grades of resin in batches for which stripping ia completed during the 24-hour period.
If no 24-hour average combined reactor opening loss and emissions from all sources following the reactor used a stripper in excess of the limits prescribed in 161.84(f) are determined, the report shall state that no excesa vinyl chloride emission* were determined.
23. By adding paragraphs (d], (e) and ffj to | 81.70 aa follows:
181.70 Reporting.
***
(d) The owner or operator shall
include in the report a record of relief
valve dischargee aa p--
fa
181.85(a)(4). and the owatfpr operator
shall report excoedeacM ofna relief valve discharge frequency Iroita
prescribed in 16145(a) to be determined aa follows:
(1) For polyvinyl chloride plants
producing diaperfare, latex or bulk
resins, the relief valve discharge
frequency from polyvtnly chloride
reactors is to be determined using the following equation. Separate
calculations are to be made for etch, resin type (t)aa defined
N Y
Where
F,* relief velve discharge frequency per 100 polymerization batches from all reactors producing reaing type t
N-total number of relief valve discharges during the 12-mouth period preceding the close of the 5-month reporting period from ail reactor* producing resin type t
Y - total number of polymerization batches of resin type t during the 12-month period preceding the close of die 5-month reporting period divided by 100
t resin type: dispersion (including latex] or bulk resin type
(2) For polyvinyl chloride plants producing suspension resins, the relief valve discharge frequency from polyvinyl chloride reactors is to be determined in two ways using the following, equations:
m
F_ - --, and
-M
where
F.=relief valve discharge frequency per 100 polymerization batches from aO reactor* producing suspension resin
Fj relief valve discharge frequency per 12month period from all reactors producing suspension resin
N total numbv of relief valve discharges during the 12-month period preceding the close of the 5-month reporting period from ell reactor* producing suspension resin
Y total number of polymerization batches of suspension resin during the 12-month period preceding the close of the 5-month reporting period divided by 100
(3) Foe polyvinyl chloride plants producing suspension dispersion, latex, or bulk resins, the relief valve discharge frequency from all other equipment (excluding polyvinyl chloride reactors) ia to be determined ii> two ways using the following equations:
N F. --; end Fi - N
Y
where
relief valve discharge frequency per 100 polymerization batches from all equipment (excluding reactors) Fi = relief valve discharge frequency per 12month period from all equipment (excluding reactors) N total number of relief valve discharge* during the 12-month period preceding the close of the 5-month reporting period from all equipment (excluding reactors) Y=total number of polymerization batches of all resin types combined divided by 111)
(4) For polyvinyl chloride plants using the solution process or any other continuous production process, the relief valve discharge frequency is the summation of each relief valve discharge from all equipment types during the 12-month period preceding the close qf the 8-month reporting period.
(5) For ethylene dichloride/vinyl chloride plants, the relief valve discharge frequency is the summation of each relief valve discharge from all equipment types during the 12-month period preceding the close of the 8month reporting period.
(8) A polymerization batch consist* of each sequence of charging VC and other materials to the reactor, heating reactor contents, polymerization of reactor contents, and removal of reactor contents including any incomplete sequence that ia aborted after charging VC to the reactor. For bulk resin production plants, a single "polymerization batch" includes both prepolymerization and postpolymerization reactor operations.
(e) The owner or operator shall include in the report the number of relief valve discharges to the stmosphere during the 3-month period preceding the report from each of the following sources: suspension resin production reactors; dispersion and latex resin production reactors: bulk resin production reactors; all nonreactor equipment in PVC plants: aD equipment used in solution process and other continuous process PVC plants; and all equipment in EDC/VC plants; any other source.
(f) The owner or operator shall include in the report the number of reactor openings and the design capacity of the number of polymerization batches for each type of resin in each plant during the 8-month period preceding the report The design capacity of the number of polymerization batches may be defined
SL 067117 jf
HftMu / Voi 14 Tim, > / Wedn--day. January 9l 1--* / fogyA Rolf
initially and remain uadH^^ mlaan significant change* to the desinn capacity occur.
24. By revising paragraph (a| introductory text of | 81.71 a* follow*
S 61.71 Recordkeeping.
(a) The owner or operator of any source to which this subpart applies shall retain the following information at the source and make it available for inspection by the Administrator for a minimum of 3 years;
e
23. By adding the words "vinyl chloride" to the definition of the term "volatile hazardous air pollutants" in { 01.241 of Subpart V as follows:
$61-241 PotlnWona. * * **
"Volatile hazardous air pollutant" or "VHAP" means a substance regulated under this part for which a standard for equipment leaks of the substance has been proposed and promulgated. Benzene is a VHAP. Vinyl chloride is a VHAP.
(Sec. 112 Oean Air Act of 1978)
[FR Doc. 83-509 Filed 1-8-85; 8:43 am]
*
120&
Si 067U8