Document 2q3N4M1r2wNRp9XXggKdydVYb
Texas Air Control Board
General Rules Chapter 101
Page 32 of 35
$101.20.
Compliance with Environmental Protection Agency Standards.
Any person owning or operating a source of air contami nants shall comply with any applicable new source performance standards promulgated by tHe Environmental Protection Agency pursuant to Section 111 of the Federal Clean Air Act, as amended, and any applicable emissions standards for hazardous air pollutants promulgated by the Environmental Protection Agency pursuant to Section 112 of the Federal Clean Air Act, as amended.
5101.21. The National Primary and Secondary Ambient Air Quality Standards.
The National Primary and Secondary Ambient Air Quality Standards, as promulgated pursuant to Section 109 of the Federal Clean Air Act, as amended, will be enforced through out all parts of Texas.
5101.22, Effective Date.
The general rules contained in this chapter shall be in force immediately and shall supersede all previous General Rules of the Texas Air Control Board.
March 20, 1981
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ROUTING ANO TRANSMITTAL SUP
TO: (Nama. office symbol, room numbor, building, Agency/Post)
1, Mr. J. F. Erdmann, P.E.
2. Union Carbide Corporation
Date
Az/s-t
Initials Date
KiSfr.pi.
3. P.0, Box 471_______________
4. Texas City, Texas 77590
8.
Action Approval
File For Clearance
Note and Return Per Conversation
As Requested Circulate Comment Coordination
For Correction For Your Information Investigate Justify
Prepare Reply . See Me Signature
remarks As per your telephone request this date, I have enclosed the Evaluation of your proposal for the Alternative NESHAP sampling procedure for Vinyl Chloride (Method 107) which reflects our current direction.
Please note that enclosure is for purpose of discussion as you requested and does not constitute the formal response from this office to your request at this time.
DO NOT uw this form a* a RECORD of approval*, concurrences, disposal*, clearances, and similar actions
FROM: (Nama, org. symbol, Agoney/Post)*py. ^ jQ
Martin E. Brittain, P.E. _ EPA, Region 6
Room No.--Bldg.
Phone No.
214-767-2755
5041-102
<r U GOVERNMENT RRINTINO OFFICE I#?*->01 104'
OPTIONAL FORM 41 (Rev. 7-76) Pnicrilud bv GSA FPMR (41 CflQ 101-U.20S
teCryuT*
date 19 FEB 1981
Research Triangle Park, North Carolina 27711
2 6 1331
subject Evaluation of Alternative NESHAP Sampling procedure for Vinyl Chloride (Method 107)
6AEfi
from Don R. Goodwin, Director Emission Standards and Engineering Division (MD-13)
to. Diana Dutton, Director Enforcement Division, Region VI (6AE)
We have evaluated your request of October 31, 1980, concerning an alternative sampling procedure for determining compliance with the vinyl chloride (VC) standard for sources following polyvinyl chloride (PVC) resin strippers. The request, originated by Union Carbide Corporation in Texas City, Texas, concerns the approvability of sampling on a weekly basis rather than a daily basis as required by the VC standard. After evaluating this request, we recommend that it not be approved. However, we recommend another procedure which we could consider as an alternative to the required procedure. Our reasoning is
presented below.
Union Carbide Corporation (UCC) shows that it consistently reduces the concentration of residual vinyl chloride monomer in the PVC resin (residual YCM/PVC) at its Texas City plant to less than 400 ppm.. This type of resin is produced by an unique solvent-based process. UCC removes the residual VCM/PVC through distillation. The result of this control, according to UCC's data, is an average level of 10 ppm or less residual VCM/PVM. UCC concluded that their data indicate that daily sampling and analytical procedures may not be necessary to show compliance with the VCM standard; therefore, less costly, weekly procedures should be approved as an alternative procedure for showing compliance.
Weekly sampling does not allow for the determination of compliance for
1o'4 jC .. any day other than the day of sampling. Operating parameters can vary from
one batch to another and batches can vary from one day to another. Because K r 1 operating parameters greatly influence the residual VCM/PVC, a residual
VCM/PVC sample on one day would not be a reasonable indicator of the residual VCM/PVC on another day. Thus, we do not consider a weekly sampling procedure adequate for determination of compliance with the residual VCM/PVC standard.
The situation that UCC describes was considered during proposaKand
promulgation of the VC standard. The standard's support information* explains
that it may be possible to establish a relationship between the measured
/
emissions and the corresponding operating parameters used to comply with the standard. If a relationship can be established between the residual VCM/PVC
A. ^ fyJ ^<nd operating parameters, then an individual plant could be allowed, under
the authority of emission test waiver and alternative test method provisions,
^ fftf-fl'l'to record certain parameters rather than to conduct emission measurement.
Thus, we could approve an alternative sampling procedure based op establishing
relationship between residual VCM/PVC and operating parameters.
Zf.*
EPA Fn 1320-4 (R. 3-74fC
UCC
051346
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To establish the relationship, if any, between the residual VCM/PVC and operating parameters, a plant would need to establish a predictive equation which would reasonably estimate the residual VCM/PVC given the operating parameters (such as pressure, temperature, grade of resin, and residence time). An analysis of variances may be the most appropriate statistical tool to establish a predictive equation in this situation. Variances between samples and within samples could be used to establish a predictive equation and to show whether the process can be predicted with a reasonable degree of certainty.
After establishing a relationship, a plant could record the operating parameters and these would be used for determining compliance. A plant could also measure the residual VCM/PVC upon request (e.g., semi-annually or annually) if you or the appropriate enforcement agency believed that verification of the predictive equation was necessary on a periodic basis.
In summary, we recommend that you do not approve the alternative sampling
procedure as requested by UCC because it does not allow an adequate determination
of compliance with the residual VCM/PVC standard. However, we could approve
an alternative sampling procedure based on establishing a relationship between
residual VCM/PVC and operating parameters which would achieve UCC's desire to
reduce costly measurements yet would allow an adequate determination of
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compliance. If you have any questions, please contact Fred Dimmick (FTS 629 WW)
or Leslie Evans (FTS 629-5454).
cc: Martin Brittain, Region VI (6AEAE) Richard Biondi, DSSE (EN-341) Susan Wyatt, SDB (MO-13)
UCC
051347
REFERENCES 1. Attachments to memorandum from Diana Dutton to Don R. Goodwin, dated
October 31, 1980. 2. SSEIS: Emission Standard for Vinyl Chloride (EPA-450/2-75-009),
page 8-44. 3. Miller, I., and Freund, J.E.; Probability and Statistics for Engineers.
Prentice-Hall, Inc. 1965, Chapters 12-14.
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