Document 6BxZVzO1jK0jz79Dmb95zQbD3

ABDOO133463 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS - NESHAP NESHAPs are nationally uniform standards oriented toward particular pollutants at the point of emission. Vinyl chloride is in this category. It applies to new and modified sources that commenced construction after EPA proposed an applicable NESHAP. As with NSPS applications for approval of construction or modification must be made and accepted prior to the date on which construction or modifications is commenced. The following pages outline the part of the Federal Register that pertains co NESHAPs. 2-3 ABDOO133464 EPA REGULATION PROPOSED 12/24/75 PROMULGATED 10/20/76 PLANT OPERATED UNDER A WAIVER OF COMPLIANCE UNTIL SYSTEMS COULD BE INSTALLED TO MEET THE STANDARD 9/1/78. - STRIP SLURRY T0^ 400 PPM VCM - REACTOR OPENING LOSS 4 20 PPM VCM - NO MANUAL VENTING OF VCM - NO RELIEF VALVE DISCHARGES OF VCM - MINIMIZE FUGITIVE VCM EMISSIONS o RAILCAR UNLOADING LINES 0 DOUBLE MECHANICAL SEAL ON ROTATING PUMPS AND COMPRESSORS AND AGITATORS 0 REDUCE VCM IN EQUIPMENT BEFORE OPENING TO ATMOSPHERE o SAMPLES o REQ'UIRED LEAK DETECTION AND ELIMINATION PLAN CONTINUOUS MONITORS PORTABLE MONITORS o IN-PROCESS WASTEWATER STRIPPED TO LESS THAN 10 PPM VCM o EXHAUST GASES REDUCED TO 4^10 PPM VCM - EMISSION TESTS - EMISSION MONITORING OF INCINERATOR OFFGAS - REPORTING RECORDKEEPING ABDOO133465 NATIONAL EMISSION STANDARD FOR HAZARDOUS AIR POLLUTANTS (NESHAPS) 40 CFR PART 61 General Provisions: Sub Part A Definitions: 61.02 1. Alternative method 2. Capital expenditure 3. Compliance schedule State Delegation: 61.04(b) Bureau of Pollution Control Department of Natural Resources Jackson, MS Prohibited Activities 61.05 Don't modify without written approval from the Administrator (State) Application for Approval to Construct 61.07 Notification of Start-up 61.09 Initial Report 61.10 Waiver of Compliance 61.11 Up to two years Compliance with Standards 61.12 Determine by tests specified in rules Alternate, methods Emission tests 61.13 Withfri 90 days of start up Notify Agency 30 days before test Modification 61.15 ABDOO133467 9. Manual Venting 10. Opening Equipment 11. Samples 12. Leak Detection and Elimination - Approval required i. Fixed point monitoring ii. Definition of a leak iii. Subpart V - annual performance test. Submit results in next quarterly. 13. In process wastewater Emission Tests 61.67 Method 106 Alternate method Method 107 Emission Monitoring 61.68 Reporting 61.70 Quarterly Reports Exception reporting Recordkeeping 61.71 3 years Leaks Emission measurements Daily reactor operating record including T and P ^-- ABDOO133466 A change, operational or physical, that increases emissions is a modification unless it is not a capital expenditure or is routine maintenance. Subpart F - VCM Definitions 61.61 In vinyl chloride service Relief valve Leak Exhaust gas 3 hour period Emission Standards for PVC Plants 61.64 Reactors 10 ppm exhaust gas limit ROL Slurry PVC and VCM plant emission standards 61.65 (a) RVD's (b) Fugitives 1. Loading & Unloading 2. Slip gauges 3. Rotating pumps 4. Reciprocating pumps 5. Rotating Compressors 6. Reciprocating Compressors 7. Agitators 8. Leaks from RV's ABDOO133468 ! !/. HISTORY OF VCM NESHAP'S ENFORCEMENT Oct. 20, 1976 Jan. 19, 1977 Feb. 2, 1979 Jan. 19, 1980 Apr. 3, 1980 Apr. 7, 1980 Sept. 16, 1981 Oct. 16, 1981 Nov. 5, 1981 Jan. 11, 1982 June 10, 1982 Jan. 13, 1983 Dec. 18, 1983 VCM Neshap's Promulgated VCM Neshap's Becomes Effective RVD 25,500 lbs. RVD 24 lbs. RVD 180 lbs. RVD 36 lbs. RVD 20 lbs. RVD 357 lbs. RVD 89 lbs. RVD 3-7 lbs. RVD 57 lbs. RVD Manual Vent 222 lbs. 229 lbs. D-300 D-400 D-9 D-9 Charge filter T-201 Charge filter Recovered monomer condenser Recovered monomer condenser D-745 ? Feb. 1, 1984 After July 20, 1984 Aug. 19, 1985 Sept. 16, 1985 Oct. 25, 1985 Nov. 14, 1985 Dec. 31, 1985 Conoco Sued by DOJ on behalf of EPA July voluntarily becomes a party to the suit Vista & Conoco agree to settle out of court. $100,000 penalty Agree to submit a compliance plan. Compliance plan submitted to EPA. Suggest 3 projects plus administrative; asks for ROL equivalency EPA asks for more information Vista sends more information EPA tentatively approved plan; they do not approve ROL equivalencies. 1- - i__ Mar. 27, 1986 Apr. 1, 1986 Apr. 3, 1986 Dec. 23, 1986 July 27, 1986 Aug. 8, 1986 Mar. 11, 1987 Apr. 14, 1987 Aug. 6, 1987 Nov. 7, 1987 ABDOO133469 A EPA approves ROL equivalency. AFE for projects submitted. $107,500 1. Reactor valve limit switches 2. Water Stripper T/P recorder 3. New module BD Tank level indicator Conoco EPA Approves compliance plan. Three projects complete. VCM release VCM release MS Bureau of Pollution Control issues complaint for 2 releases Vista settles with the State for $2,000. Termination filed on the consent decree. Case closed. 2- -