Document 6Q706ZOq8x5EgrzKX85M7gXm

3. R. SHEuKAM . V1 h s ; 11 - / inter-off re M^3 TEN N E Cft CHEN IM'k*. INC. to D.C. Coldiron NOV 3 019/6 at Piscataway DATESeptember 13, 1976 from j.p. Sandstedt at Piscataway Subject TRIP REPORT MEETING OF SPI TECHNICAL COMMITTEE WITH EPA - REPRESENTATIVES OF EMISSION STANDARDS AND ENGINEERING DIVISION copy toW.P. Anderson W. F. Gabel-' R.T. Gottesman R.E. Harmond R.S. Miller W. Miringoff F* X* Ritter M.K. Rosen G.I. Rozand E.V. Schenke C.G. Thompson Attendees: SPI Members EPA Representatives Fred Dehn - PPG Don R. Goodwin W.C. Holbrook - Goodrich Susan Hyatt John Lawrence - SPI Jack Farmer Nick Wheeler - Union Carbide Cecil Loechelt - Ethyl Bill Maddon - Firestone Gary Baise - SPI Counsel John Sandstedt - Tenneco ^ This meeting with EPA was held in order to present an industry request for an additional modification to the revised EPA emis sion standard on vinyl chloride monomer, as it pertains to R&D facilities. In its revised fogm, research equipment with a capacity of no more than 0.19ni (50 gal) are exempted from control. Further, pilot facilities with a capacity of greater than Q.19ni (50 gal) and no more than 4.07mJ (1100 gal) need comply with paragraphs 61.64(a)(1), (b), (c), and (d) only. Thus, pilot facilities in the range of 50-1100 gal need only control their vents. NOTE: This is of particular importance to Tenneco since fugitive emission sources need not be controlled. It means, for example, that as suming an OSHA problem- is not created the vapor containment system proposed for the Flemington Pilot Plant may not be necessary. The current standard poses certain problems for SPI members whose pilot facilities are removed from production sites. For example, Union Carbide's has PVC pilot facilities in Bound Brook; there are no production units on site. B.F. Goodrich has facilities more than a mile from its plant. COLORITE 007617 To: D.C. Coldiron Fr: J.P. Sandstedt September 13, 1976 Page 2 TRIP REPORT All of the industry members present indicated that plant scale "control devices" would be used to reduce emissions from pilot facilities. Thus, in certain instances there exists a potential for contamination of product through recovered monomer. The third and final point brought out was that in its present form the standard requires development of stripping Tn<*i-h<->ds for every new reliin type. It was agreed that the stripping technique could be more costly to develop than the product itself. These items were presented to the EPA representatives, who were quick to recognize the problems. The attached letter was presented to support the SPI position. This position will be modified to include, however, alternative ways of achieving compliance by a) For those facilities able, complying by adherance to the standard as written or b) Reducing total emissions to 0.05 lb vcm per lb. of vcm charged to the reactor. Alternate (b) was proposed by W.C. Holbrook of Goodrich. Mr. Goodwin indicated two problems. First, the industry position was presented at a bad time since promulgation of the standard is imminent. Second) he felt that industry (i.e. companies other tnan Goodrich) would have to present plans, which would be accept able to the Enforcement Section, to insure compliance. (I have asked Mr. M.K. Rosen to determine whether this latter technique would be feasible and/or beneficial to us. We plan to review this matter before week's end.) Goodwin requested typical plans from any company interested. We should respond if the alternate is beneficial. Further, Mr. Goodwin suggested he might try to give industry a basis for i waiver of compliance by inserting a paragraph in the Preamble. This would state, in effect, that a modification to the pilot plant provision would be forthcoming based on "new informa tion" concerning cost-benefit effects. Other information gleaned during conversations: 1. Goodrich has had an explosion in a gas holder - will not install except under duress"; " 2. Several companies considering venting off-gases to boiler house. 3. Use of incinerators considered excessively costly - both capital and operating (PPG, Goodrich) COLORITE 007618 To: D.C. Coldiron Fr: J.P. Sandstedt September 13, 1976 Page 3 TRIP REPORT 4. Several companies looking to solvent recovery (Ethyl, Firestone). 5. Subject of carbon adsorption avoided. JPS:nt /; ,/ ' <' i 1 t ,i J.P.Sandstedt COLORITE 007619