Document 6R6rkXrkRV865pzGxeX3DMBm9

ABDOO134411 A CONFIDENTIAL REPORT FOR RESPONDENTS TO ESSO CHEMICAL PVC QUESTIONNAIRE Submitted by: O'Connor Associates Environmental Inc. March 1990 o'connoR ajjocmtcj ABD00134412 CONTENTS 1.0 OVERVIEW OF REGULATORY PRACTICES 1.1 United States and Canada 1.2 United Kingdom and Europe 1.3 Japan and Australia 2.0 SURVEY RESULTS 2.1 Ambient/Property-Line AirQuality and Compliance ' 2.2 Emissions at Source 2.3 Control Technologies 2.3.1 Reactor Openings 2.3.2 Slurry Stripping and Post Stripping Technologies 2.3.3 Recovery System Venting 3.0 TRI DATABASE Page 1 1 3 3 4 4 5 5 5 6 6 6 o'connon asiocmtcj ABD00134413 Esso Chemical Canada in conjunction with O'Connor Associates Environmental Inc. has synthesized the data obtained from the "Level 1 Questionnaire" distributed to PVC producers in the United States, United Kingdom and Europe. The enclosed summary is for your perusal, and represents Esso's commitment to inform the respondents of the results on a confidential basis. 1.0 OVERVIEW OF REGULATORY PRACTICES 1.1 UNITED STATES AND CANADA For regulation of vinyl chloride emissions the majority of U.S. jurisdictions still follow NESHAP Regulations; however, an increasing number of states are adopting more stringent air emission standards as a condition of permit approval. The manner in which standards for toxic substances are being enforced varies; available data are summarized on Drawing No. 1.1. It is evident from this figure that existing sources are subject to less stringent regulatory programs relative to new/proposed sources. For carcinogens, the control approach most frequently identified by STAPPA and ALAPCO utilizes a combination of control technology requirements, acceptable ambient levels and risk assessment. The principle method for implementing these programmes throughout the United States is the permitting process. Our discussions with various state and local air pollution control officials indicate a wide variance in interpretation of how PVC plants should be monitored. The majority of States with operating PVC plants have yet to impose ambient air quality standards (AAQS). On the other hand, at least 12 states have daily or long term ambient air quality standards or guidelines for vinyl chloride which would be thought of as stringent. o connon ajiociatcj ABD00134414 2 Within this group, only 1 state has a plant which is subject to the AAQS, 2 states have plants which are exempt from these standards ("grandfathered"), and the remaining 9 states have no PVC producers. One aspect of this trend is that the stringent regulations may become a deterrent to industry establishing PVC plants in these states. In Canada, the federal Vinyl Chloride National Emission Standards Regulations became effective July 1, 1979, under Canada's Clean Air Act. These regulations establish the point source limitations for vinyl chloride emissions; however, no emissions from fugitive sources are included under the CAA. Based on re-drafted regulations under the Canadian Environmental Protection Act (Canada Gazette Part 1, Sept. 30, 1989), this situation appears unlikely to change. Nonetheless, there is a Canadian "Code of Good Practice" which is designed to minimize fugitive emissions from the plant The Ministry of Environment in Ontario has proposed interim AAQC and POI concentrations of vinyl chloride* as follows: - 3 ug/m3 0.5 hr POI - 1 ug/m3 24 hr average AAQC - 0.2 ug/m3 annual average AAQC Our analysis ofjurisdictions in Europe, North America and Australia indicate that these interim standards, if promulgated, will be the most stringent in the world. A *1 ug/mJ = 2.57 ppb at STP. o'connoR associate* ABD00134415 3 Quebec and Alberta, the only other provinces in Canada with PVC producing facilities, follow Federal Regulations Table 1.1 , although Quebec has recently established an ambient air guideline which is not as stringent as proposed by Ontario. A 1.2 UNITED KINGDOM AND EUROPE Regulatory authorities in the United Kingdom use the BACT (Best Available Control Technology) approach without ambient air quality guidelines. As in North America, there are limits for emissions released during reactor openings and following stripping. Of interest is the provision to make some allowance in standards based on the heat sensitivity of certain suspension grades. In Europe the regulatory approach is undergoing legislative changes, and the most comprehensive regulations at present appear to be embodied in the German (GFR) TALuft, promulgated in 1986. These regulations appear to be destined to be adopted in several other countries. From the ambient air quality perspective, the only country with any guideline is the Netherlands. 1.3 JAPAN AND AUSTRALIA Emission regulations are still under development in Japan, although industry stewardship is in place through the Japanese PVC Association. In Australia, the vinyl chloride regulations appear to be patterned after the EPA in the United States. Ambient fenceline monitoring requirements have been set for the 1 plant for which Esso Chemical Canada was able to obtain data. o'connon aiiocmtci ABD00134416 2.0 SURVEY RESULTS 4 Questionnaires were circulated to PVC manufacturers in North America and Europe* resulting in a total of 17 responses. In the United States the Toxic Release Inventory (TRI) List was used as a means of scanning those companies reporting significant vinyl chloride emissions to the EPA. A total of 12 responses were received from the United States, spanning the spectrum of small to large PVC producers (20 kT to 380 kT PVC annual production). Four responses were received from European producers, and 1 of these was indicated to be representative of a large number of plants owned by the same company in 4 countries. A 2.1 AMBIENT/PROPERTY-LINE AIR QUALITY AND COMPLIANCE * Two companies indicated that AAQS limits (standards! were established and enforced by the regulatory authorities through fencelme monitoring. * An additional 2 companies indicated that AAQS guidelines were established and enforced through permitting using dispersion modelling. One country has a stringent annual "strive value", monitored periodically by the government. A total of ten companies indicated that their plants were subjected to some form offenceline monitoring (periodically or continuously) and/or dispersion modelling (based on risk analysis factors) to demonstrate compliance or renew permits. Including the United Kingdom. o'connon associates ABD00134417 2.2 EMISSIONS AT SOURCE 5 All respondents indicated that they were normally compliant with the existing regulations. Ten companies indicated they were required to demonstrate compliance continuously (mostly for recovery vents). Several indicated they were only asked to demonstrate compliance "on demand", "only during permitting", "quarterly" or "semi-annually". Six companies indicated that in order to compare plant performance to the regulated limits, VCM emissions were determined by direct measurement of concentrations and flow rates. The remainder indicated that flow rates were estimated. In terms of gauging the need for technology change in response to new regulations, North American companies either had not assessed the impact of such changes, or indicated that they believed technology changes were not required. In contrast, all European respondents indicated that some technology changes would be required. A 2.3 CONTROL TECHNOLOGIES 2.3.1 Reactor Openings Eleven companies indicated they used closed reactors in combination with antifoulant technology. Ten companies indicated that reactor opening emissions were controlled by steam sweeping. o'connon associates ABD00134418 6 Six North American companies incinerated the reactor ventilation stream, whereas none of the European respondents used this technology. A variety of downstream technologies were employed including incineration ot slurry blend tank vents (3), air stripping (2) or containment (1). Eight respondents indicated that no_post=stripping-technologies-were employed. 2.3.3 Recovery System Venting Eight companies utilize refrigerated condensors, 6 of these in combination with incineration of the vent stream, and 2 in combination with absorbers. Four companies use only incineration technology, and 3 companies use absorbers exclusively. 3.0 TOXIC CHEMICAL RELEASE INVENTORY (TRI) DATA The Toxic Chemical Release Inventory (TRI) data provide a basis for determining the performance of PVC producers in the United States. Despite some inherent differences in the manner in which such numbers may have been generated, the emissions data offer a first basis for comparing plant performance. In order to normalize the data, we have ratioed the total emissions reported (in kg) on an annual basis as submitted to TRI over the annual capacity (in metric tonnes) of the 2o'connon auociato * > ABD00134419 7 plant as reported by the Digest of Polymer Development. The plant capacities reported in this document matched closely the capacities reported by respondents to the questionnaire. These ratios, designated by O'Connor Associates as the "TRI Factors" are plotted on the accompanying Figure. Your plant has been highlighted in colour to give you a relative measure of performance. Note that the proportions of suspension, emulsion, solution or bulk product are based on figures quoted in the Digest of Polymer Development, and may not be totally accurate. Respectfully submitted, O'CONNOR ASSOCIATES ENVIRONMENTAL INC. L.W. Curtis, Ph.D. o'connon auociatcj ABDOO134420 A TABBE 1. 1 AMBIENT AIR QUALITY VINYL CHLORIDE 3 GUIDELINES OR STANDARDS (ugm/m ) UNITED STATES AND CANADA Jurisdiction Status California^ S Connecticut Kansas Massachusetts Michigan G North Carolina G Nevada New York G Pennsylvania G South Carolina South Dakota Vermont Virginia Quebec G Short Term Ihr) 0.25 hr 150 Daily (< 24 hr) 24 hr 26 Long Term VCM/P\ (Annual) Plant Yes^ 8 hr 50 No 3.85 No 24 hr 3.90 No 0.4 No 0.38 No 8 hr 238 0.4 6.18 No Yes12 3 Yes2 24 hr 50 No 8 hr 50 No 0.2 No 24 hr 1 No 8 hr 50 Yes Ontario IS 0.5 hr 3 G 0.5 hr 560 24 hr 1 24 hr 280 0.2 Yes'* 1. Guideline enforced; jurisdiction is SCAQMD, Rule 1163-1. 2. Guideline not enforced on existing VC/PVC plants. 3. Proposed change to guideline/standard. S Standard G Guideline IS Interim Standard o'connoR associates ABDOO134421 A* Status of State Air Toxics Programs with New Source Review f~ | Informal NSR Proposed Comprehensive Regulations Status of Air Toxic Programs United States o'connon associate! JOB NO. : 10.1293 DRAWN BY: LWC DATE : 90/03/30 DWG. NO.: 1.1 TOXIC RELEASE INVENTORY (TRI) DATA, NORMALIZED TO CAPACITY FOR UNITED STATES' PVC PLANTS 1987-1988 vy ABDOO134422 SiNVld JO `ON SiNVId JO *0K u o o vo O <0 If) (0 *' Q <0 5 (4f-)>