Document 8ox0wd0yVY6Ny5vvNyaQqXkd
f s,7
To From
natg 14 January 1985
INTEROFFICE MEMORANDUM
Subject Proposed Revision to Vinyl Chloride NESHAP
Distribution J T. Barr
__________________
(Leutlori, o>9*nUton, 01 Department)
Regulatory Response
(Location, O'pniMtion, or Mpartmant)
L. Allen J. Anderson A. Dlgllo R. Duggan
6. Gebbia B. Helms J. Pfeiffer
R. Schenck
J. Spata
EPA has proposed the revision to the vinyl chloride NESHAP which we have been following for the past months. See 50 FR 1182, 9 January .1985.
The proposal follows the draft submitted to NAPCTAC in August, and which has been sent to you earlier, so only the differences are discussed here. The significant differences are marked by a line In the left margin on the FR pages attached.
EPA has agreed to at least some modifications, where requested, on almost every point except the rounding off of the number of emissions allowed. See column 3 of p. 1189.
On the subject of the leak detection program, they offer an alternative to part V, whereby a facility may elect to go under a 2% rule. If 200, or 90% of the flanges and valves, whichever Is less, are tested and If no more than 2% are found to leak at any one time, then the present system may be kept, or amended. See the discussion at pps. 1190-91, and the revised wording of 61.65 (b)(8) on p. 1197. You may well chose to revise the current plan, because of the redefinition of "no emissions" as less than 500 ppm over ambient.
There are changes in recordkeeping, emission testing (3 hours), reporting (exception only In many cases), and so on. The Vinyl Institute Manufacturing Committee will be meeting soon to prepare the Industry comments. Please look this over and get back to me by 4 February with your comments so I can takee thenr^fc the Committee.
JTB:CSb
Attachment
(3201
r
APOOOf8501
1 Wednesday January 9, 1985
Part V
Environmental
\ Protection Agency
i\ 40 CFR Part 61 National Emission Standards for Hazardous Air Pollutants; Vinyl Chloride;
I Proposed Rule and Notice of Public
i Hearing
> >
AP00018502
im
Federal Register ! Vo1. SO. No. 6 / Wednesday, ]anuafy~lh\ 1985 / Proposed Rule*
ENVIRONMENTAL PROTECTION AGENCY
40CfRPart81
IAD-FRL-2707-4)
National Emission Standards for Hazardous Air Pollutants: Vinyl CWorido
aatNCY; Envoroomental Protection Agency (EPA).
action: Proposed rule and notice of public hearing.
suMMAav:The current emission standard for vinyl chloride (VC) was promulgated under Section VI2 of the Clean Air Act in SB7B. 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 (1J proposes administrative and clarifying revisions to the standard and (2) announces decisions pertaining to other aspects of the current standard. This notice also withdraws proposed revision* to the current standard which were published in the Federal Register on June 2,1977 (42 FR 2E154).
If requested, a public hearing will be held to provide interested persons an opportunity for oral presentations of data, views, or arguments concerning the proposed revisions to the current standard. datss; Comments. Comments must be
received on or before March 25.1985.
Public Hearing. If anyone contacts the EPA requesting to speak at a public hearing by January 301085. a public hearing will be held on February 26. 1983 beginning at 9.-00 a.m. Persons interested in attending the hearing BTnnifcr'can Ml. Shelby Joumigan at (PIP) S4t-557B to verify that a hearing will occur.
Request to Speak at Hearing. Persons wishing to present oral testimony must contact EPA by January 30,1695.
Incorporation by Reference. The incorporation by reference of certain publications in these standards will be approved by the Director of the Federal Register as of the date of the final rule.
ADDRESSES: Comments. Comments should be submitted (in duplicate if possible) to: Central Docket Section (Atao). Attention Docket Number A-81-21. U.S. Environmental Protection Agency, 401 M Street. S.W.. Washington. D.C. 20460.
Public Hearing, if anyone contact* 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 1 limit for relief valve discharges. (2)
Drive. Research Triangle Park, North l providing a compliance test procedure
Caroline. Persons interested in attending and a specific emission limit for
the hearing should call Ms. Shelby
operatore who perform stripping
Joumigan at 1919) 541-5576 to verify that Operations In reactors, and (3) specifying
a hearing will occur. Persons wishing to requirements for leak detection and
present oral testimony should notify Ms. repair programs for certain equipment in
Sheiby Joumigan, Standards
VC service. Additional minor
Development Branch (MD-13). LT.S,
administrative changes to the standard
Enviromental Protection Agency.
are being proposed and are explained
Research Triangle Park. North Carolina later in Wit premable.
27711. telephone number (919) 541-5576.
Summary ofHealth, Environmental
BackgroundInformation Document
Energy, and Economic Impacts. Since no
The general findings of the review study major revisions to the standard are
are documented In "Vinyl Chloride--A being proposed, the impacts resulting
Review of National Emission
from the current standard remain
Standards", EPA-430/3-82-003 (NTIS- generally unchanged. In 1975. it was
PS 64-114354). available from the
estimated that amissions of VC from
National Technical Information Service, plants producing ethylene dichloride
5235 Port Royal Road. Springfield.
(EDC). VC monomer and polyvinyl
Virginia 22161. The major technical
chloride (PVC) would be reduced from
analysis for the review study is
P6.000 Mg/yr to 4,910 Mg/yr under the
contained in a separate document which A current standard, representing an
may be obtained from the US. EPA jjy emission reduction of 91.000 Mg/yr of
Library (MD-35). Research Triangle (rfyy VC (or 95 percent of VC amissions).
Park. North Carolina 27711. telephone^ Emissions of volatile organic compounds
number (919} 541-2777. Pluase refer to IT (VOC) and EDC are also reduced under
"Vinyl Chloride: Relief Valve Discharnv the standard.
Standard." EPA-4S0/3-B5-OO2. for tryK <
technical document.
{) At",
Docket. Docket No. A-Ql-21. yyf
containing supporting information usfcd
in developing the proposed standard, is
available for public inspection and
copying between 8:00 a.m. and 4:00 p.m..
The estimated risks attributed to
exposure to VC from EDC/VC and PVC plants in operation prior to the current standard were 5.5 cases per year for liver angiosarcoma and 11 cases per year for ail cancers. The risks attributed to exposure to VC Irom sources under
Monday through Friday, at EFA's
the current standard have been
Central Docket Section. West Tower
estimated to be 0-28 cases per veer for
Lobby. Gallery 1. Waterside Mall 401 M liver angiosarcoma and 0.55 cases per
Street. SW., Washington, D.C. 20460. A year for aii cancers.
reasonable fee may be charged for copying.
in 197S, the estimeted capital cost for existing plants to meet the VC standard
FOR FUTHER INFORMATION CONTACT:
was $198 million, of which -313 million
Mr. Robert B. Rosensteel or Mr. Leslie B. was for EDC and VC monomer plants
Evans. (919) 541-5671, concerning
and SI83 million was for PVC plants.
technical aspects of the industry and
The EPA estimated that the annualized
cost(fnciudingrcapttafamortization, eta}
Dimmlck or Mr. Gilbert H. Wood, (919) to these plants to maintain the required
541-5S78. concerning regulatory
emission levels would be S70 multcm per
decision*. The address for these
yeer.
contacts is Emission Standards and Engineering Division (MD-13), U.S.
Background
Environmental Protection Agency,
The VC standard was proposed on
Research Triangle Park. North Carolina December 24.1975 (40 Fr 595321. nd
27711.
promulgated on October 21.1978 (-51 Fr
SUPPLEMENTARY INFORMATION:
46559). It is applicable to plants
Summary of Revisions to Current Standard
producing EDC by the reaction of oxygen and hydrogen chloride with ethylene, plants producing VC by any
Revisions. Several administrative
process, and plants producting one or
changes are being proposed as a result more polymers containing any fraction
of a review of the national emission
of VC. These plants are sublect to
standard for VC No major revisions are different requirements at numerous VC
being proposed to the standard. As with emission points In the manufacturing
the current standard for VC. the revisions are being established under
process. These requirements include numerical emission limits, equipment
Section 112 of the Clean Air Act The
specifications, and work practices.
significant administrative revisions include: {1} Reformatting the emiasion
The standard was designed to minimize the health risks associated
with V meatus
the pro Decern
thrash: Therefelimitu
VC wo This ap
an app the hee use of,
On h Enviropetitloi
Appea Circuit March
-moved
basis o rcquirl;
amend: increas equiprr control
tncrear vicinit!
constn propos theEP. carcinc Clean,
goal of carcinc initiate
years s umend
On) propot
pertaic feaaibi propos Review that ad inform, propos ' she pre uromul
Meaj with th ^stabile prograi carcinc
Clean, petitior itanda similar 1977. a Based* amend comprt airborr that it propos had ac
OaC EPApr
for Idet
AP000I8503
;dmr
pacifying -.nd oment in
-ndarri i/iined
-ental Since no *re uiting n \as f:um ride
i tram rr Ihe n \r of ns). Tir-oundf* ; under
. :o "u PVC. .-"'(nr
:ur .c-r ibuttd ."hIm
irior per
v'St foi :ndard iiinn .imis .-is, . wired n. etc.) .iiiirfcd v.n per
i un nd 4J Pr
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lion
::* VC .im*
nt'
L-nt
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Federal Regiiter / Vol, SO, No, 6 / Wednesday, January 9, 1955 / Proposed Rule*
1183
with VC by requiting reasonable contra) measures. As stated in the preamble to the proposed standard (40 Fr 59932! December 24,197$), there is no known threshold level of effects 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 reasonable control measure.
On November 19.1976, 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
requiting thcEPAto projCne 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's 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 June 2,1977, the amendments were proposed (42 FR 28194). 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 lor regulating airborne carcinogens under Section 112 of the Clean Air Act. The aspects of the EDFs petition concerning the development of standards under Section 112 were similar to those proposed in the June 2. 1977, amendments to the VC standardBased on the similarity of the proposed amendments and the EDF'i requested comprehensive program for regulating airborne carcinogens, the EPA believed that H should not take final action on the proposed VC amendments until after it had acted on the EDFs petition.
On October 10.1979 (44 FR 58642), the EPA proposed "Policy and Procedures for Identifying. Assessing, 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
ollutant emission standard would not e based on a policy that requites zero emissions of carcinogens. 11118 policy it consistent with the oasis for other
recent actions tinder Section 112. For example, standards for benzene 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.
wtdeb considers emissions and'health risks.
The EPA believes 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 the following section of this notice, the EPA began a review study to obtain additional technical data and cost 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 this notice.
Review of VC Standard
Early in 1980 the 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, end enforcement and
compliance experience which have occurred since the standard was first promulgated. The review consisted of a
screening study of: (1) Existing and new control technologies. (2) sources not regulated by the standard, and (3) enforcement and compliance experience since promulgation of the stendaid. Information and date evaluated during this study were obtained through literature searches, plant visits, end interviews with Industrial representatives and EPA regional personnel involved in enforcement and surveillance of the VC-emitting industries. The information and data are presented in a document that m;iy be obtained as described in ihe AODNEZSIZ
section of this preamble. Decisions based on this review are summarized in the next two sections ol' this preamble.
As another aspect of the review of the VC standard, the EPA's Carcinogen
Assessment Group reviewed new health
studies that have become available
since Ihe standard was promulgated.
This review included a study of the
1
estimated carcinogenic strength of VC j
(the VC unit risk number) and focused j
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
esociated with population exposure to
atmospheric VC, However, none of
these new studies have sufficient
exposure information to warrant a
refinement of the quantitative cancer
risk estimate.
A*.
Findings and Conclusions of the Review ,
Study
The findings and conclusions of the
VC review study are presented in the following subsections. The first subsection discusses the 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 the
appropriateness of regulating these
sources.
'if Need andBasil for Current Standard
The current VC standard was nslabllehed based on judgments concerning the costs and benefits of the 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 (evaluated before the current standard
was established) strongly indicate that VC causes or contributes to the development of angiosarcoma, other
cancers, and various noncercinogenic disorders in people with occupational exposure and In animals with
experimental exposure to VC Although no dose-response data are available at the concentrations of VC found In the
ambient air. the EPA concluded when the standard was established that nnv atmospheric concentration of VC poses
Home public heath risk. To eliminate the risk of VC exposure entirely, a complete prohibition of all VC emissions would he necessary. This would require the
closure of the entire industry and result in serious, adverse economic impacts.
Furthermore, the EPA concluded at the lime the current standard was established that complete prohibition of all VC emissions would not be esirable or necessary. The EPA
AP00018504
1184
Federal Register / VoL 50, No. 8 / Wednesday, January 9. 1985 / Proposed Rules
concluded this in view of (1) the beneficial use* of VC products for which desirable substitutes are not readily
available: (2) the potential adverse health and environmental impact* associated with VC substitutes that
have not been throughly studied: (3) the number of employees, particularly In fabrication industries, who would become at least temporarily unemployed: and (4) the availability of control technology that is capable of substantially reducing emissions of VC iota the atmosphere.
Although aU EDC. VC and FVC plants have now incorporated VC emission controls, the maintenance ofa Federal standard for VC is still considered necessary. The VC standard contains requirements for the proper operation and maintenance of control device* end the proper implementation of work practices. These requirements reflect an appropriate balance between the need to minimize health risks and the avoidance of unreasonable economic and community impacts which would result from standards designed to reduce risks to zero. Relative to the initial control costs, the additional cost` of maintaining and implementing the Federal VC standard is smalL Nevertheless, if the Federal standard is discontinued, these small costs may be sufficient to provide the industry with an economic Incentive fordisconrinuing the use of proper control measures. Thus, the continued maintenance of Federal standards for the control of VC is necessary to ensure a continuation of the current lave! of control. Additionally, the standard is important for the control of VC emissions from. . ^atttyBfiilt fn the future. The consequence of not maintaining a Federal standard would be to increase the carcinogenic risk to large segments of the population, (in 1975 when the standard was originally proposed, approximately 4.6 million people lived vrithin a 9-mile radius of EDC. VC and PVC plants.) Accordingly, the CPA has concluded that the maintenance of the Federal standard for VC, or reasonable revision of the standard, is appropriate.
(21 Review of Technology-Basedteve! of Control
This subsection describee the status of the technology-based level of control for sources covered by the current standard. The present status of emissions from sources covered by the current VC standard is presented in Table 1.
Tabu 1. Status os Currcnt emosiow l*vels From sources Covirco *v thi Vwvt CWLORIO* NESHW*
EmJMn
Mint
Btonaw*
iTimion* [<**'*'
UneontoM*
(prwr fc> 107*
Coavomo*
lVevisMwUw
femeon* Sow a mMW 316.000
EOC/vC
cenra. CiycNoA*.
tortvwit
ie pww..........
si*
0.9 EDC
prodJO. NUE piMi mm
M OQuipnwa Wwuh
bw tMfjfcr-fws*
114
37*
hot
Avatabw*
M M
3t
91
enliar fen node ssaoe me/)T PVC (adtp
Airy consoi
mcw
;?.*n CONOCO i';r npona ........
0 OpMW.__ _
0002kfl/1QO k*PVC PMuet
`00 C9XW WWH&t*.
</r0* ewc^* 4-0 CWMOWW l'a'<J4'04
'ienortv*'***. 64
CT*.
no
312
etc
1040
-C*
'<
* Bum on (* SPA mu> MyntiM Orwopod ko>
0*a *u6flt>CM by rautM fSutMi oner to a'cr*;j<Mieng>
it* i7S VC tartvtL
*'Cnatemowewwing**noMoutM"tcnuelMtaJdcUtnM*maraeO.*Q.onaMf *an~60oCe/eVnCro*inNo PVC
E3CVC s'anu or*t to >sn
-9mm trw spa 'PMtom
for
uwopjkor plant. Effl'nion MinnttM <or fc*. atoa we
eworKou warn* * not pwwmKl iw
10ppmv Standard. Emission sources covered by this standard include EDC purification and VC monomer formation and purification equipment monomer recovery GKateB^an^othataqulpmecii
at PVC plants, end 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 specifies an emission limit of 10 parts par million by volume (ppmv) of VC averaged over a 3hour period. The 10 pptnv standard applies to control device bypass streams.
One of the amendments proposed its 1977 would have required reduction of the emission limit from 10 to 8 ppmv. The goal of the proposed 9 ppmv limit was to ensure that tha standard continued to approach a "zero emission goal" by requiring owners and operator* both to maximize the effectiveness of existing control systems and to design improved new control systems at the time of construction. The s ppmv limit was not baaed on data for control
technology different from that analyzed
at the time of the promulgation of the 10 ppmv limit
Comment* received on the proposed 1977 amendments stated that in order to meet a limit of 5 ppmv. a control device would have to be capable of control at a level even lower than S ppmv to offset emission fluctuations. Commenters also stated that a change from to to 5 ppmv would result In little reduction in mass emissions of VC Finaly. commenters
questioned the rationale of the "zero emission goal" policy.
Because the proposed 8 ppmv emission limit was not based on data
from a control technology different front that analyzed for the current standard
and because 20 ppmv represents the lowest level of control which has been consistently achieved, the EPA withdraws the proposed 5 ppmv limit and affirms tha original 10 ppmv limit. If such a technology had been identified, it could have been the basis of a revised standard. However, during the review study no more advanced technology was identified, even though additional dam on incinerators, carbon adsorbers, and solvent absorption control systems on existing plants were obtained. Although these data Indicate that incinerators are capable of reducing emissions below m ppmv. 10 pptnv represents the lowest
level of control which has been consistently achieved. Based onthrainformation. <he EPA ha* concluded tiuit there is no improved or new control technology disk has been demonstrated
to significantly and consistently reduce emissions to a level belotv that required by the current standard. Therefor*, no
further technological investigation of the to ppmv standard is planned.
O*jchlorination Vent Standard--02:
S/kft EDCXne current oxyefclormatlon vent standard of 0.2 g of VC per kg ol EDC does not require an add-on control
device. Instead, the limit can be achieved st most plants by controlling operating conditions and at the remaining plants through process modifications. At the time tht original standard was written, incineration of oxychlorlnatlon vent emissions was investigated. Because of expected high energy costs associated with supplemental hie! requirements for combustion, incineration was determined not to be a reasonable method of control for this source.
The amendments proposed in 1977 specified a level of 5 ppm for the oxychiorination vent. The proposed requirement was based on installation
of an oxygen feed system with an incinerator or equipment control device. The use of oxygen feed in the EDC
oxychlorinaton process decreases the
v. s' s. i: P o r. P tr E. c it E lr 8: d ir e
i i
/
r
I-
rr
AP00018505
Federal Register / VoL SO, No. 6 / Wednesday, january fl, 1965 f Proposed Rules
1183
volume of inert substances (n the vent
ircara and. consequently. the coat for supplemental fuel required far
include blend tanks.^ryer*. centrifuges,
storage silos, bagging operations, and any sources following the stripper.
Eirocesaors meeting the more stringent
imtts proposed previously ere stripping these resins to this low level to offset
incineration. Comment* received on this Control of these emissions U based on emissions from those resins which are
proposed amendment focused primarily either stripping the PVC resin to a
more difficult to strip. Without this
on the high expense and large energy
specified (based on resin type] residual ability to average the emissions and
requirements associated with the
VC level {lt 400 ppm for suspension,
reductions among resins, these
production of oxygen.
bulk, solution, ana latex mins: and
processors might not achieve the current
The review study identified no control 2.000 ppm for dispersion resins) or
standard. Exempting resin grides
technology for oxychlorination vents at controlling the emissions from all
known to be difficult to strip is not
HOC/VC plants that had not been
sources following the stripper with a
feasible because these resins cannot
considered during the development of
control device. The 1977 proposed
readily he defined. For the foregoing
the original standard. Additionally, the amendments would have required "new reasons, die EPA has concluded that
EPA reevaluated the coat of retrofit
resins'* to be stripped to lower levels
there is no demonstrated level of control
incinerator controls and reached the
(!.., 100 ppm for suspension, bulk,
which could eignlficantly end
same conclusion drawn in the
solution, and latex resins? and 900 ppm consistently reducs residual VC levels
development of the original standard.
for dispersion resins). When the
in resins to levels below that required
As before, the high cost associated with amendments were proposed, the EPA
by the current standard. Therefore, the
insinswjno^yckloriaation-.'^tvU^t
~JMlieved4fei tome resistseu&meaLd&i CPA is Tiofinvstigattas further the
i-xistlng'ESC/VC plants makes this level proposed limits; whereas, for other
control of the combined sources after
control unreasonable. Thus, the
resins the manufacturer would have
stripping.
<"irrent standard of 0.2 g/kg EDC is
considered still to be the most . :.isonabU level of control for existing
been required to develop improved
stripping technology or not to produce the resin.
Equipment Leaks. Because little was known about leek detection and elimination programs for control of
` * vchlorination vents. In addition, the I'-'.isw study concluded that significant
Industry comments slated that must dispersion, copolymsr. and bulk resins
equipment leaks from components In VC service, specific requirements for these
,v.tf construction or modification of >DC'VC plants is not expected. At this
only one new EDC/VC facility is
would suffer degradation if more
stringent emission limits were imposed. Additionally, the commemers noted the
programs were not included in the current standard Instead, each plant was required to Institute and implement
'T-ortedly planned. (Er Goodrich has
: ::s to construct en EDC/'VC facility in i nvent Louisiana.] Oxychlorination
at new EDC/VC plants will be
inherent difficulties in defining a "new
resin." Information submitted by cemmenters indicated that minor adjustments to resin compositions ate
it formalized leak detection and elimination program incorporating both a fixed-point monitor and a portable
monitor. Plant-specific programs were
.
. deleted by the proposed standards of
; -.nermance for air oxfdetion processes * ` c:rR Part 60 Subpart ill) or by the :j.'.CT or LAER requirements of new * urce review regulations applicable in
'pfir.fic locations to a level comparable
`J (hat achievable through the use of idneration. Because the >> hnoloaically achievable level of
wntrol is assured through the current quireruents, the EPA concluded that nvcsiiSdtion of additional control (t.e..
"vnaraiion) was not required for y-Morlnaticn vent 9. Victor Opening--0.02g/Ag P\ 'C
l`'duct. The current VC standard `'ricta emissions during
made routinely, and completely new
resins are rarely, if ever. made. As a result of these comments, the EPA concluded that it is impossible in many cases to distinguish between new and
existing resins and still have any resins
covered by the proposed amendments. Further, the proposed amendments did
not address what levels of control couid
be achieved by improved stripping technology. For these reason*, the EPA
chose to evaluate whether higher levels
of control are achievable for all resina. or only for some special clssse* c? resins.
The review study found that resin stripping technology has improved since
subject to approval by the Administrator. Consequently, due to site-specific differences among plants, a* well as variations In leak definition* and monitoring practices, differences in
control of equipment leaks among the plants have resulted. Since the standard was promulgated, the EPA has obtained more information pertaining to the control of equipment leaks from components In VC service. With the
information obtained form the development of other standard*, an
effective leak detection and repair program bated on use of a portable monitor can now be specified for
;,,!ymerizatiort reactor openings, The -mnderd was based on reactor purging
the current standard wss promulgated, and that some processors can achieve
equipment covered by this program. The specific leak detection and repair
on a reduction in the frequency of lower resin residual VC levels than
requirements are discussed in the
'Jii.tor openings. An increased level of those required in the original standard, Administrative Revisions section of this
'r*ntroi was rotproposed in the 197"
in certain cases, some resins can meet
preamble.
intendment*. (The level of control
the more stringent levels specified in the
Relief Valve Discharge Standard.
rrovided bv 'he current standard.
previously proposed amendments.
Sources of VC emissions covered by this
"|V- q/ka of PVC product, reduce* VC
However, other processors
standard include discharges from relief
'niiasion* to about 1.36 Mg per year for manufacturing resins of differing grade* velvet on pressure vessels, transfer
** ^odal PVC olent.) Dunne the review and characteristics can only marginally lines, and other equipment In EDC/VC
!'[ the standard, no technology was
comply with the original standard.
and PVC plants. The standard is based
'ItmifJcd ihaj would provide additional Because of the wide variation in resin
on emfssion control by a combination of
vC rr*r]uct(ijna beyond he ii*vcl of the
grades and characteristics, it cannot be equipment and process modifications,
'urrent standard. Therefore, the EPA is concluded that, even though a particular and operational procedures, found in
cot invrsiiaatma further the control of
resin made by one company can meet a plants during development of the
"cior noeninss-
particular level, any other resin or
standard. An exact combination ni
Ccmhinrf Sounds A*er Resin
Kimilar resins produced by another
modifications and operational
t 'n!>pfa*. The source* of VC emissions company could also meet that level.
procedures was not specified. Instead, a
flv*rftd vindwr the current standard
Furthermore, in some cases these
performance standard (i.e.. an emission
AP00018506
1186
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 ail relief valve dischargee except emergency discharges. Emergency discharges are described os those which could not have been avoided by taking measures to prevent the discharge (i-e., those that are
nonpreveatable"). Sines the standard u * wias promulgated, all plants have > 3 e*xperienced some releases. Many of
` ese 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 a 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 limit* lot relief valve discharges in a different format
Administrative Aspects of the
Standard. Even though the EPA decided novto revise die level of control associated with the current VC standard, the EPA identified revisions to several administrative aspects of the standard. These revision* as well as those identified above, are discussed in the Administrative Revisions section of the preamble.
(3) Review ofSources 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 a Federal standard was warranted. The EPA`e assessment of these sources was based primarily on a quantitative analysis of VC emissions from these sources combined with a qualitative analysis of risks associated with exposure 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 a Federal standard is warranted for these sources. Because these sources are already relatively well-controlled and the quantity of VC emission, and consequently, the risks associated with exposure to VC from these sources, ate small in comparison
to sources covered by the VC standard,
the EPA concluded that none of the additional sources identified la the review study warrant a Federal
standard.
Miscellaneous Sources of VQ
Emissions. Miscellaneous sources are plants other than PVC and EDC/VC plants that uss VC as a raw material or produce VC as an intermediate or by
product The EPA has Identified four such plant*, two of these plants produce l.l.t-trichloroathane, one produces
perchloroethylene and trichloroethylene and the fourth plant produces pesticides. (An additional 1.1,1-trichloroethan# unit was constructed at a fourth location but has reportedly never operated. There 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 less than l Mg/ yr to 14 Mg/yr per plant. In general, the
VC NESHAP requirements for process
vents and equipment in VC service are being met at the miscellaneous sources
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 nonattainment areas. Based orrthe investigation of these sources, the EPA concluded that they ere 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 6.000 fabrication plants which takssthe resin preducecrby PVtf'pfants
and fashion It into intermediate or final products. Emissions from these plants are estimated to be about 0.0035 Mg/yr per plant In comparison to VC production plants (which typically emit about 92 Mg/yr}, PVC fabrication plants ere small emitters of VC. If standards were developed for this category they would not result in reduced emissions because the best control for these plants is to reduce the VC levels in the resin*
being processed by the fabricators. Resin stripping beyond the level that process economics would dictate is
already being dons as a 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 o! controls for PVC fabrication plants is
vr
unnecessary and that the current level ofcontrol resulting bom the EPA's standard and OSHA's standard is still reasonable.
Landfills. Off-aperificatlon resins Containing VC has bean taken to
landfills where the gaseous VC can be released. However, the current EPA standard intends that aU 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 explidty 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 today. However, the EPA recognizes that VC may ba 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 st hazardous waste disposal facilities. The EPA also recognizes (hut VC has been detected in municipal landfills. Therefore, in addition (o assessing VC emissions from hazarenm waste disposal facilities, a (RCRA) Subtitle D TASK FORCE has been formed which will'assesi all environmental releases including uir * emissions from Subtitle D facilities f.,/ cateaory which Includes muniIc'-iipKa*l"! r m landfills).
Administrative Revisions
As discussed in the Findings and Conclusions of the Review Study section of this preamble^the. EPA.i493tifia*i. several administrative revisions that are appropriate a* 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) Reformetting the emission limit for relief valve dischargee. (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 sen-ice. and (4) miscellaneous revisions.
Relief Valve Discharges
Background. The current format of the standard for relief valve discharges 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.
F
AP00018507
Federal Register / Vo!. 50, No. 6 / Wednesday, jannary 0, 1985 / Proposed Rule*
1187
rr.msiw line*, and other equipment in WJCJ/VC and PVC plants. The control
of decreased discharges over the compliance period. Following an initial
hardware end operational procedures implemented by each of the plants along
'.-..hfiiques considered as the basis of the standard involve a combination of equipment modifications. process
drop in relief valve discharges afler the
standard went into effect, the frequency and quantity of reliefvalve discharges
with the attitudes adopted toward preventing relief valve discharge* represent the types of control measures
modifications, and operational
by EDC/VC plants have decreased
that tha standard intended. In particular,
procedures. An exact combination of
slightly or remained relatively constant. the EPA concluded that the low
modifications and operational
Genera/Basil forNumerical Limits. frequency of dischargee by the visited
procedures was not specified in the
In selecting the proposed numerical
plants was indicative of their degree of
current standard; rather, a performance limits, EPA first evaluated in detail the effort to prevent relief valve discharge*.
standard (!.., an emission standard)
recent performance (test to 1883) of five Consistent with the goal of this
vvas established beeause different
PVC plants and one EDC/VC plant.
proposed revision, the EPA decided that
ia
combinations of the modifications and These plants were chosen based on
o alternative numerical emission limit
procedures were expected to be equally discussions with EPA Regional Office
based on performance resulting under
effective in controlling relief valve
personnel and Industry and were
the current standard could be revised In.
discharges.
intended to represent plants with good a format that would be easier to
Baaed on 8 years of enforcement end relief valve discharge records. In
understand by enforcement and industry
compliance experience, the EPA has
general, the EPA's evaluation of these
personnel.
'occluded that the relief discharge
plants indicates that each has adopted
The EPA Investigated two basic ways
landard has resulted in: (l) Significant tbe combination of equipment,
of expressing relief valve discharge
inductions in the frequency' and quantity operational procedures and altitude
performance for PVC plants. Ona format
:>i VC discharges from relief valves. (2) toward prevention of relief discharges
It based on mats emissions, for
significant use of agency resources to
intended by the current stenderd. end
example, the pounds of VC discharged
evaluate individual discharges for
that their resulting performance is
per million pounds of PVC produced (lb
rrevenlabiiity. and (3) uncertainty on
consistent with compliance with tha
VC/MM lb PVC). Based on a review of
`hu part of producers regarding whether current standard. The EPA's evaluation methods used by industry to determine
ipv comply with the standard, >,<)jiiionally. the EPA learned some of
found that a few discharges may
the amount of VC discharged from relief
continue to occur from some plants that valves, the EPA was unable to identify a
C and PVC believe that this part of the comply with the standard. This
sufficiently accurate method for
"irrent standard upplics only to
observation is consistent with the
measuring discharge quantities from
.^charges through safety relief vahea expec'jHgn held by the EPA when the relief valves. At present, producers are
.'.<i that dtschar^os through other
standard was written.
required only to estimate discharge
assure relief devices, such as rupture Ii-jks or manual or automatic ve.nl
In order to revise the standard in terms of numerical limits representing
quantities for reporting purposes. Demonstration of compliance with a lb
lives, are not covered.-This
-compliance with the current format of
-:terprelation is not compatible vviih the the standard, this evaluation separated
VC/MM lb PVC limit would require producers to measure the amount of VC
itent behind the current standard. To
ovide more eFieient enforcement by ' v.ieH5tng the burden of Individual
PVC and EDC/VC plants. For plants, relief valve discharge performance data were.further separated by source
discharged during an incident. Because sui table measurement method was not Identified, the EPA decided not to
venlability assessments on the EPA. Ireactor vs. nonreactor) and by resin
redefine relief valve discharge
old to provide a better understanding to type The EPA then reviewed the
performance by PVC plants in a lb VC/
plant operators of the goal of the
perlormance of 25 additional PVC plants MM lb PVC format.
'( indard. the EPA is proposing to
and 12 additional EDC/VC plants. The
Another formal ia baaed on the
; "format the standard tor relief v;ike
EPA reviewed this large set of plants to frequency (i.e.. number per unit time) of
lirdiaiges and to define the emission
ensure that the level of performance
discharge from occurrences. No method
t-
points covered bv this standard to
demonstrated by the evaluated plants
for measuring the amount of VC
i]:'l;:iieupp:opi!4eh el? pressure relief could be achieved by all PVC and EDC/ discharged from relief valves Is needed
;h`' ices. As discussed more completely VC plants.
because only the occurrence of a release
ti.o following sections, the EPA is [;roptiitj;ig to change the* format of the :-M;n.n:cal limits tn the standard Ui
The numerical limits presented in the is required for this formal. The
Findings section of this preamble are
occurrence of e discharge ean be
based on an evaluation cf the number of determined by monitoring process
1 - -ii.ut the number of discharges that
discharges representing the
parameters as well as inspecting relief
from those plants rompbiisg with t..r*nut of tha current standard.
demonstrated performance level associated with compliance with the
valve performance reports. Thus, of the two basis ways of expressing relief
I >* EPA found in the review study
provisions of the existing standard.
valve performance that were
fiuit efforts by all EDC/VC and PVC
Format for Numerical Limits. The
considered, the EPA selected e format
vrudtuxTS lo conpiv with the standard EPA visited the five PVC plants
based on the frequency of discharges.
rtJiiccted ;n their preformance (in
evaluated in detail. As expected, the
Based on this decision, the EPA then
ivrms of size and frequency of
EPA found differences fn the
considered how the format would be
'it^nhurqes! since the standard went into liuct. in general, a reduction in fho ;`-ported trequenev Bnd size of relief
`dve dischargss by PVC producers has >ci*crred since 1978. A further decrease
combinations of hardware and operational procedures associated with control ol relief valve dischargee of each
of the plants. Furthermore, no exact relationship was found between the
applied lo PVC end EDC/VC plants. At PVC plants, the frequency of discharges
from polymerization reactors and
associated process equipment may be related to the fact that a batch p;cress is
' relief valve discharges bv the PVC ~iiu:ry occurred between ltUW and iHHi. Poncjrmanee b\ the EDC/VC
IB'l*iry exhibited a less marked nend
effectiveness of specific hardware items end operational procedures and prevention of discharges. In the EPA's judgment, the various combinations of
used to produce most t\pes of PVC. For batch PVC production processes, the opportunity for discharges is related to the number of times a new
I,
AP00018508
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Federal Register / Vol. 50, No. 6 / Wednesday, fanuary 9. 1988 / Proposed Rules
polymerization batch is initiated.
Expressing relief valve discharge performance for these plants with a
discharge-per-batch format accounts for
variations among plants in the number of batches produced. The EPA selected
too polymerization batches as a convenient basis for sxpresaing relief valve discharge performance by PVC
plants with batch production processes In 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 resiir 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.s, reactor vs. nooreactor) and the'reactor discharges were separated by resin
type. Nonreactor discharge sources at PVC plants include blowdown tanks, transfer lines, and storage vessels.
Decause usage of this equipment is also related to some extent to the frequency of batch polymerization operations, the relief valve discharge performance by nanreactor sources in PVC plants with
batch production processes was also
examined on the basis of number of dtscharges/100 batches.
L'nlike 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 ip terms of the total number of discharges (reactor and nonreactorl per year.
SimtiarJy. the EDS/VC production*
process is not a batch process, but Is continuous. Thus, relief valve discharge performance by EDC/VC plants also cannot be expressed on a frequency per batch basis. Moreover, the EPA wae unable to detect a direct relationship between discharge frequency and VC production at EDC/VC plants. Thus, the EPA decided to define releif valve discharge performance for EDC/VC plants on the basis of a total number of annual discharges.
Findings- 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 than
0.03S dlscharges/100 batches or is much greater. (Recent reactor discharge
frequencies for suspension resin plants
with poorer performance levels ranged between 0.059 and 0.101 discharges/100
batches.) Further examination of relief valve discharge performance by
suspension resin producers indicates
that only one plant experienced more than 4 discharges per year during the
eriod from 1961 to 1663. Performance y this plant also axeeeded 0.035 discharges/100 batches. The reactor discharge frequency associated with dispersion and latex production is typically zero. However, for e typical dispersion or latex resin process with a low production rate (i-e., 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. Nanreactor
discharge frequencies oy PVC plants
typically were either less than 0.025 dlscharges/100 batches or were much greater. (Recent nanreactor discharge
frequencies reflecting poorer performance than the 0.025 level ranged between 0.046 and 0.225 discharges/100
batches.) Furthermore, with the exception.of two pcoducers.no more-
than three discharges per year were reported from nonreactor sources in PVC plants during ths period from 1981 to ISWi.
Each of the five PVC plants that the fPA evaluated in detail was among hose achieving 0,035 discharges/100 batches or less in each of (he reactor discharge categories and O.OC3 discharges/100 batches cr less in the rionreactor discharge category. Ths FPA examined individual discharge incidents for the PVC producers whose recent performance has exceeded 0.035 discharges/100 batches In one or more of the reactor discharge categories or who exceeded 0.025 discharges/100 batches end 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 the EPA evaluated in detail.
Solution PVC Process. Discharge frequency from both reactor and nonreactor sources by the single plant producing PVC by the solution process waa zero during the period 1061 to 1983.
Previously, this plant experienced as many as two discharges in a 12-month
period. Recent performance suggests that prevsntsble discharges have bean
eliminated at 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 (1SS1 to 1983) relief
valve discharge performance data for other EDC/VC producers indicates an industry range of0 to 7 discharges/yr. Information obtained from plants during the review indicated dial, 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 1961 and found that one or more of the discharges at each plant were
preventable. Elimination of the preventable discharges would allow each of these plants to reduce their annual discharge frequency to four or
fewpr.
Summary ofXunerica! 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 reusing an exceedence of any numerical limit
presented below would be considered a v iolation without regard to whether any individual discharge was preventable.
i*i twvwi few F.p IH.UMM a IOmt-
ion. (m. OJW p<MMMe
(j Raoetov
,
--tutotAOM i*Wi pe 003$
N. tWMt, f>t CMAnf
0K(iMgM/yr.
--mn pm> 003$ anciwoM/ toa
M Mm btiehM. umL
rMw i>mw acos bUchM.
<91 NoMwew teacm----- 0,02*
awhKBM/ieo *MhM9M/10S
btKJm noi nwisn 3
mgr*Onw-icnftoigunn"Mm we*vwe 1 ftKntroM/yr. cgnduM giKHM.
(3, C'M'J'SK I'M* EOCjVC
Compliance Pruvisions. The EPA
recognizes that ail plants may experience an unavoidable relief v<\, discharge Incident at some time. Examination of relief valve dirh;i,.
performance by PVC plants with lw
-1
AP00018509
Federal Register / Vol. SO. No. 8 / Wednesday, January 9. 19S5 / Proposed Rules
1189
discharge frequencies indicated that
"polymerization bajch" consists of each \ operating history, relief valve discharge
plants with the lowest polymerization
sequence of charging VC and other
performance by certain plants is
butch frequencies typically experience materials to the reactor, heating reactor, expected to be much better than the
about one discharge in a 12-month
contents, polymerization of reactor
; respective limits. For example, some
period. The EPA concluded that for most contents, and removal (he- blowdown]
plants a 12-montb reporting period
of reactor contents. Any batch that is
new suspension resin PVC plants produce about B, 000 batches during a
(rolling every B-months) was both
aborted following charging of VC to the 12-month compliance period. One end
suitable and appropriate for determining reactor is nonetheless counted as a
two discharges at one of these plants
compliance with the proposed numerical polymerization batch in assessing
' during a compliance period would result
limits. For plants producing only a small compliance. For PVC plants producing r tn a discharge performance of o.oz and
amount of a particular resin [i.e. low
bulk resin, a tingle "polymerization
; 0.05 discharges per 100 batches.
number of polymerization batches), an batch" includes both prepolymerization respectively. The second discharge
apparent violation of the standard may result from a single discharge
and postpolymerization reactor operations.
\ during the compliance period would be \ t violation of the proposed 0-035
occurrence during a 12-month compliance period as described below.
Discharge frequency can be recorded in two ways. Discharge frequency can
discharges per 100 batches limit despite the fact that the first discharge would
For a PVC plant producing a single
be recorded on the basis of discharge
result in performance well below the
resin type to meet the numerical limit for events (involving discharges from one or limit These types of plants were
reactor discharges (i.e., 0.035
more relief valves] or on individual
. considered in selecting theproposed
dJscharges/100 batches), it must
reM valve -disdhargeS.Tn most cases, ` limits and reporting procedures for relief
experience and average of no more than plants currently report discharges
valve discharges. The result that plants
one discharge per 2,838 polymerization individually when they occur from relief of this type must perform well below the
batches over the preceding 12-month
valves on separate equipment However, limits In the standard in order to be in
period. An average reactor discharge
' certain equipment such as
' compliance is consistent with the
frequency exceeding one discharge per polymerization reactors that are
' proposed limits, which were selected to
2,853 batchee would be a violation of the equipped with multiple relief valves may represent an upper boundary on the
standard. However, if the plant made
experience discharges elmulta isously
number of allowable discharges
less than 2.358 polymerization batches from more than one relief valve. Most
intended by the standard. The EPA
over the 12-month compliance period, a plants currently report such multiple
expacts that plants using the best
single discharge occurrence would be an discharges from a single piece of
technology and procedures should be
apparent violation of the standard (i.e., equipment as a single discharge. Thus, able to perform bettor than the proposed
the discharge frequency per 100 batches the performance levels serving as the
limits.
would exceed 0.035). Because
basis for the numerical limits represent
Reporting Requirements. The current
insufficient batches were made, the
individual discharges and not multiple 'Standard for relief valve discharges
reported discharge frequency per 100
discharge events except when they
requires producers to report discharges
batches would not correctly reflect the occur from a single piece of equipment. within 10 days of the incident The EPA
performance by that plant in comparison For determining compliance with the
is proposing tc eliminate the 10 day
to other plants complying with the
numerical limits, discharge frequency is reporting requirements and to require
standard. In rectifying the undue
to be recorded on the basis of individual reporting of all discharges on a quarterly
compliance burden posed on plants with discharges except when simultaneous
basis. Although compliance is to ba
smell numbers of batches by the
discharges occur from relief valves on
determined on a semiannual basis,
discharge/100 batch format and the
the same piece of equipment.
quarterly reporting of discharges is
selected 12-month compliance period,
A relief valve discharge in considered appropriate because violations of the
the EPA Is proposing to add additional to be any venting through a pressure
standard may occur well before the end
provisions affecting the number of
batches used to calculate the discharge f: equency. For PVC plants producing
relief device to prevent or relieve an overpressure condition from equipment
In VC service that results in emissions
of the 8-month period. Quarterly reporting notifies enforcement personnel of potential violations and violations
less than 2.858 batches of a particular
resin, the minimum number of 2.858 batches will be used when determining
of VC directly or indirectly to the atmosphere. In determining whether or not a relief valve discharge results in
that have already occurred prior to the end of the compliance period so that corrective actions can take piece sooner
compliance with the numerical limits.
emissions to the atmosphere, the
following the end of the compliance
PVC plants producing more than one controlling factor is the ultimate
period. Information to be included in the
resin type must demonstrate compliance disposition of the gases. Venting to a
semiannual report for Individual relief
separately for reactor discharges
manifold or header system that
valve discharges is to be reduced to
occurring from different resin production ultimately discharges to the atomsphere Include only the date, time, source,
processes. Only the relief valve
constitutes a relief valve discharge. If
causo and estimated amount of eaeh
discharges and polymerization batches the manifold or header discharges gases discharge occurrence. The semiannual
specific to each resin typo are
through a control device meeting the 10 report will also inicude information on
considered for determining compliance. ppmv VC emission limit, the venting
compliance status.
However, for determining compliance
does not constitute a relief valve
In addition, plants will now be
with the standard for nonreactor
discharge.
required to maintain relief valve
discharges, the total number of
For purposes of reporting compliance discharge records for 9 years, because of
polymerization batches (regardless of
status with the limits, plants wilt be
the potentially significant increase in the
resin type) are counted.
. required to calculate their discharge per time period between a discharge
To determine the number of
. batch frequencies with sufficient
occurrence end reporting of the
polymerization batches produced for
precision to demonstrate that
discharge.
purposes of assessing compliance, the
performance is either equal to, below of
Effective Date ofRevision. The
following guidelines apply. A
in excess of the limits. Based on
current standard as written will remain
ti i ! i
I
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AP000185I0
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Federal Register I Vol. SO, No. 6 / Wednesday, January 9. 1985 / Proposed Rules
in effect for relief valve discharges until t calculation methods are then used in
effectiveness of leak detection end
the proposed revisions are promulgated. establish the reactor opening loss.
repair programa Some plants
The proposed administrative revisions Based on experience of the EPA
implemented rigorous programs and
do not change the standard's original
Regional offices, a method for
other* implemented programs lacking
intent and are intended only to set limits determining the reactor opening lose
specific procedures or requirements.
to facilitate compliance and enforcement efforts. Thus, the current
that accounts for stripping In the reactor Accordingly, the effectiveness of leak
has been developed for use by all
detection and elimination programs
standard will continue to be enforced
nonbulk resin producers with reactor
varies among the plants.
until the revtsione are promulgated.
resin stripping operations and is
Strlpping-tn-Reactor Conph'ance Test Procedure
included in the proposed revisions lo the current VC standard. Limitations for resin residua! and reactor opening lose
The test method for measuring reactor are added together to give a total
opening losses was developed for resin allowable VC content from these two
stripping operations that take place In
sources. Thq measured resin residual
vessels separate from the reactor. Some VC and the calculated resetor opening
PVC plants, including all bulk resin
lose would then be added together, and
manufacturers, however, do not use
`averaged overo 24-hour period
separate strippers to remove residual , according to resin type. If the 24-hour
VC from the resin produced Instead. ,i average meets the combined standard,
these plants strip VC from the product
the plant would be considered to be in
. Since the current standard was promulgated, the EPA has obtained more Information pertaining to die control of amission 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
resin in the reactor (postpolymerization compliance with both the stripping and
reactor in the case of bulk resin
\ the reactor opening loss requirements.
development of other standards indicates that a routine leak detection
producers). For plants with reactor resin I Lrak Detection and Repair stripping operations, the concentration r
and repair program with a portable monitor can be an effective emission
of VC in the reactor vapor space* as
background. The current standard
reduction technique without the
measured in accordance with the current standard, exceeds die 0.pg/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 diet
must be broken before the reactor can be emptied) end before the reactor is completely Emptied of PVC resin. According to the Federal Register notice of promulgation of the current VC standard (40 FR 46SB3. October 21,4976).
any VC escaping from the resin after it has been stripped to acceptable levels is not intended io be counted as part of the :eaclor opening toss. However, the current standard did not Include in (he measurement me&xLss. a caeptable
'Sthod for determining what part of the VC in the vapor space has escaped from
^e resin after stripping Is completed.
The current standard allows bulk rfcsta producers to calculate reactor opening loss emissions from the poetpolymerization reactor based on the
requires implementation of a formalised requirement of a fixed point monitoring
program for detection of leaks from
system, the EPA concluded that fixed-
equipment in VC service and
point monitoring systems already in
elimination of these leaks. The
place have uses that justify their
formalized program Includes a
retention In the current standard. In
multipoint VC delector and a portable 'particular, fixed-point monitors allow
volatile organic compound (VOC)
1 for quick detection of certain large VC
analyzer. The fixed-point monitoring
leaks that might otherwise go
system continuously monitors VC
, t undetected _u.n..t.i.l,,t,,h,,e next routine
concentrations in the work area around .1!:portable monitor screening. The EPA
equipment in VC service end sounds an recognizes that existing fixed-point
alarm when concentrations exceed a
monitoring plans will need to be
prescribed level. The portable monitor is used independently to screen Individual
reviewed in light of the leak detection and repair requirements being specified
equipment eompoifents for leak*. Rather i: Ht thia time. The complexity of existing
mthai nn sMpAeMciiWfyiIinhmg 4thke nntutvmikbaenr *o1f fptaatinatias Ptoit * f--ixed-point monitoring plans, in terms of
be monitored. Ihe sensitivities of the multipoint detector, the VC concentration that indicates a teak, and
the action*t^hitaken.JfttaBflit leaks, the current standard requires each plant owner or operator to prepare e program
plan containing these specifications and
to submit the plan to the EPA for approval. Plant owners or operators are
required to submit date on background . concentrations of VC in different area* of the plant to use in determining the VC
' number and distribution of monitoring points, varies greatly among plants.
, Consequently, some plantovucistBi.ee operators may want to alter the number . cf points that are monitored and the distribution of monitoring locations to
better complement the specified portable monitoring requirements. Such
changes to existing fixed-point | monitoring plans will be allowed providing they do not alter the plant's
number of reactor evacuations, the vacuum invloved and the volume of gas
concentration that should be designated , .ability to detect large VC leaks. as Indicating a leak. Plans, therefore, :The proposed revisions are primarily
i:> (he reactors. For nonbulk resin
were tailored by each plant and
Intended to standardize control of VC
producers with reactor resin stripping
reviewed by the the EPA Regional
emissions from equipment leaks, (n
operations, calculation of reactor
Offices.
doing this, the EPA is concerned that
opening loss emissions is more
The EPA found in the review study
existing effective plans not be
compliccted due to the presence of.
that differences in leak detection and
Inappropriately changed. The proposed
water vapor in the reactor vapor space. elimination programs exist among PVC revisions Include provisions that allow
Currently, waivers of testing for producers with nonbulk resin stripping
and EDO/VC production plants and miscellaneous sources and that site-
< plants with existing effective plans to periodically demonstrate the
operations in the reactor have been -
specific differences include variations in effectiveness of their plans without
granted on a case-by-case basis by the leak definitions and monitoring
additional requirements. Accordingly.
EPA Regions, typically with (he
practices. The definition and monitoring ' trie EPA requests comments from
provision that residual VC samples are practices, along with repair practices, I industry representatives concerning ih*
aolayzed on each batch. A variety of
are primary influence* on the control '_spe<ufir. effects of specifying leek
)
AP00018511
Federal Register f Vol. 50, No. 6 / Wednesday, january 0,19SS / Proposed Rule#
1191
((election and repair requirement* on fi 2.0 percent or less. Any process unit In
rlTeetive existing plans.
' which,the percentage of leaking valves
Leak Detection and Repair
la found to exceed 2.0 percent will be
Requirements. Hie EPA established leak required to comply with the provisions
detection and repair requirements (40
of Subpart V.
CFR Part 61 Subpart V) for certain
*} The Subpart V requirements for
equipment in volatile hazardous air pollutant (VHAP) service on June 6. 1984. These requirements were
valves are based on a leak detection
and repair program that requires (1) monthly monitoring for valves in gas/
established in conjunction with the final vapor and light liquid service, (2) an standard for benzene equipment leaks. initial attempt at repairing these valves
The requirements of Subpart V generally within 5 days after detection of a leBk.
apply to pumps, compressors, pressure relief devices, sampling connection
(3)repair of leaking valves within 15 days efter detection of the lesk unless
systems, open-ended valves or lines,
repair would require a process unit
valves, flanges and other connectors,
shutdown, and (4) repair of valves
and product accumulator vessels. These during the next process unit shutdown
requirements reflect the level of control after repair Is delayed until a process
that the EPA considers reasonable for
unit shutdown. Valves found not to leak
equipment covered by developing
Jagg^MQcaastee months/wahe
etanaardsTor'VHJCP. The EPA is
monitored quarterly until leaks are
therefore proposing to add VC to the list detected. Monitoring of equipment to
of substances covered by Subpart V.
detect leaks is conducted in accordance
Subpart V would substantively affect with Method 21 and a leak is defined as
only valves and flanges in VC service
a meusured organic concentration equal
within this industry. All other equipment to or greater than 10,000 parts per
in VC service are Already required by
million by volume (ppvm). For a
l*"G VC standard to comply with
complete description of the leak
;t]'jfpmenl and work practice standards detection and repair requirements, see
insistent with those in Subpart V. For Subpart V (49 FR 23498. June 0,1984).
-Ti'.oie. pumps and compressors
in addition. Subpart V contains
the dual mechanical seal
standards for other types of equipment
; 'iiuircmcnts of the current VC standard (e.g., flanges, and open ended valves nr
v-Jii be in compliance .with the Subpart .lines). Standards for flanges include
V requirements. In addition, the
monitoring with a portable instrument
- .mpitng connection systems
under prescribed procedures within 5
quircmcnts of Subpart V are
days of observing evidence uf a
'semJaNy the same as the current
potential leak by visual, audible or oilier
landard. The use of rupture discs for
means. Open-ended valves or lines are
I'cntrolling leaks from pressure relief
required to be capped, blinded or fitted
devices, as required by the VC standard, with a second valve. These provisions
is consistent with the "no detectable
are not expected to significantly affect
omissions" requirement included in
producers with these types of equipment
Subpart V, Requirements for controlling in VC service. The equipment and
leaks from pressure relief devices are
procedures employed as normal practice
described in more detail later In this
by these producers or os a resull of the
section. Thus. Subpart V will affect
current VC standard are expected
primarily valves and flanges in VC
generally to ensure compliance with
service by requiring a specific
Subpart V.
monitoring schedule, leak definition and
Pressure ReliefDevices. The EPA
repair provisions.
proposed and promulgated the work
Compliance with the provisions of
practices, equipment, design and
Subpart V will be used to determine
operational standards in the current
compliance with the portable monitor
standard before explicit legal authority
leak detection end elimination
existed in Section 112. These
requirements in the current VC atandard requirements are found In 101.85(b). In
(40 CFR 61.65(b)[8)(ii)), and therefore,
August of 1977, Congress amended
the current standard is being revised to Section 112 to allow the use of these
reflect this change. However, process
requirements. Section 112 of the Clean
units within VC and PVC plants in
Air Act requires that an emission
which the percentage of leaking valves standard (i.e.. a performance standard)
is equal to or less than 2.0 percent are
be established for control of a
considered by the EPA to be effectively hazardous air pollutant unless, in the
controlling VC emissions from leaking
judgment of the EPA, it is not feasible to
valves. For these process units, the
prescribe or enforce such a standard. An
existing leak detection end elimination emission standard allows for some
program will continue to be allowed
flexibility in complying with the
while the percentage of leaking valves is 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: (1) 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 is not practicable due to technological or economic limitations. Section 112(e)(1) allows that if an emission standard is not feasible to prescribe or endoree. then the EPA may istead promulgate design, equipment
work practice, or operational atandard. or combination thereof.
The EPA has reviewed the design, equipment, work practice and 4peralianal-M}uis**Entsaatl*d Jo .
the current VC standard. The only sources covered by the current standard with one of the requirements for which a
performance slundard (i.e.. an emission standard) is feasible are pressure relief devices. As discussed below, the EPA is setting a "no detectable emissions'* limit for these sources. For the other sources, the KPA is reinstating those
requirements as set forth In the current st.iti'l.jrd.
The ili'A selected the use of rupture
disks as the baits for the current
standard for pressure relief devices. When the integrity of ruptures 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 an overpressure, replacement of the rupture disk once again eliminates equipment leaks of VC through the pressure relief device.
For emission control techniques that eliminate equipment leaks, such at the use of rupture disks, a "no detectable
Amissions'* limit is feasible. An instrument reading of less than 500 parts
er million by volume (ppmv) above a
ackground concentration based on Reference Method 21 can be used to indicate whether equipment leaks have
been eliminated: that is, that the
equipment hat "no detectable Amissions."
The "no detectable emission** limit would not apply to discharges through the pressure relief device during overpressure relief. (These releases are covered under 1161.64(a) and 61.65(d).)
The standard would specify, however, that the relief device be returned to a state of "no detectable emissions"
within 5 days after such a discharge. The standard would further require an annual test to verify the "no detectable omissions'* status of the pressure relief devices and a test after each over
.j;
APOOOf8512
vm
Federal Register / Vol. 50, No. ft / Wednesday. January 9. T9S5 / Proposed Rules
piossure relief. This administrative
chanaaimplementsthebasisphhl* standard consistent with the requirements of Section 112(*1.
the 3-hour averaging period is intended . carried out in two separate vessels. The
--; to clarify that the 10 ppmv standard
reaction is Initiated in the
/ applies to VC emissions in all exhaust . "prepolymerisatioiT reactor and the
gas stream* covered by the 10 ppmv / reactor contents ere then transferred to
Miscellaneous Revisions
` requirements, including any control
, the "postpolymerisatioaM reactor where
Dosed on discussions with the EPA
device bypass streams. Requirements / the reaction is completed. Stripping of
for calculating the VC content In
residual VC In bulk resin is performed
' tgional personnel regarding their
, bypassed emissions for purposes of v. following the postpolyrneriiatioa step In
experience In administering the current / reporting VC emissions in excess of the ; the reactor vessel The
VC standard, the EPA is proposing several additional administrative
\ 10 ppmv standard are being added to / postpoiymerization reactor generally is the regulation. The EPA may use these i opened after every batch and must
revisions that would facilitate compliance and enforcement efforts
I calculations along with continuous ^ emission monitoring results as
\ comply with the reactor opening loss I limits specified in the standard. Because
associated with the current standard These revisions represent minor changes
'indication* of noncompliance if they I the prepolymerlxattoa reactor is opened show clearly that emissions in excess of V. less frequently and because
to the standard. A brief description of
these administrative revisions and the
SnVts for making them follows.
Definition ofleak. Exhaust Cm anti
Relief Valve Discharge. Functional definitions of "leak'*, "exhaust gas" and
'relief valve discharge" ere being added
to the standard to clarify the
applicability of the standard to each of
these types of VC emissions. During
/hair review of enforcement and
compliance experience since the standard was promulgated, the EPA
discovered several cases of confusion
over the intended meaning of `leak'*, "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 a dear understanding of
which part of the standard applies to
.tr.y given discharge of VC emissions to 'he atomosphere.
the 10 ppmv requirements occurred.
/ determination of gross product (for
The second clarifying revision to the
reuctor opening loss estimation) is
10 ppmv standard involves the
difficult the EPA has allowed plants to
specification that the to ppmv requirement* apply to each exhaust gat
meet the equipment opening requirements for minimizing VC
strewn from the covered equipment The/ emissions from polymerization reactor
purpose of this revision is to dearly
openings. The reactor opening loss
prohibit plants from using dilution with \ requirements are being revised at this
other exhaust gas streams as a
time to specifically exclude
technique for meeting the 10 ppmv
prepoiymerizatian reactors.
requirement. This revision is not
Accordingly. VC emissions from ail
intended to prohibit the common
opening of prepolymerization reactors
practice of combining two or more
will be subject to the equipment opening
exhaust gas streams in a common
requirements. This revision is intended
header leading to a control device.
to clarify and Improve the consistency
According to the revised 10 ppmv
of the equipments of the revised
requirements, combining an exhaust gas, standard as they apply :o bulk PVC
stream containing more than 10 ppmv v resin producers in light of actual
VC with another exhaust gas stream
industry practice. No reduction in VC.
containing less than 10 ppmv VC is
t emission control stringency will result
allowed only when the combined stream' from the change in requirements fur
ducted to the control device.
prepolymerization reactors.
: Relief Valve Definition. The current ; 1 fnpreoea* Wqstgt%xitfr Requirements
Definition ofEDC and VC
standard for reliefvalve discharges was fprydsfiptier Seal$t Under the current
t'ltrification. In the past, some plants huve misinterpreated which equipment'
intended to apply not only to safety
; ~s EandarcsTtKe VC content of Inproeeee
relief valves but to all types of pressure wastewater must be reduced to less
components ere Included in EDO
relief device*. A definition of "relief
/ than 10 ppm exposure of the wastewater
i<di ification and VC purification
valve" i* being proposed under the
to the atmosphere. In the case of
processes with the result that emissions revised standard to clarify1 that the.
gasholder water seals, the VC content in
from certain equipment Intended to be
current relief valve discharge standard
the exposed water seal may sxrymdltt
i.ovxgKbb^thestandard magnet hewe also spplieto rupture discs, manual
ppm curing nerraai'aperation of the
;*en controlled. The definitions of "EDC vents and olher pressure relief devices gasholder. Experience since tha
f urification" end "VC purification" are that vent to the atmosphere to protect
standard was promulgated indicates
being revised to clarify that ail
process equipment from unsafe
that compliance with the atmospheric:
purification equipment following EDC .nd VC formation were subject to
overpressure condition*. The definition exposure limit la not practicable for this of relief valve is the proposed standard particular Inprocess wastewater source.
. ^illation under the current standard. ` IVppmv Standard. Two clarifying
;$ not intended to include pressure
Consequently, the definition of
control valves used to control flow to an inprocess wastewater is being revised In
a'vVsior.s'sra 6emg"mada to the 10 ppmv ' incinerator or other control device.
exclude the exposed water seal of
regulations to improve understanding of However. the current relief valve
. gasholders. The inprocess wastewater
the applicability of this part of the
discharge standard did cover emissions stripping requirements will continue to
standard. First, although the test method from pressure control valves. Also not
apply to wastewater after removal from
for determining compliance with the to ppmv standard specifies that the average results from three 1-hour . sampling runs be used, this 3-hour
averaging period is not specified in the to ppmv requirements. Specifying dial
included in the definition of relief valve the gasholder seal
are pressure control systems such as
Elimination of30-Day Limit tut
polymerization reaction shortstop
EquivafencyRequest*. The current
systems or refrigerated water systems * standard specifies a 3d>day limit for
which act to reduce prassure by means existing sources to submit requests for
other than venting.
use of equivalent methods. Because surt>
emissions may not exoeed 10 ppmv over ' Reactor OpeningJos* Requirements u 3-hour averaging period clarifies that ffr'a"Riernin Producers. Bulk*
a limit poses restriction on initiative by industry to develop alternative, and
icstanianeous compliance with the 10
PVC resin production differs from
potentially more effective, control
ppmv standard is not an intended
production of other types of PVC resin measures, the 30-dey limitation is being
requirement Moreover, specification of in that the polymerization reaction is
eliminated.
i
L
AP00018513
Federal Register / Vol SO. No. 6 / Wednesday, January 9. 1685 / Proposed Rules
1193
Other. In addition to the revision* /increase or decrease in the overall
revision* do not Increase the cost of
described above, a review of the
recordkeeping and reporting currently
compliance with the standard.
recordkeeping and reporting requirement* of the current standard
practiced by individual plants. / The EPA concluded that the current
Public Hearing
was performed to identify ways to ease 1 recordkeeping requirement!, its
If requested a public hearing will In-
recordkeeping end reporting burden on specified in 40 CHI 61.71, are still
held to discuss the proposed revisions to
Plants and to identify any additional
appropriate. However, the EPA is
the VC standard in accordance with
recordkeeping and/or reporting needs. proposing to extend the current
sections 112(b)(lUB} and 507(d)(5) of the
The EPA Identified two tnti where the recordkeeping requirements for all
Clean Air AcL Persons wishing to make
reporting burden on plants could lie
reporting activities from 2 to 3 year*.
oral'presentsdons on the proposed
reduced The current reporting
Tbs net impact of the revised
revisions should contact the EPA at the
requirements for residual VC monomer recordkeeping and reporting
address given in the AODRE8SE* section
specifications and reactor opening
requirements proposed by the KPA is
of this preamble. Oral presentations wil)
measurements require that result* of all estimated to be a decrease in a
l-e limited to 15 minutes each. Any
compliance tests be reported in
paperwork burden or about 24 person
semiannual reports. The EPA is
years.
proposing to allow plant* to report only t It should be noted that all
member of the public may file a written eutoment before, during, or within 30 tluys after the hearing. Written
test results that show exceedences of *. ./sCompretensive Environmental
the respective standards-if no
/Response. Compensation, and Liability
exceedences occur, plants wilTbfc
"feet tCERCLS) Section 101(14]
required to Indicate that fact in the
/hazardous substances such a* vinyl
semiannual report. This type of
- chloride are subject to reporting
exception reporting is currently allowed requirements under Section urilaj uf
'or demonstration of compliance with Tie 10 ppmv standard for process vents
CERCLA. CERCLA require* that person* In charge ofvessels or facilities from
!>e second area is the requirement to
Which hazardous substances have been
import relief valve discharges within ift released In quantities (RQsj
''V* of their occurrence* The EPA is vposing to allow plants to report n-lh f 've discharge occurrences on a
immediately notify the National Response Center (NRC) of the release.
The toll-free 24-hour telephone numtii*
-"ferly basis rather than within 10
nf the NRC is 80CH24-W502 and in
,-s of their occurrence* Furthermore. ' reporting requirement* for relief
.vr discharges have been streamiiiifd
dropping the need to report action*
in end implemented preventive
Mires for each discharge. inrmatloB. on the data. time, source. -*c and estimated amount of
r.dividual relief valve discharge will tie .winded with the semiannual report*
`.ong with information on compliance
Vt'ashington, D.C. mctropci.iiin area r (202) 426-2675. (See CERCtA Kouirn
103 and 48 FR 23S52. May ~>- 1**31 ' ` Vinyl ehloride was itssianvu h
f statutory 1 pound renortutiit* nuinhix v. under Section loll 141 uni-;v. ii ><y / regulation, and is pre**n*Lv until . to'nv \ assessment for both chronic toxicity *:ul
/carcinogenicity. Its FQ will be aniusted
( pending the outcome of these reviews by the Office of Emergency and Remedial
1 Response. Federally permitted releaMis
`litUS.
Additional semiannual reportinc requirement* being added for FVC producers are the number of reactor opening* and the design capacity
under CERCLA (Sec CERCLA Section i('lfl) end 48 FR 23SSZ1 are not auhleet
to CF.RLA notification retmiremrni* w `Abilities. However, rcleast;* of hazardous substances that ere r>oi
".umber of polymerization batches fur
subject to a permit or control regulation
each resin type. This requirement will provide general information to facilitate
must be reported.
review of industry-wide compliance
Regulatory Flexibility Anah sis
statements should be addressed to the Centra) Hfzfcet GactiomHldrM^pit^n *n the ADDRESSES section of this preamble.
A transcript of the hearing ,..il ivnrtrn t-tntemems will be nvnilubh c t j-tibhc Inspection and copying during '{fncl uoriritn hours at the ITA** u. n*Ml lliif kr.t Section in Washington. D.C. eODKCSSES section of this , '>V`
:> ket
4 're rii<; *e*.*(.ryar.Jzetl and !'> > ot all the infotmatiou
~-.tr; tf a. otherwise considered h\ ! ; .\ -n trie i.c\fc;ciptr.entof this .." 'omui ruU-mak.ns. The principal -reuw-s ol 8 docket are; (l)To allow - Vvs'ul parties to identify und locate -. Tiotus. *t< that they can eitce.iivcly 7;>r::cipuu* in ure rulemaking prove**. and 2I to serve as the record in case of mdiriat review (except for Interagency tevltw materials ({ 5(r(d)(7(A)H.
Miscellaneous
In ncccvdunee with section 117 of the Act. publication of this proposal was preceded by consultation with -ippruprihie ctivisory commiitues. independent experts, and Federal departments and agencies. The Administrator will welcome comments or. ali aspects of the proposed
status during past reporting periods.
The Regulatory Flexibility Act of ihuo ri Ui;!a:ion. including health, and
Specific recordkeeping and reporting require* that adverse effects of all
economic and technological Issues.
requirements are included as part of the Federal regulation* upon small
The information collection
revisions to the leak detection and
businessea be identified. According to
requirement* in this proposed rule have
repair requirements. The recordkeeping the current guideline* of the Small
been submitted for approval to the
requirement* include preparation of an Business Administration (SBA). a smell Oirice fManageihent arid Budget
initial log to record equipment
business that produces or processes VC (OMB1 under the Paperwork Reduction
component identification, physical
is one that has 500 employees or less. 1 Act of IBM). 44 U.5.C 3501 el spq.
tagging of equipment components which Currently, none of the existing
Comment* on these requirements should
leak, and maintaining a record of
producers or processors that are
be submitted to the Office of
equipment leaks and repair action
affected by the standard ore estimated Information and Regulatory Affairs of
-Included in the reporting requirements to be small by this definition. Since nont1 OMB. marked `.`Attention: Desk Offirtr
are the number of equipment leaks and of the companies meets (he SBA
for FJ'A". a* well a* tn the EPA docket
the tepair status of leaking component* definition of small business, no
described above. The final rule will
Depending on the particular leak
regulatory flexibility analysis is
respond to any OMB nr public
detection and repair program in place,
required. Even If an analysis were
comments on the information collection
hese requirement* may represent Rn
required, the proposed administrative
requirements.
I
T
AP000185I4
1
llg*_______ Federal Reglstet / Vol 50, No. 6 ) Wednesday, January 9. 1965 / Proposed Rules
Under Executive Order 12291, the EPA product containing vinyl chloride or
\ limits are prescribed in 181.62 (a) ami
must judge whether a regulation is
polyvinyl chloride but which has not i (bh 16143(a); 161.64 (a)(1). (a)(2). (b).
"major*' end therefore subject to the
been discharged to a wastewater
<; (c) and (d); 161.65 {b)(l)(iij. (bj(2). (b)(3)
requirement of Regulatory Impact
treatment process or discharged
!i (b)(6)(H) and (b)(9)(d)- A leak as defined
Analysis. This regulation is not major
untreated as wastewater. Caa-holder ' in paragraph (w) of this section is not an
because: (l) The national annualized
_ seal water la not tnprocess wastewater - exhaust gat,
compliance costs, including capital charges resulting from the standards
^until It is removed from the gasholder. **a
11 (y) "Relief valve discharge" mean# j any nonleak discharge through a relief
total less than $100 million; (2) the
(1) "In vinyl chloride service" means (valve.
standards do not cause a major increase that a piece ofequipment either contains. (z) "3-hour period" means any three
in prices or production costs: and (3} the standards do not cause significant
or contacts a liquid that is at least 10 lc_o__n_s_e_c_u_ti_v_e_1__-h_o_u_r_p_e_r_io_ds (each hour percent vinyl chloride by weight or a gas \ commencing on the hour).
adverse effects on domestic competition, that is at least 10 percent by volume
employment, investment productivity.
vinyl chloride as determined according
Innovation or competition in foreign
! to the provisions of I 61.87(h). The
markets.
; provisions o!} 61.67(h) also specify how
This regulation was submitted to the to determine that a piece of equipment (t
Office of Management and Budget for
not in vinyl chloride service. This
3. By changing " all exhaust gases'* to "hick exhaust gas stream" and making
other minor clarifying revisions in i 61.82(a), f 61.83(a). and | 61.84 (a)(1). (b), (c) and (d) as follows:
review as required by Executive Order . definition must be used in place of the
f 1142 emission standard forethyfene
12291. Any comments from OMB to EPA definition of "VHAP service" in Subpart dfeWorld* plant*.
and any EPA response to those
V of this part
(a) Ethylene dichloride purification:
comments are included in Docket
* * *
The concentration of vinyl chloride in
Number A-61-21. The docket is available for public inspection at EPA's
Central Docket Section, West Tower Lobby, Gallery 1, Waterside Mall, 401M Street. SW,, Washington, D.C, 20400.
Pursuant to tha provisions of 5 U.S.C. 605(b). 1 hereby certify that this role, if
promulgated, will not have a significant
economic impact on a substantial
(o) "Ethylene dichloride purification"
includes any part of the process of ethylene dleWoride 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.
** *
each exhaust ges stream from any
equipment used in ethylene dlnhlorii)- , purification is not to exceed 10 ppm ' (average for 3-hour period or as ' determined in accordance with
I 61.67(g)(1)), except as provided in
$ 81.65(a). This requirement does not preclude combining ofexhaust gas streams provided the combined steor.* -
number of small entitles because no small entitles are affected.
list of Subjects in 10 CFR Part 81
(v) "Relief valve" means each
ducted through a control system from
pressure relief device including pressure relief valves, rupture disks, manual
which the concentration of vinyl ' chloride in the exhaust gases does not
Air pollution control. Asbestos, Beryllium, Hazardous materials, Mercury, Vinyl chloride.
Dated: Dated December 31.1984. Alvin U Aim,
vents end 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.
exceed 10 ppm, or equivalent as
provided in 161.08. This requirement does not apply to equipment that has been opened, is out of operation, snd
met the requirement in $ 61.65(b)(6Hi) before being opened.
ActingAdministrator.
(w) "Leak" means any of several
events that indicate interruption of
PART C1-4AMENDE0]
confinement of vinyl chloride within
It ia proposed to amend 40 CFR Part
process equipment Leaks include events
61 as follows: T. TBe proposed changes to 40 CFR
--TlTl^.*A`Ji urht*S=bp6v43^5Sp-arf' such as: (l) An instrument reading of
Part 61 proposed at 42 FR 28154, June 2. 10,000 ppm or greater (2) indications of
1977 ara withdrawn. 2. By revising the definitions in
existing f 61.61(0. (1). (o) and (p) for "in
liquid dripping; (3) a sensor detection of failure of a seal system, failure of a
barrier fluid system, or both; and (4)
process wastewater'', "in vinyl chloride detectable emissions us indicated by sn
service", "ethylene dichloride
instrument reading ofgreater than 500
purification" and "vinyl chloride
ppm above background. Leaks also
purification" and by adding definitions for the terms "relief value". "leak", "exhaust gas", "relief valve discharge and "3-hour period" in new paragraphs
(v),(w). (x). (y) and (z).
include events regulated under
i 01.6fi(bK8)(i) of detection of ambient concentrations in excess of background * concentration. Emissions of vinyl chloride not regulated under 8 81.81 (a) ' and (b); 161.83(a); 161.04 (a), (b). (c),
f 81.11 Def*inition*.
' (d). (e) and (f): and 161.65 (a) and (b)(1). (b)(2). (b)(3). (b)(4). (b)(5). (b)(9), (b)(7)
(j) "Inprocess wasterwater" means
and (b)(6) shall be considered a leak. A
any water which, during manufacturing relief valve discharge is not a leak.
or processing, comes into direct contact
(x) "Exhaust gas" means any offgas
with vinyl chloride or polyvinyl chloride discharged directly or ultimately to the
or results from the production or use of atmosphere that was initially contained
any raw material. Intermediate product, In or was in direct contact with the
finished product, by-product, or waste a equipment for which 10 ppm emission
161.63 Emission standard for vinyl chloride gfante.
<*a?g?WPrufov'-tatdrof:h vfnyT' chloride plant shall comply with the requirements of this section and i 61.63
(a) Vinyl chloride formation and purification: Tha 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-houi period or as determined in accordance with S 6147(g)(1)), except as provided in | 61.65(a). This requirement does not preclude combining of exhaust gas streams provided the 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 at
provided in 161.86. This requirement does not apply to equipment that has been opened, is out of operation, and met the requirement In | 6i.65(b](G)(i! before being opened.
, / r> itss's
i
AP00018515
Federal Rctiter
st(t.ir\ !>. HW5 f IVopusrd Rules
1195
.{"WJtt Of operator of polyviml
chloride plant thill comply wuh the requirements of this semen <md t m.M.
W Reactor. The following requirements apply to reactors:
(l)The concentration of vinyl chloride In each exhaust gas stream from each \reactor is not to exceed 10 ppm (average /tar 3-hour period or as determined in 'accordance with i 81.87(g)(1)], except as provided in paragraph (a)(2) of this
section and | 61.65(a).
(b) Stripper. The concentration of vinyl chloride in each exhaust gas
stream from each stripper is not to exceed 10 ppm (average for 3-hour period or as determined in accordance with S 81.67(g)(1)), except as provided in 81.65(a). This requirement does not npply to equipment that has been opened, is out of operation, and met the requirement in 161-65(b)(6)({) before
being opened.
(c) Mixing, weighing, and hrMing
.ontamers. The concentralian cf vinyl
chloride in each exhaust gas stream
:'-om each mixing, weighing, or holding
jcntciner 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 19 ppm
(average for 3-hour period or as determined in accordance with
} 61.67(g)(1)), except as provided in
5 61.65(a). lilts requirement dors not
apply to equipment that has been
opened, is out of operation, and met the
requirement in i 61.65(b)(6)(i) before
being opened.
(4)Monomer neegvery aynaem.
joneentraHon of vinyl chloride in each
exahust gas stream from each monomer
recovery system is not to exceed 10 ppm
(average for 3-hour period or as
determined in accordance with
i 81.67(g)(1)), except as provided in
*v 81.65(c). This requirement does not
apply to equipment that has been
opened, is out of operation, and met the requirement in S 6t-65(b)(G)(i| Lx fore
being opened.
44
4*4
"'4/By revising existing parxuniph*
$**.64(a){2) and by removing (n i{3) .<* follows:
16164 Emission standard for polyvinyl chloride plants.
;\n owner or operator of a pulyvinyi hlotide plant shuil comply with the 'ufiuiremenia of this section and f 61.6$. '<.] Reactor. The following *.'tmiremenls apply to reactors:
-----------*------------- rs
; < h n .irtnr nnrnirtK loss from each ' 7. Dv revising paragraph (a) to I (165
.< tor m nol lo exceed (1.02 g vinyl
as,"follows:
vnmle/ka 10.00002 lb vinyl chloride,/lb) . joly vinyl chloride product, except as provided in paragraphs (f)(1) and (f)(2)
of this section, with the product
4 C1.6S Emission standard for sthytsno cNebloridt. vinyl ehlorids and polyvinyl
eWorld* plants
determined on a dry solids basis. This
An owner or operator of an ethylene
, requirement does not apply to
dlchloride, vinyl chloride, and/or
. prapolymerication reactors in the bulk polyvinyl chloride plant shall comply
.process. This requirement does apply to with' the requirements of this section.
' postpolyraerizetion reactors In the bulk
(a) Reliefvalve discharges, (l)
process, where the product means the gross product of prepolymerization and 'postpolymerization. *
Polyvinyl chloride plants (suspensioo. dispersion, latex, and bulk processes), o1
- (i) Reactor. The number of discharges ' to the atmosphere from relief valves on
: 5. By revising paragraph (e)
polyvinyl chloride reactors In vinyl (
irifroductory text and adding paragraph chloride service is not to exceed the
(e)(3) lo ! 61.64 as follows:
following limits except as provided in
5 61.04 Emission standard for polyvinyl chloride plants, *****
paragraph fa)(l)(iii) of this section. Por ' all reactors producing suspension resins within a PVC plant, the number of relief
valve discharges is not to exceed O.Q35
(e) Sources following the stripperlsl
discharges per 100 polymerization
The following requirements apply to
' batches nor 4 discharges per year. For
emissions of vinyl chloride to the
all reactors producing dtspeislon and r
atmosphere from the combination of all . latex resins within a PVC plant, the
sources following the strippor(s) (or the number of relief valve discharges it not
reaetor(s) is the plant has no stripper(s)) to exceed 0.033 discharges per 100
in the plant process flow including but
polymerization batches. For alt reactors
rot limited to. centrifuges,
including prepolymerization and
concentrators, blend tenks. Alters,
poetpolymerization reactors, producing
dryers, conveyor air discharges, baggers, bulk resins within a PVC plant the
storage containers, and inprocess
number of relief valve discharges is not
t wastewater, except as provided in
to exceed 0.035 discharges per 100
paragraph (f) of this section:
polymerization batches.
(3) The provisions of this paragraph
apply at all times including when offspecification or other types of resins ere made.
(it) Tbe number of discharges to the
atmosphere from relief valves on
equipment {excluding polyvinyl chloride
reactors) in vinyl chloride sendee is' not
to exceed 0.025 discharges per 100
/
6. By adding paragraph (f) to | 61.64 as follows:
polymerization batches nor 3 discharges ' per year except as provided In
jsswFgK^folflXttfj'of tfewroenSw.
561.64 Emission standard for polyvinyl chloride plants VI6
(i/f> The limits specified in paragraph* ()(1)(il and (aJ(lKii) of this section may
be exceeded when only one nrlii*f vain*
(f) Reactor used as stripper. When e
nonbulk resin reactor is used os a
,
' stripper this paragraph may be applied `
discharsc O She tmnphrr* during the i;-momh period pr* ct-cl.: 4
iht* tf {* *V --.nr.'h
in lieu of J 61.64 U5{2) and ( t V.
(1) The weishted average emission*
\invi cntoTicie Srom reactor oremra
a;i xou'cls luiiownj :-.e ,-> r . -
i.*vj is .i *:r:r;:{r ::n ...i
x t;.*
7 j.w.r.\i cnionae n:s;n stnoped in 'hi*
".u i.T'
r-_ii.-f ui-vus u:i .nl
ii-ipmeru in vinyi chloride service is
on each calendar dav mav not
not to vxccud 1 discharge per year.
. \cu.u:
13) Ethylene dichloride and vinyl
(!1 202 g/kg (0.00202 lb/lb) nf polyvinyl chloride plants. The number of
chloride product for dispersion polyvinvl discharges to the atmosphere from relief
chloride resins, excluding iatex resins,
valves on equipment in vinyl chloride
with the product determined on a dry
service is not to exceed 4 discharges per
solids basis.
year.
(;l) 0.42 3/kg (0.00042 Ib/tb) of
(4) Each relief valve dfschurc* that
polyvinvl chloride product for all other contributes to a relief valve discharge
polyvinyl chloride resins, including latex frequency in excess of any limit
resins, with tbs product determined on a prescribed in paraearphs
(a)(2)
dry solids basis.
and (a)(3) of this paragraph ronstitntea
AP000I8516
1106
Federal Register / Vol, 50t No. 6 / Wednesday. January 9.1985 / Proposed Rule#
an individual violation of the respective ' routing compressors in vinyl chloride
limit.
service ere to be minimised by installing
(5) For every relief valve discharge to ' compressors with double mechanical
* Ihs atmosphere, the owner or operator seals, or equivalent as provided in
hail record the identity of the source, ' f 61.06. if double mechanical seals are
the date and time of the discharge, the
used! vinyl chloride emissions from the
cause of the discharge, the approximate seals ere to be minimized by
*
total Vinyl chloride loss during the / maintaining the pressure between the
discharge, and the method used for
two seals so that any leak that occurs is
. determining the vinyl chloride loss. This Into the compressor; by ducting any
\ Information shall be submitted in
t vinyl chloride between the two seals
. writing to the Administrator as part of - through a control system from which the
, St the reporting requirements of paragraph concentration of vinyl chloride in the
61.70. This information shall be
\ exhaust gases does not exceed 10 ppm:
..retained end mede available for
or equivalent as provided In f 61.68.
inspection by the Administrator for a minimum of 3 years.
(iv) Reciprocating compressors. Vinyl chloride emissions from seals on all
& By revising paragraphs (b)(3),
reciprocating compressors in vinyl
(b)(6)(i), (b)(8)(tii), (b)M(lv) "d (bj(8)(vij to 161.65 as follows;
chloride service are to be minimized by inetallingodouhl* outbgvd seals. or
| et.es Emission standard for ethylene dicnioride, vinyl ehtorioe 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 (2) * *
(3) Leakage from pump, compressor,
equivalent as provided in I 81.66, If double outboard seals are used, vinyl chloride emissions from the seals are to be minimized by maintaining the pressure between the two seats 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 f 61.66
and agitator seals: (i) Rotating pumps.
(v) Agitator. Vinyl chloride emissions
Vinyl chloride emissions from seals on all rotating pumps in vinyl chloride
from seals on all agitators In vinyl Ghloride service are to be minimized by
service are to be minimized by installing installing agitators with double
sealless pumps, pumps with double
mechanical seals, or equivalent as
mechanical seals or equivalent at provided in | 61.90, If double mechanical seals are used, vinyl
provided in 161.69. If double mechanical seal* are used, vinyl
chloride emissions from the seals ore to
chloride emissions from the seals are to be minimized by maintaining the
be minimized by maintaining the
pressure between the two seals so that
pressure between the two seals so that any leak that occurs is into the agitated
any leak that occurs is into the pump: by vessel: by ducting any vinyl chloride
ducting any vinyl chloride between the between the two seals through a control
two seals through a control system from system from which the concentration of
which the concentration of vinyl
vinyl chloride in the exhaust gases does
chloride in the exhaust gases does not not exceed 10 ppm; or equivalent as
exceed 10 ppm: or equivalent as
provided in 161.66.
provided in {61.69.
(ii) Reciprocating pumps. Vinyl chloride emissions from seals on all
reciprocating pumps in vinyl chloride
service are to be minimized by installing double outboard seals, or equivalent as provided in | 61.66. 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 occur* is
into the pump: by dueling any vinyl chloride between the two seal* 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 f 61.66.
(Hi) Rotating compressor. Vinyl
chloride emissions from seals on all
(8) Leak detection andelimination,
(i) It includes a reliable and accurate vinyl chloride monitoring system for detection of mafor leaks and identification of the general area of die plant where a leak is located. A vinyl chloride monitoring system means a device which obtains air samples from one or more points on a 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.
(Hi) It provides for an acceptable calibration and maintenance schedule
for the vinyl chloride monitoring system and portable hydrocarbon detector. For the vinyl chloride monitoring system, a
dally span check Is to be conducted with a concentration of vinyl chloride equal
to the concentration defined as a leak
according to paragraph (b)(8)(vi) of this section. The calibration is to be done with either:
(A) A calibration gas mixture prepared from the gasea specified In sections 5.2.1 and 5.2 of Test Method
108 and in accordance with section 7.1 of test Method 300, or
(B) A calibration gas cylinder standard containing the appropriate concentration of vinyl chloride. The gas
composition of the calibration gas cylinder standard is to have been certified by the manufacturer. The manufacturer must have recommended * maximum shelf life for each cylinder so that the concentration does not change
greater than 5 percent from the. certified value. TTie date of gas cylinder
preparation certified vinyl chloride
concentration and recommended maximum shelf life must 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 gas
mixtures may be directly used to prepare a chromatograpn calibration
curve as described in section 7.3 of Test Method 106. The requirements in section 5.2.3.1 and 5.2.32 ot Test Method 108 for
certification of cylinder standards and
for establishment and verification of calibration standards ere 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 are compared with the number of pieces of equipment in vinyl chloride service and the size
a nd ph ysic*al layout of the plant.
(vil It contains a definition of leak which is acceptable when compared 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 given plant m.iy vary among the different areas within* the plant and is also to change over i;-n,, us background concentrations in the
plant are reduced.
t
f
t t
i <
AP00018517
Federal Register / Vol, 50, No. 6 / Wednesday, January 9, 1985 /. Proposed Rules
1197
9. By revising paragraph (b)(4) to 8 81.65 as follows:
61.65 Emission aundsrd for athylene dlehloride, vinyl chlorid* end polyvinyl ehleridt plants *****
(b) Fugitive emission sources.
**
(4) Leaks from relief valves. Vinyl chloride emissions due to leaks from each relief valve on equipment in vinyl chloride service shall comply with 8 61.242-4 of Subpart V of this part a t 4
-*s
10. By revising paragraph (b)(7) t>{ S $1.65 as follows;
$ ei.CS Emission standard for athylene diehlertde, vinyl chloride and polyvinyl chloride plants.
*
(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. Sampling techniques are to be such that sample containers in vinyl chloride are purged into a closed process system.
Ut. By revising paragraphs (b)(8) introductory text. (b)(6)fii). and fb)(8;(v> to $ 61.63 as follows:
8 61.65 Emission standard for ethylene dlchlorlde, vinyl chloride and polyvinyl chloride plants.
* ** *
(b) Fugitire emission sources 0 ft
(6) Leak detection and elimination. Vinyl chloride emissions due to leaks from equipment in vinyl chloride service are to be minimized 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 of these regulations, unless a waiver of compliance is granted under | Gl.n. Approval of a program wiil be granted by the Administrator provided he finds.
(!) (iii It includes a reliable and accurate portable hydrocarbon detector to be used consistent wilh the provisions of Subpart V of this part. An owner or operator is exempt from I 61.242-1(0). 88 61.242-7 (a), (b) and (c). 8 61.246 and 8 61.247 of Subpart V of this part for any process unit in which the percentage or leaking valves is demonstrated to be equal to or less than 2.0 percent, es
determined in accordance with the
' 14. By revising paragraphs (g)(3)
following;
introductory text. (a){3)[i), and (g)(3)[iii)
(A) A performance test as specified in of 8 61.67 as follows:
paragraph (b)(8)(ii)(C) of this section
shall be conducted initially within 90 days of the effective date of these
8 $1.67 Emission tssU. 4
regulations, annully and at limes
(e) * * *
requested by the Administrator.
(3) When a stripping operation is used
(B) For each performance test, a
1 to attain the emission limits in i 61.64
minimum of 200 or 90 percent of the total (e) and (f), emissions are to be
valves in VOC service (as defined In
j determined using Test Method 107 as
8 60.481 of Subpart W of Part 60) within : follows;
the process unit shall be randomly
(i) The number of strippers (or
selected and monitored within 1 week
reactors using as strippers) and samples
by the methods specified in 8 61.245(d) and the types and grades of resin to be
of Subpart V of this part. If an
sampled are to be determined by the
instrument reading of 10,000 ppm or
Administrator for each Individual plant
greater is measured, a leak is detected. at the time of the test based on the
The leak percentage shall be determined plant's operation.
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 is detected, it shall be repaired in accordance with 8 61.242-7 (d) and (e) of Subpart V of this part.
(ii) *
(Sii) The corresponding quantity of material processed by each stripper (or reactor used as stripper) is to be determined on a dry solids basis end by a method submitted to and approved by the Administrator.
(D) The results of the performance test 4 *
shell be submitted in writing to the Administrator in the first semiannual report following the performance test as
part of the reporting requirements of
15. By revising paragraph (g)(5) introductory text and adding paragraph
(g)(3) to 8 61.67 as follows;
8 61.70.
61.67 Emission tests.
(E) Any process unit in which the
* *4
percentage of leaking valves is found to be greater than 2.0 percent must comply with all provisions of Subpart V of this part within 90 days. 4*4
(v) It contains a plan of action to bo taken when a leak is detected consistent with Subpart V of this part.
12. By revising 8 81.66 as follows:
Eg) " * *
(5J The reactor opening io68 for which an emission limit is prescribed in 8 61.64(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 based
on the plant's operation.
8 51.66 Equivalent equipment and procedure*.
Upon written application from an owner or operator, the Administrator may approve 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 these prescribed for compliance with a specific paragraph of this subpart.
IX By revising paragraph (1) of 8 65-67 as follows:
861.67 Emission testa* tti
(f) The owner or operator shall retain at the plant and make available, upon request, for inspection by the Administrator, for a minimum of 3 years, records of emission test results aha other data needed to determine emissions.
(6) For a reactor that is used as a stripper, the emissions of vinyl chloride from reactor opening loss and all sources following the reactor used as a stripper for which an emission limit is prescribed in 8 61.64(f) are to be determined. The number of reactors for which the determination is to be made is to be specified by the Administrator for
each Individual plant at the time of the determination based on the plant's operation.
(i) For each batch stripped in the 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
(Ct The reactor temperature f'C) at end of strip from plant instrument.
AP00018518
1
1198
Federal Resistor / Vot. so, No. 0 / 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 (mm Mg] of water in the reactor at end of strip from the following table:
escter temeara. era |'C]
H.O WOT
frJ*t
irm
ho K44CW* | *004 VtttT j F4*> HTsn* . &_'4 M* I'CJ ! ("*ni
1 H
e4ctor tteor tf-fniMr*. (UT4 1 Cl
M3 vapor PT9*. Sur4 {mm
40 993 41 96.3
42 61J 43 64.6 44 (11
48 71.9 ?I6
47 70S 41 S3.? 41 30 0
SO 92 5 St Hi
u 102.1 S3 10/2 $4 '2 9
99 118.0
M IMS 97 <29.8 94 138.1 S9 !U( 60 lift A
61 ! 1964
62 384.9
a 163.S
63 400.6
u 1714 64 ' 179.3 66 is?.9
416.9 9 433.9 M 4SQ.I
66 196 1
87 6fl.7
67 8099
86 467.1
86 2-4.2
9 906.1
99 . 2837
989.6
?c - 233.7
91 9460
71 2419
98 967 0
72 294 S 7J 235 7
93 SB8.6 W 109
74 2772 7 299 1 76 XI 4
VS 1 833 9 657.6 9? ' 882.1
77 V1
36 707 3
78 387.3
i 733.3
70 34' 0
ICO 780.0
<0 3$9.i , ,,w.
..
61 :s7
..........
(B) The partial pressure (mm ii^l uf \ inyi chiorida in reactor at end r.f strip from the following equation:
wvA-rw-nv -\piv
Wljorg: IspVC = paiTi.ll prison* 'i* \ isv! i.hlrKftltt. in
mnHg
"'tl---ntTn<l*p!Vtri- prwj*un* j D C. in nun I Iq
HV -- jbsrliile value ai iva tor vacuum, in mm H?
V1HVv^por p:*aure of water. in tnm Ha
(C) The reactor vapor space volume (m*) at end of strip from the follow ing equation:
mflVSV-.RC .IMV -
where:
RVSV reactor vapor spaca volume, m m* RC reactor rapacity. In m* WV volume of water tn reactor from re< :ipe.
in m* HVCWadry weight of pol>vio>l chluride in
reactor from recipe, in kg H31 * typical density of polyvinyl chluriile. In
lafro3
(iii) Fur each butch stripped in the reactor, the combined reactor opening less and emissions from ail sources following the reactor used as a stripper is to be determined using the following equation:
C-1PPMVC1U0-V
where:
C*g vinyl chloride/kg polyvinyl chlomie
product PPMVC-concentriition of vinyl chloride in
resin after stripping, in ppm 1(reconversion factor for ppm PPVC*partial pressure of vinyl chloride
determined according to paragraph (3)()UKB) of this section, in mm i-tg RVSV reactor vapor apace volume determined according to paragraph fgKWMC) of this section, in ra* l.(>02ideal gas constant In g--'K/r.vm H#-- tna for vinyl chloride l*VCW*lry weight of poivvinyl rhlnndi* in reactor from recipe, in ke 273 m conversion factor for 'C to 'K RT-=reactor temperature, in 'C
16. By adding paragraph fh) lo $ tii.7 ns follows:
(h)|l) Each piece of equipment within a process unit that can reasonably contain equipment in vinyl chloride service is presumed to be in vinyl chloride service unless an owner or operator demonstrates that the piece of equipment is not in vinyl chloride service. For a piece of equipment to be considered not in vinyl chloride service, it must be determined that the percent vinyl chloride content can be reasonably expected not to exceed 10 percent by weight for liquid streams and 10 percent by volume for gat streams. For purposes uf determining the percent vinyl chloride content of (he process fluid (fait Is contained in or contacts equipment, procedures that conform to the methods described in ASTM Method D-2267 [incorporated by reference as specified in S 61.131 shall be used.
(2)(i) An owner or operator may use engineering [udgmenl rather than the procedures in paragraph (h)(1) or this section to demonstrate that the percent vinyl chloride content does rot exceed 10 percent by weight for liquid streams and 10 percent by volume for gas streams, provided that the engineering judgment demonstrates that the vinyl chloride content clearly does not exceed 10 percent. When an owner or operator and the Administrator do not agree on whether a piece of equipment is not in vinyl chloride service, however, the procedures in paragraph (h)(1) of this section ahull be used to resolve the disagreement.
(ii) If on owner or operator determines that a piece of equipment is in vinyl chloride service, the determination can
(Ft>VC)(KVSV)(1.002)
tl'VCWHsn+RTl
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 lf) to | fU.03 as follows;
S 61.6t Emission monitoring.
(d) When exhaust gas(es). having <*rnission limits that are subject to tta* 1 equirement 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 baaed on the discharge duration and known VC concentrations in the affected equipment as determined in accordance with 561.07(h) of 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 cl lime that emissions were continuously monitorud and that omissions bypassed the continuous monitor) for purposes oi reporting excess emissions under 3 Hl^nfcUl).
<f) For each, vinyl chloride emission. 10 ihe atmosphere determined in accordance with paragraph (e) of this section lo be in excess of the applicable emission limits, the owner or operator ithall record the Identity of the sourcelst. the date, lime, and duration of the excess emissioa the cause of the mmsslon. the approximate total vinyl chloride loss during the excess emission, artd the method used for determining the vinyl chloride lass. This information shall be retained and made available fur inspection by the Administrator os required by $ 61.71(a).
' ~ 181 By changing the title from `Semiannual report*' lo "Reporting" ami hy revising paragraph (a) of | 61.70 as fellows:
|
I
| j lj __
AP00018519
T
Federal Register } Vol. 50, No. B / Wednesday, lanuary 9. 1985 / Proposed Rules_________1190
? 61.70 Reporting. (a)(1) The owner or operator of any
I (vinyl chloride content in the polyvinyl i-hlnriHo Potn " "T1
vinyl chloride concentration, as determined in this paragraph, in excess
source to which this subpart applies
of the limits prescribed in ft 61.64(e). The
shell submit to the Administrator on
vinyl chloride content found in each
i September 15 and March 15 of each vent (iii} The vinyl chloride content in each sample required by paragraphs (c)(2){i)
a report in writing containing the
sample is to be determined by Test
end (c)(2)(h) of this section shall be
information required in paragraphs, (c). Method 107 as prescribed in
averaged separately for each type or
(d) and (e) of this section and on
ft 61.67(g)(3).
resin, over each calendar day and
December 15 and June 15 of each year a
(iv) [Reserved]
weighted according to the quantity of
report in writing containing the
tv) The report to the Administrator by each grade of resin processed by the
information required in paragraph (e) of the owner or operator is to Include a
Btripperfs) that calendar day. according
this section, except as provided in
record of any 24-hour average resin
to the following equation:
* paragraph (a)(2).
^ (2) In the case of an existing source
' that submits semiannual reports on an
f approved fixed schedule other than
p#i.Woi+p#jAf8l+... i
'y September 15 and March 15, the ^approved semiannual reporting schedule
At<------ 5^---------------------- <*7,--------------
''snail be used to report the information
required in paragraphs (cj. (d) and (a) of
this section. In addition, the information where:
include a statement that excess
'required in paragraph (e) of this section 4 *24-hour average concentration of type. 7} emissions have not been detected.
will be reported exactly 3 months
resin in ppm (dry weight basis).
4
Hollowing the semiannual reporting plates.
(3) The first report is to be submitted following the first full 3 month reporting period after the initial report is Submitted,
^19. By revising paragraph (c)(l 1 uf
Q-Total production of type 71 resin over the 24-hour period, in kg.
7;--Type of resin: iml.2 . ./nwheremis
total number of resin types produced
during the 24-hour period. /./Concentration of vinyl chloride In one
scmple of grade G< resin, in ppm.
reproduction of grade C> resin represented
22. By adding paragraph (c)(4) to ft 61.70 as follows:
61.70 Reporting * 4
[Cj * (4) In polyvinyl chloride plants for
61.70 as follows:
hy the sample, in kg.
which stripping in the reactor is used to
61.70 Reporting.
Gi* C,\ule of resin: e g., C,-. Ct. and Cs-
attain the emission level prescribed in
.'=Tiul number of grades of resin produced ft 61.64(f). the owner or operator shall
curing the 24-hour period.
include in the report a record of the
(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 ft 61.62 (a) or (b). ft 61.83(a). or ft 61.64 (a)(1). (b), (c). or (d). or during
which average emissions are in excess
of the emission limits specified for nr.\
control system to which reactor
emissions are required to be ducted <n
ft 61.64(a)(2) or to which fugitive
i emissions are required to be ducted in
ft G1.65
(b)(2). (b)(5), (biiBp). c-r
| (b)(9)(H). If emissions in excess of the
emission limits are not detected, the
report shall contain a statement that no
f-xccse emissions have been detected.
The emissions are to be determined in accordance with { 61.68(e).
If no 24-hour average resin vinyl rhluride concentrations in excess of the limits prescribed in ft 61.64(e) are measured, the report shall state that no excess resin vinyl chloride concentrations were measured.
fvi| The owner or operator shall retain at the source and make available for Inspection by the Administrstor for a minimum of 3 years records of all data r.eeced So furnish the information required by paragraph (c)(2)(v) of this section. The records are to contain the following information:
(A) * (B| *
21. By revising paragraph (c)(3) of ft 61.70 as follows:
vinyl chloride emissions from reactor opening loss and si! sources following the reactor used as a stripper.
(ij One representative sample of
polyvinyl chloride resin is to be taken
from each batch of each grede 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 is to be
recorded and identified by resin type
and grade and the date and time the
batch is completed.
(11) The vinyl chloride content in each
sa mple is to be determined by Test
Method 107 as prescribed in ft 61.67(g)(3),
(iii| The combined emission from
20. By revising paragraph (c)(2) introductory text, removing paragraphs (c)(2)(iv), revising paragraph (r|(2l(iii) and revising (e)(2)(v) and (cj(2)(vi)
ft 61.70 Reporting.
**4
(C) *
reactor opening loss and ail sources following the reactor used as a stripper are to be determined for each batch stripped in a reactor according to the
introductory text to ft 81.70 as follows:
(3) The owner or operator shall
procedure prescribed in ft 61.67(g)(6).
include in the report a record of any
(iv) The report to the Administrator by
5 61.70 Reporting.
emissions from each reactor opening in the owner or operator is to include a
*
excess of the emission limits prescribed record of any 24-hour average combined
(<->** (2) In polyvinyl chloride plants for ,, which a stripping operation is used to
. attain the emission level prescribed in '".ft 61.64(e), the owner or operator phnll Conclude in the report a record of tht-
)
/
in ft 81.64(a)(2). Emissions are to be determined in accordance withft 61.67(g)(5), except that emissions
for each reactor are to be determined. If emissions in excess of the emission limits are not detected, the report shall
reactor opening loss and emissions from all sources following the reactor used as a stripper as determined in this paragraph, in excess of the limits
prescribed in ft 61.64(0- The combined reactor open inn loss ar.d emissions from
A*
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Federal Register / Vol. 50. No. 6 / Wednesday, January 9. 1985 / Proposed Rules
all sources following the reactor used as a stripper associated with each batch are to be averaged separately for each type of resin, over each calendar day
anil weighted according to the Quantity
of each grade of resin stripped in reactors that calendar day as follows:
Far each type of resin (suspension, dispersion, latex, bulk, other], the
following calculation is to he performed:
n z Pr cr
A W G1G1
Pr Cf. ^ Ql G1+
4>
Where:
A-24-hour average combined reactor opening loss and emissions from hU sources following the reactor used as a stripper in g vinyl chinridtf/kg product (dry weight basis).
Q--Total production of ream tn batches for which stripping is completed during the 24-hour period in kg.
C --Average combined reactor opening lass and emissions from ail sources following the reactor used as a stripper of ail batches <>(grace G, rr'in for which stripping is comnicied during the 24-hour period in % vinyl rMorice/kg product (dry weight basis) idff'.annirad Hocording to procedure prescribed in $ rJUTfsHS)).
P-Productton of grade G, resin in the batches for wnich C is darermined. in kq.
Ci-Grade of resin: s.g.. Gi. Ca. ana C. n--Total number ci grades of resin in batches
for which stripping is completed during the 24-hour period.
If no 24-hour average confined reactor opening iosa and emissions from ail sources following the reactor used a stripper in excess of the limits prescribed in g 61.64(f) are determined, the report shall state that no excess vinyl chloride emissions were determined.
23. By adding paragraphs id). (?) end (0 fo g C1.70 as follows:
61.70 Reporting. ** V
(d) The owner or operator shall include in the report a record of relief
valve discharges as prescribed in 5 51.65(a)(4). end the owner or operator shall report exceedences of the relief valve discharge frequency limits prescribed in i 61.65(a) to be determined as follows:
(1) For polyvinyl chloride plants producing d'spersion. latex or bulk resins, the raiief valve discharge frequency from polyvinlv chloride reactors is to be determined tiling the fallowing equation. Separate calculations are to be marie for each resin type {t| as defined:
N
Where Fi relief valve discharge frequency per 100
polymerization batches from all renrtnr* producing reslng type t V--total number of relief valve discharges during the 12-month period preceding the close of the 6-month reporting period from all reactors producing r*$:n type i V -- total number of polymerization batches oi resin type t during the 12-mrv.h period preceding the dose of the e-month reporting period divided by 100 i*resin type: dispersion (including UreiJ rr bulk resin type
|2) For polyvinyl chloride plants producing suspension resins, the relU*f valve discharge frequency from polyvinyl chloride reactors is to be determined In two ways using the following equations:
P,, - --N ; an* f,, H
where
K,,,--relief valve discharge frequency per too
polymerization batches from all reactor*
producing suspension resin
Ft - relief valve discharge frequency per 12-
mouth period from all reactors producing
suspension resin
N * total number of relief valve disi-harqua
during the 12-month period preceding the
close of the 6-month reporting period
From dll reactors producing suspension
resin
Y - total number of poll irerrzation
t
suspension resin during (ho 12-r**.:u ih
period preceding the dose of the 6-tnomh
reporting period divided hy 100
13) For polyvinyl chloride plants
producing suspension, dispersion. I.riev or bulk resin*. the rrliuf valve d'scli.uqe
frequency from all other equipment (excluding polyvinyl chloride reactors) is to be determined in two wavs using the following equations:
N F, --; and F -- N
r
where
F*,,sa-CQlt:f vslv* discharge frequency p-r urn polymerization batches from ail equipment (excluding reactors)
F, - relief valve discharge frequency per 12month period from all equipment (excluding reactors)
V-total number of relief valve discharges during ths 12-month period preceding the close of the 6-month reporting period from all equipment (excluding reactors!
Y -.total number of polymerization batches of nil resin types combined divided hy 100
H) For polyvinyl chloride plants using the solution process or any other continuous production process, the re!:.! 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 6-month reporting period.
(0) For ethylene dichloride/vinyl chloride plants, the relief valve
discharge frequency is the summation oi uadi relief valve discharge trom ali equipment types during the 12-month
period preceding the close of the 8* month reporting period.
(81 A polymerization batch consists of (inch sequence of charging VC and other materials to the reactor, heating react.tr contents, polymerization of reactor concents, and removal of reactor contents including any incomplete sequence that is aborted after charq r.g VC to the reactor. For bulk resin production plants, a single "polymerization batch" Includes both prepoiymerizatlon and potftpnlymerizalion reactor operations
(ul The owner or operator shall include in the report the number of mJ-Vi
valve discharges to the atmosphere during the 3-month period preceding iut> report from each of the following
sources: suspension resin production reactors: dispersion and latex renin production reactors: bulk resin production reactors: all nonreactor vquipmunt in PVC plants: all equipment used in solution process and other ,:i;:ttinu,iu process PVC plants: And ail equipment in EDC/VC plants: any other source.
if) The owner or operator shall include in the report the number of reactor openings and the design impurity of the number of polvmunzatlon batches for each tvpi* <f renin in each plant during the 6-momn period pr eceding the report. The design capacity of the number of polymerization batches may be defined
{ 1 ir.
I<
!5
u rr I 1
1
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AP00018521
Federal Register / Vol. 5n. Mu. b I Wednesday, January y. 1985 / Proposed Rules
'Uin!ly and remain unchanged uniat*. ' gnificant changes to the design ..polity occur.
. 24. Rv revising paragraph (aj '"mjciuctory text of $ 91 71 n* Ibhe^
? 61.71 Seeordkeeplng.
(a) The owner or operator ol atit, (Hirce to which this subpart applies `.fialt retain the following information ai -he source and make it available for fispection by the Administrator tor a inimumof3years:
*4
55,`By adding the words "vinyl -.loride" to the definition of the term oSiitile hazardous air pollutants** in 1 ti.241 of Subpart V as follows
$61,241 Definitions.
* Volatile hazardous ait yotk:i; i.t' o< ''Vf f \P`* means a substance rerr.ilalod unci, this part for which a siandaicl fo<
equipr.rr.l leaks of the substance has been proposed and promulgated Benzere * a VHAP. Vinyl chlorine .s *
VHAP.
(Sec . Cli-.in Air Act of 1C(h
(FR l)i..
Filed 1-a-a.'- S'-ie m-:
hum ecu
1201 *
AP00018522