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AQC 73-1 Manufacturing Chemists Association Minutes of Meeting AIR QUALITY COMMITTEE Landmark Inn Atlanta, Georgia April 25-26, 1973 MEMBERS PRESENT-. J. H. Huguet, CHAIRMAN M. B. Tohline, VICE-CHAIRMAN I. L. Alexander for J. G. Brown M. V. Anthony W. B. Barton C. B. Beck Z . G. Bell, Jr. w. F. Bixby w. R. Chalker D. G. C larke D. B. Coghlan B. W. Eley for E. P. Wheeler H. R. Guest, Member Alternate E. M. Ilgenfritz for R. E. Reinker G. J. Kauffman for A. H. Phelps D. J. Heilman for R. E. Chaddock E. D . Lemon *w. L. Mann R. L. Maycock P. W. McDaniel M. G. Morris E. G. Opdyke J. W. Pervier T. H. Rhodes L. W. Roznoy W. R. Taylor Ethyl Corporation Mobil Oil Corporation AMAX - USMR Stauffer Chemical Company Borden, Inc. Cabot Corporation PPG Industries, Inc. B. F. Goodrich Chemical Company E. I. du Pont de Nemours & Company Rohm and Haas Company Foote Mineral Company Monsanto Company Union Carbide Corporation The Dow Chemical Company The Procter & Gamble Company Hercules Incorporated United States Borax & Chemical Corporation N L Industries, Inc. Shell Chemical Company Union Carbide Corporation Hoppers Company, Inc. Kay-Fries Chemicals, Inc. Air Products and Chemicals, Inc. Exxon Chemical Company U.S.A. 01in Corporation Diamond Shamrock Chemical Company CMA 086091 F . W. Velguth C. R. Walbridge Jerome Wilkenfeld K. D . Johnson, SECRETARY J. P. Turner GUESTS PRESENT: J. A. Evans R. E. Farrell MEMBERS ABSENT: J. S . Eckert R. H. Mansur S . N. Robinson J. H . Rook J. C. Schwegmann J . D. Underwood AQC 73-2 CPC International Inc. Allied Chemical Corporation Hooker Chemical Corporation MCA Staff MCA Staff Shell Oil Company Vistron Corporation Norton Chemical Process Products/Division of Norton Company Reynolds Metals Company Mallinckrodt Chemical Works American Cyanamid Company Kaiser Aluminum and Chemical Corporation Celanese Corporation 1. Minutes of the Meeting of January 24-25, 1973 There being no additions or corrections offered to the subject minutes, they were ordered approved as distributed. 2. Membership - Secretary The Committee was informed of the approval by the Board, at their February 13, 1973 meeting, of the nom inations of Messrs, J. D. Underwood and R. E. Reinker. Mr. R. E. Farrell, of The Standard Oil Company (Ohio), was introduced to, and favorably received by, the Committee. His nomination will be forwarded to the Board with the Committee's recommendation for approval at the earliest opportunity. CMA 086092 AQC 73-3 3. Liaison with MCA Board - Mr. Tohline Mr. Tohline, who had represented the Committee at the last meeting of the Board Liaison Committee for Environmental Quality and Control, reported that the Liaison Committee had expressed a willingness to provide greater Board support for MCA's technical committees. He expressed his disappointment that more of its members did not participate in the Liaison Committee's activities. 4. AQC Budget for Fiscal 1974 - Chairman Mr. Huguet reported that he had been informed by Mr. Driver that the Committee project for consultative support in the area of photochonica1 oxidants was slated for Board approval. The Committee's recommendation that MCA support the ASTM Project Threshold - Phase II, in the amount of $25,000 has been disapproved. The Chairman expressed his approval of the MCA decisions. 5. Status Reports on Existing Special Projects 5.1 A. D. Little Odor Research Project CMA086093 The Secretary reported that he had not yet been able to arrange a schedule for a conference with Mr. Kendall because of conflicts in travel schedules. Dr. Bell and the Secretary will attempt to schedule such a conference as soon as possible, and will make every ef fort to secure early submission of the two reports now overdue: (1) a consolidated report on odor threshold measurements, combining the results of the first four years' study, and (2) a final report on the last year and a half's work on physiological responses to odor stimuli, 5.2 Joseph Coon's Paper on Plume Visibility The Secretary noted that the final draft of this paper was now undergoing staff review, and was expected to be approved shortly for submission to the printers. 6. Report from Petrochemicals Advisory Committee Messrs. Pervier and Guest Mr. j. W. Inc. , submitted various studies contract: Pervier, of Air Products and Chemicals, the following chart of the status of the completed or in progress under their EPA r AQC 73-4 Status of Contract 1)8-02-0255 Chemical Screening Study Acetaldehyde via ethylene via ethanol Acetic acid via methanol via butane via acetaldehyde Acetic Anhydride Acrylonitrile Adipic Acid Adiponitrile via butadiene via adipic acid Carbon Black Carbon Disulfide Cyc Lohexanone Dimethyl Terephthalate (+ TPA) Ethylene Ethylene Dichloride via oxychlorination via direct chlorination Ethylene Oxide Formaldehyde - silver catalyst - iron oxide catalyst Glycerol Hydrogen Cyanide Isocyanates Maleic Anhydride Nylon 6 Nylon 6,6 Oxo Process Phenol Fhthalic Anhydride High Density Polyethylene Low Density Polyethylene Polypropylene Polystyrene Polyvinyl Chloride Styrene Styrene-Butadiene Rubber Vinyl Acetate via acetylene via ethylene Vinyl Chloride Complete Complete Complete Not Required Complete (2) Complete (3) Complete (3) Not Required In Progress Complete (2) In Progress Complete (2) Not Required Not Required Complete (3) Not Required Complete (2) Comp!ete In Progress In Progress Complete Complete Complete Not Required Complete (2)' Complete (2) Complete Complete (3) In Progress In Progress Complete In Progress Complete (2) 1 ** NOTES (1) In-depth study scheduled, (2) Discussed publicly March 22, 1973. (3) Scheduled for public discussion May 3, 1973. April 24,' 1973 In-Depth Study Complete (3) Complete (2) Complete In Progress In Progress In Progress d> In Progress CMA 086094 AQC 73-5 The written reports of Mr. Guest on the March 22 meeting have been distributed directly to the Air Quality Committee; the next meeting is scheduled for May 3, 1973. Mr. Guest reported that EPA has made the decision to designate the manufacture of formaIdehyde as a process for which standards of performance are to be promulgated pursuant to section 111 of the Clean Air Act. Mr. Bixby reported that EPA has let a contract for a "tota1 environmental impact" study of the butadienestyrene rubber industry. 7. EPA Strategies for the Control of Organic Emissions R. L. Maycock Dr. Maycock recounted the history of present nego tiations of industry with EPA concerning possible re visions to the organic emissions standards suggested in "Appendix B" of the August 14, 1971 promulgation of "Requirements for Preparation, Adoption, and Submittal of Implementation Plans." At a meeting held in Durham last November 22, attended by delegations from both the MCA and the National Paint and Coatings Association, it had been pointed out to EPA that the needs of the chemical industry were not necessarily met by options that might be adequate to meet those of the paint industry. Given a reasonable list of approved solvents, the latter might avail themselves of alternate formulations"for their products, but the chemical industry requires rules per mitting rational handling of the solvents and volatile organics that are their primary products. In pursuing this subject further, an MCA delegation, with Dr. Larry Faith present as our consultant, had met with EPA representatives on February 27, 1973. At that time, favorable consideration was given to a concept proposed by our delegation that, rather than a narrow list of "exempt" solvents, with all others subject to very rigid, uniform restrictions, a control scheme be based upon the concept that a graded series of controls be established to be applied to organic emissions to a degree proportional to their photochemical reactivity. At the invitation of EPA, Dr. Maycock prepared an extensive list of volatile organic compounds of commercial importance. Copies of this list were distributed to the members of the Committee, and he asked them to review this list and suggest additions or deletions. CMA 086095 ----- T........ AQC 73-6 Discussions are continuing between MCA and EPA to develop criteria for the division of candidate chemicals into categories based upon photochemical reactivity, test methods for determining the classifi cation of compounds of presently unknown photochemica1 reactivity, and control schemes appropriate to such cla sses. 8. DuPont Draft of CEP Report on Economic Impact of Sulfuric Acid Plant Controls The Secretary relayed the request of Mr. James Parsons, author of this draft, for prompt submission of comments and corrections from those to whom he had sub mitted review copies. 9. Recent Developments in Small Particle Control Technology 9.1 Pentapure Scrubber - Mr. Lemon Mr. Lemon reported that he had visited the plant of the manufacturer, and had observed operation of a pilot scale unit in a test in which a gas stream bear ing 5-3 grains/scf of redispersed bag house dust had been cleaned to 0.001 gr/scf. Security restrictions (during pendency of patent negotiations) prevented him from describing the design of the unit, but he expressed optimism that the device would prove to'be a significant development in particulate control technology. 9.2 Aronetics "Apitron" Scrubber - Mr. Beck Mr. Beck described this as a modified ven ture in which both the gas flow and the high relative velocities of particulates and water droplets are achieved by partial flash evaporation of superheated water in a two-phase flow nozzle at the throat of the venturi. As the water is heated by the hot, dirty process gas, fouling of heat exchange surfaces in the waste heat boiler is a major problem. 9.3 Petersen Separator - Mr. Walbridge device. No performance data were available on this CMA 086096 AQC 73-7 9,,4 Other Developments Mr. Kauffman (of Procter & Gamble) briefly described a new scrubber thar had proved effective in removing fatty materials from waste gases in a detergent manufacturing process. These had proved very trouble some with conventions 1 devices because of their tendency to clog them. A recent development at. John Manville for cleaning high temperature gases was also called to the attention of the Committee, which expressed an interest in being kept informed as operating experience was gained with these devices. 10. Technical Seminar on Air Pollution Control Technology The Secretary reported on the cancellation of the Houston seminar for lack of adequate registration. He indicated that a renewed effort would be made to pub licize the fall session (September 10-14 in Chicago). In the absence of strong support for this meeting, he said that MCA would urge this program be discontinued. The Committee expressed hope that a successful and useful seminar program could survive, but agreed that, lacking industry support evidenced by student registrations, the Committee ought not place itself in the position of trying to promote further seminars. 11. Report from r.he Joint Subcommittee on Environmental Law - Mr. Evans ,, Mr. Evans discussed the concern of the Subcommittee with the failure of EPA to give consideration to statutory requirements for consideration of factors of economics and technologica1 feasibility in the standards they were promulgating or encouraging the states to adopt. Standards recently proposed and/or adopted by the state of Illinois . were given particular mention. He mentioned potential avenues for judicia1 challenge of such standards on these grounds. Items of common interest to both the Air Quality Committee and the Joint Subcommittee on Environmental Law, and potential topics for consideration at the joint session of these two groups next October (see paragraph 18.2 of these minutes) were reviewed. The presentation of selected case histories of enforcement cases seemed to be of par ticular interest. CMA 086097 AQC 73-8 The chairman appointed Dr. M. V. Anthony as Chair man of a task group to work with the JSEL Chairman in Developing a suitable program for the joint session. 12. Emergency Releases for Chemical Process Operations Mr. Clark for Mr. Paist In the absence of Mr. Paist, his alternate, Mr. Clark, reported on the progress made by the task group assigned to this problem. They are developing proposed guidelines for equipment designers in the provisions they make for emergency releases. At least one more draft of these guidelines will be subjected to task group review before they are ready for distribution to the Committee. 13. Toxic Substances Legislation The Secretary reported on current developments on pending legislation. MCA`s President Driver had testified at both House and Senate hearings on March 16 and March 21, respectively. Copies of MCA statements have been made available to the Committee. Neither subcommittee had yet reported out a bill. 14. Site Selection Workshop Dr. Anthony reported the favorable consideration of the proposed workshop by the intercommittee task group studying the concept. Efforts will be made to secure the active collaboration of these other committees (Water Resources, Solid Wastes, Public Relations, and Industrial Relations) in developing a program for the workshop. 15. Report from the Public Relations Department Mr. Turner After summarizing the Public Relations Department's current activities of interest to the Committee, Mr. Turner discussed the proposal to broaden the case history reports to cover safety problems, as proposed in Mr. Richard Blewitt's letter of April 16 to the Committee. Among the developments indicating wider public awareness of the need to balance equities in arriving at environmental management decisions, he noted the formation CMA 086098 AQC 73-9 of the Council for Environments 1 Balance, the tone of the President's message on energy and the environment, and the activities of the Nations 1 Environments 1 Development As sociation . 16 . Chemical Safety Data Sheets The comments of Mr, R. J. Brenner. Mobil Chemica11s Manager of Environmental Controls, in regard to the failure of certain MCA safety data sheets to recognize regulation requirements in the handling and disposa1 of chemicals and waste materials, was brought to the attention of the Com mittee. Although MCA and its committees cannot, be expected to maintain an awareness of regulatory requirements in all state and local jurisdictions, our members, in the prepa ration of Chemical Safety Data Sheet sections on handling and waste disposal, should be careful not to imply sanction of practices that may be in violation of loca1 regulations. In questionable cases they should alert the reader to the possible existence of specific regulatory requirements that may conflict with MCA 1s genera 1 recommendations. 17. Liaison Reports '' 17.1 American Petroleum Institute - Mr. Tohline Mr. Tohline's report of API projects of interest to the Committee is distributed as.an enclosure with the mailing of these minutes. 17.2 Intersocietv Committee on Methods of Air Sampling and Analysis PPG has again offered to have one of their staff men cover the next meeting of the Committee as an MCA observer. His report will be distributed to the Air Quality Committee when received. 17.3 American Institute of Chemical Engineers The following excerpts from the AIChE's "Goals for 1973, " relating to their effort to increase their interaction with the federal agencies and their views on the energy crisis, may be of interest to the members of the Air Quality Committee: CMA 086099 AQC "3-10 INCREASE OUR INTERACTION WITH THE FEDERAL GOVERNMENT VIA a) making significant, progress in the AID/LIFE Project b) transmitting a completed report on "Moti vation Techniques for Pollution Control" c) transmitting a status report on what has already been accomplished in "Technology Transfer" d) developing a strategy and action plan for transmitting a 197 4 report on "Testing Procedures for Pollution Control Equip ment" e) presenting at least 10 different federal "testimonies of record" by Division mem bers (identified as such, but acting as independent professional (s) , The current fuel crisis, which has hit many parts of the nation this winter, at least a year earlier than was anticipated, points up in just one more way the inter-relationship of all aspects of environmental problems,, It shows again not only that an interdisciplinary approach to problem solution is needed, but also that an overall long-range systems ap proach and evaluation is a necessity. The fuel crisis has, in part, been brought on by the conversion of combustion operations from high sulfur coal to natural gas and low sulfur fuel oil. Now it becomes apparent that these moves represented purely short-range and tem porary expedients to solving pollution problems It is time, in fact past time, to make a long-range appraisal of our pollution problems and of our resources - of energy, minerals, manpower, and production and financial capa bility - and to adopt a program that does not have to continually shift gears or change direc tions. CMA 086100 AQC 73-11 The energy situation emphasizes the need for non-polluting methods of using our vast coal reserves, since these are the only cur rent energy sources rather rapidly available in adequate quantity, it also points to the longer-range need of developing a non-pollut ing energy source which could be made avail able all over the world in abundant quantity. Perhaps this means we must put greater emphasis on research into more practical methods of utilizing solar radiation and recovery of waste energy. In the area of manpower and production facilities, it appears that we need to consider regulatory timing commensurate with engineer ing manpower and facilities available for production of control equipment. A little thought here indicates that neither the manpower nor the production facilities are available to convert every power-generating station in the country to pollution-free op eration within a period of two years. ' And last, but certainly not least, we as members of the technica1 community shouId be hard at work looking for aIternate routes and better ways to apply processing technology in a non-polluting manner. Anaconda has been much In the news this past week in regard to their plans to use a new solvent refining method for copper ore. Instead of roasting the sulfide ore as in the past, which releases SO2 to the atmosphere, they will use a liquid proc essing technique which extracts copper from the ore by solution. While the technique is not really new, this is apparently the first time it has been considered as a means of preventing pollution on a large scale. If Anaconda has also been successful in preventing formation of water pollutants, it should certainly be a step forward. This is an example of the types of alternate processing techniques that we must be considering and developing. CMA 086101 AQC 73-12 Mr. Huguet summarized the scheduled program of the Institute, including both meetings and training sessions, pertinent to air pollution controls. 17.4 Air Pollution Control Association The annual meeting is scheduled for June 24 29 in Chicago. No major sessions appear to be of partic ular Interest to the chemical industry- 17.5 U. S. Environmental Protection Agency EPA schedules (as of February 1973) of interest to the Air Quality Committee are listed below (1) Revision of National Secondary Ambient Air Quality Standards for Sulfur Dioxide Publish proposed revisions - April 1973 Promulgate final revisions - July 1973 (2) Standards of Performance for Groups II and III Industrial Facilities Publish proposed Group II standards March 1973 Publish proposed Group III standards July 1973 Promulgate final Group -II & III stan dards - October 1973 (3) NationaI Emission Standards for Haz ardous Air Pollutants Publish final standards for mercury, beryllium, and asbestos - March 1973 18. Future Meeting Plans CMA 086102 18.1 Field Trip to TVA SO2 Control Project The Secretary reported that he had been informed by TVA that it would be two to three years before the full scale demonstration project on S02 control by limestone injection and wet scrubbing would be operat ing . The Committee agreed to postpone consideration of a field trip in conjunction with a southeastern meeting until a more firm estimate could be obtained on the time of completion of the project. --T AQC 73-13 18.2 Fall Meeting 1973 The Committee agreed to schedule its fall meeting in Washington, D. C., on Wednesday and Thursday, October 10 and 11. The Secretary was instructed to invite the JSEL to meet concurrently with us, and to schedule a half-day of joint sessions and a joint lunch eon on Thursday, He was also asked to select a suitable member of the EPA legal staff to be our luncheon guest and to address the group. 18.3 Winter Meeting 1974 In response to a strong expression of interest by members of the Committee in a visit to the Las Vegas facilities of the National Environmental Re search Center, the Chairman appointed a Task Group (Bailey Barton, Chairman, M. V. Anthony, and L, W. Rosnoy) to submit recommendations concerning the pos sible reconsideration of the previous decision to meet in Research Triangle Park, North Carolina, and the sub stitution therefor of a meeting in Las Vegas. The Task Group subsequently reported with a recommendation that the Committee meet on February 13 and 14, 1974, in Las Vegas, Nevada, with a visit to the National Environmental Research Center there. The Committee strongly supported this recommendation, and asked the Task Group to submit written justification for this site to permit MCA man agement to judge the need to make an exception to" the general rule against committee meetings in ''resort" areas. - Respectfully submitted. Kenneth D. Johnson, Ph.D. Secretary Air Quality Committee Minutes Subject to Approval September 26, 1973 KDJ:mb Distribution "C" Attachment CMA 086103