Document DGNXEeE2wYq9eNE5E2k8qb4ZN

UNION CARBIDE CORPORATION PERFORMANCE CHEMICALS AND POLYMERS DIVISION 19206 Hawthorne Boulevard, Torrance, CA 90503 (213) 772-6435 RECEIVED MAR 1S '9&0 R. N. Wheeler, Jr. Mr. A. S. Amatangelo Union Carbide Corporation 270 Park Avenue 33 Floor New York, NY 10017 March 11, 1980 FILE COPY DO h r Subject: Proposed Vinyl Chloride Rule Promulgation 1005.1 South Coast Qir Quality Management District Dear Tony: For your information, I have attached a copy of the oral testimony given to the Air Quality Management District Board on March 7, 1980. Nick Wheeler accompanied me and has given an immense amount of help with preparation of written submissions and strategy development. He deserves a lot of credit for his expert help. Also, attached is a listing of the Board Members and a summary of the rule. Unfortunately, Board Member, Mrs. Gladys Meade from the Lung Association, lives in Torrance. The hearing ended with a one-month reprieve on a decision. The Board has decided to visit the affected plants before the next meeting, April 4, when a vote will be taken. (Mrs. Meade entered a motion to pass the rule, as written, hut later withdrew her motion when the plant visits were suggested). We will do our best to favorably impress the Board when they visit. Now, more is to cornel The District has decided to rewrite and tighten up on the base rule 1005. They have scheduled a work shop meeting for March 13. Our sales force and RTM's are continuing to pursue "VACA" business in this region. I would like to see the business team address the advisability of this "thrust" in view of the.Districts hard stance against vinyl chloride. The factors to consider are: QUALITY EMULSION POLYMERS Mr. A. S. Amatangelo March 11, 1980 Page -2- a. Are we willing to make the investments required by 1005.1? b. If our Western Region VACA business continues to grow, we will need another VACA Reactor System. Are we willing to replace the No. 3 line cooling tank? c. With little room for error in violating the Dis tricts rules, is Union Carbide willing to accept adverse publicity, if some mishap'occurs? d. What will the next rule be? May I have some comments on your views? Very truly yours, a G. W. Sanders GWS/bd Enclosures cc: Dr. T. L. Dawson - So. Chas. 720-126 Mr. K. J. Hutchinson - New York - 33 Mr. P. J. Johnston - New York - 33 Mr. G. L. Miller - So. Chas. 2000-3331 Mr. K. G. Morlock - Alsip Mr. E. L. Peterson - New York - 33 Mr. R. N. Wheeler - So. Chao - 3005-210/511 / SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT BOARD Mr. Philip L. Anthony Supervisor, County of Orange 10 Civic Center Plaza Santa Ana, CA 92701 P. 0. Box 687 (Mailing Address) Santa Ana, CA 92702 714/834-3110 Alternate: Mr. Paul Raver 714/834-3831 - Mr. Marvin Braude Councilman, City of Los Angeles 200 North Spring Street, Room 275 Los Angeles, CA 90012 213/485-3811 Ms. Yvonne Braithwalte Burke Supervisor, County of Los Angeles Hall of Administration - Room 822 500 West Temple Street Los Angeles, CA 90012 213/974-1044 Alternate: Ms. Julie Mulvaney 213/974-4444 Mr. Lionel E. Hudson* (representing cities of Riverside and San Bernardino Counties) Lung Association of San Bernardino County 371 West 14th Street San Bernardino, CA 92405 714/884-5864 Mr. A. A. McCandless (Chairman) Supervisor, County of Riverside P. 0. Drawer 1330 Indio, CA 92201 714/342-8211 - Indio J 714/787-2840 - Riverside Alternate: Supervisor Norton Young!ove | 4080 Lemon Street -14th Floor 1 Riverside, CA 92501 f Mrs. Gladys Meade (Public Member) The California Lung Association 1670 Beverly Boulevard Los Angeles, CA 90026 213/484-9300 ' ; Mr. Dennis Hansberger Supervisor, County of San Bernardino Civic Center Building 175 West Fifth Street San Bernardino, CA 92415 714/383-2911 Alternate: Supervisor Robert Townsend 714/383-2713 Mr. Robert Rigney 714/383-1718 Dr. Thomas F. Heinsheimer, Vice Chairman*** (representing cities, Los Angeles County) Director, ATMOSAT Office The Aerospace Corporation 2350 East El Segfundo Boulevard El Segundo, CA P.0. Box 92957 (Mailing Address) Los Angeles, CA 90009 213/648-5171 Mr. Don R. Roth** . (representatlng cities of Orange County) 1000 East Lincoln Avenue - (Office) : Anaheim, CA - 92806 * 1 P. 0.-Box 3222 - (Anaheim City Hall) | Anaheim,- CA *92806 - 1 714/533-5611 (City Hall) or 714/772-1691(off' Mr. Peter F.. Schabarun Supervisor, County of Los Angeles Hall of Administration, Room 856 500 West Temple Street -- Los Angeles, CA 90012 213/974-1011 Alternate: Mr. Relne J. Corbell 18 Aurora Drive Rolling Hills Estates, CA 213/326-9551 - (home) 213/539-5641 - (office) 9027 * Councilman, City of San Bernardino ** Councilman, City of Anaheim Councilman, City of Rolling Hills June, 1979 - ucc 022554 MY NAME IS GLOVER SANDERS. I AM PLANT MANAGER OP UNION CARBIDE CORPORATION'S LATEX PLANT IN TORRANCE. I HAVE MANAGED THIS PLANT FOR SIX YEARS AND HAVE BEEN A RESIDENT OP LQS ANGELES COUNTY FOR 14 YEARS. WE HAVE PREPARED WRITTEN COMMENTS ON THE PROPOSED RULE, WHICH I AM PROVIDING THE BOARD. TO CONSERVE THE BOARD'S TIME, I WILL DISCUSS ONLY THE HIGHLIGHTS ' OF THE WRITTEN SUBMISSION. THE UNION CARBIDE PLANT IS LOCATED ON A ONE ACRE SITE. WE EMPLOY 34 PEOPLE AND OPERATE FIVE DAYS A WEEK TO PRODUCE 34 DIF FERENT PRODUCTS TOTALING LESS THAN 30,000,000 POUNDS PER YEAR. THE PLANT IS LOCATED IN CALIFORNIA TO SUPPLY BASIC LATEX MATERIALS FOR WATER BASED PAINTS, SEALANTS, CAULKS, ADHESIVES, AND TEXTILE TREATMENTS. USE OF WATER BASED POLYMERS BY OUR CUSTOMERS REDUCES HYDROCARBON EMISSIONS WHICH CAUSE SMOG. VINYL CHLORIDE IS USED IN 25% OF OUR PRODUCTS TO SECURE CER TAIN DESIRABLE PROPERTIES, SUCH AS TOUGHNESS AND WATER RESISTANCE. WE RECOGNIZE THE HAZARDS OF WORKING WITH VINYL CHLORIDE AND HAVE INVESTED OVER $400,000 TO CONTROL VINYL CHLORIDE EMISSIONS IN A PLANT THAT COST SLIGHTLY OVER $2,000,000 TO BUILD. WE HAVE PROVIDED THE BOARD'S STAFF WITH COMMENTS ON EACH DRAFT OF THE PROPOSED RULE. THE STAFF HAS ACTED IN MAY CASES TO IMPROVE THE PROPOSAL. DESPITE THIS COOPERATION, WE BELIEVE THE PROPOSED RULE CONTAINS IMPERFECTIONS AND UNDULY PENALIZES OUR SMALL BUSINESS OPERATION. AS MANACZR OF THIS SMALL POLYMER PLANT, I AM IN THE SAME POSITION AS THE MANAGER OF ANY SMALL BUSINESS. I MUST MAINTAIN A PROFITABLE BUSINESS WITH LIMITED RESOURCES. I AM HERE TODAY TO ASK FOR A REVISION TO PARAGRAPH (i) AMBIENT AIR MONITORING THAT WOULD EXCLUDE OUR PLANT.FROM THE EXPENSIVE AMBIENT AIR MONITORING REQUIREMENTS OF THIS PROPOSED RULE. OUR PLANT IS SMALL IN SIZE AND HAS LOW POTENTIAL FOR VINYL CHLORIDE EMISSIONS. THE DISTRICT'S MONITORING VAN SAMPLED OUR FENCE LINE FOR TWO MONTHS. ALL SAMPLES WERE UNDER THE 10 PPB LIMIT. OUR PLANT ALREADY HAS AN AUTOMATIC AIR MONITORING SYSTEM THAT MONI TORS 19 POINTS IN OUR PLANT ON A CYCLED TIME INTERVAL. THIS ANALYZER GIVES '"REAL-TIME" DATA FOR ANY LEAK THAT MIGHT OCCUR AND PROVIDES AN ALARM FOR PLANT OPERATORS TO TAKE CORRECTIVE ACTION. WE BELIEVE THIS ANALYZER ENSURES OUR COMPLIANCE WITH THE ucc 022555 -2- CALIFORNIA AMBIENT AIR QUALITY STANDARD. THE 10 PPB 24 HOUR BAG SAMPLES SPECIFIED BY THIS RULE WOULD REQUIRE OUR SMALL PLANT TO INVEST $50,000 IN LABORATORY FACILITIES AND EQUIPMENT, AND EMPLOY AN ADDITIONAL ANALYST TO DO. THE MONITORING FOR $30,000 PER YEAR ADDITIONAL COST. THE ONLY FUNCTION THIS ANALYZER WOULD PERFORM IS TO DOCUMENT A 24 HOUR SAMPLE THAT OCCURRED YESTERDAY. WE BELIEVE OUR PRESENT COST EFFECTIVE CONTROL?'PROGRAM COUPLED WITH OUR SMALL SIZE PROVIDES PROTECTION FOR THE CALIF. AMBIENT AIR WITH A CONSIDERABLE MARGIN OF SAFETY. ANOTHER ITEM I WOULD LIKE TO DISCUSS FOR THE BOARD IS PARA GRAPH (e) AIR POLLUTION CONTROL EQUIPMENT, WHICH RELATES TO CON TINUOUS STACK MONITORING REQUIREMENTS. OUR PLANT HAS A UNIQUE SITUATION WHERE OUR VENT STREAM, WHICH IS VERY SMALL, IS FED TO A NEIOTBORING UNION CARBIDE PLANT FURNACE, WHERE IT IS INCINERATED IN A RELATIVELY HUGE VOLUME OF COMBUSTION FUEL AND AIR. OUR UNIQUE SYSTEM WAS APPROVED BY THE EPA, AND LATER AC CEPTED WHEN THE DISTRICT TOOK OVER FROM THE EPA. THE STACK WAS PERFORMANCE TESTED AND ZERO VINYL CHLORIDE DETECTED AS WITNESSED BY THE DISTRICT. IF OUR WAIVER IS NOW REMOVED, WE WILL HAVE TO INVEST $150,000 AND SPEND $25,000 ANNUALLY IN EXTRA OPERATING COST. THIS SECTION STATES "THE EXECUTIVE OFFICER MAY WAIVE THE REQUIREMENTS OF THIS SUBSECTION FOR THOSE OPERATIONS FOR WHICH HE DEEMS THEM UNNECESSARY, AND SHALL NOTIFY THE BOARD OF GRANTING SUCH WAIVERS IN WRITING." THIS AUTHORITY BY THE EXECUTIVE OFFICER WOULD APPEAR TO PROVIDE THE MEANS OF RELIEF FOR OUR PLANT. IF THIS IS SO, WE ENDORSE THIS SECTION. WE WOULD PREFER TO HAVE PARAGRAPH (e) REVISED TO PROVIDE SPECIFIC DIRECTION TO THE EXECUTIVE OFFICER. IN ADDITION TO THE OBJECTIONS WE HAVE TO THE MONITORING AND AIR POLLUTION CONTROL EQUIPMENT REQUIREMENTS OF THIS RULE, WE FEEL IT CONTAINS OTHER PROVISIONS WHICH ARE VAGUE, MEANINGU3SS, OR UN SAFE AND SHOULD BE REDRAFTED. THESE ITEMS ARE POINTED OUT IN OUR WRITTEN SUBMISSION TO THE DISTRICT. WE RECOMMEND THAT THE BOARD DIRECT THE STAFF TO CORRECT THESE DEFICIENCIES AS WELL AS THE ONES I MENTIONED EARLIER, AND THAT APPROVAL OF THE RULE BE DELAYED UNTIL THIS IS DONE. ucc 022556 Los Angeles County South Coast Air Quality Management District 1005.1 Rule Summary *c 1. The rule will he effective 12 months from adoption by the District; except: a. within three months a "Management Plan" for reduction of emissions must be submitted. b. Within 60 days the leak detection plan must be initiated. No plant can operate with a "leak". ,m 2. A "leak" is the detection of vinyl chloride exceeding 10 ppm. over the background level, 5 centimenters from the source. 3. Equipment venting or appurtenances venting over 1 ppm vinyl chloride must be vented to a control device including: reactors, storage tanks, purification vessels, strippers, mixing-weighing tanks, holding tanks. (This provision of the rule would negate the use of the No. 3 cooling tank at Tor rance which is not pressure rated and; therefore, negate the use of the No. 3 reactor. There may also be a problem with the various blend tank vents, which are now open to the at mosphere. Blend tank vent data is being gathered. The ex isting agitator seal on the No. 1 cooling tank may not be adequate. 4. Fence line concentrations of vinyl chloride may not exceed 10 parts per billion. The plant would have to provide and operate up to four air monitoring stations to determine 24 hour ambient air vinyl chloride measurements. The exact num ber and location is to be approved,by the Air Quality Control District. 5. Our relatively low use of YC would exempt Torrance from the following a. Up to four additional air monitoring stations must be maintained in the populated areas near the plant. b. Meterological data must be measured, summarized, and sub mitted to the District. A plant producing less than ten million pounds of vinyl chloride polymer in one year is exempted from this as well as (a) above. 6. Emission control devices must be operated to limit the total amount of vinyl chloride in the stack to less than 50 grams per hour. A continuous stack monitoring system, measuring flow rate and concentration of vinyl chloride must be employed. There is a waiver provision that might make it.possible to have our plant exempted from this requirement. ucc 022557 I -2- 7. All vent valves and relief valv s {except eraerg ncy relief ' valv s) shall be vented to a receiving vessel.' 8. Reactors and other equipment* upstream of the "stripper", shall be equipped with an automatic pressure reduction sys tem, which will open at a pressure between operating pres sure and the emergency pressure relief valve setting. The vapors from such pressure reduction systems 'shall be directed to a receiving vessel, vapor recovery system, or air pollution control system. 9. Scheduled inspections of flanges, punps, valves, storage containers and process vessels shall be initiated. All leaks shall be recorded and records maintained two years. All leaks shall be eliminated within 24 hours. 10. If a plant can demonstrate compliance with 10 ppb fenceline concentration continuously for six months, it can get an exemption from sane of this rule except for the provisions for a Management Plan, Leak Detection Program-, and fenc line monitoring requirement. After getting an exemption, it can ' be voided by a violation of the 10 ppb requirement. This exemption would be "shaky" in my opinion and up to the whim of the "district. 11. Within six months of adoption of the rule, a schedule of progress for emission control must be submitted to the Dis trict Board for approval. 3/3/80 GWS UCC 022558