Document DdddOdj619ObGneR88RNOzzm4

VINYL CHLORIDE EMISSIONS TEAM MEETING February 27, 1976 Attendees: A. S. Amatangelo R. W. Martin W. R. Manning C. E. Fry G. W. Stocking Copy to: T. L. Dawson L. P. McMaster E. Bell H. R. Guest T. T. Szabo C. Bayard C. E. Herald R. N. Wheeler, J. L. Wor stell^ A. J. Romanach A. E. Donaldson J. L. Carvajal R. W. Sesler M. E. Eisenhour J. B. Hollingsworth OSHA STANDARD 1. Amendments to the OSHA standard will not be permitted in the forseeable future per Mr. Barry White of OSHA. 2. Interpretations of the Standard The most recent interpretation cited by Mr. Barry White revised the definition of "fabricated product". A--11 which__QaJ^ixlhfer pro_ej change permit V^F^as well as bagged nan-solvent resin to be considered a "fabricated product". Hi 1 niiAi.w'tojBiK. Forced a This could be a major step in closer coop eration between industry and OSHA if the offer is accepted. UCC 104103 I 3. Citations (a) The citation involving Genesco at Knoxville, Tennessee is still unresolved though there appears to be no reason for its continuance. This is a state OSHA action. (b) Discussion with various other industry representatives through Organization Resources enforcing thestandard ifl^tSstaTf Citations are being issued for failure to have proper training or procedures after the compliance officer is notified ve 4. Training The OSHA standard requires that the standard be reviewed with the employee on an annual basis. Training TV tapes will be redone at South Charleston in the week ending March 6, 1976. 5. Permanent Variances from the OSHA vinyl chloride standard are avail able only if an owner/operator demonstrates that a particular piece of equipment or a particular procedure is equal to or better than the same item required in the standard. To date there appears to be no need for a permanent variance in any Union Carbide Corporation operation. 6. Temporary Variances from the OSHA vinyl chloride standard may be obtained for short periods. Since the standard has been in effect for almost a year the only temporary variance would be related to the per missible exposure limits which go into effect April 1, 1976. These var iances if requested must show a compliance plan, be acceptable to the employees or their representatives and show evidence of good faith efforts to achieve the levels required by the standard. Firestone has petitioned for a continuation of the 25 ppm voluntary employee ceiling. Borden is considering a request for one year at 8 ppm TWA. PROPOSED EPA STANDARD 1. C ontent The proposed standard was reviewed briefly from the attached summary sheet. The principal area of confusion was on the items under "Fugitive Emissions". It should be noted that the proposed standard bans emissions during sampling and requires that emissions be minimized in all other "Fugitive Emissions" section items. 2. ucc 104104 2, Comments on die proposed standard were submitted to EPA by Union Carbide Corporation February 23, 1976, These were on specific items in the standard which are overly restrictive or are not clear. Copies of the comments are available from R, N. Wheeler. Despite the obvious merit of the comments their acceptance by EPA should not be presumed for planning purposes. 3. The time schedule for the proposed EPA vinyl chloride standard is as follows: >ei 17, 1976. 4, Equivalency 61.66 Equivalent Equipment and Procedures Upon written application from an owner or operator, the Administrator may approve use of equipment or procedures which have been demon strated to his satisfaction to be equivalent in terms of reducing vinyl chloride emissions to the atmosphere to those prescribed for compliance with a specific paragraph of this sub part. The most pressing points of equivalency are the prescribed uses of Test Method 106 and Test Method 107. Neither of these methods are in general use by Union Carbide Corporation; thus, eqi A. E. Gabany and M. E. Griffith will establish Union Carbide Corporation equivalency to Test Method 107. 5. Waivers from certain portions of the proposed EPA standard maybe obtained for periods not exceeding two years. Requests are to be made in writing and shall include the following information. (a) A description of the controls to be installed to comply with the standard. (b) A compliance schedule including the date each step toward com pliance will be reached. (c) A description of interim emission control steps which will be taken during the waiver period. 3. ucc 104105 Based on the information, provided, the Administrator may grant a a waiver of compliance. The waiver may contain such additional conditions as the Administrator determines to be necessary to assure the installation of the necessary controls within the waiver period and to assure protection of the health of persons during the waiver period. For greater detail see the attached Part 61 National Emission Standards for Hazardous Air Pollutants. The foregoing is shown to stress that applications for waivers will be complicated and approvals not automatic. Status Solvent Resins was reviewed by Mr. C, E. Fry for 5 14. No data was available for 515, Dispersion Resins was reviewed by Mr, G. W. Stocking. 5 14 Distribution was reviewed by Mr, R. E. Jarrett. Suspension - Non Solvent Resins were not discussed. PROGRAMS FOR COMPLIANCE WITH OSHA AND EPA 514 Distribution OSHA No temporary variance will be required. Monitoring shows VCM generally below action level except for leaking tank car valves. A written procedure for abatement of the leaking tank car valve problem is needed. The OSHA training program will be updated and completed in March, 1976. EPA 4, UCC 104106 The sphere work will be completed by September 1, 1976. The sphere should not require further work for ten years. The tank car unloading hoses will be revised so that the sections vented on completion of unloading will contain less than one gallon of VCM gas per hose. The Corkean stripping compressors will be checked in regard to the rod packing system used. A plan will be prepared for equipment maintenance under the EPA proposed standard identifying pipeline connections, compressors, etc. that may be needed. Work will begin on identification of possible waiver requests and on assembly of data for EPA's Initial Report. A vent line from the sphere to the tank car unloading rack will be installed to vent inerts from the sphere to the tank cars being unloaded. Dispersion Resins OSHA No temporary variance will be required. The OSHA training program will be updated and completed in March, 1976. A compliance program based on the planned shutdown will be prepared. EPA No projects required. Work on the assembly of data for the Initial Report and the Leak Program will begin. 5. UCC 104107 514 SOLVENT RESINS OSHA - EPA Projects 1. Rectifying (stripping) column modifications Cost No completion date $110, 000 2. Portable compressor Cost No completion date 3. Replace four vinyl chloride pumps Cost No completion date 4. Vent line to powerhouse Cost 938-5374 $48, 000 $24,000 $60, 000 5. Revise packing an autoclave pumps Cost Two are complete Completion by ? 6. Revise Number 14 stripping compress packing Cost Completion date $5,000 ? 7. 2708 Tank Vent Cost Completion date Under study - solution being tested ? ? 6, UCC 104108 8. Revise packing on two Stripping System Pumps Cost Completion Under study - solution being tested ? ? 9. Install rupture discs under all relief valves in vinyl chloride service Cost Completion date $100, 000 9 10. Install a double mechanical seal or stripping dilution tank agitator Cost Completion date $10, 000 ? 11. Autoclave agitator secondary power supply Cost Completion date Investigation only. Need is not clearly defined by EPA. ? ? 12. Autoclave pressure test vent gas Cost Completion date Investigation of disposal in progress ? ? 13. Sampling of autoclaves Cost Completion date EPA procedure requires study 14. Revise autoclave pressure controller to eliminate liquid 'filled leads Cost Completion date 7. ? ? $5,000 9 UCC 104109 15. Vinyl chloride system maintenance Cost Completion date ? A procedure with appropriate equipment must be defined to meet EPA*s limits for equipment opening emissions. 16. Vinyl chloride transfer line repairs Cost Completion date ? ? This work may be done in total or in pieces to replace corroded pipelines. OSHA STANDARD No temporary variances will be required. Update and complete the OSHA training program. A written abatement program is needed covering planned reductions in VCM concentration. EPA STANDARD Waivers from the proposed standard will be required in the following areas 1. Vinyl chloride system maintenance 2. Number 14 compressor packing 3. Four vinyl chloride transfer pumps 4. Rupture discs under all relief valves 5. Dilution tank agitator seal 6. Rectifying column modifications (maybe) 8. ucc 104110 Schedules for individual items and projects will b d veloped by the various department managers to meet governmental deadlines. RNWJr. /pm Attachments March 3, 1976 9. UCC 104111