Document Dvw9qo0q6L6Mqbr95eXV2wZmN
TENNECO POLYMERS, INC.
' (COMPANY)
ftjioOTunu.L_
INTEROFFICE COMMUNICATION
TO:
OPERATIONS - PASADENA
FOR: F. KOSLOSKY
FROM: 6. E. DISCH
RE: EPA: STANDARD ON VINYL CHLORIDE
DATE: JANUARY 17, 1985
I am attaching for your use the latest standard for vinyl chloride issued by the EPA. It was issued on January 9 in the Federal Register.
GED/rs Attachment
cc: H. R. Bowers D. M. Hersh J. W. Kachtick R. R. Neugold
uy E. Disch
TEN 4459
Wednesday January ft, iftss
Part V
Environmental Protection Agency
40 CFR Part 61 National Emission Standards for Hazardous Air Pollutants; Vinyl Chloride; Proposed Rule and Notice of Public Hearing
rEN 4460
JJ62
Federal Remitter / Vol BO. No. 6 / Wednesday, January 8, 1965 / PropoaedRulei
ENVIRONMENTAL FftOTECTOON AGENCY
40CFR9rt1 IAD-FRL-2707-4)
t
National Emlaalon Standards for Hazardous Air Pollutant*; Vinyl Chloride
AOENCY: Envoronmental Protection Agency (EPA).
action: Proposed rule and notice of public hearing.
Summary: The current emission ~ standard for vinyl chloride (VC) was promulgated under Section 132 of the Clean Air Act jn 1976. 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 (1) 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 revisions to the current standard which were published in the Federal Register on June 2.1977 (42 FR 28154).
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.
DATES: Comments. Comments must be received on or before March 25,1965.
Public Hearing. If anyone contacts the EPA requesting to speak at a public hearing by January 301965, a public hearing will be held on February 25, 1985 beginning at 9:00 a.m. Persons interested in attending the hearing ahould call Ms. Shelby Joumigan at (919) 541-5576 to verify that a hearing will occur.
Request to Speak at Hearing. Persons wishing to present oral testimony must contact EPA by January-60,1985.
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 (A130). Attention Docket Number A-81-21, U.S- Environmental Protection Agency. 401 M Street. 5.W., Washington, D.C. 20460.
Public Hearing. If anyone contacts the EPA requesting to speak at a public hearing by .January 30,1985. the public hearing will be held at EPA Auditorium.
coroar of Highway 54 and Alexander
toil for relief valve discharges. (2)
Drive. Research Triangle Park, Worth . providing a compliance test procedure
Carolina. Parson* interested in attending and a specific emission limit for
the bearing ahould call Ms. Shelby
operators who perform stripping
Joumigan at (919) 541-5576 to verify that operations in reactor*, and (3) specifying
a hearing will occur. Persons wishing to requirements for leak detection and
present oral testimony ahould notify M*. repair programs for certain equipment in
Shelby Joumigan, Standards
VC service. Additional minor
Development Branch (MD-13), U-S.
administrative changes to the standard
Environmental Protection Agency,
are being proposed and are explained
Reaearqh Triangle Park. North Carolina .later in this preamble.
27711, telephone number (918) 541-6576.
Summary of Health. Environmental,
Background Information Document.
Energy, and Economic Impacts. Bince 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
froig the current standard remain
Standards", EPA-450/3-62-003 (NT1S- generally unchanged. In 1975. it was
PB 64-114354). available from the
estimated that emissions of VC from
National Technical Information Service, jplBnts producing ethylene dichloride
5285 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
96.000 Mg/yr to 4,910 Mg/yr under the _
contained in a separate document which current standard, representing an
may be obtained from the U.S. EPA
emission reduction of 91.000 Mg/yr of
library (MD-35). Research Triangle
VC (or 95 percent of VC emissions).
Park, North Carolina 27711, telephone
Emissions of volatile organic compounds
number (919) 541-2777. Please refer to
(VOC) and EDC are also reduced under
"Vinyl Chloride: Relief Valve Discharge the standard.
Standard," EPA-450/3-65-002, for the technical document.
Docket. Docket No. A-81-21,
The estimated risks attributed to exposure to VC from EDC/VC and PVC plants in operation prior to the current
containing supporting information used standard were 5.5 cases per year for
in developing the proposed standard, is Ever angiosarcoma and 11 cases per
available for public inspection and
year for all cancers. The risks attributed
copying between B:00 a.m. and 4:00 p.m.. to exposure to VC from sources under
Monday through Friday, at EPA's
the current standard have been
Central Docket Section, West Tower
estimated to be 0.28 cases per year for
Lobby. Gallery 1. Waterside Mall, 401 M liver angiosarcoma and 0.55 cases per
Street, SW., Washington. D.C. 20460. A year for all cancers.
reasonable fee may be charged for copying.
In 1975. the estimated capital cost for existing plants to meet the VC standard
FOR FVTHER INFORMATION CONTACT:
was 3196 million, of which $15 million
Mr. Robert E. Rosensteel or Mr. Leslie B. was for EDC and VC monomer plants
Evans, (919) 541-5671, concerning
and 31B3 million was for PVC plants.
technical aspects of the industry and
The EPA estimated that the annualized
control technologies, and Mr. Fred
cost (including capital amortization, etc.)
Dimmick or Mr. Glibert H. Wood, (919) to these plants to maintain the required
541-5576. concerning regulatory
emission levels would be S70 million per
decisions. The address for these
year.
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 59532), and
27711.
promulgated on October 21,1976 (41 Fr
SUPPLEMENTARY INFORMATION:
Summary of Revisions to Curreot Standard
46559). It is applicable to planta 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 subject to
standard lor 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
process. These requirements include
revisions Bre being established under
numerical emission limits, equipment
Section 112 or the Clean Air Ad. The
specifications, and work practices.
significant administrative revisions
Tbe standard was designed to
include: (1) Reformatting the emission
minimize the health risks associated
TEN 4461
Fadaral Raglstar / Vol. 8ft No. e / Wodnesday, January 9, 1965. / Proposed Rulea
1183
' with VC by requiring reasonable oontrol Regulating Airborne Substances Posing Assessment Croup reviewad naw haalth
mtaaurei. Ai atated in the preamble to a Risk of Canoar.** This proposal
tudies that have become available
the proposed standard (40 Ft (0632.
addressed several Usual which were
Inca the standard was promulgated.
December 24,1975), there is no known centra) to the proposed VC
This review included a study of the
threshold level of effects for VC.
amendmenU. It also articulated the
estimated carcinogenic strength of VC
Therefore, the only approach that would EPA'e conclusion that Section 112 does (the VC unit risk number) and focused
eliminate health risks associated with
not express an Intent to eliminate totally on whether this number should be
VC would ban its production and use.
all risks from emissions of airborne
changed to reflect new informaton.
This approach wbs not selected. Rather, carcinogens. The EPA's selection of the ' Since the current atandard was
an approach was selected to minimize level of control for a hazardous air
promulgated, new occupational studies
the health risks associated with VC by poliuUnt emission standard would not have confirmed qualitatively that liver
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
requiring the EPA to'propose 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 djfepnogens and that the EPA would ^0iate a review of the VCelandard 3
be based on policy that requires zero emissions of carcinogens. This policy is consistent with the basis for other recent actions under Section 112. For example, standards for benzene from coke ovens and leaks from equipment components is benzene service are not based on a zero emissions policy but rather on a reasonable level of control, which 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 thiB 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
and brain cancer incidence are etoriated with population exposure t atmospheric VC. However, none of these new studies have sufficient exposure information to warrant a refinement of the quantitative cancer risk estimate.
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 thin! subsection identifies source categories not covered by the current standard and evaluates the appropriateness of regulating these sources.
(1) Need and Basis for Current Standard
years after the promulgation of the amendments.
On June 2,1977, the amendments were proposed (42 FR 26164). 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 for regulating airborne carcinogens under Section 112 of the Clean Air Act. The aspects of the EDFs petition concerning the development of
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 Id investigate the adequacy and appropriateness of the standard in light of policy decisions, health studies, control technology developments, and 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 standard. Information and data evaluated during this study were obtained through
The current VC standard was established 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 noncsrcinogenic disorders in people with occupations! exposure and in animals with experimental exposure to VC. Although no dose-reBponse data are available at the concentrations of VC found in the ambient air, the EPA concluded when
standards under Section 112 were
literature searches, plant visits, and
the standard was established that any
similar to those proposed in the June 2, interviews with industrial
atmospheric concentration of VC poses
1977, amendments to the VC standard. representatives and EPA regional
some public heath risk. To eliminate the
Based on the similarity of the proposed personnel involved in enforcement and risk of VC exposure entirely, a complete
amendments and the EDF* requested - surveillance of the VG-eraitting
prohibition of all VC emissions would
comprehensive program for regulating
industries. The information and data are be necessary. This would require the
airborne carcinogens, the EPA believed presented in a document that may be
closure of the entire industry and result
that it should not take final action on the obtained as described in the Aoostutu in serious, adverse economic impacts.
proposed VC amendments until after it section of this preamble. Decisions
Furthermore, the EPA concluded at the
bad^hed on the EDFs petition.
based on this revjew are summarized in time the current atandard was
d^biober 10.1979 (44 FR 58642), the the next two sections of this preamble. established that a complete prohibition
EPA proposed "Policy end Procedures
As another aspect of the review tif the of all VC emissions would not be
for identifying. Assessing, and
VC standard, the EPA's Carcinogen
desirable or necessary. The EPA
tlM
FwWrri Raftettr /Vet. 80. No. i / Wcdrvesd.y, January t. WS / Ftopoacd Kvk$
MBflmtod this in vfew of (1) Ac beneficial ** of VC products lor which desirable substitutes are not readily
svsllsble; (Z) the potential adverse health and environments! impacts associated with VC substitutes that have not been throughly studied; (9) the number of employees. psrticularty hi 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 Into the atmosphere.
Although all EDC, VC and PVCpUnts have now incorporated VC emission controls, the maintenance of a Federal standard for VC is still considered necessary. The VC standard contains requirements for the proper operation and maintenance of control devices and the proper implementation of work practices. These requirements reflect an appropriate balance betwem the need to minimise health risk* and the avoidance of unreasonable economic and community impacts which would result from standanis designed to reduce risks to xero. Relative to the initial control costs, the additional cost of maintaining and implementing the Federal VC standard is small. Nevertheless, if the Federal standard it discontinued, these small costs may be sufficient to provide the industry with an economic incentnre for discontinuing 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 cunent level of control Additionally, the standard is important for the control of VC emissions from plants built in the future. The consequence of not maintaining a Federal standard would be to increase the carcinogenic risk to large segments of the population. (In 1S75 when the standard was originally proposed, approximately 4.6 Million people lived within a 5-mile radius of EDC. VC and PVC plants.) According)} , the EPA has concluded that the maintenance of the Federal standard for VC. or reasonable revision of the standard, is appropriate.
(2) Review of Techoalogy-Btaed Level of Control
This subsection describes the status of the technology-based level of control for sources covered by the current standard. The present status of emission* from sources covered by the current VC standard Is presented In Tsble 1.
Taau t. Rsatus or Cwwmt Cii--o taw at 0>e time of the psomalyettoB of the M u Fmom Bounds Doveaeo rr vhk Vara ppmv Knit.
CMJOMDC INSWAP
CommiiU received on the proposed
MS
IwwsMri M 1S7S sr
1077 amendments staled that in order to meet a limit of & ppmv, a control device
would have to be capable of oontrol at a level even lower than 5 ppmv to offset
emission fluctuations. Commenters also
stated that a change from 10 to 5 ppmv
PS""'--------
product *** --. MMpncM .
am)
** u would result tn little reduction In mass emission* Of VC Finely, commenters
1W so questioned the rationale of the "zero #* m emission goal" policy.
Because the proposed 5 ppmv
emission limit was not based on data
Rife*
__ "r*
tot MM*
n from a control technology different from that analyzed for the current standard
and because 10 ppmv represents the
CfitiMws Son * maw Siroc *s'V PVC Mc*V
lowest level of control which ba* been consistently achieved, the EPA
Prhfy toPOl
a--cw
000? kQ'tOO If PVC
IS 07 withdraws the proposed 5 ppmv limit 111 14 and affirms the original 10 ppmv limit If
such a technology had been identified. It
Contnd KWH wtm
"product ABO (ipm-
Mcwnaion*.
S60
Z7
could have been the basis of a revised standard. However, during the review
study no more advanced technology was
Eu0*Wr______ Wuft p'OCtCO to*
1J&40 too identified even though additional data on incinerators, carbon adsorbers, and
Widordt nuM- ivrv _ Nyytxnli
to
solvent absorption control systams on 136 L4 existing plants were obtained. Allhough
- these data indicate that incinerators are
my capable of reducing emissions below 10
ppmv, 10 ppmv represents the lowest
dra KSxnntM) bj neuww aanat pne* sniumr
r* is7s vc mmm
<npna oMnstod >!'! ti a St* EDC'VC and SVC pttna inMflnc arnfTt mndard
Oil* am not icdocnd on toM aofco dadvga* Vo* EDC/VC pan* pnp K> 1875
Bum) on V* EPA vwa oovnotoa W Vpc* MKbi Mux twi on ovn*v to> ME M. it tsnor pus n not prmmd hem.
level of control which has been consistently achieved. Based on this information, the EPA has concluded that there is no improved or new control technology that has been demonstrated to significantly and consistently reduce
10ppmr Standard. Emission sources covered by this standard indude EDC purification and VC monomer formation and purification equipment, monomer recovery systems and other equipment at PVC plants, and vents from fugitive
emission capture systems. The standard is based primarily on the control of theBe emissions by incineration or other primary control devices and specifies an emission limit of 10 parts per million by volume (ppmv) of VC averaged over a 5hour period. The 10 ppmv standard applies to control device bypass streams.
emissions to a level below that required by the current standard. Therefore, no further technological investigation of the 10 ppmv standard is planned.
Oxychlorinotion Vent Standard--0-2 g/kg EDC The current oxychlorination vent standard of 0.2 g of VC per kg of EDC does not require an add-on control device. Instead, the limit can be achieved at most plants by controlling operating conditions and at the remaining plants through process modifications. At the time the original standard was written, incineration of oxychlorine bon vent emissions was investigated. Because of expected high
One of the amendments proposed in energy costs associated with
1077 would have required reduction of supplemental fuel requirements for
the emission limit from 10 to S ppmv.
combustion, incineration was
The goal of the proposed S ppmv limit
determined not to be a reasonable
was to ensure that the standard
method of control for this source.
continued to approach a "zero emission
The amendments proposed in 1977
* requiring owners and operators specified a level of S ppm for the
both to maximize the effectiveness-of
oxychloriaabon vent. The proposed
existing control systems and to design requirement was based on installstion
improved new control systems at the
of an oxygen feed system with sn
time of construction. The 5 ppmv turrit
incinerator or equipment control device.
was not based on data for control
The use of oxygen feed In the 1DC
technology different from that analyzed oxychlorinaton process decreases the
TEN 4463
Fadaral Rastas j Vot- 0. w / Wedneadey, january $, 1985 / fYqpoafed.ftnto .........im
volume of toast substance* In At vanl
stream and. oonaaqaantiy. tHs coat for au^iWroental foal required for
incineration. Commenta received on fell proposed amendment focused primarily on the high expense end large energy requirement* associated with the
production ol oxygen. The review study identified no oontrol
technology for oxychlorination vents at EDC/VC plants that bad not been considered during the development of the original standard. Additionally, the
EPA reevaluated the cost of retrofit incinerator controls and reached the __ same conclusion drawn in the development of the original standard. A* before, the high cost associated with incinerating oxychlorination vents at existing EDC/VC plants makes this level of control unreasonable. Thut, die current standard of 0.2 g/kg EDC is considered stiU to be the most reasonable level of control for existing oxychlorination vents. In addition, the review study concluded that significant new construction or modification of EDC/VC plants is not expected. At this time, only one new EDC/VC facility is reportedly planned. fBF Goodrich has plans to construct an EDC/VC facility in Convent, LouisianaJ Oxychlorination brents at new EDC/VC plants will be ^H^ulated by the proposed standards of wP^rformanceTor air oxidation processes (40 CFR Part 60 Subpart HIJ or by the BACT or LAER requirements of new source review regulations applicable in specific locations to a level comparable to that achievable through the use of incineration. Because the technologically achievable level of control it assured through the current requirements, the EPA concluded that investigation or additional control (Le., incineration} was not required for
oxychlorination vents. Reactor Opening--0.02 g/kg PVC
Product. The currenl VC standard restricts emissions during polymerization reactor openings. The standard was based on reactor purging and on a reduction in the frequency of reactor openings. An increased level of control was no! proposed in the 1977 amendments. (The level of control provided by the current standard. 0.02 g/kg of PVC product, reduces VC emissions to about 1.36 Mg per year for a model PVC plant.) During the review of the standard, no technology was identified that would provide additional VC reductions beyond the level of (he current standard. Therefore, the EPA is nc^feestigs ting further the control of refl^m openings.
Combined Sources After Resin Stripping. The source* of VC emission* covered under (he current standard
Include blend tanks, dryer*, centrifuges, storage altos. bagging operations, and any source* following the stripper.
Control of these emissions is based on either stripping the PVC resin to a specified (based on resin type) residual VC level (!., 400 ppm for suspension, bulk, solution, end latex reslnr. and 2.000 ppm for dispersion resins) or controlling the emissions from all sources following the stripper with a control device. The 1077 proposed amendments would have required "new resins'' to be stripped to lower levels
(i.e,, 100 ppm for suspension, bulk, solution, and latex resins; and 500 ppm for dispersion resins). When the amendments were proposed, the EPA believed that some resin* could meet the proposed limits; whereas, for other resins the manufacturer would have been required to develop improved stripping technology or not to produce the resin.
Industry comments stated that most
dispersion, copolymer, and bulk resins would suffer degradation if more stringent emission limits were imposed. Additionally, the commcnters noted the inherent difficulties in defining a "new resin." Information submitted by commenlers indicated that aainor adjustments to resin compositions are 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 oontrol could be achieved by improved stripping technology. For these reasons, the EPA chose to evaluate whether higher levels of control are achievable for all resins, or only for some special classes of resins.
The review study found that resin stripping technology has improved since the current standard wbs promulgated, and that some processors can achieve lower resin residual VC levels than those required in the original standard. In certain cases, some resins can meet the more stringent levels specified in the previously proposed amendments. However, other processors manufacturing resins of diHering grades and characteristics can only maiginally comply with lhe original standard. Because of the wide variation In resin grades and characteristics, it cannot be concluded that, erven though a particular resin made by one company can meet a particular level, any other resin or similar resins produced by another company could also meet that level Furthermore, in tome cases these
processors meeting the more stringent
limits proposed previously are stripping these resins to tnlilow Wvtl to onset
emissions from those resins which are more difficult to strip. Without this ability to average the emissions and reductions among resins, these processor* might not achieve the current standard. Exempting resin grades known to be difficult to strip is not feasible because these resins cannot readily be defined. For lhe foregoing * reasons, the EPA has concluded that there is no demonstrated level of control which could significantly and consistently reduce residual VC levels in resins to levels below that required by the current standard. Therefore, the EPA is not Investigating further (he control of the combined sources after
stripping.
Equipment Leaks. Because little was known about leak detection and elimination programs for control of equipment leaks from components in VC service, specific requirements for these programs were not included in the current standard. Instead, each plant was required to institute and implement a formalized leak detection and elimination program incorporating both a fixed-point monitor and a portable monitor. Piant-apecific programs were subject to approval by the Administrator. Consequently, due to site-specific differences among plants, as well as variations in leak definitions and monitoring practices, difference* in control of equipment leak* 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 standards, an effective leak detection and repair program based on use of a portable monitor can now be specified for equipment covered by this program. The specific leak detection and repair requirements are discussed in the Administrative Revisions section of this preamble.
Relief Valet Discharge Standard. Sources of VC emissions covered by this standard indude discharges from relief valves on pressure vessels, transfer lines, and other equipment to IDC/VC and PVC plants. The standard is based on emission control by a combination of equipment and process modifications, and operational procedures, found in plants during development of the standard. An exact combination of modification* and operational procedures was not specified. Instead, a performance standard (i.e., an emission
v'JOt *r ^ m
1166
rUrm) Ragistar / VoL SO. No. 6 f Wednesday. lanuary 6. 1065 / Proposed RuWs
standard) wii established because It wu believ d that different combination* could b* equslly effective In oontroQinf relief valve diechargee. The currenlTonnat of the etandard prohibit* all relief valve discharge* except emergency discharges. Emergency discharge* are described as those which could not have been avoided by taking measures to prevent the discharge (i.e., those that are "nonpreventable*'). Since the standard was promulgated, all plants have experienced some releases. Many of these 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 limits for relief valve discharges in a different format.
Administrative Aspects of the Standard. Even though the EPA decided not to revise the level of control associated with the current VC standard, the EPA identified revisions to several administrative aspects of the standard. These revisions as well as those identified above, are discussed in the Administrative Revisions section of the preamble.
(3) Review of Sources Not Previously Covered
This subsection discusses the status of VC sources not covered by the current standard that were identified in the review atudy. For these sources, the EPA assessed whether a Federal atandard was warranted. The EPA's assessment of these sources was based primarily on a quantitative analysis of VC emissions from these sources combined with b 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 atandard is warrant d 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, are small in comparison
to sotiroes ooversd by the VC standard, the EPA concluded that non* of tha additional sources identified In the
review atudy warrant a Federal standard.
Miscellaneous Sources of VC Emissions. Miscellaneous sources are
plants other than PVC and EDC/VC plants that use VC as a raw material or
produce VC at an Intermediate or by* product The EPA has identified four such plants, two of these plants produce 1,1,1-trichloroethane, one produces perchloroethylene and trichloroethylene and the fourth plant produces pesticides. (An additional 1,1,1-trichloroethane 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 1 Mg/ yr to 14 Mg/yr per plant In general, the VC NESHAP requirement* 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-aervice would be covered by standards of performance for new sources and standards for sources in nonattainment areas. Based on the investigation of these sources, the EPA concluded that they are already relatively wellcontrolled and do not contribute significantly to VC exposure. For these reasons, additional requirements for miscellaneous sources of VC ere not being proposed at this time.
PVC Fabrication Plants. There are about 6,000 fabrication plants which take the resin produced by PVC plants 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 are 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 resins being processed by the fabricators. Resin stripping beyond the level that process economics would dictate is already being done as a result of the EPA's current standard and OSHA'a 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 of controls for PVC fabrication plants is
nnsosssary and that the currant lava] of control resulting from the EPA's standard and OSHA's standard Is still
reasonable.
Londjfi7/*.'Off-apadfication resins containing VC has been taken to landfills where the gaseous VC can be released. However, the current EPA atandard intends that all 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 explicity address ofTspecification 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 be 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 at hazardous waste disposal facilities. The EPA also recognizes that VC has been detected in municipal landfills. Therefore, in addition to assessing VC emissions from hazardous waste disposal facilities, a (RCRA) Subtitle D TASK FORCE has been formed which will assess all environmental releases including air emissions from Subtitle D facilities (a category which Includes municipal lan dTills).
'Administrative Revisions
As discussed in the Findings and Conclusions of the Review Study section of this preamble, the EPA identified several administrative revisions that are appropriate as 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) Reformatting the emission limit for relief valve discharges. (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 service, Bnd (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.
TEN 4465
--
Eqgfater / Vat 10, No. / Wado--day. Jonnary A, H65 1 fVqpoatd Mat
transfer lines. aifa ether MtipaMl io
EDC/VC and PVC plants. Tb control
technique oontidsred es tbs basis of
the standard faveNa a combination of
equipment modification*. process
modification*, and operational
procedures. Ad exact combination of
modification* end operational
procedures was not spedEnd in the
cunent standard; rather, a performance
standard (i.e., an emission standard)
was established because different
combinations of the modification* and
procedures were expected to be equally
effective in controlling relief valve
discharge*.
_
Based on 6 years of enforcement and
compliance experience, the EPA has
concluded that the relief discharge
standard has resulted in; (1) Significant
reduction* in the frequency and quantity
of VC discharges from relief valves, (2J
significant use of agency resources io
evaluate individual discharges/or
preventability, and p) uncertainty on
the part of producers regarding whether
they comply with the standard.
Additionally, the EPA learned some of
VC and PVC believe that this part of the
cunent standard applies only to
discharges through safety relief valves
and that discharges through other
pressure relief devices, such a* rupture
disks or manual or automatic vent
valves, are not covered. This
interpretation is not compatible with the
intent behind the current standard. To
provide more efficient enforcement by
decreasing the burden of individual
preventability assessments on the EPA
and io provide a better understanding to
plant operators of the goal of the
standard, the EPA is proposing to
reformat the standard for relief valve
discharges and to define the emission
points covered by this standard to
include appropriately all pressure relief
devices. As discussed more completely
in the following sections, the EPA is
proposing to change the format of the
numerical limits in the standard to
reflect the number of discharges that
occur from those plants complying with
the format of the current standard.
The EPA found in the review study
that efforts by all EDC/VC and PVC
producers to comply with the standard
are reflected m their preformance (in
terms of size and frequency of
discharges) since the standard went into
effect. In general, a reduction in the
reported frequency and size of relief
valve discharges by PVC producers has
occurred since 1974. A further decrease,
#relief valve discharges by the PVC 'd ustry occurred beI ween I960 and
1981. Performance by the EDC/VC
industry exhibited a less marked trend
of decreased discharges ewer the compliance period. foUowtng an tekial drop fa rebar wahra Asebarge* after tee standard want fato aBack tee frequency and quantity of setter veive discharges
by EDC/VC plants beet decreased slightly or remained relatively constant.
General Both for Numerical Umlte. In selecting the proposed numerical limits, EPA Bret evaluated fa detail the recent performance (1661 to 1983) of five PVC plant* and one HDC/VC plant These plants were chosen based on discussions with EPA Regional Office personnel end industry end were
Intended to represent plants with good relief valve discharge records, fa general, the ETA*# evaluation of these plants Indicates that each has adopted the combination of equipment, operational procedures and attitude toward prevention of relief dischaige* intended by the current standard, and that their resulting performance is
consistent with compliance with the current standard. The EPA) evaluation found that few discharges may continue to occur from some plants that comply with the standard. This observation is consistent with the expectation held by the EPA when the standard was written. .
fa order to revise the standard in terms of numerical limits representing compliance with the current format of the standard, this evaluation separated PVC and EDC/VC plants. For plants, relief valve discharge performance data were further separated by source (reactor vs. nonreactor) and by resin type The EPA then reviewed the performance of 25 additional PVC plants and 12 additional EDC/VC plants. The EPA reviewed this large set of plants to ensure that the level of performance demonstrated by the evaluated plants could be achieved by all PVC and EDC/ VC plants.
The numerical limits presented in the Findings section of this preamble are bated on an evaluation of the number of discharges representing the demonstrated performance level associated with compliance with the provisions of the existing standard.
Format for Numerical Limit*. The EPA visited the five PVC plants evaluated in detail. As expected, the EPA found differences in the combinations of hardware and operational procedures aasodated wirh control of relief valve discharges of each of the plants. Furthermore, no exact relationship was found between (be effectiveness oS specific hardware Items and operational procedures and prevention of discharges fa the EPA'* judgment the various oombteationt of
hardware and opervtlooal procedure* Implemented by each of Ih* plants along
with the attitudes adopted toward preventing relief valve ditcherges represent the types of oortrol measures that the standard intended. In particular, the EPA concluded that the low frequency of discharges by die vixlted plant* was indicative of their degree of effort to prevent relief valve discharges. Consistent with the goal of Oils proposed revision, the EPA decided that an alternative numerical emission limit bated on performance resulting under the current standard could be revised fa a format that would be easier to understand by enforcement and industry personnel.
The EPA Investigated two bask ways of expressing relief valve discharge performance far PVC plant*. One format is based on mass emission*, for example, (he pounds of VC discharged per million pounds of PVC produced (lb VC/MM lb PVC). Based on a review of methods used by industry io determine the amount of VC discharged from relief valves, the EPA was unable to identify a sufficiently accurate method for measuring discharge quantities from relief valves. A present, producers are required only to estimate discharge quantities for reporting purposes. Demonstration of compliance with a lb VC/MM lb PVC limit would require producers to measure the amount of VC discharged during aa faddent. Because a suitable measurement method was not identified, the ETA decided not to redefine relief valve discharge performance by PVC plants in a lb VC/ MM lb PVC format
Another format is based on the frequency (i.e, number per unit time) of discharge from occurrences. No method for measuring the amount of VC discharged from relief valves is needed because only the occurrence of a release is required for this format. The occurrence of a discharge can be determined by monitoring process parameters as well as inspecting relief valve performance reports. Thus, of tbe two basis ways of expressing relief valve performance that were considered, the EPA selected a format based on the frequency of discharges.
Based on this decision, the ETA then considered how tbe format would be applied to PVC and EDC/VC plants. At PVC plants, tee frequency of discharge* from polymerization reactor* and associated process equipment may be related to the feet that a batch process (s used Io produce most types of PVC. For batch PVC production processes, tee opportunity for discharges is related to the number of times a new
TEN 4466 '
11*8
FwUral RtfUlar / Vol 10, No. 8 / Wednesday, Jimmy *. 1965 / Proposed Rules
Elyxserixstlon batch ti initiated. pressing relief valve discharge performance for theae plants with a
production of suspension and bulk resins Indictte that reactor discharge frequency generally ta either lees than
discharge-per-bstch format accounts for 0,035 discharges/100 batches or is much
variations among plants In the number grestar. (Recent reactor discharge
of batches produced. The EPA selected freouendes for euspeneion resin plants
100 polymerisation batches as a
with poorer performsnee levels ranged
convenient basis for expressing relief
between 0.059 and 0.101 dischaiges/100
valve discharge performance by PVC
batches.)Further examination of relief
plants with batch production processes valve discharge performance by
in a discharge frequency format
utpeniion resin producers indicates
Further, the EPA noted that the ability that only one plant experienced more
of batch PVC producers to limit the
than 4 discharges per year during the
discharge frequency may be different for period from 1081 to 1083. Performance
reactor and nonreactor discharges and . by this plant also exceeded 0.035
that reactor discharges may vary by
discharges/100 batches.
resin type st any plant Consequently,
The reactor discharge frequency
relief valve discharges by individual
associated with dispersion and latex
PVC plants (except for continuous
production it typically zero. However,
solution process plants) were classified for a typical dispersion or latex resin
according to type of discharge (Le,
process with a low production rate fi.e.,
reactor vs. nonreactor] and the reactor number of polymerization batches per
discharges were separated by resin
year), a single emergency reactor
type. Nonreactor discharge sources at
discharge in a given year would be
PVC pUnts include blowdown tanka,
equivalent to a discharge frequency of
.transfer lines, and storage vessels.
about 0.035 discharges/100 batches.
Because usage of this equipment is also
Nonreactor Discharges. Nonreactor
related to some extent to the frequency discharge frequencies by PVC plants
of batch polymerization operations, the typically were either less than 0.025
relief valve discharge performance by
discharges/100 batches or were much
nonreactor sources in PVC plants with greater. (Recent nonreactor discharge
batch production processes was also
frequencies reflecting poorer
examined on the basis of number of
performance than the 0.025 level ranged
discharges/100 batches.
between 0.048 and 0.225 discharges/100
Unlike the batch process used to
batches.) Furthermore, with the
produce other PVC resin types, the
exception of two producers, no more
solution PVC process is continuous.
than three discharges per year were
Thus relief valve discharge performance reported from nonreactor sources in
for the solution PVC process cannot be PVC plants during the period from 1981
expressed on a frequency per batch
to 1983.
basis. Instead, the relief valve discharge
Each of the five PVC plants that the
performance associated with the
EPA evaluated in detail was among
solution production process can only be those achieving 0.035 discharges/100
expressed in terms of the total number batches Dr less in each of the reactor
of discharges (reactor and nonreactor) discharge categories and 0.025
per year.
discharges/100 batches or less in the
Similarly, the EDC/VC production
nonreactor discharge category. The EPA
process is not a batch process, but is
examined individual discharge incidents
continuous. Thus, relief valve discharge for the PVC producers whose recent
performance by EDC/VC plants sIbo
performance has exceeded 0.035
cannot be expressed on a frequency per discharges/100 batches in one or more
bBtch basis. Moreover, the EPA was
of the reactor discharge categories or
unable to detect a direct relationship
who exceeded 0.025 discharges/100
between discharge frequency and VC
batches and 3 discharges per year from
production at EDC/VC plants. Thus, the nonreactor sources. In every case, the
EPA decided to define releif valve
EPA identified one or more discharges
discharge performance for EDC/VC
that were preventable. Elimination of
plants on the basis of a total number of these preventable discharges indicates
annual discharges.
that these producers should have
Findings. PVC Reactor Discharges.
achieved discharge frequencies
Suspension resins account for the
comparable to the five PVC plants thBt
highest percentage of total PVC
the EPA evaluated in detail.
production. The remaining PVC
Solution PVC Process. Discharge
production is in the form of bulk,
frequency from both reactor and
dispersion and solution resins. (A small nonreactor sources by the single plant
amount of latex resin is produced by a producing PVC by the solution process
process closely related to the dispersion was zero during the period 1981 to 1963.
process.) Examination of relief valve
Previously, this plant experienced as
discharge performance associated with many as two discharges in a 12-month
period. Raoent performance suggests thst preventable discharges have bean limlnatad at this plant With tha
exception of s 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 (1981 to 1983) relief vafve discharge performance data for ' other EDC/VC producers indicates an industry range of 0 to 7 discharges/yr. Information obtained from plants during the review indicated that, where applicable, similar types of equipment, process modifications and perational 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 1981 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 fewer.
Summary ofNumerical 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 causing an exceedence of any numerical limit presented below would be considered a violation without regard to whether any individual discharge was preventable.
Coaowy
Nunancto fcnVt
(1) Qacharpaa tom PVC
ptara (fcrtpOTaicrv. dtapvo\ ton. tx* pOLnMin) 4*} Hrettn
0.035
tfatfvrpMMDC
batch**, not a*0Mn 4
Attftarpai'yr
0.035
dacha-'pat'lOC
ttocfrto
0035
Otc*wpc*/lOC
(B) XontMClPf aotfni___ , OCCS
OufeirvM'IOC
balctM. not it--rtne S
O DtoChtopn* tom PVC
ptortt (aoMion ng) pvw
centra* ptaum) p) tecftarpM ton EDC/VC
JlWtL
1 (tach*p*/yi.
Compliance Provisions. The EPA recognizes that all plants may experience an unavoidable relief valve discharge incident at some time. Examination of relief valve discharge performance by PVC plants with low
TEN 4467
y*dwl Ktglatw / Vo!. 60. No. 0 / Wednesday, January 0. 1965 / Propoacd Ruki
,
discharge frequsnciee Indicated (hit , plants with the k>w*t polymerization batch frequencies typically experience
about one discharge in a 12-month period. The EPA concluded that for inoit plants a 12-month reporting period (rolling every 6-months) waj both
uitable and appropriate for determining compliance with the proposed numerical limJta. For plant* producing only a *mal] amount of a particular resin (i.e., low number of polymerization batches), an
apparent violation of the standard may result from a single discharge occurrence during a 12-month compliance period as described below.
For a PVC plant producing a single resin type to meet the numerical limit for reactor discharges (i.e., 0.035 dischaiges/100 batches), it must experience end a verage of no `more than one discharge per 2,858 polymerization batches over the preceding 12-month period. An average reactor discharge frequency exceeding one discharge per 2,858 batches would be a violation of the standard. However, if the plant made less than 2,858 polymerization batches over the 12-month compliance period, a single discharge occurrence would be an apparent violation of the standard (i.e., the discharge frequency per 100 batches would exceed 0.035). Because Insufficient batches were made, the Reported discharge frequency per 100 batches would not correctly reflect the performance by that planl in comparison to other plants complying with the standard. In rectifying the undue compliance burden posed od plants with small numbers of batches by the discharge/100 batch format and the selected 12-month compliance period, the EPA is proposing to add additional provisions affecting the number of batches used to calculate the discharge frequency. For PVC plants producing less than 2,858 batches of a particular resin, the minimum number of 2.658 batches will be used when determining compliance with the numerical limits.
PVC plants producing more than one resin type must demonstrate compliance separately for reactor discharges occurring from different resin production processes. Only the relief valve discharges and polymerization batches specific to each resin type are considered for determining compliance. However, for determining compliance with the standard for nonreactor discharges, the total number of polymerization batches (regardless of resin type) are counted.
determine the number of jHymerization batches produced for purposes of assessing compliance, the
following guidelines apply- A
"polymerization batch" consists of each aaquenoa of charging VC and other materials to the reactor, besting reactor, contents, polymerization of reactor contents, and removal (be., blowdown) of reactor conttnts. Any batch that la aborted following charging of VC to the reactor is nonetheless counted as a polymerization batch in assessing compliance. For PVC plants producing bulk resin. single "polymerization batch" includes both prepolymerization
and postpolymerization reactor operations.
Discharge frequency can be recorded In two ways. Discharge frequency can be recorded on the basis of discharge events (involving discharges from one or more relief valves) or on individual relief valve discharges. In most cases, plants currently report discharges individually when they occur from relief valves on separate equipment. However, certain equipment such as polymerization reactors that are equipped with multiple relief valves may experience discharges simultaneously from more than one relief valve. Most plants currently report such multiple discharges from a single piece of equipment as a single discharge. Thus, the performance levels serving as the basis f6r the numerical limits represent individual discharges and not multiple discharge events except when they occur from a single piece of equipment For determining compliance with the numerical limits, discharge frequency is to be recorded on the basis of individual discharges except when simultaneous discharges occur from relief valves on the same piece of equipment
A relief valve discharge in considered to be any venting through a pressure relief device to prevent or relieve an overpressure condition from equipment in VC service that results in emissions of VC directly or indirectly to the atmosphere. In determining whether or not a relief valve discharge results in emissions-to the atmosphere, the controlling factor is the ultimate disposition of the gases. Venting to a manifold or header system that ultimately discharges to the atomsphere constitutes a relief valve discharge. If the manifold or header discharges gases through a control device meeting the 10 ppmv VC emission limit, the venting does not constitute a relief valve
discharge. For purposes of reporting compliance
status with the limits, plants will be required to calculate their discharge per batch frequencies with sufficient precision to demonstrate that performance is either equal to. below of in excess of the limits. Based on
operating history, relief valve discharge performance by certain plants Is
expected to be much better than die respective limits. For example, tome new suspension resin PVC plants produce about 5.000 batches during a 12-month compliance period. One and two discharges at one of these plants during a compliance period would result in a discharge performance of 0-02 and 0.05 discharges per 100 batches,
respectively. The second discharge during the compliance period would be `a violation of the proposed 0.035 discharges per 100 batches limit despite the fact that the first discharge would resuit in performance well below the
limit These types of plants were considered in selecting the proposed limits and reporting procedures for relief valve discharges. The result that plants of this type must perform well below the limits in the standard in order to be in compliance is consistent with the proposed limits, which were selected to represent an upper boundary on the
number of allowable discharges intended by the standard. The EPA expects that plants using the best technology and procedures should be able to perform better than the proposed limits.
Reporting Requirements. The current standard for relief valve discharges requires producers to report discharges within 10 days of the incident. The EPA is proposing to eliminate the 10 day reporting requirements and to require reporting of all discharges on a quarterly basis. Although compliance is to be determined on a semiannual basis, quarterly reporting of discharges is appropriate because violations of the standard may occur well before the end of the 8-month period. Quarterly reporting notifies enforcement personnel of potential violations and violations that have already occurred prior to the end of the compliance period so that corrective actions can take place sooner following the end of the compliance period. Information to be included in the semiannual report for individual relief valve discharges is to be reduced to include only the date. time, source, cause and estimated amount of each discharge occurrence. The semiannual report will also inlcude information on compliance status.
In addition, plants will now be required to maintain relief valve discharge records for 3 years, because of the potentially significant increase in the time period between a discharge occurrence knd reporting of the discharge.
Effective Date ofRevision. The current standard as written will remain
TEN 4468
UN
Fndarnl Register / Vol. M.No.1/ Wndnesday, January >, 1885 / Proposed Rate
to effect for relief velve discharges until the propoeed revision* ere promulgated The proposed administrative revisions
do Dot change the elenderd'i original intent end ere intended only to eet limit* to facilitate compliance era enforcement eflorla. Thus, the current standard will continue to be enforced until the revision* ere promulgated.
Strippingin-Reactor Compliance Test Procedure
The test method tor measuring reactor pening loaaea waa developed for resin stripping operations that take place in vessels separate from the reactor. Some PVC plants, including all bulk resin manufacturers, however, do not use separate strippers to remove residual VC from the reBto'produCed Instead,, these plants strip VC from the product resin to the reactor (postpolymerization reactor to the case of bulk resin producers). For plants with reactor resin tripping operations, the concentration of VC to the reactor vapor space, as measured to accordance with the current standard, exceeds the O.Q2g/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 that must be broken before the reactor can be emptied) and before the reactor is completely emptied of PVC resin. According to the Federal Register notice of promulgation of the current VC standard (40 FR 46563. October 21/1976), any VC escaping from the resin after it has been stripped to acceptable levels is not intended to be counted as part of the reactor opening loss. However, the current standard did not include to the measurement method an acceptable method for determining what part of the VC in the vapor space has escaped from The resin after stripping is completed.
The current standard allows bulk resin producers to calculate reactor opening loss emissions from the postpolymerization reactor based on the number of reactor evacuations, the vacuum tovloved and the volume of gas to the reactors. For nonbulk resin producers with reactor resin stripping operations, calculation of reactor opening loss emissions is more complicated due to the presence of WBter vapor to the reactor vBpor space. Currently, waivers of testing for producers with noDbuIk resin stripping operations to the reactor have been granted on a case-by-case basis by (he EPA Regions, typically with the provision that residual VC samples are anlayzed on each batch. A variety of
calculation matbod* are than used So establish the reactor opening foas.
Basad M experience of ths EPA Regional offices, method for determining the reactor opening loss that accounts for stripping to the reactor has been developed for use by all nonbulk resin producers with reactor
resin stripping operations and ia Included to the proposed revisions to the current VC standard. Limitations for ` resin residual and reactor opening foes are added together to give a total allowable VC content from these two sources. The measured resin residual VC and the calculated reactor opening loss would then be added together, and averaged over a 24-hour period according to resin type. If the 24-hour average meets the combined standard, the plant would be considered to be in compliance with both the stripping and the reactor opening loss requirements. .
Leah Detection and Repair
Background. The current standard requires implementation of a formalized program for detection of leaks from equipment to VC service and elimination of these leeks. The formalized program includes a multipoint VC detector and a portable volatile organic compound (VOC). analyzer. The fixed-point monitoring system continuously monitors VC concentrations to the work area around equipment to VC service and sounds an alarm when concentrations exceed a prescribed level The portable monitor is used independently to screen individual equipment components for leaks. Rather than specifying the number of points to be monitored, the sensitivities of the multipoint detector, the VC concentration that indicates a leak, and the actions to be taken to repair leaks, the current standard requires each plant owner or operator to prepare a program plan containing tbese specifications and to submit the plan to the EPA for approval. Plant owners or operators are required to submit data on background concentrations of VC in different areas of the plant to use to determining the VC concentration that should be designated as indicating a leak. Plans, therefore, were tailored by each plant and reviewed by the the EPA Regional Offices.
The EPA found to the review study that differences to leak detection and elimination programs exist among PVC and EDC/VC production plants and miscellaneous sources and that sitespecific differences todade variations to
leak definitions and monitoring practices. The definition and monitoring practices, atoqg with repair practices, are primary influences on the control
affectivenote of leak detection usd repair program#. Sons plants implemented rigorous programs and. other* implemented programs lackbg ' pacific procedures or requirement*.
Accordingly, the effectiveness of leak detection and elimination programs varies among tha plants.
Since the current standard was
promulgated, the EPA has obtained more Information pertaining to the control of emission from equipment leaks. Based on this information and the review of the leek detection and elimination plans being implemented to control emissions of VC, the ETA
decided to specify leak detection and * repair requirements for certain equipment components to VC service. Although information obtained from development of other atandards Indicates that a routine leak detection and repair program with a portable monitor can be an effective emission reduction technique without the requirement of b fixed point monitoring system, the ETA concluded that fixedpoint monitoring systems already to place have uses that justify their retention to the current standard, to particular, fixed-point monitors allow for quick detection of certain large VC leaks that might otherwise go undetected until the next routine portable monitor screening. The EPA recognizes that existing fixed-point monitoring plans will need to be reviewed to light of the leak detection and repair requirements being specified at this time. The complexity of existing fixed-point monitoring plans, in terms of number and distribution of monitoring points, varies greatly among plants. Consequently, some plant owners or operators may want to alter the number of 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 ability to detect large VC leaks.
The proposed revisions are primarily intended to standardize control of VC emissions from equipment leaks. In doing this, the ETA is concerned that existing effective plans not be inappropriately changed. The proposed revisions include provisions that allow plants with existing effective plans to periodically demonstrate the
effectiveness of their plans without additional requirements. Accordingly, the EPA requests comments from Industry representatives concerning the Specific effects of specifying leak
TEN 4469
Fodaral Register / Vol. 80, No. 6 / Wednesday, January 0, 1985 / Proposed Rulea
im
detection and repair requirements on
2-0 percent or less. Any prooeas unit in
effective existing plans.
which tha percentage of leaking valves
Leak Detection and Repair
Is found to exceed UO percent will be
Requirement*. The EPA established leak required to comply with the provisions
detection and repair requirements (40
of Subpart V.
CFR Part 61 Subpart V) (or certain
The Subpart V requirements for
equipment in volatile hazardous air
valves are based on a leak delection
pollutant (VHAP) service on June 6,
and repair program that requires (1)
1964. These requirements were
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 e leak,
apply to pumps, compressors, pressure (3)repair of leaking valves within IS
relief devices, sampling connection^
days after detection of the leak unless
systems, open-ended valves of 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
for 2 successive months can be
standards for VHAP. 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 SubpBrt 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 measured 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
the VC standard to comply with
complete description of the leak
equipment and work practice standards detection and repair requirements, see
consistent with those in Subpart V. For Subpart V (49 FR 23498. June 6,1984).
example, pumps and compressors
- In addition. Subpart V contains
meeting the dual mechanical seal
standards for other types Df equipment
requirements of the currenl VC standard (e.g- flanges, and open ended valves or
will be in compliance with the Subpart lines). Standards for flanges include
V requirements. In addition, the
monitoring with a portable instrument
sampling connection systems
under prescribed procedures within 5
requirements of Subpart V are
days of observing evidence of a
essentially the same as the current
potential leak by visual, audible or other
standard. The use of rupture discs for
means. Open-ended valves or lines are
controlling 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
emissions" 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 as a result 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 end
Piessure 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 and elimination
existed in Section 112. These
requirements in the current VC standard requirements are found in { 81.65(b). In
(40 CFR 61.65(b)(8)(H)). and therefore,
August of 1977. Congress emended
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 2j0 percent are
be established for control of a
fesidered by the EPA to be effectively hazardous air pollutant unless, in the
^Pntrolling VC emissions from leaking judgment f the EPA It is not feasible to
valves. For these process units, the
prescribe or enforce such a standard. An
existing leak detection and elimination emission standard allows for some
program will continue to be allowed
flexibility in complying with the
while the percentage of leaking valvea is standard, since any control technique
that achievas that standard may ba applied. Section 112(e)(2) defines the following conditions under which It U 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 endorce, then the EPA may istead promulgate a design, equipment work practice, or operational standard, or combination thereof.
The EPA has reviewed the design, equipment work practice and operational requirements contained in the current VC standard. The only sources covered by the current standard writh one of the requirements fpr which a
performance standard (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 EPA is reinstating those requirements as set forth in the current standard.
The EPA selected the use of rupture disks as the basis 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 as the use of rupture disks, a "no detectable emissions" limit is feasible. An instrument reading of less than 500 parts per million by volume (ppmv) above a background concentration based on Reference Method 21 can be used to indicate whether equipment leaks have been eliminated: that is. thBt the equipment has "no detectable emissions."
The "no detectable emission" limit would not apply to discharges through the pressure relief device during overpressure relief. (These releases are covered under H 61.64(a) and 61.65(a).) The standard would specify, however, that the relief device be returned to a state of "no detectable emissions" within 5 days after eoch a discharge. The standard would further require an annual test to verify the "no detectable, emissions'* status of the pressure relief devices and a test after each over
TEN 4470
1112
Federef Eegtotf / Vel. ID. No. / Wedneedey, ^artoery V, 1W5 / Fropoocd Futos
pressure relief. This adaakiistrath*
tha I hoar evaragtg period la toleaded . canrtod eat to two separate uresis lb
change implements the beat* (this
to clarify that the 10 ppm standard
reaction Is Initiated to toe
ataiutord consistent with foe
apphas to VC eerisaiona b all axheust
"prepolymerizatkm" reactor and toe
requirements of Section 112(e).
gas stream covered by tha 10 ppasv
reactor oontenle ere tbee transferred to
Miscellaneous Revisions
Bated on discussions with the EPA regional personnel regarding their experience in administering the current VC standard, the EPA is proposing several additional administrative revisions that would facilitate compliance and enforcement efforts associated with the current standard. Three revisions represent minor changes to the itandard. A brief description of these administrative revisions antTfoe basis for making them follows.
Definition of Leak. Exhaust Cos and Relief Valve Discharge. Functional definitions of *3eak", "exhaust gas" and "relief valve discharge" are being added to the standard to clarify the applicability of the standard to each of these types of VC emissions. During their 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 Bid industry personnel with a dear understanding of which pari of the standard applies to any given discharge of VC emissions to the atomosphere.
Definition of EDC and VC Purification. In the past, some plants have misioterprented which equipment
requirements. Including any orailrol device bypass streams. Requirements for calmatii$ the VC content in bypassed amissions for purposes of reporting VC emissions in excess of the 10 ppmv standard art being added to the regulation. The EPA may use these calculations along with continuous emission monitoring results as Indications of noncompliance if they
bow dearly that emissions in excess of the 10 ppmv requirements occurred.
The second clarifying revision to the 10 ppmv standard tovetres the Specification that the 10 ppmv requirements apply to eadi exhaust gas stream from the covered equipment. The purpose of this revision it to clearly prohibit plants from using dilution with other exhaust gas streams at a technique for meeting the 10 ppmv requirement This revision is not intended to prohibit the common practice of combining two or more exhaust gas streams in a common header loading to a control device. According to the revised 10 ppmv requirements, combining an exhaust gas stream containing more than 10 ppmv VC with another exhaust gaa stream containing less than 10 ppmv VC is allowed only when the combined stream is ducted to the control device.
Relief Voire Definition. The current standard for relief valve discharges was intended to apply not only to safety relief valves but to all types of pressure
the "poetpolymerixettoe*' snartnr adhere toe reaction is completed. Stripping of residual VC In bulk resin to performed following tbe postpolyrnarizaUon step to the reactor *easel. Tbe postpolymertoation reactor generally to opened after every belch and moat comply with toe reactor opening loe# limits specified to the standard. Because the prepdymerixation reactor to opened less frequently and because determination of gross product (for reactor opening loss estimation} to difficult, ibe EPA baa allowed plants to meet tbe equipment opening requirements for minimizing VC emissions from polymerization reactor openings. The reactor opening loss requirements ere being revised at this, time to specifically exclude prepolymerization reactors. Accordingly, VC emissions from all opening of prepolymerization reactors will be subject to the equipment opening requirements. This revision to intended to clarify and improve the consistency of the equirements of tbe revised standard ss they apply to bulk PVC resin producers in light of actual industry practice. No redaction in VC emission control stringency will result from the change In requirements far prepolymerization reactors.
Inprocess Wastewater Requirements for Gasholder Seeds- Under the current standards, tbe VC content of inprocess wastewater must be reduced to less
components are included in EDC purification and VC purification
relief devices. A definition of "relief valve" is being proposed under the
than 10 ppm exposure of the wastewater to the atmosphere. In the case of
processes with the result that emissions revised standard to clarify that the
gasholder water seals the VC content in
from certain eqaipment intended to be current relief valve discharge standard the exposed water seal may exceed 10
covered by the standard may not have bIso applied to rupture discs, manual
ppm during normal operation of the
been controlled. The definitions of "EDC vents and other pressure relief devices gasholder. Experience since the
purification" and "VC purification" are that vent to the atmosphere to protect
standard was promulgated indicates
being revised to clarify that all
process equipment from unsafe
that compliance with tbe atmospheric
purification equipment following EDC
overpressure conditions. The definition exposure limit is not practicable for this
and VC formation were subject to
of relief valve in the proposed standard particular inprocess wastewater source.
regulation under the current standard.
it nol intended to include pressure
Consequently, the definition of
10ppmv Standard. Twe clarifying
control valves used to control flow to an inprocess wastews ter is being revised to
revisions arc being made to the 10 ppmv incinerator or other control device.
exclude the exposed water seel 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 10 included in the definition of relief valve the gasholder teal.
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 10 ppmv requirements. Specifying that
are pressure control systems such as polymerization reaction shortstop systems or refrigerated water systems which ad to reduce pressure by means other thsD venting.
Elimination of30-Day Limit on Equivalency Requests. The current standard specifies a 30-day limit for existing sources to submit requests for use of equivalent methods. Because such
emissions may not exceed 10 ppmv over
Reactor Opening Lem Requirements
a limit poses a restriction on initiative
a 3-hour averaging period clarifies that for Bulk PVC Basin Producers- Bulk
by industry to develop alternative, end
instantaneous compliance with the 10
PVC resin production differs from
potentially mare effective, control
ppmv standard is not an intended
production of other types of PVC resin measures, the 30-day Iannation is befog
requirement. Moreover, specification of in that the polymerization reaction is
ehmfoated.
. FjlwaJ lafkslm / Vol ML No. e / Wadnanday, janotry a 1966 / Proposed Rides
ms
Other. In addition to tbi nviiiou
Increase or decrees# ht dw overall
srvialons do aot increase the oast of
described above, a review ! (he
recordkeeping and reporting currently
comp!trace with dm atamdard.
reoordktaping ad reporting requirement* of tha current standard
practiced by Individual plant*. The EPA concluded that lb* current
Fubbc Hearing
ai performed to identify .way* to aaae racordkesplag requirements, as
If requested, a public bearing wiB be
recordkeeping and reporting burden on specified in 40 CFR 11.71. are still
held to discus* the proposed revisions to
plant* ana to identify any additional
appropriate. However, the EPA is
the VC standard In accordance with
reoordkeeptng and/or reporting need*. proposing to extend the current
Section* tl2{bXlK6) and 907{d)(5} of the
The EPA Identified two area* where the recordkeeping requirements for all
Clean Air Act Person* wishing to make
reporting burden on plant* could be
reporting activities from 2 to S years.
oral presentation* on the proposed
reduced. The current reporting
The net Impact of the revised
revision* should contact the EPA at the
requirements for residual VC monomer recordkeeping and reporting
specification* and reactor opening
' requirement* proposed by the EPA is
sddrass given In the AKMtttit section of this preamble. Oral presentations will
measurement* require that result* of all compliance tests be reported In semiannual reports. The EPA is proposing to allow plants to report only test results that show exceedences of the respective standard*. If ao exceedence* occur, plants will be required to Indicate that fact in the semiannual report This type of exception reporting U currently allowed for demonstration of compliance with the 10 ppmv standard for process vents. The second area is the requirement to report relief valve discharges within 10 days of their occurrence, lbs EPA is proposing to allow plants to report relief valve discharge occurrences on a quarterly basis rather than within 10 . days of their occurrence. Furthermore, die reporting requirements for relief reive discharges have been streamlined by dropping the need to report action* 'taken and implemented preventive measures for each discharge. Information on the date, time, source, cause and estimated amount of , ( individual relief valve discharge will be included with the semiannual reports along with information on compliance status.
Additional semiannual reporting requirements being added for PVC producer* are the number of reactor openings and the design capacity number of polymerization batches (or each resin type. This requirement will provide general Information to facilitate review of industry-wide compliance
estimated to be a decrease in a paperwork burden of about 2.8 personyears.
It should be noted that all Comprehensive Environmental Response, Compensation, and liability Act (CERCLA) Section 101(14} . hazardous substance* such as vinyl chloride are subject to reporting requirement* under Section 103(a) of CERCLA. CERCLA requires that persons in charge of vessels or facilities from which hazardous substances have been released in quantities {BQ*} immediately notify the National Response Center (NRCl of the release. The toll-free 24-hour telephone number of the NRC is 800-424-6602 and in Washington, D.C. metropolitan area it is (202) 428-2675. (See CERCLA Section 103 and 48 FR 23552, May 25,1983.)
Vinyl chloride was assigned a statutory 1 pound reportable quantity under Section 101(14) until adjusted by regulation, and is presently undergoing assessment for both chronic toxicity and carcinogenicity, hi RQ will be adjusted pending the outcome of these reviews by the Office of Emergency and Remedial Response. Federally permitted release*
under CERCLA (See CERCLA Section 101(1) and 48 FR 23552} are not subject to CERLA notification requirements or liabilities. However, releases of hazardous substance* that are not subject to a permit or control regulation must be reported.
Regulatory Flexibility Analysis
be limited to 15 minutes etch. Any member of the public may file e written etatement before, during, or within 90 days after &e hearing. Written statements should be addressed to die Central Docket Bectkm address given in the ADMtcttcg section of this preamble.
A verbatim transcript of the hearing and written statement* will be available for public inspection and copying during normal working hours at the EPA's Centra] Docket Section to Washington, D.C. (see ttPoaaitl section of this preamble).
Docket
The docket is an organized and complete file of all the information submitted to or otherwise considered by the EPA in the development of this proposed rulemaking. The principal purposes of the docket are: (1) To allow interested parties to identify and locate documents so that they can effectively participate in the rulemaking process, and (2) to serve as the record in case of judicial review (except for interagency review materials (5 907(dH7(A)p.
Miscellaneous
In accordance with section 117 of the Act. publication of this proposal was preceded by consultation with appropriate advisory committees, independent experts, and Federal departments and agencies. The Administrator will welcome comments on all aspects or the proposed
status during past reporting periods.
The Regulatory Flexibility Act of 1960 regulation, including health, and
Specific recordkeeping and reporting requires that adverse effects of ell
economic and technological issues.
requirement* are included a* part of the Federal regulations upon small
The information collection
revisions to the leak detection and
businesses be identified. According to
requirements in this proposed rule have
repair requirements. The recordkeeping the current guidelines ef the Small
been submitted for approval to the
requirements include preparation of an Business Administration (SBA), a small Office or Management and Budget
initial log to record equipment
business that produces or processes VC (OMB) under the Paperwork Reduction
component identification, physical
is one that has 500 employees or less.
Act of 1980.44 U.S.C. 3501 et teg.
tagging of equipment components which Currently, none of the existing
Comments on these requirements should
leak, and maintaining a record of
producers or processors that are
be submitted to the Office of
equipment leak* and repair action.
affected by the standard are estimated Information and Regulatory Affairs of
Included hi the reporting requirement*
to be small by this.definition. Sines none OMB. marked "Attention: Desk Officer
ar^he number of equipment leaks and of the companies meets the SBA
for EPA". ju well a* to the EPA docket
ti^Rpcir status of leaking component*. definition of small business, no
described above. The final rule will
EflIKding on the particular leak
regulatory flexibility analysis is
respond to any OMB or public
detection and repair program in place, required. Even if an analysis were -
comment* oa the bdbnaaboa collection
these requirement* may represent an
required, the proposed administrative
requirement*. TEN 4472
11*4
Federal Raglslw / Vol, BO, No. 6 I Wednesday. January 9,1065 / Proposed Rule*
Under Executive Order 12291, the EPA product containing vinyl chloride or
limits art prescribed ta 16142 (a) and
must fudge whether regulation te
polyvinyl chloride but which has not
(b) : 16143(a); 161.64 (aXU (a)(2). (b).
"major" end therefore eubject to the requirement of e Regulatory Impact
been discharged to a wastewater treatment process or discharged
(c) and Id): 16145 (bJUKH). (b)(2). (b)(5), (b)(6)(ii) and (b)(0)(U). A leak as defined
Analysia. Thi regulation ie not major becauee: (1) The national annualized
untreated as wastewater. Gas-holder teal water is not tnprocess wastewater
In paragraph (w) of this section it not an exhaust gas.
compliance coete, including capital
chargee leeulting from the etandarda
total leti than SlOO million; (2) the
standards do not cause a major increase
in prices or production costs; and (3) the
standards do not cause significant
adverse effects on domestic competition,
employment, investment productivity,
innovation or competition in foreign
markets.
_
This regulation was submitted to tbe
Office of Management and Budget for
review as required by Executive Order
12291. Any comments from OMB to EPA
and any EPA response to those
comments are included in Docket
Number A-81-21. The docket is
available for public inspection at EPA's
Central Docket Section, West Tower
Lobby, Gallery 1, Waterside Mall. 401 M
Street SW,, Washington, D.C. 20460.
Pursuant to the provisions of S U.S.C.
005(b), I hereby certify that this ride, if
promulgated, will not have a significant
economic impact on a substantial
number of small entities because no
amali entities are affected.
list of Subjects in 40 CFR Part 61
Air pollution control. Asbestos, Beryllium. Hazardous materials, Mercury, Vinyl chloride.
Dated: Dated December 31, IBM. Ahh Aim,
until it ia removed from the gasholder.
ft 6
(1)"In vinyl chloride service" means that a piece of equipment either contains or contacts a liquid that is at least 10 percent vinyl chloride by weight or a gas that Is at least 10 percent by volume vinyl chloride as determined according to the provisions of | 6147(h). The provisions of | 6147(h) also specify bow to determine that a piece of equipment is not in vinyl chloride service. This definition must be used in place of the definition of "VHAP service" in Subpart V of this part
ft
ft 4
(o) "Ethylene dichloride purification" includes any pert of the process of ethylene dichloride production which follows ethylene diddoride formation.
(p) "Vinyl chloride purification"
includes any part of the process of vinyl chloride production which follows vinyl chloride formation. ft ft ft ft
(v) "Relief valve" means each pressure relief device including pressure relief valves, rupture disks, manual vents and 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.
(y) "Relief valve discharge" means any nonleak discharge through a relief valve.
(z) "3-hour period" means any three consecutive 1-bour periods (each hour commencing on the hour).
9. By changing " all exhaust gases" to "each exhaust gas stream" and making other minor clarifying revisions in I 6142(a), | 61.63(a). and | 61.64 (a)(1), (b). (c) and (d) as follows:
141.62 Emission standard for etttytsne dlchlorMo plants.
(a) Ethylene dichloride purification: The concentration of vinyl chloride In each exhaust gas stream from any equipment used in ethylene dichloride 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 | 61.65(a). This requirement does not preclude combining of exhaust gas streams provided tbe 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 as provided in I 61.66. This requirement does not apply to equipment that has been opened, is out of operation, and mel the requirement in | 61.65(b)(6)(i) before being opened.
Acting Administrator.
(w) "Leak" means any of several
'ft
ft
6*
PART. 61--(AMENDED]
It U proposed to amend 40 CFR Part 61 aa follows:
3. The proposed changes to 40 CFR Part 61 proposed at 42FR 26154, June 2, 1977 are withdrawn.
2. By revising the definitions in existing ( 614l(j), (1), (o) and (p) for "in process wastewater", "in vinyl chloride service", "ethylene dichloride purification" and "vinyl chloride purification" and by adding definitions for the terms "relief value", "leak", "exhaust g8B*\ "relief valve discharge and "S-hour period" in new paragraphs
(w). (x), (y) and (z).
|141 Definitions.
events that indicate interruption of confinement of vinyl chloride within process equipment Leaks include events regulated under Subpart V of this part such as: (1) An instrument reading of 10,000 ppm Dr greater (2) indications of liquid dripping; (3] a tensor detection of failure of a seal system, failure of a barrier fluid system, or both; and (4) detectable emissions as indicated by an instrument reading of greater than 500 ppm above background. Leaks also include events regulated under
| 61.65(b)(8)(i) of detection of ambient concentrations in excess of background concentration. Emissions of vinyl chloride not regulated under I 6141 (a) and fb); | 61.63(a); | 6144 (a), (b), (c), (d). (e) and (fi: and t 61.65 (a) and (b)(1).
f 61.63 Emission standard lor vinyl cMorida ptsnts.
An owner or operator of a vinyl chloride plant shall comply with the requirements of this section and $ 61.65
(a) Vinyl chloride formation and purification: The 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-hour period or as determined in accordance with { 6147(g)(1)). except as provided in | 61.65(a). This requirement does not preclude combining of exheust gas streams provided the combined steam is ducted through a control system from which the concentration of vinyl
4 4
(b)(2). (b)(3), (b)(4), (b)(5). (b)(6). (b)(7)
chloride in the exhaust gases does not
(j) "Inprocess waslerwater" means
and (b)(B) shall be considered a leak. A exceed 10 ppm, or equivalent as
any water which, during manufacturing relief valve discharge is not a leak.
provided in | 61.66. This requirement
pr processing, comes into direct contact
(x) "ExhBusI gas" means any offgas
does not apply to equipment that has
with vinyl chloride or polyvinyl chloride discharged directly or ultimately to the been opened, is out of peration. and
or results from the production or use of atmosphere that was initially contained met the requirement in f 6145(b)(6)(i)
any raw material, intermediate product, in or was in direct contact with the
before being opened.
finished product, by-product, or waste
equipment for which 10 ppm emission TEN 4*473 ' '
Ttdmwi ttagbtoc / Vol. *0, No, I / WadnoeAiy, )tnuary >. 1985 / Propped Rule*
1116
161.64
(2) The reactor opening Ism from each 7. By revising paragraph (a) to | NAB
reader is acrtlo exceed WO g vinyl
as follows:
An wmr or operator of a polyvinyl chloride plant shall comply with 6m requirements of thia wedon end | NM.
(a) Reactor. Tbt following
chiarida/kg (000002 lb vinyl chloride/lb) of poly vinyl chloride product, except aa
provided in paragraphs (f)(1) and (f)(2) of thia aectioo. srith the product
16166 Ewtoalon standard toe ethytaoa dkttorida, Mnyt chloride vtd potyrinyl enfonov plants
requirement* apply to reactora:
determined an a dry solids basis. This
An owner or operator of an ethylene
(1) The concentration of vinyi chloride in each exhaust gas stream from each reactor to not to exceed 10 ppm [average for 3-bour period or aa determined in
requirement doea not apply to prepolymerlxsbon reactors in the bulk process. This requirement doea apply to postpolymerixation reactor* in the bulk
dichloride, vinyl chloride, and/or polyvinyl chloride plant shall comply with the requirements of this aection.
(a) Relief valve discharges. (1)
accordance with 161.67(g)(1)), except aa
provided in paragraph (aX2) of thia
aection and | 61.05(a). m
_
process, where the product means the gross product of prepolymerixation and postpolymerixa tion. 6666
Polyvinyl chloride plants (suspension, dispersion, latex, and bulk processes).
(i) Reactor. The number of discharges to the atmosphere from relief valves on
(b) Stripper. The concentration of vinyl chloride in each exhaust go* 'stream Grom each atripper to not to
6. By revising paragraph (e) introductory text and adding paragraph (e)(3) to 161.64 as follows:
polyvinyl chloride reactors in vinyl chloride service is not to exceed the following limits except as provided in
exceed 10 ppm (average for J-bour period or aa determined in accordance with | 61.67(g)(1)), except aa provided in | 61.65(a). Thia requirement doea not apply to equipment that haa been opened, to out of operation, and met the requirement in 16165[b)[6)(i) before being opened.
(c) Mixing, weighing, and holding containers. The concentration of vinyl chloride in each exhaust gat atream from each mixing, weighing, or holding container in vinyl chloride aervice which precedes the stripper (or die reactor if mhe plant has no stripper) in die plant process flow is not to exceed 10 ppm (average for 3-bour period or as determined in accordance with
f 1144 Emission Standard lor polyvinyl ChloriOe plants.
**** a
(e) Sources following the stripperfsj. The following requirements apply to emissions of vinyl chloride to die atmosphere from the combination of all sources following the stripperfa) (or the reactor(s) to the plant has no etripper(s)] in the plant process flow including but not limited to, centrifuges, concentrators, blend tanks, filters, dryers, conveyor air discharges, baggers, storage containers, and inprocess wastewater, except as provided in paragraph (I) of this section: *
paragraph (a)(l)(iii) of this section. For all reactors producing suspension resins within a PVC plant, the number of relief valve discharges is not to exceed 0.035 discharges per 100 polymerization batches nor 4 discharges per year. For all reactor* producing dispersion and latex resins within a PVC plant, the number of relief valve discharges to not to exceed 0.035 discharges per 100 polymerization batches. For all reactors including prepolymerixation and postpolymeriZBtion reactors, producing bulk resins within a PVC plant the number of relief valve discharges to not to exceed 0.035 discharges per 100 polymerization batches.
(ii) The number of discharges to the
| 61.67(g)(1)), except aa provided in
(3) The provisions of this paragraph
atmosphere from relief valves on
1 61.65(a). This requirement doea not
apply at all times including when off-
equipment (excluding polyvinyl chloride
apply to equipment that baa been
specification or other types of resins are reactors) in vinyl chloride service is not
opened, is out of operation, and met the made.
to exceed 0.0Z5 discharges per 100
requirement in | 61.65(b)(6)[i) before being opened.
(d) Monomer recovery system. The
6. By adding paragraph (f) to | 61.64 as follows:
polymerization batches nor 3 discharges per year except as provided in paragarph (a)(l)(iii) of this section.
concentration of vinyl chloride in each exahust gaa stream from each monomer recovery system to not to exceed 10 ppm
16144 Emission standard tor potyvtnyl chloride plants *
(iii) The limits specified in paragraphs (a)(l)(i) and (a)(1)(H) of this section may be exceeded when only one relief valve
(average for S-hour period or aa
(f) Reactor used os stripper. When a
discharge to the atmosphere occurs
determined in accordance with
nonbulk resin reactor to used as a
during the 12-month period preceding
S 61.67(g)(1)). except as provided in
stripper this paragraph may be applied the close of the 6-month reporting
t 61.65(a). This requirement does not
in lieu of ( 61.64 (a)(2) and (e)(1):
period.
apply to equipment that has been
opened, to out of operation and met die
requirement in | 61.65(b)(6)(i) before
being opened. *
(1) The weighted average emissions of vinyl chloride from reactor opening loss and all sources following the reactor used as a stripper from all grades of polyvinyl chloride resin stripped in the
(2) Polyvinyl chloride plants (solution and other continuous PVC production processes). The number of discharges to the atmosphere from relief valves on all equipment in vinyl chloride service is
4. By revising existing paragraphs
reactor on each calendar day may not
not to exceed 1 discharge per year.
{ 61.64(a)(2) and by removing (a)(3) as exceed:
(3) Ethylene dichloride and vinyl
follows:
(i) 202 g/kg (0.00202 Ib/lb) of polyvinyl chloride plants. The number of
161.64 Emission standard lor potyvtnyl chloride plants.
An owner or operator of a polyvinyl ^foride plant shall comply with the ^Biremento of this aection and i 6L65.
^a) Reactor. The following requirements apply to reactors:
chloride product for dispersion polyvinyl chloride resins, excluding latex resins, with the product determined on a dry aolids basis.
(ii) 0.42 g/kg (0.00042 Ib/lb) of polyvinyl chloride product for all other polyvinyl chloride resins, including latex resins, with the product determined on a
discharges to the atmosphere from relief valves on equipment in vinyl chloride service to not to exceed 4 discharges per year.
(4) Each relief valve discharge that contributes to a relief valve discharge frequency in excess of any fimit prescribed in paragarph* (a)(1), (a)(2)
dry solids basis.
and (a)(3) of this paragraph constitutes
live
Federal Register / Vol BO, No. 6 / Wednesday, January V, 1965 / Proposed Rulas
*
an individual violation of the respective rotating compressors in vinyl chloride
(Hi) It provides for an acceptable
limit
aervioe are to be minimized by installing calibration and maintenance schedule
(5) For every relief valve discharge to compressors with doubls mechanical
for the vinyl chloride monitoring system
the abnoaphere, the owner or operator seals, or equivalent es provided In
and portable hydrocarbon detector. For
ehall record the Identity of the aource,
161.66. If double mechanical seals are
the vinyl chloride monitoring system, a
the date and time of the discharge, the
used, vinyl chloride emissions from the daily span check Is to be conducted with
cauee of the discharge, the approximate seals are to be minimized by
a concentration of vinyl chloride equal
-total vinyl chloride loaa during the
maintaining the pressure between the
to the concentration defined as a leak
diecharge, and the method uaed for
two seals so that any leak that occurs is according to paragraph fb)(8)(vi) of this
determining the vinyl chloride loaa. Thia into the compressor, by ducting any
section. The calibration is io be done
information shall be submitted in
vinyl chloride between the two seels
with either
writing to the Administrator aa part of the reporting requirements of paragraph | 61.70. Thia information ahBli be retained and made availableior_. inspection by the Administrator for a minimum of 3 years.
6- By revising paragraphs (b)(3), . (b)(6)[i), (b)[8)(iii). (b)(e)(iv) and (b)(8)(vi) to | 61.65 as follows:
19145 Emission standard for ethylene dichtortde. vinyl chloride and polyvinyl ehtorids 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
(1) * * * (2) * * * (3) Leakage from pump, compressor,
through control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm; or equivalent at provided in | 61.86.
(iv) Reciprocating compressors. Vinyl chloride emissions from seals on all reciprocating compressors in vinyl chloride service ace to be minimized by installing double outboard seals, or equivalent as provided in I 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 teals to 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 | 61.66
(A) A calibration gas mixture prepared from the gases specified in sections 6.2.1 and 6.22 of Test Method 108 and in accordance with section 7.1 of test Method 106, 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 a maximum shelf life for each cylinder so that the concentration does not change greater than 5 percent from the certified value. The 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
and agitator seals: (i) Rotating pumps.
(v) Agitator. Vinyl chloride emissions gas chromatograph is used as the vinyl
Vinyl chloride emissions from seals on from seals on all agitators in vinyl
chloride monitoring system, these gas
all rotating pumps in vinyl chloride
chloride service are to be minimized by mixtures may be directly used to
service are to be minimized by installing installing agitators with double
prepare a chromatograph calibration
sealless pumps, pumps with double
mechanical seals, or equivalent as
curve as described in section 7J of Test
mechanical seals or equivalent as
provided in | 61.66. If double
Method 106. The requirements in section
provided in { 61-66. If double
mechanical aeals are used, vinyl
6.2.S.1 and 5.24.2 of Test Method 106 for
mechanical teals are used, vinyl
chloride emissions from the seals are to certification of cylinder standards and
chloride emissions from the seals are to be minimized by maintaining the
for establishment and verification of
be minimized by maintaining the
pressure between the two seals so that calibration standards are to be followed.
pressure between the two seals so that any leak that occurs is into the pump; 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 S 61.66.
(ii) Reciprocating pumps. Vinyl chloride emissions from seals on all
any leak that occurs is into the agitated vessel; by ducting any vinyl chloride between the two seels 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 S 61.66. *9
(8) Leak detection and elimination.
(iv) The location and number f 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 and physical layout of the plant
ta*
(vi) It contains e definition of leak
reciprocating pumps in vinyl chloride
(i) It includes a reliable and accurate which is acceptable when compared
service are to be minimized by installing vinyl chloride monitoring system for
with the background concentrations of
double outboard seals, or equivalent as provided in S 61.66. If double outboard
detection of major leaks and identification of the general area of the
vinyl chloride in the areas of the plant to be monitored by the vinyl chloride
eals are used, vinyl chloride emissions plant where a leak is located. A vinyl
monitoring system. Measurements of
from the seals are to be minimized by
chloride monitoring system means a
background concentrations of vinyl
maintaining the pressure between the
device which obtains air samples from chloride in the areas of the plant to be
two seals so that any leek that occurs is one or more points on a continuous
monitored by the vinyl chloride
into the pump; by ducting any vinyl
sequential basis and analyzes the
monitoring system are to be Included
chloride between the two seals through samples with gss chromatography or, if with the description of the program. The
a control system from which the
the owner or operator assumes that all definition of leak for a given plant may
concentration of vinyl chloride in the
hydrocarbons measured are vinyl
vary among the different areas within
exhaust gases does not exoeed 10 ppm; chloride, with infrared
the plant and is also to change over time
or equivalent at provided in f 61.66.
spectrophotometry, flame ion detection, as background concentrations in the
(iii) Rotating compressor. Vinyl chloride emissions from seals on all
or an equivalent or alternative method. a
plant are reduced-
TEN 4475*
Faderml Be^star / V 1. JO. No. e / Wednesday, January 9, 1865 / Proposed Rules
1197
. rr\u,V1* P4rm*r,Ph M) to 16146 as follow*: -
M1JC bMon etandwtf lor ethytana *f*aorVd, vinyl oNortds and polyvinyl
(b) Fugitive emission sources. ** i
(4) Leaks from relief ratves. Vinyl chloride emisioni due to leak* from each relief valve on equipment in vinyl chloride aervice shall comply with | 61.242-4 of Subpart V of this part. * f
10. By revising paragraph (b)(7) of S 6145 a* follow*:
|4146 Emission standard for ethytana dtchtorwe, vtnyt eWorld* and polyvinyt cWortde plants. '
> < >
(b) Fugitive emission sources. *
(7) Samples. Unused portions of ' sample* 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.
11. By revising paragraphs (b)(6) introductory text, (b)[8)[ii). and (b)(B)(v) to | 6145 as follows:
(6145 Emission standard for ethytana dtchtortda, vinyl eWorld* and potyrinyl chloride plants. 64*4
(b) Fugitive emission sources.
4 6 4 44
(8) Leak detection and elimination. Vinyl chloride emissions due to leaks from equipment in vinyl chloride service are to be minimized by instituting and implementing s 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 | 61.11. Approval of a program will be granted by the Administrator provided he finds:
(i) * * * (ii) It includes a reliable and accurate portable hydrocarbon detector to be used consistent with the provisions of Subpart V of this part An owner or operator is exempt from $ 61442-l(d), I 61442-7 (a), (b) and (c). 1 61446 and 61447 of Subpart V of this part for any
Erocess unit in which the percentage of taking valves is demonstrated to be equal to r less than 2-0 percent, as
detsmlnsd in accordance with the following:
(A) A performance test as specified in paragraph (b)(8)(li)(C) of this section shall be conducted initially within 90 days of the effective date of these regulations, annuity and at times requested by the Administrator.
(B) For each performance test, a minimum of 200 or 90 percent of the total valves in VOC service (si defined in 160.481 of Subpart W of Part 60) within the process unit shall be randomly selected and monitored within 1 week by the methods specified in 161445(d) of Subpart V of this part If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. The leak percentage shall be determined by dividing the number of valve* In VOC service for which leaks are detected by the number of tested valves in VOC aervice.
(C) If a leak is detected, it shall be repaired in accordance with 161442-7 (d) and (e) of Subpart V of this part
(D) The results of the performance test hall be submitted in writing to the Administrator in.the first semiannual report following the performance test as part of the reporting requirements of {6140.
(E) Any process unit in which the 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. * 44
(v) It contains a plan of action to be taken when a leak Is detected consistent with Subpart V of this part
12. By revising | 6146 as follows:
14. By revising paragraphs (g)(3)
introductory text (g)(3)(l). and (g)(3)(IU) of 16147 as follows:
|6147 Emission teats. t66
ter * (3) When a stripping operation is nsed to attain the emission limits in 16144 (e) and (f). amissions are to be determined using Test Method 107 as follows:
(I) The number of stripper* (or reactors using as strippers) and samples and the types and grades of resin to be sampled are to be determined by the Administrator for each individual plant at the time of the test based on the plant's operation.
(ii) * *
(iii) The corresponding quantity of material processed by each stripper (or . reactor used as a stripper) is to be determined on a dry solids basis and by a method submitted to and approved by the Administrator.
15. By revising paragraph (g)(5) Introductory text and adding paragraph (g)(6) to | 6147 as follows:
16147 Emission tests.
** * * *
te) * * '
(5) The reactor opening loss for which an emission limit is prescribed in i 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.
**
*a
*
|6146 Equivalent equipment and procedures.
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 those prescribed for compliance with a specific paragraph of this subpart.
13. By revising paragraph (f) of f 61.67 as follows:
|4147 Emission tests.
(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 { 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:
46 *4 6
(f) The owner ot operator shall retain at the plant and make available, upon request for inspection by the Administrator, for a minimum of 3 year*, records of emission test results and other data needed to determine emissions.
(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
(C) Die reactor temperature PC) at end of strip from plant instrument
* PEN 4476
llftft
Fadaral RtgUl* / VoL BO. No. 6 / Wednesday, January ft. 1S65 f Propoaed RuJe>
(li) For aach batch stripped In the reactor, the following Information Is to be determined;
(A) The vapor pressure (mm Hg) of water in the reactor at and of strip from the following table:
(PPVC)fRVBV)(1.002) c-iPPMvcyio^+
(Fvcwgrs+rn
where:
mpa Imp** *rc
frto Mper r*-
xs
fMPX Wis--rsw*r
V*ft0por
5 ***fQ
HO
sawn
c
C-| vinyl chloride/kg polyvinyl chloride product
PPMVC-concentration of vinyl chloride in r*in after stripping, in ppm
10**--conversion factor for ppm
40 S6J 41 SSJ 42 su 43 LI 44 mjs m n.t 46 I6S 47 7S.S 41 S3? 4ft 6.0 0 2.5 ftl 17.2 S3 021 13 107.2 * 112.5 K 111.0 M 123J 17 ms m 061 w 142.6 so 149.4
1 1544 a? NM . m 1)U u DU SB 1V7J as M6.1 7 106.0 6 sue m 2237 *70 mi 71 243.1 72 SMS IS ami 74 r77j IS MSI 7* om 77 214.1 IS xn3 n sie to 56.1 1 60 7
at as *4 66 ^M *7 m m
to
*i
to to ** m Si ST m SO 700
M4J 400* 41SS
PPVC-parti*1 pressure of vinyl diloride determined according to paragraph .
(g)[6)(il)[B) of this section, hi mm Hg
*m RVSV--reactor vapor spaos volume
4S0J determined according to paragraph
4167 407.1 *061
' (8)(6)[ii)(C) of this section, is m* 1,002-Ideal gs* constant hi g--*K/mm Hg--
StfiJ m* for vinyl chloride
*440 ' PVCW--dry weight of polyvinyl chloride in
07.0 Ml *10* SB*
reactor from recipe, hi kg 273-conversion factor for X to *K RT--reactor temperature, hi *C
SSTJ
SSI 707J
16. By adding paragraph (h) to | 61.67
733J as follows:
MOO 6
(h)(1) Each piece of equipment within
a process unit that can reasonably
(B) The partial pressure (mm Hg) of vinyl chloride in reactor at end of strip from the following equation:
contain equipment in vinyl chloride service b presumed to be in vinyl chloride service unless an owner or operator demonstrates that the piece of
FPVA--780--RV--VPW
Where:
PFVC--partial pressure of vinyl chloride, in mm Hg
TOO=atmospheric pressure at O'C, hi nun Hg RV--absolute value of reactor vacuum, in
mm Hg VPW --vapor pressure of water, in mm Hg
equipment is not in vinyl chloride service. For a piece of equipment to be considered not in vinyl diloride 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 gas streams. For purposes of determining the percent vinyl chloride
(C) The reactor vapor space volume (m1) at end of strip from die following equation:
content of the process fluid that Is contained in or contacts equipment, procedures that conform to the methods described in ASTM Method D-2267
(incorporated by reference as specified
in | 61.38) shall be used.
be revised only after following the procedures in paragraph (h)(1) of this section.
(3) Samples used fn determining the percent vinyl chloride content shall be representative of the process fluid that b contained In or contacts the equipment
17. By adding paragraphs (d). (e) and (f) to | 61.68 as follows:
181At Entbston monitoring4
(d) When exhaust gas(es). having * emission limits that are subject to the requirement 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 amission shall be calculated (in unite of each applicable emission limit) by best practical engineering judgment based on the discharge duration and known VC concentrations in the affected equipment as determined in accordance with | 61.67(h) or 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 of time that emissions were continuously monitored and that emissions bypassed the continuous monitor) for purposes of reporting excess emissions under | 61.70(c)(1).
*33
where: RVSV-reactor vapor space volume, fan1 RC--reactor capadty. in m* WV--volume of water in reactor from recipe,
in m* PVCW --dry weight of polyvinyl chloride in
reactor from recipe, in kg 833 - typical density of polyvinyl chloride, in
kg/in'
(iii) For each batch stripped in the reactor, the combined reactor opening loss and emissions from all sources following the reactor used as a stripper Is to be determined using the foDowit^ equation:
(2X1) An owner or operator may use engineering Judgment rather than the procedures in paragraph (h)(1) of this section to demonstrate that the percent vinyl ddoride content does not 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 dearly does not exceed 10 percent When an owner or operator and the Administrator do not agree on whether a piece of equipment b not in
vinyl chloride service, however, the procedures in paragraph (h)(1) of this section shall be used to resolve the disagreement
fii) If an owner or operator determines that a piece of equipment b in vinyl chloride service, fhe determination can
(f) For each vinyl chloride emission to the atmosphere determined in accordance with paragraph (e) of this section to be in excess of the applicable emission limits, the owner or operator shall record the identity of the source(s). the date, time, and duration of the excess emission, the cause of the emission, the approximate total vinyl chloride loss during the excess emission, and the method used for determining the vinyl diloride loss. Thu information shall be retained and made available far inspection by the Administrator as required by 161.71(a).
18. By rhnngtng the title from "Semiannual report" to "Reporting" and by revising paragraph (a) of | 61-70 as follows TEN w,
Register / V 1. BO. N . 9 / Wadneaday, January 9, 1985 / Proposed Rule*
1!N
1*1.7* Reporting.
(Ml) The owner or operator of any uroe to which thla aubpail applies hall submit to the Administrator oh September 16 and March 16 of each year a report In writing containing the Information required In paragraphs, (c), (d) and (e) of this section and on December 16 and June 16 of each year a report in writing containing the information required in paragraph (e) of this section, except as provided In paragraph (a)(2).
vinyl chloride contact in tbs polyvinyl chloride resin.
(I)*** (!!)*
(ill) The vinyl chloride content in each ample is to be determined by Test Method 107 as prescribed in I 61.67(g)(3).
(lv) (Reserved) (v) The report to the Administrator by the owner or operator is to include a
record of any 24-hour average resin
vinyl chloride concentration, no determined In this paragraph. In excess
of the limits prescribed in | *1 4{t). He vinyl chloride oontent found to each temple required by paragraphs (cX2)(i) and (c)(2)[ii) of this section shall'be averaged eeparately for each type of resin, over each calendar day and weighted according to the quantity of each grade of resin processed by the tripper(s) that calendar day, according
to the following equation:
(2) In the case of an existing source
that submits semiannual reports on an
approved fixed schedule other than ~
Jp.i
September 15 and March 16, the approved semiannual reporting achedule
Ar, -------^-------
nail be used to report the information
required in paragraphs (c). (d) and (e) of
this section. In addition, die information required in paragraph (e) of this section will be reported exactly 3 months
where:
A -- 24-hour average concentration of type, 7i resin tn ppm (dry weight basis).
include a statement that excess emissions have not been detected.
*****
following the semiannual reporting dates.
(3) The first report is to be submitted following the first full 3 month reporting period after the initial report is submitted.
Total production of type 7) rosin over the 24-hour period, tn kg. 71-Type of resin: /-1.2. . .n where m it total number of resin types produced during the 24-hour period.
Af= Concentration of vinyl chloride in one
temple of grade G resin, in ppm.
22. By adding paragraph (c)(4) to | 61.70 as follows:
1*1.70 Reporting **
(c) * * *
19. By revisingjtaragraph (c)(1) of I 61.70 as follows:
rf*1.70 Reporting. B
(c) * * * (1) The owner or operator shall include in the report a record of the vinyl chloride content or emissions for each 3-bour period during which average emissions are in excess of the emission limits in s 61.62 (a) or (b), 61.63(b). or | 61.64 (e)(1). fb), (c). or (d). or during which average emissions are in excess of the emission limits specified for any control system to which reactor emissions are required to be ducted in I 61.64(a)(2) or to which fugitive emissions are required to be ducted in | 61.65 (b)(i)(ii), (b)(2), (b)(5). (b)(6)(ii), or (b) (9)(ii). If emissions in excess of the emission limits are not detected, the report shall contain a statement that no excess emissions have been detected. The emissions are to be determined in accordance with 1 61.66(e). 20. By revising paragraph (c)(2) introductory text, removing paragraphs (c) (2)(iv). revising paragraph (c)(2)(iii) and revising (c)[2)(v) and (c)(2)(vi) introductory text to $ 61.70 as follows:
|1.70 Reporting.
P-Production of grade G resin represented by the sample, tn kg. Grade of resin: t-g, C,, G,. and G,.
/j-Total number of grades of resin produced during the 24-hour period.
If do 24-hour average resin vinyl chloride concentrations in excess of the limits prescribed in 161.64(e) are measured, the report shall state that no excess resin vinyl chloride concentrations were measured.
(vi) The owner or operator shall retain at the source and make available for inspection by the Administrator for a minimum of 3 yean records of bU data needed to 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 I 61.70 as follows:
S 61.70 Reporting.
a*
(C) * * *
(3) The owner or operator shall include in the report a record of any emissions from each reactor opening in
(4) In polyvinyl chloride plants for which stripping tn the reactor is used to attain the emission level prescribed in 161.64(f), the owner or operator shall include in the report a record of the vinyl chloride emissions from reactor opening loss and all sources following the reactor used as a stripper.
(i) One representative sample of polyvinyl chloride resin is to be taken from each batch of each grade of resin immediately following the completion of the stripping operation, and identified by resin type and grade end 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.
(ii) The vinyl chloride content in each sample is to be determined by Test Method 107 as prescribed in
| 61.67(g)(3).
(iii) The combined emission from reactor opening loss and all sources following the reactor used as a stripper are to be determined for each batch stripped In a reactor according to the procedure prescribed in 181.87(g)(6).
(iv) The report to the Administrator by the owner or operator is to include a
excess of the emission limiU.prescribed record of any 24-hour average combined
Jc) * * * (2) In polyvinyl chloride plants for nich a stripping operation is used to attsin the emission level prescribed in | 61.64(e). the owner or operator shall Include in the report a record of the
in | 61.64(a)(2). Emissions are to-be determined in accordance withj 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 | 61.64(f). The combined resctor opening loss and emissions from
TEN 4478
Fmdmral BfUtw / Vol -80, No. 4 / Wednesday, January >, 1965 / Proposed Rules
U sources following the reactor wad M a stripper associated with sack batch art to be avsrsgsd separately for each typa af resin, ovar each calendar day and weighted according to the quantity
of aach grade of reeln etripped In reectore that calendar day as fcdlowe:
For each type of reain (suspension,' dispersion. latex, bulk, other), (he following calculation la to be performed:
ft t v^C Cg
V6i % % \ \A 1-1 *1 *1 rr -------------------------- 5-----------------------------------------------
Where:
A> 24-bour average combined reactor opening loaa and emiaaiona from all source* following the reactor naed a atrippcr. In g vinyl chloride/kg product (dry weight-basil).
Q--Total production of reain in batchea for which atripping la completed during the 24-hoar period, la kg.
C--Average combined realtor opening loss and emiaaiona from all aourcea following the reactor uted at a atripper of all batchea of grade G, reain for which atripping it completed during the 24-hour period in g vinyl chloride/kg product (dry weight batie) (determined according to procedure preacribed in I BliJ7(g](e)).
reproduction of grade G, reain in the batchea for which C ia determined, in kg.
C,eGrade of reain; eg.. Gi. Gv. end G. n>Total number of grades of reain in batches
for which stripping ia completed during the 24-hour period.
If no 24-hour avenge combined reactor opening loaa and emiaaiona from all sources following the reactor uaed a stripper in excess of the limits preacribed in | 61.64(f) are determined, the report shall state that no excess vinyl chloride emiaaiona were determined.
23. By adding paragraphs (d), (e) and (f) to J 61.70 ee follows:
161.70 Reporting. t66
(d) The owner or operator shall Include In the report a record of relief valve discharges as prescribed in | 61.65(e)(4). and the owner or operator shall report exceedences of the relief valve discharge frequency limits preacribed In | 61.65(h) to be determined as follows:
(1) For polyvinyl chloride plants producing dispersion, latex or bulk realm, the relief valve discharge frequency from polyvinly chloride reactors is to be determined using the following equation. Separate calculations are to be made for ericb reain type (1) as defined:
N
Where _ F, relief valve discharge frequency per 100
polymerization batchea from all reactors producing resing type t Nk total number of relief valve discharges during the 12-month period preceding the dose of the 6-mooLh reporting period from all reactors producing resin type t Y * total number of polymerization batches of resin type t during the 12-month period preceding toe dote of toe 6-monlb reporting period divided by 100 t-resin type: dispersion (including latex) or bulk reah type
(2) For polyvinyl chloride plants producing suspension reain*, the relief valve discharge frequency from polyvinyl chloride reactors is to be determined in two ways using the following equations:
Fp, " --N--; tnS F*i m N
Y
where F,,~ relief valve discharge frequency per VO0
polymerization batches from all reactor* producing auspension reain F,i w relief valve discharge frequency per 12month period from all reactor* producing suspension reain Nc total number of relief valve discharges during the 12-month period preceding the dose of the 6-month reporting period from ell reactor* producing suspension resin Y= total number of polymerization batches of auspension resin during the 12-monQi period preceding the dose or the 6-month reporting period divided by 100
(3) Far polyvinyl chloride plants producing auspension, dispersion, latex, or bulk resins, the relief valve discharge frequency from all other equipment (excluding polyvinyl chloride reactors) is to be determined to two ways using the following equation*:
N F* * "5 and F--N
where
F.wreUef valve discharge frequency per loo polymerization bathes from all equipment (exduding reactors)
Fi - relief velve discharge frequency per 12month period from all equipment (exduding resciors)
N-tote! number of relief valve discharges during the 12-month period preceding the doae of to* amonth reporting period from all equipment (exduding reactors)
Y - total number of polymerization hatches of all resin types combined divided by 100
(4) For polyvinyl chloride plants using the solution process or any other continuous production process, the relief 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.
(5) For ethylene dichloride/vinyl chloride plants, the relief valve discharge frequency is the summation of aach relief valve discharge from all equipment types during the 12-month period preceding the close of the 6month reporting period.
(6) A polymerization batch consists of each sequence of charging VC and other materials to the reactor, heating reactor contents, polymerization of reactor contents, and removal of reactor contents including any incomplete sequence that is aborted after charging VC to the reactor. For bulk resin production plants, a single "polymerization batch" includes both prepolymerization and postpolymerization reactor operations.
(e) The owner or operator shall include in the report tbe number of relief valve diactoaiges to tbe atmosphere during the 5-montb period preceding the report from each of the following sources: suspension resin production reactors; dispersion and latex resin production reactors: bulk resin production reactors: all nonreactor equipment in PVC plants: all equipment used in solution process and other continuous process PVC plants; and all equipment in EDC/VC plant*; any other source.
(f) Tbe owner or operator aball include in tbe report the number of reactor openings and the design capacity of the number of polymerization batches for each type of resin in each plant during the 6-month period preceding the report Tbe design capacity f the number of po^p^tiff batches may be defined
/
jydwl Register / Vol. BO. No. e / Wednesday. January 9. 1965 / Propoaed Rulea
initially and remain onchanged unless significant change to the design r capacity occur.
M By revising paragraph (a) introductory text of 101.71 as follows:
101.71 Aeccrdksapinfr.
(a) The owner or operator of any source to which this subpart applies hall retain the following information at the source'and make It available for inspection by the Administrator for a minimum of 3 years: t I
25. By adding the words "vinyl chloride" lo the definition of the term "volatile hazardous air pollutants" in | 61.241 of Subpart V as follows:
I #041 DefMfena.
"Volatile hazardous air pollutant" or "VHAP" means a substance regulated under this part for which a standard for equipment leaks of the substance has been proposed and promulgated. Benzene is a VHAP. Vinyl chloride is a VHAP.
(Sec. 112 Clean Air Act of 1676}
^^IFRDDooc. 65-50 Piled 1-0-65; 8:45 am]
U01
ten 4480