Document E9nLaxY9dQVBkMQpMb3XDzwR

PROPOSED REGARDIN THE N, STIOUS FOR EPA STAFF 'OSED AMENDMENTS TO IISSION STANDARD 'VINYL CHLORIDE June 22, 1977 Durham, North Carolina SPI Manufacturing Technology Committee: Robert Laundrie, Chairman John Lawrence, Technical Director BFS 00S94 INTRODUCTION Once again, we appreciate the opportunity to meet with the staff of EPA. We hope this exchange will lead to a better understanding of what it is you propose to do regarding the National Emission Standard for Vinyl Chloride. We would be less than honest if wg(^c3J<5 you we were happy to be here. Frankly, we bKphght all issues had been explored over the last tfc"years regarding vinyl chloride, but appar^rte^^'we were wrong. We are disappointed that ch^^eS would now be suggested without apparently any new information suggesting that changes be made. However, being responsible corporate citizens, we will work with you and attempt to improve, if we can, upon what we have already committed to do. But please do not ask us to do the impossible. Now, we have some questions we would like to raise regarding the proposed amendments. I will go through the questions on a section-by-section basis. BFS 00 _T. I. SECTION 61.62 (a) In the proposed regulations preamble, (F.R. 28155), it is stated that new oxychlorination or PVC reactors installed at an existing grant will be subject to the new source standards. If this new equipment were installed as replacement items and would not increase production or emissions, we fail to see why they must meet the new standard. The EPA has recognized that replacement of pumps, etc./^ should not subject the plant to the new stands For these reasons we do not see the needa different approach on reactor vessel^i^^Would you explain the rationale for sugges|jfil5^this change now? Are the technical facts any d^^ferent today than they were in October when the Vinyl Chloride Standard was promulgated? (b) In proposing a 5 ppm standard for new oxychlorination plant vents, the EPA has concluded that oxygen technology is economic and can be applied to all the various basic technologies which exist. This conclusion is apparently based on a reference which quotes the price of oxygen at a level several years ago. Also, that quoted price ($14.34/ton) was based on the co-purchase of nitrogen BFS 0BS944 -3- which may or may not be needed by the plant. Current prices of oxygen, which also presumes purchase of nitrogen, are on the range of $120-25 per ton. This increase in price reflects primarily the increased cost of fuel to produce and deliver the oxygen. We believe you have failed to recognize that an oxygen based technology is more energy intensive than air based systems. The increased energy consumption may be between 30 and 50 million BTU's fer hour. This should be considered by EPA be^g^e^promulgating new standards. Were you aware^f0tkis change in oxygen costs? Based on theg^^al world costs, do you believe oxygen technology((isy''till economical? V- (c) Concerning the use of oxygen technology for new oxychlorination plants, the EPA economics assume a nearby available source of oxygen. This can only exist where there is already a concentration of oxygen consuming industry and therefore implies that new sources must locate near old sources to gain any economic advantages. On the other hand, the offset policy, as we understand it, may well require the dispersement of new sources of vinyl chloride. If a new source were to locate at a remote location, it is not likely that any source of oxygen could be enticed to locate there for such a small offtake unless much higher prices were paid for the oxygen. BFS 00S945 These two parts of the proposal appear to be in conflict. Are they in conflict? Were you aware of this practical problem? Do you see this as a problem? If not, why not? II. SECTION 61.63-64 (a) Under the current standard, it is presumed that a 10 ppm allowable emission is a 1-hour average standard. To meet this on a continuing basis, industry has designed and installed a certain reliability into the abatement devices. Is it the 4fofc<Stion of the proposed revision to also requireCa 5 ppm, 1-hour average compliance? If sq/ws Relieve that industry will actually have to35s>ball additional control devices which aprigars^contrary to EPA's stated intention of not requiring changes or additions to equipment installed to meet the existing 10 ppm standard. Now would you clarify the reasoning by which the new lower emission level of 5 ppm was chosen, and how it is to be achieved by existing equipment while maintaining the 3-hour not-to-exceed provision of the present standard. Lower limits will mean more excursions, unless new technology, of which we are not aware, exists. (b) We need a definition of what is meant by a new grade of resin. Will small changes in molecular weight, comonomer content, or other BFS BOS 946 physical properties constitute a new grade? There are many grades and types which cannot yet meet the present standard completely, and we have no forseeable technology to change this situation. How will this requirement be administered? (c) We believe it will be extremely difficult for small plants who specialize in acetate copolymer or dispersion resins to maintain their market position under this "new grade resin" rule. Have you considered the difficulties this may cause the small plants? (d) We have polled the dispersion resin companies and find that there is no new technology for stripping dispersion resins to 50^^^m. By October, 1978, there is a consensuSiftat most companies will be in compliance\ with 2000 ppm on most products. Even then,@$>me resins will have to be discontinued. You/Sfeem'to imply in the preamble, "that for some res-Sos-, companies have already developed stripping technology which would meet the proposed amendment." We would agree with you regarding certain suspension resins, but you surely do not believe that is the case for dispersion resins, do you? If so, tell us what we are missing? (e) We are concerned as to what you mean by "commenced." For existing sources, subject to the Standard issued on 10/21/76, which have not yet BFS DOS 947 received an approved compliance schedule or have not actually started construction, does this new proposal reduce their allowable emissions from 10 ppm to 5 ppm? What happens if you have been negotiating contractual obligations before June 2, but they are not signed until after June 2, 1977? Assume your waiver is approved on June 3, or later, and you enter into the first contractual obligation on September 1, 1977, pursuant to the approved waiver? What if the construction work is to be performed by an in-house construction firm and no contracts have been signed. Work is to commence July 1, 1977 before June 2, 1977. after June 2, 1977. W III. SECTION (a) A plant co^fd well develop several emission limits, e.g. new and old reactors, new and old grades, etc. There would then be no single correct calibration gas. Why is there felt to be any substantial loss of accuracy at 5 ppm if the instrument is calibrated at 10 ppm? BFS 00S94S