Document EZkZ2b5LM3NJVGr6B3vNy9pb

The Society I the plasties Industry, Inc. 355 Lexington Avenue New York, New York 10017 (212) 573 9400 Kept ml>er 7, 1976 Mr. Don R. Goodwin Emission Standards & Engineering Division Environmental Protection Agency Research Triangle Park, North Caroline 27711 Dear Mr. Goodwin: After reviewing the proposed EPA Vinyl Chloride Standard, members of SP1 have raised an issue regarding the portion of the Proposed Standard relating to the Laboratory and Research and Development facilities. In SPI*s initial comments to EPA on the Proposed Standard for Vinyl Chloride we proposed that polymerization reactors of 500 gal, or less capacity be exempt from the standard. After reviewing current and complete industry data, the SPI now agrees with the EPA that 50 gal. is the appropriate cut-off point for exemption, based on examination of the data presented in Exhibits A and B; however, SPI respectfully requests that EPA reconsider its requirements for reactors between 50 and 1100 gallons capacity. The difficulties created in meeting the current proposal by EPA, in paragraph 61.64 go beyond the fact that costs far outweigh the benefits derived. It is true that larger reactors tend to be installed near production facilities for convenience of monomer supply; however, please be advised that several are at research facilities. Other research reactors are at a sufficient distance from the production equipment that their interconnection is not feasible. Long runs of vacuum or slurry lines are not practical, esp, r.jally in climates \^ere subfreezing conditions are experienced. Line plugging, horning of resin, and excessive pressure drops will make these lines inoperative. There are also problems with sync v on i/. at Ion of remote operations and availability of equipment. In the short time we have focused on this issue, we have had confirmation from Air Products, Conoco, Firestone, Goodrich, Tenneco and Union Carbide that they will experience some or all of the problems raised above. Two of the major purposes for which pilot-scale equipment is used are development of improved products and processes, and the solution of plant production problems. In the first case, it is often impossible to obtain adequate scale-up data from a 50 gal. reactor. This is becoming more important as reactor size increases in modern plants. In the second case, it Is necessary that equipment be available V t ucc 007851 Continued .... "r. Don R. Hood win 2- Scptt-mber 7, 1976 f-n.i.mH ntoly fo resolve production problems, and that the polymerizcr be as similar to production equipment a3 possible. Another problem arises when the research facilities are using different comonomers from those In use at the production plant, which is a frequent occurrence. Common use of a single recovery/abatement facility is not possible under these circumstances. The spirit of the Proposed Standard calls for the use of the best available technology, to encourage innovations and to minimize potential losses by encouraging research and providing means for performing needed studies on the smallest practical scale. Any regulation that discourages the use of research equipment will limit innovation and improvement in the industry, and will lead to more developmental work being done in production equipment, where the potential for major releases is increased. We believe the present wording of the standard will inhibit use of research facilities, not only because of the cost of compliance* but because of res trictions on the flexibility of operations. For example, in several installations the interconnection of research and production equipment would take the operation of the research equipment out of the hands of trained engineers and put it under the Jurisdiction of production later because of the wording of union contracts. As .:.'oth< r example, the rate and timing of the termination and recovery of unreacted monomer at the end of a batch can affect the properties of the product, and to depend on a product-oriented facility for this important service is not realistic. Ue, therefore, request chat 61.60(b) and (c) be amended to read as follows: (b) Research and development equipment of 50 gal, or smaller capacity shall be exempt from this subpart. Equipment larger than 50 gal. but no greater than 1100 gal, shall be exempt, except that total combined amissions from all sources shall be no more than 0.05 lb. vinyl chloride per lb, of vinyl chloride charged to the reactor. Each operator of such facilities shall submit a standard operating procedure to the agency for approval of its plan to meet this re quirement. "'he iLtached data in Exhibit B show that eight companies would reduce their emissions .-ubs taut tally in complying with the SPI proposal, while company g is already in com pliance. The resulting total emissions would be about 68,000 lbs, per year, less than that emitted by reactors of 50 gal. or less, and less than 25% of current emissions. These 9 companies represent 45% of industry capacity, and include many of the major producers. Finally, we want to address the cost-benefit issue raised by the proposed Research and Development Regulation. The Agency has declared it does not want to require a technology when it will create costs which are grossly disproportionate to the benefits derived. SPI believes the proposed Research and Development Regulation creates a problem which to date EPA has sought to avoid--namely grossly disproportionate costs for the removal of small amounts of monomer. For example the cost of compliance with ucc 007852 Mr. Ti'n R. flood./in -3- Sci.t'...*cr 7, 1976 the SPI proposal haa been estimated at about $90,000 for one research facility in excess of 50 gal., while compliance with the EPA proposal will be about $'*00,000 per facility. The cost of the Sl*l proposal is equivalent to $.42 per lb, versus $7.19 per lb, of VC removed if the EPA level of 10 PPM is adopted. At least two companies have confirmed the magnitude of these estimates, based on our yet in complete survey. These are disproportionate costs for the removal of only 68,000 lb/yr of monomer of the entire country. Based on the foregoing SPI contends that the proposed EPA VC Standard relating to laboratories and Research and Development facilities limits and restricts the flexibility of operation of these facilities while at the same time Imposing disproportionate costs for the removal of so little monomer. We thank you for the opportunity to present these views. Very truly yours. John R. Lawrence Technical Director UCC 007853 EXHIBIT A EMISSIONS DATA ON LABORATORY AND PILOT FACILITIES (< SO GAL. SIZE) UTILIZING VINYL CHLORIDE Comoanv Code A B B C D D D D D D E E F F F G H H I I J J K K L M N N 0 0 0 Reactor.St*e Number of Reactom SO gal. 0.4 3.25 50 .5 .8 .8 15 30 30 5 10 .5 10 50 .5 to 2 15 10 .5 SO 5 30 2.5 10 1?.5 30 10 30 .05 1 10 i 2 6 1 1 1 4 2 6 1 2 3 1 1 2 2 11 1 1 7 7 4 1 1 1 4 2 2 1 1 7 2 PVC Produced */7T 30,000 1,084 987 17,000 192 2,112 696 23,100 960 28,800 400 100 380 27,338 136,687 16,000 5,468 608 2,245 75,634 76 5,285 1,823 606 15,480 34,172 66,582 24,698 1,200 1,063 ____ 224 521,080 Emisalone ft VCM/# PVC Emissions ft VCK/vr .013 .082 .101 .165 .25 .33 .104 .25 .25 .43 15.1 30.38 .066 .058 .079 .014 .17 .164 .049 .063 .105 .061 .055 .05 .1 .011 .329 .111 1.41 .329 .164 400 89 100 2,800 48 697 910 5,775 240 12,384 6,075 3,038 25 1,600 10,800 225 928 100 110 4,870 8 321 100 30 1,548 375 21,920 2,740 1,700 350 SO * 80,355 UCC 007854 EXHIBIT B EMISSION DATA ON LABORATORY AND PILOT FACILITIES fc>50 GAL. SIZE) UTILIZING VINYL CHLORIDE Company Code Projected Reactor. Number of PVC Produced Emissions Current Emissions Emissions Size Reactors #/vr _ # VCM/# PVC #vcM/vr (a 0.05 control B 300 gal. 1 36,450 D 1,100 2 888,000 E 300 . 2 113,812 G 50-100 5 G 750 2 H 200 1 10,000 50,000 72,900 I 200 1 2,430 I 220 1 12,029 I 500 - 7,594 I 1,000 1 33,413 J 300 1 31,894 L 200 1 24,000 0 100 1 6,075 0 500 1 1,519 0 600 1 364.500 1,654,616 .137 .29 .087 .05 .04 .234 .079 .258 .008 .134 .081 .1 .164 .066 .011 5,000 257,520 10,000 500 2,000 17,045 192 3,110 60 460 2,582 2,400 1,000 100 4.000 305,969 1,823 44,400 5,690 500 2,000 3,645 122 601 60 1,670 1,595 1,200 304 76 4.000 67,686 UCC 007855 minutes EPA - Emission Standards A Engineering Division Durham, North Carolina VCM/PVC PRODUCERS GROUP EPA TECHNICAL COMMITTEE Wednesday, September 8, 1976 - 6:30 PM Thuraday, September 9, 1976 - 8:30 AM i ATTENDANCE: For Industry: G. Balse, Beveridge, Fairbanks A Diimaond F. C. Dehn, PPG Industries V. C. Holbrook, B. F. Goodrich J. R. Lawrence, SPI C. Loechelt, Ethyl Corp. W. H. Madden, Firestone J. P. Sandstedt, Tenneco R. N. Wheeler, Union Carbide For EPA: Jack Farmer Don Goodwin Susan Wyatt 1. The EPA Technlcel Committee net on the evening of September 8, to review lt> position on RAD facilities with respect to EPA's Proposed Standard on Vinyl Chloride. It was agreed that the position stated In the letter on SPI stationery (copy attached) should be submitted. However, several members urged that the proposed change In the regulation be presented as an alternative to the language In the moat current Draft Standard. 2. In meeting with Mr. Goodwin and his staff on September 9, the Industry's position as presented in the SPZ letter was presented with the recoonendation SPI's suggested language be considered as an alternative to EPA's most recent version of the Standard. Mr. Goodwin explained that hla work on the Standard is basically completed and that there would be dlfflcultlea to make any changes or delay its Issuance as it now reals. He indicated that ha did understand the concepts of the problem but he would like to have more Information on the specific facilities having such problems and the costs in volved in conforming to the Standard as it now reads. Mr. Goodwin indicated that if sufficient Information can be supplied rapidly, he would consider introducing some language Into the preamble of the Standard when It is published indicating some late information on RAD facilities la being reviewed that may require certain changes to be made In that area of the Standard. He emphasized that this is an unusual procedure and that he would need to have supporting facts THE SOCIETY OF THE PLASTICS INDUSTRY, INC. 355 Lexington Avenue New York, N.Y. 10017 (212) 573-9400 UCC 007856 before he would propose ehnges la the Standard. He further Indicated that he wee concerned about alternate Interpretations of the Standard for RAD facilities as this would cause confusion with enforcement. 3. There were no other significant comments made by the Industry with respect to the proposed Standard. Mr. Goodwin did Indicate that his people will be working with the Enforcement Division of EPA as It prepares Its guideline Document for use by EFA's field enforcement staff. 4. In a post-meeting discussion, the Industry representatives agreed that John Lawrence send EPA a letter confirming our position on the September 7 letter being used as m alternative approach. It was further agreed that all members of the VCM/PVC Producers Group be contacted and encouraged to supply EPA with the following: A description of the operating procedures that would be followed to verify compliance with the requirement that total combined emissions from all sources not exceed 0.05 lb of vinyl chloride per lb of vinyl chloride charged to the reactor. . Description of RAD facilities, identifying where they are located with respect to production equipment and the type of neighborhood surrounding the facility. . Information on the technical problems relating to compliance with the Standard as it now reads vs. the proposed alterna tive. . Information on the cost of compliance with the Standard as It now reads vs. the proposed alternative. 5. The meeting concluded at approximately 12:00 noon Respectfully submitted. John R. Lawrence Technical Director ucc 007857 The Society of tho Plastic* Industry, Inc. 355 Lexington Avenue New York. New York 10017 (212)5739400 September 13, 1976 Mr. Don R, Goodwin Emission Standards & Engineering Division Environmental Protection Agency Research Triangle Park, North Carolina 27711 Dear Mr. Goodwin: Following up on our meeting with you on September 9, we want to be sure that you understand that the proposed paragraph (b) included in my letter of September 7 is to be considered as an alternative to be added to the language of paragraph 61.60 of the proposed Standard. Me understand the problems that might be posed by the enforcement of such an alternative without a specific understanding of the measuring and record keeping procedures that would be used to verify compliance. Therefore, as you suggested, I .-.in atklug that our PVC Producers Group contact you with information on the operating procedures they would follow to show conformance with the suggested alternative that total combined emissions from all sources in existing 0.05 lbs of vinyl chloride per lb vinyl chloride charged to the reactor. Tn addition, I am asking that those companies interested in using this alternative supply you with the following: . Description of the R&D facilities identifying where they are located with respect to production equipment and the type of neighborhood surrounding the facility. Information on the technical problems relating to compliance with the Standard as it now reads versus the proposed alterna tive. Information on the cost of compliance with the plan as it now reads versus the proposed alternative. Me appreciate having had the opportunity to meet with you to discuss this important matter to our industry. Technical Director dRT.sgm ucc 007858 1 The Society of the Plastic# Industry, Inc. 355 Lexington Avenue New York, New York 10017 (212) 5739400 September 13, 1976 f 17 ISft A HI. WHEQitf, JR. TO: VC-FS&DXERS~GROli> VOTING WFR2SNTATXVES EPA TECHNICAL COMMITTEE You will find attached the Minutes of the Committee Representatives with the EPA Technical Staff on September 9 in Durhma, North Carolina. You will note that although Mr. Goodwin understands the problems we face In the research and development facilities meeting the proposed EPA Standard, he indicated that It would be extremely difficult to change the plan before it la published. However, he did indicate that if sufficient supporting information can be made available to him, he will give this matter his best consideration. Therefore, it is urgently requested that all of you who have a concern for the present plan to be changed to allow for the alternative proposed in the SFI letter of September 7, supply the following information directly to Mr. Goodwin as rapidly as possible: . Information on the operating procedures they would follow to show con formance with the suggested alternative that total combined emissions from all sources in existing 0.05 lbs of vinyl chloride per lb vinyl chloride charged to the reactor. . Description of the RAD facilities identifying where they are located with respect to production equipment and the type of neighborhood surrounding the facility. . Information on the technical problems relating to compliance with the Standard as it now reads versus the proposed alternative. . Information on the cost of compliance with the plan as it now reads versus the proposed alternative. I would appreciate your keeping me and Mr. Gary Baise of Beveridge, Fairbanks A Diamond informed on any such correspondence that goes directly to Mr. Goodwin. In the event that there is any confidential information that you do not wish to be retained in confidence in the SFI files, please advise me of your activities and, if possible, copy Mr. BaiBe with a list concerning Information for retention in his files. The urgency of our response cannot be over emphasized if we are to give Mr. Goodwin an opportunity to make an intelligent review of our situation and hopefully approve changes in the plan. Please contact me if there are any further questions. Very truly yours, JRL:gm Attachment Technical Director UCC 007859