Document EvREdQKOarVokXnBQgJO360Bx

* 4' JOSEPH E KELLER JEROME H HECKMAN CH&MLES M MEEHAN WILLIAM H BOROHESaM.JB ROBERT R TIERNAN WAYNE V BLACK DAVIL L HILL MARTIN W BERCOVILI PETER M NEMKOV JOSEPH E HADLEY, JR. CAROLE C HARRIS PETER THOMAS SMITH MICHAEL F MORRONE LARKY S SOLOMON nL Kelleh and Heckman uao ins STREET, N. w. SUITE IOOO WASHINGTON, D. C- S0036 January 24, 1977 FBSam *b 7 TELEPHONE SOS 497-1100 CABLE ADDRESS "kELMAN" WRITERS direct dial NUMBER 202-457-1116 Mr. J. M. Devoe Allied Chemical Corporation P. 0. Box 1139 R Morristown, New Jersey 07960 Dear Mr. Devoe: Pursuant to the request we received from your secretary on Wednesday, January 19, 1977, we have enclosed herewith a copy of the Guidelines for the Enforcement of the Vinyl Chloride Regulations, If you should need any further in formation or if you have any questions or comments about any other aspect of the vinyl chloride regulations, please do not hesitate to let us know. Cordially yours Enclosure cc: Mr. John R. Lawrence w/o end 11 ~fi i ' ' ASI 00006193 -25 GuIDZLEE FCR TIE EATOFCEEAT VDTiL CHLORIDE FEGoLATIOL'3 THE Ties guideline is being issued to assist the regional offices in the endcrcemant of the regulations for the control of vinyl chloride emissions. Three.types of facilities are required to be controlled by these regulations; (1) ethylene dichloride plants, (2) vinyl chloride plants and (3) polyvinyl chloride plants. Included in these major categories are potentially numerous points of emissions. The regula tions, due to the nature of the facilities, are very cotrdex and should be examined very carefully. SOURCE LOCIFICATIO'I Vinyl chloride v.as declared a hazardous air pollutant on Decsrber 24, 1975. Simultaneously regulations were proposed for the control of vinyl chloride under Section 112 of the Act, National Emission Standards for Hazardous Air Pollutants (NESHAPS) 40 FR 59532. Since this regulator.frame'.-,or:: has bean previously utilized for the control of asbestos, beryllium, and mercury, additional helpful inforiration is available in Guidelir.es S-17 thru S-20, which should also be consulted. The regional offices should notify all affected sources immediately following the promulgation of the vinyl chloride regulations, or immedi ately upon identification of affected sources anytime after promulgation (see guideline S-17 for example notification). A list of all known ethylene dichlcride, vinyl chloride and polyvinyl chloride production plants is attached. However, since some new plants may have been cor.- strucuca ana no rose: 1 development facilities are included in this listing, some addition: investigation should be made to -plate the list. All affected sc: c_j are .to be ceded into CDS. 0000619A ASI r\ 2 r^- fhCMpnoxs von REuCATt::; a. .n development :: \cilities Polyvinyl chloride reactors and as sc elated equipment are exempted from applicability ol' all parts of the standard if the reactors are use. in research and development and have a capacity of no no re than 0.19:nJ (50 gal.). Reactors in tit is site range can generally be found in a laboratory. Also exempted are research and development facilities containing reactors greater than O.ifm0 (50 gal.) and no more than 4.07;n'i (1,100 gal.) in capacity free all parts of the standard except the 10 ppm limit for reactors, strippers, monomer recovery systems, and mixing, weighing and holding containers. The following discussion concerns itself with those portions of th: regulations most critical to the enforcement of these requirements. Frequent referral to the regulations is recommended for detailed explanation of the remainder of the regulations. A. Ini-tin l Submittals - hniver Requests, Equivalent Methods, Monitoring Plans . 1. V.aiver of Compliance Cuideline 8-19 should be consulted for administrative procedures for the review of waivers of compliance. Attached is a list of control alternatives which can be applied to the vinyl chloride/polyvinyl chloride industry. Included in this attachment are projected times needed for installation' of these various control options. Virile some of these alternatives appear to last beyond the two-year compliance period allowed under 8112(c) (1) (ii) of tire Clean Air Act, it is the opinion of the Emission Standards and Engineering Division that the two-years should be sufficient in most cases. All sources have bve.n put on notice .Mace the time of proposal that control of vinyl chloride emissions will be necessary, 1 acre Lore, it is safe to assume that the additional time frame from proposal to promulgation will provide the additional time which mav be neccssarv in seme instances. r *i I i ASI 00006195 & 3 Source errors cr operators ray apply.for use of equivalent control technique.. (3G1.65). Omars or operators should bo directed to reeko application for a waiver of compliance at the same tir.e application is made for the equivalent control option. The waiver request should be for the time necesjury to core into ccrrpliance with the regulations should the application for the equivalent method be denied. Should the regional office fail to respond to an equivalency request within the initial 90 day period, the waiver of ccrrpliance would automatically take effect for the period necessary to act on the request. If it is deter mined that the equivalency request is not satisfactory the regional office should consider granting the source a wiavar for the time neces sary to install the required control equipment. However, in no case will the waiver or ccrrpliance be extended beyond two years from the date of promulgation. 2. Equivalent Equipment and Procedures (SSI.66) Upon written application from an owner or operator, the Adminis trator may approve use of equipment or procedures which have been demon strated to his satisfaction to be equivalent in terms of reducing vinyl chloride emissions to ths atmosphere to those prescribed for compliance wish a specific paragraph of these requirements. Requests for using equivalent methods as the initial measure of control are to be submitted to the Administrator within 30 days of the effective date. For a new source, any request: for using an equivalent method is to be submitted wish the application for approval of construction or modification required bv 61.07. Many existing vinyl chlorids/colyvinyl chloride plants are currently minimizing or are considering minimising their emissions of vinyl chloride ti_-sugh methods ether chon those specified in the rt_ yulatiers. If -.host methods of con arc1 car. b_- demonstrated to have ar equivalent effect on vinyl chloride emissions they will be allowed. Requests fer ass: tur.ee in determining equivalent control capability should be directed to: Director, Emission Standards and Engineering Dr ".si on (DSED), ".3. Environmental Protection Agency, Research Triangle P:rk, M. C. 2771 1. ASI 00006196 3\ l i l 1 i is i t*i. ? ?5 *4 \,, It- t i t * t Vr Tonitorir.g 'roqra: Section 61 .65(b) (3) requires the owner or operator to institute a formal leak detectten ar.d elimination program. The owner or operator must submit a doscriprion of the program to the regional office for approval, within '15 *days of promulgation, unless a waiver of compliance is granted. In that case the regional office would then schedule a suirrioral cate for th.. program. This leak detection program should nclude: (a) a reliable and accurate vinyl chloride monitoring systam for detection of major leaks and idantification cf the general area of the plant where the leak is located. A vinyl chloride monitoring system means a device which obtains air samples fran one or more points on a continuous sequential basis ar.d analyzes the samples with gas chroma tography or, if the corner or operator assumes that all hydrocarbons measured are vinyl chloride, with infrared spectrophotometry, flame ion detection or an ecruive.lant or alternative method. (b) a rel_iuie and accurate portable hyc :ccn aecector to be us:d routinely to small leaks and to pinpoint the major leaks chloride monitoring system. A portable hydro carbon detector means a device which measures hydrocarbons with a sansicivity of at least 10 ppm and is of such design and size that it can he used no measure amissions from localized points. (c) an acceptable calibration and maintenance schedule for the vinyl chloride monitoring systam and portable hydrocarbon detector. For rha vinyl chloride monitoring system, a daily span check is to be conducted with a concentration of vinyl chloride equal to this concentra tion cfir.cd ns a l^:.k according to 361.65(b) (S) (vi). The calibration is to be dene with either: (1) calibration gas rrttucure nrenared from the w -c -Lpeci. :c;d in saccionc 5.2.1 and 5.2.3 of Test Method 1C5, or ASI 00006197 99 5 (2) A calibration gas cylinear containing the appropriate . concentre tion of vinyl chloride. If a calibration gas cylinder is used, *--i n * - "C sis rust be traceable to the National Bureau of Standards or to a graver; trically calibrated vinyl chloride permeation tuba. (d) the location and number of points to be monitored and the frequency r>f monitoring provided for in the program are acceptable when they are compared with the number or pieces of equipment ih vinyl chloride service and the sice and physical layout of the plant; (e) an acceptable plan of action to be taken when a leak is detec-c.ee.-, arc (f) a definition of leak v;hich is acceptable when compared with the background concentration of vinyl chloride in the areas of the plant to be monitored by the vinyl chloride monitoring system. The definition of lea!-; for a given plant ray vary among the different areas within the plant and is also to ciianga ever time as background concen trations in the plant arc reduced. The background level should not be so high so that any loci: -mould be masked by the high background level and therefore co undetected. 3. DhTTk 'X'ATXCh 0? CCIPLIAhCE 1. Initial Becort (S51.69) An owner or operator of a source must submit a written state ment notifying the Administrator (regional office) that the equipment and procedural spccificacions to control fugitive emissions [351.65 (b) (i), (b) (2) , (b)(21 , (b) (4), (b)(5), (b)(6), (b)(7), and (b)(8)] are being implemented. Eidsting sources or new sources v.hich have an initial startup cate preceding the effective cate must summit the statement id.then 90 cays of the affective dace. If a waiver is granted to an-existing ASI 00006198 r 6 rcurcG tha regional office vn.ll establish a date for submission of this report. Pew sources he ring an initial startup date c.n or after the effect!va date must submit the statement within SO days of the initial startup date. The statement should contain the following information: (a) A list of equipment installed for compliance. (b) A description of the physical and functional characteristics of each piece of equipment. (c) A description of the methods which have been incorporated into the standard operating procedures for measuring or calculating the emissions for v/hich emission limits are prescribed in 361.65(b) (1) (i) and (b; -.5) (i). (d) A statement that each piece of ecuimment is installed and that each piece of cmuepnent and each procedure is being used as required 2. Emission Tests (361.67) VJichin 50 days of the effective date of the regulations in the case of an existing source, the owner or operator shall test emissions from th source, unless a waiver of emission testing is obtained under S61.13. This time rat' also be e:cter.dtc if a waiver of compliance is granted . (See -19 ar.u.S-20.) The owner or operator shall provide the regional office at least 1) davs crier notice of an emission test. Emission to.-, -s are to bo conducted while tits ojudgment being tC3 tCd is operated at mo maximum production rata at which, the equipment wiO1 be operated and muter other relevant conditions as may be specified bv the reeicnel office. ASI 00006199 7 All samples are to b analyzed with:n 24 hours, and vinyl . .'.lori'ie emissions are to be ci terminod within 30 days after the mission test. The cv/ner cr c erator must report the determinations by registered leader befor3 the rlose of the next business day following me ceterrains teen. Tne c-.r.ar or operator must retain for tv.o years records of mission test results ar.d other data needed to determine missions. Thera are four general testing procedures required by this standard. Them are as fellows: (a) Stack Test - Ethylene dichlorice, vinyl chloride, and polyvinyl chloride plants - Test tethod 106. Each emission test is to consist of three consecutive runs. The average is to be computed on a time weighted basis. (b) Poscocr Cm-zninc - Polyvinyl chloride plants, Test r'ethed 106 or nortabla hvdrc-carbon detector. The reactor opening loss for which an emission limit is prescribed in 061.64(a) (2) is to be determined. The number of reactors tor which the determination is to be made is to be specified by the regional office for each individual plant based on the plants operation. lines this test will be done on a continuous basis, the regional office may decide to test a limited number of reactors and resin combinations at the time of the compliance test. This method is outlined cn pages 12 and 13. (c) `-athod 107. .r.n Cmarm-ion - Polvvinvi chloride micros - Tc there a snipping operation is used to ata. in. tne emisOOP. in 111.64(s) emuss ions are to be determined as cutlined on ASX 00006200 8 rages 10, 11 and 12. Sines tils test will also be done on a continuous ..asis the regional office may decide to test a limited number of strippers vid resin combinations at the time of the ccmoliance test. (d) Inprocess Wastewater Test - Ethylene Dichloride-Vinyl -hlcride and Pelwir.vl Chloride Plants - Test Method 107. Section 61.65(b)(9) requires that the vinyl chloride content of all inprocess waste./ater streams as they leave a piece of equipment be reduced to no more than 10 ppm by weight before being mixed with any other inprccass wastev/ater stream which contains less than 10 ppm vinyl chloride; before being exposed to the atmosphere; before being discharged to a wastewater treatment process; or discharged untreated as a wastewater. The Test Methods in Appendix B of Part 61 are to be used '.unless an equivalent method or an alternative method has been approved by the Administrator. Approval of an alternative or equivalent method .must be concurred upon by the Director of the Emission Standards and Engineering Division. If the results obtained by an equivalent or -iuamarive method are thought to be inaccurate, the regional office may require the us2 of a reference method. If the results obtained by the reference method do net agree with those of the alternative or equiva lent method the results obtained by the reference method shall prevail. C. HUSSION MCEITOPIEG (3S1.6S) 1. The vinyl chloride monitoring system, required in 831.65(b)(3)(i), or equivalent is to be used to monitor on a continuous basis the Emis sions from-: these sources for which emission limits are prescribed in .551.62 (a) and :b) , Sol. 62 (a), and Sol.64 (a) (1), (b), (c), ar.J (d), and `or any contra! system to which reactor amissions are required to be -tod in a-31. !4(r; (2; cr to w.nich fugitive amissions are required to be duotc-u in 51. !5(b) (1! (ii) , and (b) (2) , (b) (5) , (b) (6) (li) , and (b)(9) (ii). ASI 00006201 9 2. The vinyl chloride monitoring system(s) used to meet these requirements is to b:- a device which obtains air samples from one or more points on a cor sinuous sequential basis and analytes the samples v.iah gas chrcmotogrr.ghy or, if the owner cr operator assumes that all hydrocarbons measured are vinyl chloride, with infrared spectrophoto metry, flame icn detection, or an equivalent or alternative method. The vinyl chloride monitoring system used to meet the requirements in 361.65(b)(3)(i) may be used to meet the requirements of this section. 3. A daily span check is to be conducted for each vinyl chloride monitoring system used. For all of the emission sources listed in para graph (1) of this section, except the one for which an. amission limit is prescribed in 361.62(b), she daily span check is to be conducted with a concentration of vinyl chloride equal to 10 ppm. For tine emission source for which an emission limit is prescribed in 361.62(b), the daily span check is to be conducted with a concentration of vinyl chloride which is determined to he equivalent to the emission limit for that source based on the amission test required by 361.67. The calibration is to be done wish eitimer: (a' A calibration gas mixture prepared from the gases specified in sections 5.2.1 and 5.2.3 of Test Method 106, or (b) A calibration gas cylinder containing time appropriate concentration of vinyl chloride. If a calibration gas cylinder is used, the analysis must be traceable to the National Bureau of Standards cr to a cravimetricully calibrated vinyl chloride permeation cube. D. 1. Semiannual Popcrt (361.70) The emur cr op-erator of any source must submit to the qional office on Sect-Tier 15 and March 15 cf each year a written /acre. Tie first c:u a annual retort is to be submittal foilc.-.ir.c bh-: ASI 00006202 1 I - ' i t it.. tefrC T a p gMMsikiStifcac '?S o> 10 first full si>: month reporting period after the initial report is submitted. The regulations require that the report include: (a) A record of any emissions in excess of the omission limits prescribed in 1561.52(a) or (b), 551.63(a) or 3351.64(a)(1), (b), (c), or (d), or for any control system to which reactor emissions are required to be ducted in Sol.64(a)(2) or to which fugitive emissions are required to be ducted in 351.65(b)(1)(ii), (b)(2), (b)(5), (b)(6)(ii), or (b)(9)(ii). (Emissions are to be measured in accordance with Sol.62.) Omissions will be averaged ever a one-hour period. Excess emissions obtained through the use cz a continuous monitor will not be considered a violation, of the emission standard, except as provided in (b) and (c) belcw. (b) In polvvinyl chloride plants for which a stripping opera tion is used to attain the emission level prescribed in 561.64(e), the owner or operator shall include in the report a record of the vinyl chloride content in the polyvinyl chloride resin. In order to determine vinyl chloride content Test Method 107 is to be used as follows: (1) I: batch stripping is used 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 immediately after stripping is completed, and identified by resin tape and grade and the cate and time the batch is completed, The correspending quantity of material processed in each stricter batch is to be recorded and identified by resin type and grade aid the ; the beach is ccmpietea. (2) ' ( continuous scrapping is used ana r a presents-, save sample of polyvinyl c.boride rosin is to be ; * ,, 4. w- resin processed or ua intervals of eight hours for o_ch crude of resin i ASl 00006203 I 1 which is being processed whichever is nor a frequent. Tee sample is to he taken as aha resir. flc-.u cut of the .saripeer and identified by resin t\pe and erada and the data ar.d time the sarnie was taken. The correspending qmtitv of material processed by each stripper over the time period represented by trie sample during the eight hour period, is to be recorded and identified by resin type and grade and the date and tire it represents. (3) The quantity of material processed by the stripper is to be determined on a dry' solids basis and by a method submitted to and approved by the regional office. (4) Duplicates of samples shall be provided at the prior request of the regional office. (5) The report is to include the vinyl chloride content found in all the samples required, averaged separately for each type of resin, over each calendar day ard weighted accor;. .g to the quantity of each grade of resin processed by the stripper(s) that calendar day, according to the foil twin.ecuaticn: n y'A i <d~ PGl,"MxC. + p*Gs,Mf, ci, + ... + P*GnMGn,, Q"mT. A = 24-hour average concentration of type resin, in ppm. Q = Total Droduction of tvoe T. resin over the 24-hour oeriod, in Kg." 3 . T.-po of rerun; = 1,2, ... n, where n is total number of 1 ras'.n roues or. dead daring da 24-hour nor led. {: - Concentration of vinyl chloric.- in one saroJe of grace Gl r"3i;1' ' ^I Mhi nVI fJ 7* /* n *; r* ' l :i ASI 00006204 12 'p - Production c:: grade resin represented by the sample, in kg. C-. = Grade of res. , e. c:., G^, G~, ar.d G^. n - Total r.trber cf grades cf resin produced during the 24-hour period. Trj:= standard nl 1 m-m s" averaging r.1 rr<=* nf 24 hour?; to allow sore grades cf r:.:in which canr.cr be stripped to 400 ppm to be average:-! with other or: las of resin which can be stripped considerably lower than 4C0 per?.. T.cis continuous measurement or residual vinyl chloride content is r.c-.: just a reporting requirement, but a means for determining compliance with 561.64(e)(i). (c) A reccr;! of the emissions from each reactor opening for which a? emission limi.-: is prescribed in 361.64(a)(2). For a reactor that is also used as a stripper, the determination may be made immsdiately following the sorippir.g operation. If a re.ictor is also used as a stripper, the resin is in the rerotor when it is ooened. This means that vinvl chloride in the resin which has already been stripped to acceptable levels can escape from the resir. ar.d bee:me part of the reactor opening loss. It is the intent or the stancarc chat once a resin has been stripped to the required levels, that :idditional controls are not required. Under this provision, vinyl chlor:Lee escaping from the resin after it has been stripped to acceptable- levels is not counted as part of the reactor opening loss. This nr.isurem.ent of reactor opening less is to be used for deccmining compliance with 361.64(a) (2). The reactor opening .loss is to is deceimincd us!Lr.g the following equation: ,, v:(2.60) (lCf') (Co) ASI 00006205 C = kg vinyl chloric,- emissions/kg product W = Capaciov or, te, a reactor i.n3r. 2.60 = density of vinyl chloride at one atmosphere and 20 C in kg/m 10~ = conversion feecor for ppm Cb = ppm by volume vir.yl chloride as determined by 1- so Method 106 or a por hydrocarbon datscrcr which rreasur :-s hydrocarbons with a sensitivicy of at least 10 ppm V = number of batches since the reactor was last opened to the a moschere * n = Average kg of polyvinyl chloride produced per batch in the number of batches since the reactor was last opened to the autosphere. (d) For both reactor opening and improved stripping, it is possible that the relationship between the emissions measured and the corresponding operating procedures used to attain the emissions measured can be established as follows: (1) For improved stripping, for example, it ray be established that, for a given resin grace (each resin would have to ba done separately), a given set of operating conditions (temperature, residence cine, and pressure) will result in a certain concentration of vinyl chloride in the resin which is below the standard. (2) Source owners may elect to comply with the standard for reactor opening by pulling a vacuum on the reactor, purging it with nitrogen cr displacing the vinyl chloride with water and/or reducing the number of reactor openincr. For example, for a given resin in a given realtor ;y_:o it may be escublishod that a given procedure such as water displaoemem.c coupled with a given frequency of reactor openings will result in an emission level below the soondard. Pa oncchor example, for a cover. resin in a elver: r.eater the owner or coeracor rev demonstrate Pi 4 \ rt ,3 < s* -4 -I ASI 00006206 V 14 Jig a vacuum. :j a specified reassure for a certain number of tiros and/:r purging the ..-.stem sufficiently will also result in emission levels bel:. w the standard. 2 ial Foncrts zero emission limit is the standard for relief valve discharges which ; ;e prevented. Li rest cases, such discharges from reactors car. be including, limited so,, properly to detect upset conditions, injecting cheni- cals to st ation reaction during upset conditions venting the reacts gasholder during upset conditions and ulti mately to recovery system, providing employees with in-proved training on preventir.,g ar.d handling upset conditions, and utilizing a stand-by scarce of ycjar. For oin: pieces of equipment, increasing pressure due ~o inert gas35 in the system can be relieved by manual venting to a gasholder or recovery system. The conditions which lead to discharges can also b: prevented in rest cases by proper handling and transfer of vinyl chic sibe or materials containing vinyl chloride. One of tha math:tbs listed above for preventing relief valve discharges from, a reactor is manual venting of part of the reactor contents for purposes of .-toling and reduction in pressure within the reactor. The contents of a reactor can be manually vented to a gasholde / other holding vessel. However, in some cases, such as during severe wee bier conditions, several reactors ray be cut of control at one time. The,re would bo insufficient holding capacity under these conditions to manuo ily vent the concents of all tha reactors to a gasholder. Therefore, a zero emission limit applies to manual venting of gases to the atmcsghsra from reactors cwceot under these cmarcencv cori--i,Picric * Atiq gv--n lit "m ,:r these conditions, manual veering to the ro '.'ill bi por.rbt: -ad only when all other measures to proven relief vac- . discharges r ive bear, exhausted and manual venting to b etnenyhor.- is a last re.;? nt before the relief valve coons. ASl 00006207 15 It sheoid be pointed cut that the emergency manual venting provision applies only to reactors. There is to be no manual '.anting of c ,,,as to the atmosphere from other equipment. The specific regulations for relief valve discharges and manual venting are stared as follows: (a) Puller 'valve discharge (applies to eohyler.a dichloride, vinyl chloride ar.d polyvinyl chloride plants). E::cept for an emergency relief discharge, there is to be o disenarge to the atmosphere from any relief valve on any equipment: in ir.yl chloride service. An emergency relief discharge rears a discharge .:ich could not have been avoided by taking measures to prevent the cischarge, such as those caused by natural disasters. Within 10 days of ly relief valve discharge, the owner or operator of the source from -.ich the relief valve discharge occurs rust submit to the regional or:!ce a report in writing containing information on the source, nature :d cause of the discharge, the dace and time of the discharge, the :pro:airate octal vinyl chloride loss during the discharge, the method ::ad for desemiring ive vinyl chloride less, the action that '.3s taken o prevent she discharge and measures adopted to prevent future discharges. (b) Manual Yens Valve Discharge (applies to polyvinyl chloride plants) The owner or operacor of a poylvinyl chloride plant must comply with toe following requirement*. E:copt for am. emergency' manual vent valve discharge, t'. :re is to he r.c disenarge to the atmosphere from ary manual vent valve o any/ polyu:\yl chlerv'.o roacocr in vinyl chloride service, in emergency .oviai vent "alv: dice'oorca r.-i-aas a discharme lo the atnocnherc which id! ai- nrh U ji ASI 00006208 16 co :ld not have fc-c-an avoid cd by taking treasures to prevent the discharge. W: thin 10 cays of ar.y discharge to the atmosphere from any manual vent v.'.ve, the owner nr operator of the source shall submit to the Adminis trator a report in writing containing information on the source, nature a.-.I cause of the discharge, the date and tire of the discharge, the approximate total vinyl chloride loss during the discharge-, the method used for detemir_ng the vinyl chloride loss, the action that v;ns taken to prevent the discharge and measures adopted to prevent future- discharges Upon eiuoaination of these reports the regional office she old determine one following: d! was the discharge unavoidable (2) if so, v.-ere the measures taken to prevent and/or (3) if not should any additional action be taken. Any avoidable discharge is a violation cf the standard and can be directly enforced. In ordo r to determine whether a relief valve discharge or a vent valve discharge has occurred, the regional office upon ion of the source should examine the operating para e tors . ' -- -- relief valve or take polyvinyl chloride reactor, CJ35 ELTG r.C orally proceeded by abnormally high tenge. etures and prrosures i: the apparatus. Venting is performed in order to relieve to-; o pressu ana to lower the temperature of the reaction. 1 "1 ty 11JI ** $ 1 f Tt f >\tl1 i t ? i.* 34 .V- i. l ASI 00006209 17 (Sol.71) The owner o: operator of any vinyl chloride source must retain for a reinirern of two years the following information: 1. A record of tie leaks detected by the_ vinyl chloride monitoring sysc-ar, as required b*y 351.65(b) (), including the concentrations of vir.yl chloride as :measured, analyzed, and recorded by the vinyl chloride rcr.itcrirg svsten including tha location of each reasure.Te.nt and the date and approximate tire of each measurement. Also a statement of the cause cf the lea)-;, if known, action taken to eliminate the lea:-;, and tins it tcck to correct the leak. 2. A record of tha leaks detected during routine monitoring with the portable hydrocarbon detector and the action taken to repair tha leaks as required by Sal.65(b)(8), including a brief statement explain! the cease of each lea1: detected the date and tire of each leak and any action taken to eliminate that leak. 3. A record of amissions measured in accordance with S61.68. 4. For the relief discharges from reactors subject to the pro visions of SCI.65(a), a daily operating record fer each reactor, including pressures and tenperatures. This information will alert the regional office as to whan a discharge may have occurred. ASI 00006210 n c L0'- h:r.er : A "EG 10 TYPE I PTC PVC pvc II V" ^ 1 .o rvc t ?J c P7C PVC . PVC PVC III PVC PVC PVC oV' '#r rIs PVC PVC IV mr Vw PVC PVC PvC -. c C v L- V 3VC PVC PVC PVC PVC PVC VI LDC roc EJC c^ -- ------- PRODUCING COMPANY Boreon, Inc. Great African Chemical Coro. Borcen, Inc. Pittsburgh Plate Glass Pittsburgh Plate Glass 3.F. Gcct-ich Co. Goodyear Tire Co. Jennet C'.rporation Occident:! Petroleum Ccrp. Occident:! Petroleum Corp. Pantasct:- Co. Tenneco Chemicals, Inc. Tenneco Chemicals, Inc. Diamond Shamrock Corp. Firestone Tire Co. Firestone Tire Co. Pantasotc- Co. Stauffer Chemical Co. Union Carbide Corp. 8.F. Goodrich Co. B.F. Gocirich Co. Air Products, Inc. Air Prod acts, Inc. B.F. Goodrich Co. Continar.ial Oil Co. Jenr.at Corporation B.F, Goodrich Co. B.F. Gocorich Co. Borden, Inc. Dow Xhemical Co. General Tire Co. Rob indeed, Inc. A11ied C .emical Co. Continental Oil Co. Diamond ioamrock Corp. Dow Chemical Co. CAPACITY -- (MILLIONS PLANT LOCATION KILOGRAMS/YR) Leominster, M4 Fitchburg, MA 800 30 Springfield, MA 30. Guayanilla, ??. Guayanilla, PR Pedricktown, NJ Niagara Falls, NY Somerset, NJ Burlington, NJ 380 225 65 45 2 75 Hicksville, NJ 7 Passaic, NJ Burlington, NJ Flemington, NJ 25 75 30 Delaware City, DL Perryville, HD Pottstown, PA Point Pleasant, v;v Delaware City, DL S. Charleston, WV 45 105 75 45 80 25 Calvert City, KY Calvert City, KY Calvert City, KY Pensacola, FL Louisville, KY Aberdeen, MS Tucker, GA 455 455 60 35 65 120 3 Avon Lake, OH Henry, IL Illiopolis, IL Midland, MI Ashtabula, "H Painesville, OH 120 100 65 45 55 115 Baton Rouge, LA liestlake, LA. Oeer Park, TV Freeport, T.'i 295 455 120 590 i j j l1 ,,* i r ' r **- tii F3 t'* s i 5 4 i X A u kS* ! V * m* i iV * >* * * L < V :1 :< \ \j - m1 \4 r \ ASI 00006211 ESC EEC F"T rr*r UcapWr EEC EDC 4C>WT''^* EEC 1w VC VC VC VC VC VC VC VC VC VC VC PVC P7C PVC PVC PVC PVC r/w PVC Pr '.iTo V p,. pv PV; PVC Dov/ C i-nical Co. Dow C .oojical Co. Ethyl Co3*p. Ethyl Corp. Fittscji-gh Plate Glass Co. Shell Oil Co. Shell Oil Co. Union Carbide Ccrp. Vulcan All it.: Chemical Corp. Continental Oil Co. Dow C. emical Co. Dow Cremical Co. Dov; C. c-mical Co. Ethyl Corp. Ethyl Corp. Mono: ism, Inc. Pictscurgh Plate Glass Co. Shell Oil Cc. She!i Oil Co. Tennico, Inc. Bore:", Inc. Continental Oil Co. Diamnj Shamrock Coro. Ethyl Corp. Georgia-Pacific Corp. Goodyear Tire Co. Shin`.-oh, Inc. Tenn-aoo Chemicals, Inc. Union Carbide Corp. Stau;--:-r Chemical Co. Etc,. far Chemical Co. Jc-r.r--: Corporation Keys.'-Century Corp. b.r. Goodrich Co. Stauf-'er Chemical Co. Oyster Creek, TX PI aquemine, LA Baton Route, LA Houston, i:< Lake Charles, LA 5C0 525 250 120 455 Deer Park, TX Norcc, LA Texas City, TX Geismar, LA Baton Rouge, LA Westlake, LA Freeport, TX Oyster Creek, TX Plaquemine, LA B3ton Rouge, LA Houston, TX Geismar, LA Lake Charles, LA 545 530 70 no 155 330 SO 320 155 120 70 135 135 Deer Park, TX Norco, LA Houston, TX Geismar, LA Oklahoma City, OK Deek Park, TX Baton Route, LA Plaquemine, LA Plaquenine, LA Freeport, TX Pasadena, TX Texas City, TX 410 320 115 To begin operation 1975 100 125 SO 100 50 100 no 135 Long Beach, CA Long Ceacii, CA Torrance, CA Saugus, CA Long Beach, CA Long Beach, CA 135 135 2 15 53 70 ASI 00006212 AlTACH'TIiT R iccr r.:.A, smi.l data, aj::> tiil* ccinwii. rtxn;:(r;n;f. Size** Time Components General f i i*t! * In-proved A t rJjiju ntj ` Solvent C1 ca\n J nr[ * Carton Adsorption** Solve it Adsorpt ion** lU-d lun _Mod-l ai'jo ____ L-il_rje__ ik'JjHIl. ___ 1 arijn 1 hemal Incineration** Medium Med-lar^e Large I'.L-SirjP I * fiid Contractor Salcclion Egeip-cnt Dpi ivory I i; .'ftcijl Ca p i t a 1 Acquisition Total Cc-pliance t ir: a from design through ins to 1 la tion lC-24mos 24n.os )8-3C:uos 30.MS 8-1 Oi.ks lO-l`,..'r.S 10-l?i:i:s lG-22ks 12-1C-A s 22-3u..i s f!-10.;ks 1U-1 10-12i.fi lu-27.:,.t 6-fl 0-10 10-12 6-0 ' fl-10 fl" 1 C.*rS t . ~ J i . ! *. ,io-i 10-12,4:s U'-.'tlVi.s 10-12 6-0 8-10 10-12 4-6 4-6 4-6 4-6 4-6 4-6 4-6 4-6 4-6 20-30 . 20-30 20-30 30-40 30-40 30-40 40-60 40-60 40-60 4-6' 4-6 4-6 G-B 6-8 42-62uks 4G-74wks GO-90.4c s S2-7?wks 56-H4wfcs G-B G-B 6-8 . 6-0 60-100,4: s6?-92wks CG-101i.ks 70-120wfc$ ]0-14nios n-17fnos 12-21rnos 12-17rr:o5 13-]5ras 14-23:roi ,)4-21rios 15-24/r.os lfi-2B.nos T.D. Snail Report *`!CCI distribution of PVC Company sites by sales and not inccves is given by "fortune GOO". ' Rank 1-1 CO largest 101-200 largest 201-300 largest 301-400 largest 401-500 largest over TOTALS SA rs 8 of Cca:p. i of Ind. 14 47 3 10 . 3 10 27 13 _7 _23_ 30 100 lit! , 1 fit if Of Ik.'flip. t of Ind. 11 47 9 30 3 10 -- -- _7 23 30 100 : i ASI 00006213 * -***>.****< I*w*Vr|i.tmr- LO \i ,> 1^1 AijJi'i