Document KJa1kgNNOegRrOGGDVpp95VQ2

INTERNAL CORRESPONDENCE ivM UNION CARBIDE CORPORATION old ridgebury road, danbur .. ct osa i - ''Mr. Jose Colucci `S'O^ cr Bldg. 772-14 Cgd> so Mr. L. A. Crisorio Dace April 17, 1985 Originating Dept Area Regulation of Residual Vinyl Chloride in Polyvinyl Chloride Regulations covering residual vinyl chloride monomer In polyvinyl chloride are: 1. Occupational Safety and Health Administration 29CFR 1910.1017 Vinyl Chloride. This regulation does not set any limit on residual vinyl chloride monomer in PVC. The permissible exposure limit of 1 ppmv TWA 8 applies to employee exposure in the workplace. All containers of PVC must have a label stating "Contains Vinyl Chloride, Vinyl Chloride Is a Cancer Suspect Agent." All employees exposed to the resin must be monitored to establish their exposure level. Certain vinyl chloride resins and latexes have been interpreted to be "fabricated products" and are exempt from the regulation. If a resin contains 1 ppmw or less of vinyl chloride monomer, it could conceivably be eligible for a "fabricated product" exemption if sufficient testing of employee exposure is done to demonstrate low employee exposure. There is no defined residual monomer exemption level. 2. Environmental Protection Agency, 40 CFR 61.61 Subpart F, National Emission Standard for Vinyl Chloride. This regulation (attached) specifies that PVC resin from a monomer stripping system may contain no more than 400 ppmw residual vinyl chloride, or that PVC resin from a reactor when no stripper is used may contain no more than 0.4 gram/kilogram (400 ppmw) residual vinyl chloride. If this level is not achieved, then subsequent processing steps are subject to a 10 ppmv vinyl chloride concentration limit in vents. EPA in 50 FR 1182-1201, dated January 9, 1985, propose some modifications to 40 CFR 61 Subpart F, but the residual vinyl chloride monomer limits in the original regulation will not be changed. ucc 038019 2 3. Department of Transportation DOT has no regulation on residual vinyl chloride in PVC. All distribution employees, however, are subject to the OSHA regulations. The hardest limit to meet will be marketability. I have no idea what valuable special properties resin produced by the UNIPOL process may have, but I don't believe that a general purpose PVC resin containing more than 100 ppmw residual vinyl chloride is salable. Copolymer PVC could be higher in residual vinyl chloride monomer content but this depends largely on the usefulness of its special properties. I suggest you compare your PVC with that produced by the bulk process at B. F. Goodrich. RNW,Jr./maw Attachment 0327G R. N. Wheeler, Jr. ucc 038020 > 40--Pr t ction of Environment source or a new source which i initial startup date preceding ective date; or ^ v sludge test shall be conducted 90 days of startup in the case of source which did not have an startup date preceding the ef- date. rhe Administrator shall be noti- : least 30 days prior to a sludge -Qg test, so that he may at his observe the test. Sludge shall be sampled accord- paragraph (cXl) of this section, charging rate for the plant >e determined according to para- <cX2) of this section, and the ; analysis shall be performed ac- ig to paragraph (0(3) of this sec- rhe sludge shall be sampled after ering and before incineration or i, at'a location that provides a >entative sample of the sludge is charged to the incinerator or . Eight consecutive grab samples obtained at intervals of be- t and 00 minutes and thorixed into one sample. Each of ight grab samples shall have a le of at least 200 ml but not more 400 ml. A total of three composmples shall be obtained within an ting period of 24 hours. When 14-hour operating period is not ouous, the total sampling period not exceed 72 hours after the nab sample is obtained. Samples not be exposed to any condition nay result in mercury contaminar Iocs. The maximum 24-hour period } iseinerati n or drying rate be determined by use of a flow measurement device that can ire the mass rate of sludge ;ed to the incinerator or dryer an accuracy of 5 percent over >erating range. Other methods of urlng sludge mass charging rates be used if they have received approval by the Administrator. The handling, preparation, and /sis of sludge samples shall be acillshed according to Method 105 >pendix B of this part. The mercury emissions shall be mined by use of the following tiom i j ; | * I * I ) ' I < j \ , 1 } 1 * > t Chapter I--Environmental Protection Agency ,,.ixl0-c *here; Mercury emissions, g/dsy. cm Mercury concentration of sludge on s dry solids bssls. v*i\ (ppm). o~Sludge charging rate, kg/day. (e) No changes in the operation of a plant shall be made after a sludge test has been conducted which would po tentially increase emissions above the level determined by the most recent sludge test, until the new emission level has been estimated by calcula tion and the results reported to the Administrator. (f) All sludge samples shall be ana lysed for mercury content within 30 days after the sludge sample is collecteg. Each determination shall be re ported to the Administrator by a regis tered letter dispatched before the close of the next business day follow ing such determination. (g) Records of sludge sampling, charging rate determination and other data needed to determine mercury content of wastewater treatment plant sludges shall be retained at the source and made available, for inspection by the Administrator, for a minimum of 2 years. (Sec. 114, Clean Air Act ss amended (42 U.S.C. 7414)) [40 FR 48303, Oct. 14. 1075. ss intended st 43 FR MOO. Mar. 3. 19781 111.55 Emission monitoring, (a) Wastewater treatment plant sludge incineration and drying plants. All such sources for which mercury emissions exceed 1000 g/day, demon strated either by stack sampling according to 101.53 or sludge sampling according to (61.54, shall monitor mercury emissions at intervals of at least once per year by use of Method 105 of Appendix B, or the procedures specified in 161.54 (c) and (d>. The re sults of monitoring shall be reported and retained according to | 61.53(d) (5) and (O). or 161.54 (f) and (g). 1 (Sec. 114, Clean Air Act as upended (42 DB.C. 7414)) (40 FR 48303, Oct. 14, 1975, as amended at 43 FR 8800. Msr. 3. 1978] Subpart F--Notional Emissi n Standard for Vinyl Chloride Souser 41 FR 48564. Oct. 21, 1S7S. unless otherwise noted. 61.M Applicability. (a) This subpart applies to plants which produce: (1) Ethylene dichloride by reaction of oxygen and hydrogen chloride with ethylene. (2) Vinyl chloride by any process, and/or (3) One or more polymers containing any fraction of polymerized vinyl chlo ride. (b) This subpart does not apply to equipment used In research and devel opment if the reactor used to polymer ize the vinyl chloride processed in the equipment has a capacity of n more than 0.19 m* (50 gal). (c) Sections of this subpart other than 1(61.61; 61.64 (aXl), (b). (c). and (d); 61.67; 61.68; 61.69; 61.70; and 61.71 do not apply to equipment used in re search and development if the reactor used to polymerize the vinyl chloride processed in the equipment has a ca pacity of greater than 0.19 m* (50 gal) and no more than 4.07 m* (1100 gal). (41 FR 48584, Oct. 21, 1978, ss amended st 42 FR 29008. June 7. 1977] 5 61.(1 Definitions. Terms used in this subpart are de fined in the Act, in Subpart A of this part, or in this section as follows: (a) "Ethylene dichloride plant" in cludes any plant which produces eth ylene dichloride by reaction of oxygen and hydrogen chloride with ethylene. (b) "Vinyl chloride plant" includes any plant which produces vinyl chlo ride by any process. (c) "Polyvinyl chloride plant" in cludes any plant where vinyl chloride alone or in combination with other materials Is polymerized. (d) "Slip gauge" means a gauge which has a probe that moves through the gas/liquid interface in a storage or transfer vessel and indicates the level of vinyl chloride in the vessel by the physical state of the material the gauge discharges. 709 ucc 038021 $61.62 Title 40--Protection of Environment (e) "Type of resin" means the broad classification of resin referring to the basic manufacturing process for pro ducing that resin. Including, but not limited to. the suspension, dispersion, latex, bulk, and solution processes. (f) "Grade of resin" means the sub division of resin classification which describes it as a unique resin. Le,, the most exact description of a resin with no further subdivision. (g) "Dispersion resin" means a resin manufactured in such a way as to form fluid dispersions when dispersed in a plasticizer or plasticizer/diluent mixtures. (h) "Latex resin" means a resin which is produced by a polymerization process which initiates from free radi cal catalyst sites and is sold undried. (I) "Bulk resin" means a resin which is produced by a polymerization proc ess in which no water is used. (J) "Inprocess wastewater" means any water which, during manufactur ing or processing, comes into direct contact with vinyl chloride or polyvi nyl chloride or results from the pro duction or use of any raw material, in termediate product, finished product, by-product, or waste product contain ing vinyl chloride or polyvinyl chloride but which has not been discharged to a wastewater treatment process or dis charged untreated as wastewater. (k) `'Wastewater treatment process" includes any process which modifies characteristics such as BOD. COD, TSS, and pH. usually for the purpose of meeting effluent guidelines and standards; it does not include any process the purpose of which is to remove vinyl chloride from water to meet requirements of this subpart. (l) "In vinyl chloride service" means that a piece of equipment contains or contacts either a liquid that is at least 10 percent by weight vinyl chloride or a gas that is at least 10 percent by volume vinyl chloride. (m> "Standard operating procedure" means a formal written procedure offi cially adopted by the plant owner or operator and available on a routine basis to those persons responsible for carrying out the procedure. (n) "Run" means the net period of time during which an emission sample is collected. (o) "Ethylene dlcblorlde purifica tion" Includes any part of the process of ethylene dichloride production which follows ethylene dichlorlde for mation and in which finished ethylene dichlorlde is produced. (p) "Vinyl chloride purification" in cludes any part of the process of vinyl chloride production which follows vinyl chloride formation and in which finished vinyl chloride is produced. (q) "Reactor" Includes any vessel In which vinyl chloride is partially or to tally polymerized into polyvinyl chlo ride. (r) "Reactor opening loss" means the emissions of vinyl chloride occur ring when a reactor is vented to the at mosphere for any purpose other than an emergency relief discharge as de fined in f 61.65(a). (s) "Stripper" includes any vessel in which residual vinyl chloride is re moved from polyvinyl chloride resin, except bulk resin, in the slurry form by the use of heat and/or vacuum. In the case of bulk resin, stripper in cludes any vessel which is used to remove residual vinyl chloride from polyvinyl chloride resin immediately following the polymerization step in the plant process flow. (t) "Standard temperature" means a temperature of 20* C (69* F>. (u) "Standard pressure" means a pressure of 760 mm of Hg (29.92 In. of Hg). (41 FR 46564. Oct. 31, 1976, as amended at 42 FR 29006. June 7.1977] 161.62 Emiaaion itandard for ethylene di chloride plants. (a) Ethylene dichlorlde purification: The concentration of vinyl chloride in all exhaust gases discharged to the at mosphere from any equipment used in ethylene dichlorlde purification is not to exceed 10 ppm. except as provided in 161.65(a). This requirement does not apply to equipment that has been opened, is out of operation, and met the requirement in 161.68(bk6Xi) before being opened. (b) Oxychlorinatlon reactor Except as provided in 161.65(a), emissions of vinyl chloride to the atmosphere from each oxychlorinatlon reactor are not to exceed 0.2g/kg (0.0002 lb/lb) of the 710 ucc 038022 0--frolecti n of Environment thylene dichlorlde purlficoludes any part of the proee*. lene dichlorlde production liows ethylene dichlorlde fornd in which finished ethylene le is produced. inyl chloride purification" in ly put of the process of vinyl production which follows loride formation and In which vinyl chloride is produced, eactor" Includes any vessel in inyl chloride is partially or tolymerized Into polyvinyl chlo- teactor opening loss" means sslons of vinyl chloride occur- eactor Is vented to the at* t any purpose other than y relief discharge as de15(a). tripper" includes any vessel in residual vinyl chloride is refrom polyvinyl chloride resin, bulk resin, in the slurry form use of heat and/or vacuum. In ;e of bulk resin, stripper inany vessel which is used to residual vinyl chloride from /I chloride resin immediately g the polymerization step in it process flow. tandard temperature" means a iture of 20* C (69* F). Standard pressure" means a j of 760 mm of Hg (29.92 In. of 46544, Oct. 31. 1376. u amended at 3006, June 7.1377) Emiaaion standard for ethylene diiride plants. fthylene dichlorlde purification: ncentration of vinyl chloride in isust gases discharged to the atere from any equipment used in ne dichlorlde purification is not eed 10 ppm, except as provided 1.65(a). This requirement does ply to equipment that has been 1, u out of operation, and met equlrement in f 61.65(b)(6Xi) going opened. ^HhlorinatJon reactor Except vrad In f 61.65(a), emissions of ;hloride to the atmosphere from axyehlorinatlon reactor tre not eed 0.2g/kg (0.0002 lb/lb) of the Chapter I--Environmantal Protection Agency $61.64 100 percent ethylene dichloride prod uct from the oxychlorln&tion process. (43 PR 33006, June 7.18771 161.63 Emission standard for vinyl chlo ride plants. An owner or operator of a vinyl chlo ride plant shall comply with the reoulrementa of this section and 161.65. (a) Vinyl chloride formation and pu rification: The concentration of vinyl chloride in all exhaust gases dis charged to the atmosphere from any equipment used in vinyl chloride for mation and/or purification is not to exceed 10 ppm, except as provided in (61.65(a). This requirement does not apply to equipment that has been opened, is out of operation, and met the requlrment in 161.65(b)(6Xi) before being opened. 1(1.64 Emission standard for polyvinyl chloride plants. An owner or operator of a polyvinyl chloride plant shall comply with the requirements of this section and 161.65. (a) Reactor. The following require ments apply to reactors: (1) The concentration of vinyl chlo ride in all exhaust gases discharged to the atmosphere from each reactor is not to exceed 10 ppm. except as pro vided In paragraph (aX2) of this sec tion and 161.65(a)- (2) The reactor opening loss from each reactor is not to exceed 0.02 g vinyl chloride/kg (0.00002 lb vinyl chlorlde/lb) of polyvinyl chloride product, with the product determined on a dry solids basis. This requirement applies to any vessel which Is used as a reactor or as both a reactor and a stripper. In the bulk process, the prod uct means the gross product of prepolymerization and postpolymeriz&tlon. (3) Manual vent valve discharge: Except for an emergency manual vent valve discharge, there is to be no dis charge to the atmosphere from any manual vent valve on a polyvinyl chlo ride reactor in vinyl chloride service. An emergency manual vent valve dis charge means a discharge to the at mosphere which could not have been avoided by taking measures to prevent the discharge. Within 10 days of any discharge to the atmosphere from any manual vent valve, the owner or oper ator of the source from which the dis charge occurs shall submit to the Ad ministrator a report In writing con taining information on the source, nature and cause of the discharge, the date and time of the discharge, the ap proximate total vinyl chloride loss during the discharge, the method used for determining the vinyl chloride loss, the action that was taken to prevent the discharge, and measures adopted to prevent future discharges. (b) Stripper. The concentration of vinyl chloride in all exhaust gases dis charged to the atmosphere from each stripper is not to exceed 10 ppm, except ss provided in 161.65(a). This requirement does not apply to equip ment that has been opened, is out of operation, and met the requirement in { 61.65(bX6Ki) before being opened. (c) Mixing, weighing, and holding containers. The concentration of vinyl chloride in all exhaust gases dis charged to the atmosphere from each mixing, weighing, or holding container in vinyl chloride service which pre cedes the stripper (or the reactor if the plant has no stripper) In the plant process flow is not to exceed 10 ppm, except as provided in 161.65(a). This requirement does not apply to equip ment that has been opened, is out of operation, and met the requirement in 161.65(bX6Xi) before being opened. (d) Monomer recovery system. The concentration of vinyl chloride in all exhaust gases discharged to the at mosphere from each monomer recov ery system is not to exceed 10 ppm, except as provided in f 61.65(a). This requirement does not apply to equip ment that ha* been opened, Is out of operation, and met the requirement in 161.65(bX6Xl) before being opened. (e) Sources following the strippertsX The following requirements apply to emissions of vinyl chloride to the at mosphere from the combination of ail sources following the stripper(s> tor the reactorts) if the plant has no strlpperts)] in the plant process flow including but not limited to. centri fuges, concentrators, blend tanks, fil ters, dryers, conveyor air discharges, baggers, storage containers, and inprocess wastewater 35*126 0-S4- 711 ucc 038023 1 9 61.65 Tills 40--Protection of Environment (I) In polyvinyl chloride plants using discharge, the approximate total vinyl stripping technology to control vinyl chloride emissions, the weighted aver chloride loss during the discharge, the method used for determining the vinyl age residual vinyl chloride concentra chloride loss, the action that was tion in all grades of polyvinyl chloride resin processed through the stripping operation on each calendar day, meas taken to prevent the discharge, and measures adopted to prevent future discharges. ured immediately after the stripping operation is completed, may not (b) Fugitive emission sources--(l) loading and unloading lines: Vinyl exceed: (1) 2000 ppm for polyvinyl chloride dispersion resins, excluding latex resins; (II) 400 ppm for all other polyvinyl chloride resins, including latex resins, chloride emissions from loading and unloading lines In vinyl chloride serv ice which are opened to the atmos phere after each loading or unloading operation are to be minimized as fol lows: averaged separately for each type of resin; or (2) In polyvinyl chloride plants con trolling vinyl chloride emissions with technology other than stripping or in (1) After each loading or unloading operation and before opening a load ing or unloading line to the atmos phere, the quantity of vinyl chloride in all parts of each loading or unload addition to stripping, emissions of vinyl chloride to the atmosphere may not exceed: <i) 2 g/kg (0.002 lb/lb) product from the strlpperfs) tor reactoris) if the plant has no stripperisll for dispersion ing line that are to be opened to the atmosphere is to be reduced so that the parts combined contain no greater than 0.0038 m*(0.13 ft*) of vinyl chlo ride, at standard temperature and pressure; and polyvinyl chloride resins, excluding latex resins, with the product deter mined on a dry solids basis; (ii> 0.4 g/kg (0.0004 lb/lb) product from the strippers [or reactoris) if the plant has no stripperis)] for all other polyvinyl chloride resins, including latex resins, with the product deter mined on a dry solids basis. (11) Any vinyl chloride removed from a loading or unloading line in accord ance with paragraph (bXIMi) of this section is to be ducted through a con trol system from which the concentra tion of vinyl chloride in the exhaust gases does not exceed 10 ppm. or equivalent as provided In 181.48. (2) Slip gauges. During loading or I (1.45 Emission standard for ethylene di chloride, vinyl chloride and polyvinyl chloride plants. An owner or operator of an ethylene dichloride, vinyl chloride, and/or poly vinyl chloride plant shall comply with the requirements of this section. (a) Relief valve discharge. Except for an emergency relief discharge, there is unloading operations, the vinyl chlo ride emissions from each slip gauge in vinyl chloride service are to be mini mized by ducting any vinyl chloride discharged from the slip gauge through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm, or equivalent as provided tn 181.88. to be no discharge to the atmosphere from any relief valve on any equip ment in vinyl chloride service. An emergency relief discharge means a discharge which could not have been avoided by taking measures to prevent the discharge. Within 10 days of any relief valve discharge, the owner or op erator of the source from which the relief valve discharge occurs shall submit to the Administrator a report in writing containing informati n on the source, nature and cause of the discharge, the date and time of the (3) Leakage from pump, compressor, and agitator seals; (1) Rotating pumps. Vinyl chloride emissions from seals on all rotating pumps tn vinyl chloride service are to be minimized by installing sealless pumps, pumps with double mechanical seals, or equivalent as provided In 161.68. If double mechanical seals are used, vinyl chloride emissions from the seals are to be minimized by main taining the pressure between the two seals so that any leak that occurs is into the pump; by ducting any vinyl 712 Chapter I--Environmental Protect!* chloride between the two s through a control system from w) the concentration of vinyl chlorid the exhaust gases does not excee ppm; or equivalent as provider 161.88. (11) Reciprocating pumps. Vinyl > ride emissions from seals on all r roosting pumps in vinyl chloride ice are to be minimized by instr double outboard seals, or equivale provided in f 61.68. If double out) seals are used, vinyl chloride emi* from the seals are to be minimiz maintaining the pressure betwee two seals so that any leak that < is into the pump; by ducting an> chloride between the two through a control system from the concentrati n of vinyl chloi the exhaust gases does not exc ppm; or equivalent as provi< i 61.68. (Hi) Rotating compressor. Vin: ride emissions from seals on al ing compressors in vinyl chloric ice are to be minimized by in compressors with double mec seals, or equivalent as prov 161.66. If double mechanical s used, vinyl chloride emissior the seals are to be minimized t taining the pressure between seals so that any leak that into the compressor, by due vinyl chloride between the through a control system fre the concentration of vinyl cl the exhaust gases does not ppm; or equivalent as pri 161.88. (iv) Reciprocating con Vinyl chloride emissions Iron ill reciprocating compressor: chloride service are to be min Installing double outboard equivalent as provided in double outboard seals are u chloride emissions from the to be minimized by maint< pressure between the two se any leak that occurs is intc pressor; by ducting any vm between the two seals thro trol system from which the tlon of vinyl chloride in t: gases does not exceed 1 equivalent as provided in i < ucc U?s024