Document OE6GRNayaXV28bbVv4gO0MVbe

The Society of the Plastics Industry, Inc. W 'jl y Y ri 355 Lexington Avenue Ne.w York, New York 10017 (212) 573 9400 H^ ^E'CfT;\rg.D September 13, 1976 l 0 'o&R.A.3 * w. U ,vj iV] i TO: PVC PRODUCERS GROUP - VOTING REPRESENTATIVES EPA TECHNICAL COMMITTEE You will find attached the Minutes of the Committee Representatives with the EPA Technical Staff on September 9 in Durham, 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 is 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 SPI 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 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 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 & 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 SPI files, please advise me of your activities and, if possible, copy Mr. Baise 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 ^John R. Lawrence^ Technical Director BOR 013519 minutes EPA - Emission Standards A Engineering Division Durham, North Carolina VCM/PVC PRODUCERS GROUP EPA TECHNICAL COMMITTEE Wednesday, September 8, 1976 - 6:JO PM Thursday, September 9, 1976 - 8:30 AM ATTENDANCE: For Industry: G, Baise, Beveridge, Fairbanks A Diamond F. C. Dehn, PPG Industries W. C. Holbrook, B. F. Goodrich J. R. Lawrence, SPI C. Loechelt, Ethyl Corp. W. W. Madden, Firestone J. P. Sandstedt, Tenneco R. N. Wheeler, Union Carbide For EPA: Jack Farmer Don Goodwin Susan Wyatt 1. The EPA Technical Committee met on the evening of September 8, to review its 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 most current Draft Standard. 2, In meeting with Mr, Goodwin and his staff on September 9, the industry's position as presented in the SPI letter was presented with the recommendation SPI's suggested language be considered as an alternative to EPA's most recent version of the S t and ard. Mr. Goodwin explained that his work on the Standard is basically completed and that ther would be difficulties to make any changes or delay its issuance as it now reads. He indicated that he 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 is 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 I rl355 !ETV CF :T.CS `NDUSTEY 'NC v. Y v- BOR 013520 The Society of the * Plastics Industry, Inc. 355 Lexington Avenue New York, New York 10017 (212) 573 9400 Gcpt mber /, 19/6 Mr. Don R. Goodwin Emission Standards & Engineering Division Environmental Protection Agency Research Triangle Park, North Carolina 27711 Dear Mr, Goodwin: After reviewing the proposed KPA Vinyl Chloride Standard, .-ler.bers of SPI have raised an issue regarding the portion of the Proposed Standard relating to the L '/'oratory and Research and Development facilities. In SPl's initial comments to EPA on the Proposed Standard for Vinyl Chloride we proposed that polymeria .tion 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 ''xu-.iption, based on examination of the data presented in Exhibits A and 8; however, SPI respectfully requests that EPA reconsider its requirements for reactors between 50 and 1100 gallons capacity. "Hie 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 <d'.e prod uc i; i on equipi mt that their interconnect ion is not fc.slble. long runs of v.cuu.i or sbuiy lines we not practical, o *. [ . c i1 ly in cl' Gas win re subfri.v. ing conditions arc e peiwnred, T.i ne plugging, burning of resin, and ro.'.sive pres--ure d ops will m ..be these lines inoperative, 'Gu-rc are also giobM' -3 with sypi n'.rb, it ion of i.- ot e operations and ,.vai t ,ibi 1 i ty of equipment. In the Eort time we !u.ve fwi" . d on this issue, we have hud 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 alequate scale-up data from a 50 gal. reactor. This is becoming more important as reactor si^e increases in modern plants. In the second case, it is necessary that equipment be available BOR 013521 Cont ir.ued . . , "r. "Vn R. Row via -2- fept, 10 76 i-n .]--i! i at i* ly to resolve production problems, and that the polymerixer be as similar to pioduction equip: v-nt .is possible. Anothi-r problem ,irises when the research facilities are using different comonomers from those in use at the production plant, which is a frequent occurrence. Common ere 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 ti cboology, to encourage innovations and to minimize potential losses by encouraging research raid 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 dene in production equipment, where the potential for major releases is increased. We believe the present wording of the standard will inhibit use of i ism.iu'h facilities, not only becau.se of the cost of compliance, but because of restrief ions, on the flexibility of operations. For example, in .several installations the i at c iTOnnec t i on of rer-e.uch and production equipment would take the operation of the re: e-'rch npi i nment out of the hands of trained engineer.'; and put it under the juri:dirL ion of production 1nl >r because of the wording o_union contracts. As k1 a'llr r rynnplo, the rate a. id I i mi ng of the termination and recovery of unreacted Pe-icu.,ar 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. T'e, therefore, request that 61.60(b) and (c) be amended to read as follows; (b) Research and development equipm :ut 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 emissions from all sources shall be no more than 0.05 lb. vinyl chloride per lb. of vinyl chloride charged to the reactor. Each epn.n,.L- of each f.-.ciliiles shall submit a standard operating aw-- lure to the agency for approval of its plan to meet this rcquiin --`nt. e u! .'.bed data in Exhibit B show that eight companies would reduce their emissions ' i it.ially in complying with the SPI proposal, while company q ps already in com"1: co. The resulting total emissions would be about 68,000 lbs, per year, less than that c'ittcd by reactors of 50 gal. or less, and less than 25% of current emissions. Those 9 companies represent 45% of industry capacity, and include many of the major - ro.luccrs, F tally, we want to address the cost-benefit issue raised by the proposed Research '-id 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 le rived. SPI believes the proposed Research and Development Regulation creates a I^oblem 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 BOR 013522 EXHIBIT A EMISSIONS DATA ON LABORATORY AND PILOT FACILITIES (< 50 GAL. SIZE) UTILIZING VINYL CHLORIDE iany 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 Size 50 gal. 0.4 3.25 50 .5 .8 .8 15 30 30 5 10 .5 10 50 .5 to 2 15 10 .5 50 5 30 2.5 10 12.5 30 10 30 .05 1 10 Number of Reactors 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 #/vr 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 5,468 603 2,245 75,634 76 5,285 1,823 606 15,480 34,172 66,582 24,698 1,200 1,063 304 521,080 ' Emissions # VCM/ir PVC Emission # VCM/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 no 4,870 8 321 100 30 1,548 375 21,920 2,740 1,700 350 50 ' 80,355 BOR 013523 The Society of the Plastics Industry, Inc. 355.Lexington Avenue New York, New York 10017 (212) 573 9400 September 13, 1976 Mr. Don R. Goodwin Emission Stu.rvl2.rJs A Engineering Division Environmental Protection Agency Research Triangle Park, North Carolina 27711 Pear 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 Septa`her 7 is to be considered as en alternative to be added to the language of parsers ph 61.00 of the proposed St and..rd . ..'a understand the problems that might be posed by the enforcement of such an alternative wii.hout 2 rp-cific understanding of (he measuring and record keeping pc endures 11i.it ..'On 1 d bo used to verify i:n, ip 1 i me e. Therefore, as you suggested, t , a ...' i eg that our PVC Producers Croup contact you with information on the oprr.iling procedures tinny would follow t.o show ronfor , nice with the suggested a 1 t t-runt I ve th it total combined missions from all sources in existing 0.05 lbs of vinyl chloride per lb vinyl chloride charged to the reactor. in addition, T .mi .eWng that those companies interested in using Lhls al ternaf me uply 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. Fa ion .nt.i.on on the technical problems relating to compliance with the St,indued as it now reads versus the proposed alternat i ve. Information on the cost of ,p] t a -re with the plan a.s it now reads versus the pcopivcd a'torn, t'ive. We appreciate having bed the o p,.oi t en i ty to , eet with you to discuss this important matter to our industry. krohn R. Lawrence Technical Director BOR 013524