Document R7EBwB7vKR0QR5bqrbEYoNk7

2 .532, ? j 1976 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, 20460 DRAFT MM WE tt CITE AIR AND WATER PROGRAMS SUBJECT: Rulemaking for Vinyl Chloride Emissions Under the Authority of Section 112 of the Clean Air Act--ACTION MEMORANDUM FROM: Assistant Administrator for Air and Waste Management TO: The Administrator THRU: AX General Description of the Rulemaking On December 24, 1975, we listed vinyl chloride as a hazardous air pollutant amt proposed a national emission standard for it under the authority of section 112 of the Clean Air Act. We received 50 public comment letters on the proposed standard. Of these, 24 came from industry; 3 from environmental groups; 15 from Federal, State and local agencies; and 8 from individual citizens. A public hearing was held on the proposed standard on February 3, 1976, in Washington, D. C. Section 112 stipulates that the Administrator may withdraw a pollutant from the list of hazardous air pollutants only if he finds, on the basis of information presented at the public hearing, that the pollutant is clearly not hazardous. We do not feel that sufficient information was presented at the public hearing to remove vinyl chloride from the list of hazardous air pollutants. Only three of the 50 comment letters disagreed our decision to regulate vinyl chloride under section 112. Most of the other letters agreed with our decision, but commented that we had overstated the problem of community exposure to vinyl chloride. A sunmary of the comments received on the proposed standard, both in letters and at the public hearing, and our responses to them are contained in the enclosed Standard Support and Environmental Impact Statement, Volume II. ' Major Decision Issues There are no remaining major decision issues which need to be resolved before promulgating the standard. The public comments resulted in relatively minor changes in the standard. These include Spl-01979 2 exemption of certain research and development equipment from all or parts of the stanaard depending on size; provision for emergency manual venting of vinyl chloride to the atmosphere from reactors; correction in the emission limit for reactor opening; and reduced recordkeeping for the continuous monitor. The commenters recommended several other changes in the proposed standard which have not been made. These include providing for excess emissions during startup, shutdown, and malfunction; increasing the averaging time for several of the emission limits; removing the requirement for double mechanical seals on pumps, compressors, and agitators; making the resin stripping requirements more stringent; and making the resin stripping requirements less stringent. Two other comments were that vinyl chloride usage should be gradually phased out and that costs should be given more consideration in setting the level of the standard. Summary of Couments A preliminary draft of the standard we are recommending for promulgation and Volume II of the Standard Support and Environmental Impact Statement have been reviewed by the Working Group and the Steering Committee. The changes which have been made in the standard since proposal have been discussed in telephone conversations with the Environmental Defense Fund, the Society of Plastics Industry, Inc., and some State agencies. The Steering Committee did not make any major comments. The Working Group discussed the desirability of adding provisions to the standard for excess emissions during startup, shutdown and malfunction. The Office of General Counsel (OGC) stated that startup, shutdown, and malfunction provisions might be appropriate for some pollutants regulated under section 112. This should be determined based on the degree of hazard that would be presented by the particular pollutant in question if uncontrolled or only partly controlled in upset conditions and/or wnetner technology is available to avoid or control these emissions. We investigated this issue and determined that provision for excess emissions during startup, shutdown, and malfunction is not necessary for the vinyl chloride standard. Since polyvinyl chloride production is generally a batch process, startup and shutdown provisions would not be pertinent. Technology exists to avoid excess emissions during startup and shutdown at ethylene dichloride-vinyl chloride plants. During malfunctions we do not believe plants should be allowed to emit excess emissions, and therefore are requiring them to shut down immediately. Costs and Economic Impact The proposal of an emission standard for vinyl chloride was considered to be a major action and was therefore subject to the requirements of Executive order 11821. An economic analysis SPl-01920 3 of the inflationary impact of this action was prepared in accordance with the Agency's guidelines and submitted to the Council on Wage and Price Stability. This analysis was included in Volume I of the Standard Support and Environmental Impact Statement and is sunman zed in Tab B. Comments on the proposed standard have resulted in only one major change in the economic impact analysis. VJe estimated that there would be four plant closures as a result of the promulgated standard. Of the four plants identified as possible closure candidates, one has given notice that it no longer produces polyvinyl chloride and the other three have indicated that they do not intend to close as a result of the standard. Intermedia Effects Changes in the standard since proposal do not affect the level of control required. Thus, the environmental impact of the promulgated standard is, with one exception, the same as that described in Volume I of the Standard Support and Environmental Impact Statement and is sunmarized in Tab A. Based on data submitted by the Society of Plastics Industry, Inc. (SPI), the impact on water consumption in the draft environmental impact statement was overstated. We had based our estimates of this impact on worst case conditions. That is, we assumed that those control systems with the greatest water usage would be employed and that there would be no recycling of water. There is no regulation which would require water recycling. According to SPI, the control system using the most water will not be used generally by the industry and economics will cause plants to recycle much of the water. Therefore, the impact of the standard on water consumption will be negligible. Programmatic and Resource Consequences The manpower requirements which would be needed to enforce the recommended standard are listed in Tab C. During the first year after promulgation of the standard most of the manpower would be spent in reviewing applications for waiver of compliance and setting up compliance schedules. The peak manpower requirement of 5.2 manyears is expected to occur in the second year after promulgation, when the majority of the emission tests would be conducted. Region VI with 18 plants and Region III with 13 plants would have the greatest manpower requirements, but the peak requirement for any regional office would be 1.5 manyears. Regions VII, VIII, and X currently have no plants. Energy Consequences The increased energy consumption which would be required by average sized plants attaining the recommended standard is presented in Tab A. Energy consumption would be a significant impact if the standard required combustion of large volume, low concentration gas streams because large quantities of supplemental fuel would be SPl-01921 4 needed to support combustion. The increased energy consumption which would result at ethylene dichloride-vinyl chloride plants has been minimized by establishing the level of the recommended standard so that only one existing plant, if any at all, will use combustion to control the oxychlorination reactor. Increased energy consumption at polyvinyl chloride plants is expected to be minimal because the large volume, low concentration gas stream from the dryer operation at most, and probably all, plants will be controlled by measures other than incineration. Recommendation I recommend that you sign the enclosed notice for publication in the FEDERAL REGISTER. Enclosures Tab A - Environmental and Energy Impacts of the Recommended Standard Tab B - Total Industry Costs to Attain the Reconmended Standard Tab C - Enforcement Manpower Requirements FEDERAL REGISTER Notice: National Emission Standard for Vinyl Chloride Standard Support-and Environmental Impact Statement - Emission Standard for Vinyl Chloride, Volume II. Prepared by SDB:SWyatt:dbt:rm 730 MU, X371:6-29-76 SPI-01922 'AS A ALTERNATIVE CONTROL LEVELS SPI-01923 iw v iira D i.'iMikiii, i `i ( n ; i 111 `Vi; i i.ant ; u r inn i ^ i< AVLk/\r,i p i ami or yoo Mil I i/./v n ) liT A irn .T , I lM ;l ( O. u I'!H I) . i /,|;|i/',|;|) AIM) ALI l.llll.'U IVI CIIIIIIIOl. U VII.'. <c oOn 5 -il 5 I I- e a, > cto! *o_> :5h3 i STtOOo Mtt=o41! o ^a> co u to ^ft U^Jli*-"O c J-o-2 <Pr *TCO l/l` (L.*l f 'Z os- o ^5 <J -- --c > 4- *o3 o(J O "J ^u --O* T3 CJ OJ cO - * on 3O rQJ vi ^o > c S.3 *- >> -- to a '1 C .O w--_ nfJoU=r r c -- -TQ3o3J 5 c- T3 t*4iiC^e-t.: >*- ^ V o Co--' 5e !c a * a --" pw > o c> c, ^ a iyjz ot u *- C > s- 1^1 ^1, l/lI li w - c rp G O >' :\j f f 1 I i f SPI-01924 I I . l i " M W r fI A!'.LI I i'.'LYVIIftl Gill O'! I'll iM RM1;'! |>| AKT;' II1PACTS, >:0'> plmu ; 11 rm 11<>: K(i/Yi< os 30 1111 ik i :/) a i ; " ,ni!_ hi c im iiD c u standard AIM) ALUR'! TIV:. CG 11WA IXVELS SPI-01925 th is level o f c o n tro l has not. been c o iu -e rc ia lly demonstrated. TAB B Total Industry Costs to Attain tno Rec:_~?ncad Standard SPI-01926 Table B -l: T o ta l In d u s try Costs to A tta in the Reconmended Standard Q-- LfJ L. fsi O -- oc __I CL C3 tO < a. --j to < H- h- to I-- ^ & to- o o oo o o VO o o cc r>* OQ O < hUZ-J QC* (-- OOC _1--J4 o to H- CO O'UJ z < LU O t-- oc z-- oi *L-L. rH>h<ceIIIaO: 3 z a- o. f< <s 3 CoO o r* ro o Ouo CO 3 to Z thO-- Q--.i O3 O O' ISI O CC --J h- CZ 3O Z C_> z CO o c0o> CM o CO co Nid% CO CM COM a. CO < CO occ CC c*--c t3Qo to ~ --o oc >- >Xz CL 2 4cV-> c o <0 f* OuJ 3aa> Ou auc> accQ> *co CO (O sa- a. o </> a3> oc SPI-01927 Table B 2. T o ta l In d u s try Costs tc, A tta in the Recownended Sta ard and EPA Water E fflu e n t G u id e !ire Regulations -- o LU LU MO CC mmJ CL. <c Z2 on zo Z -J < G_ --i on < hi-- on H- o CO -J t* OS CO o o oo o m vo cm o o o 0k lO cr> oa H- UJ *-- >* O< h- u Z J "> GO -J o GO ^3 VI ^ l-U O' LU Z < UOJ JZOOHH" 1--4 I U-. h<LUO Zo hz tof.Sa. o< oo oo o o* dm m LO CM VO LO X. j-- a. on 3 3- psj o i-* ac _ v-- <Z 3O ZU <zC Of o CO CM d oo o 0 oo 1 CSJ CM CM LO m OS CvoO t* a a> .e a> T3 C <0 &. 0) c c u a a. o *D i/l O u u c tcao; c /T3 *c0 <0 oos to ia; o OJ *o 3 SPI-01928 ; TAD C EnforceT.sr.t .'`an pc., = r P.epuirecants SPI-01929 TABLE C-l ENFORCEMENT MANPOWER REQUIREMENTS (man-years) FISCAL YEAR 1977(1) 1978 1979 REVIEW REPORTING FORMS 0,4 INSPECT 50 SOURCES WITH DUBIOUS COMPLIANCE STATUS 0.8 TEST, OBSERVE AND EVALUATE 10 SOURCES 0.8 SET SCHEDULES FOR 30 SOURCES 2.4 COMPLIANCE MONITORING a) OF SCHEDULES b) OF IN COMPLIANCE SOURCES c) LITIGATION d) END OF SCHEDULE TESTS TOTAL 4.4 0.4 0.2 0.6 0.6 1.0 2.0(2) 2.4 2.0 5.2 (1) ASSUMES STANDARDS PROMULGATED BY 1C/76, 30 SOURCES IN VIOLATION. (2) ASSUMES 2 SOURCES FAIL TO COMPLY. SPI-01930 REGION I II III IV V VI VII VIII IX X MANPOWER REQUIREMENTS BY REGION (man-years) MANPOWER NO. OF PLANTS FY 77 FY '78 5, 0.4 0.2 4 0.3 0.1 13 0.9 0.4 7 0.5 0.2 CD CD O sl 10 18 1.3 0.6 000 000 5 0.3 0.1 000 FY 79 0.5 0.4 1.1 0.6 0.8 1.5 0 n 0.4 0 TOTAL 63 4.4 2.0 5.2 SPl-0l93-i