Document RJaD1xRx6KkE6Jmd4EdXjrqXB

BFGoodrich The BFGoodrich Company Geon Vinyl Division 6100 Oak Tree Boulevard Cleveland, Ohio 44131 216-447-6000 October 17, 1990 Ms. Meredith Scheck The Vinyl Institute Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 Dear Meredith: Enclosed is a copy of the Level 1 Control Report prepared by O'Conner Associates Envd ronmental, Inc. for Esso Chemical. As you recall, they attended o ur meeting last cummer when we discussed BFGoodrich's Level 1 Cc rntrol Study for the Ontario Ministry of Environment (you should have copies by now of BFG's report) . This report is being sent to pou for your information and distribution. Sincerely, THE BFGOODRICH COMPANY Geon Vinyl Division JWL/kp LSCHECK Enclosure to )fUP James W. Lewis, P.E. Manager, Environmental Affairs SPI-01631 CONFIDENTIAL REPORT FOR RESPONDENTS TO ESSO CH EMICAL PVC QUESTIONNAIRE Submitted by: O'Connc r Associates Environmental Inc. March 1990 SPI-01633 o'connon mjocmtei CONTENTS 1.0 OVERVIEW OF REGULATORY PRACTICES 1.1 United States anc. Canada 1.2 United Kingdom and Europe 1.3 Japan and Australia 2.0 SURVEY RESULTS 2.1 Ambient/Propert) -Line Air Quality and Compliance 2.2 Emissions at Sour 2.3 Control Technologies 2.3.1 Realtor Openings 2.3.2 Slurry Stripping and Post Stripping Tec:bbologies 2.3.3 Recc very System Venting 3.0 TRI DATABASE Page 1 3 3 4 5 5 5 6 6 SPI-01634 o'connon fliiocmisi Esso Chemical Canada in conjunction with O'Connor Associates Environmental Inc. has synthesized the data obtained from the "Level 1 Questionnaire" distributed to PVC producers in the United States United Kingdom and Europe. The enclosed summary is for your perusal, and represeats Esso's commitment to inform the respondents of the results on a confidential basis. 1.0 OVERVIEW OF IEGULATORY PRACTICES 1.1 IJNTTED STATE S AND CANADA For regulation of vinyl chloride emissions the majority of U.S. jurisdictions still follow NESHAP Regulations; however, an increasing number of states are adopting more stringent air emission standards is a condition of permit approval. The manner in which standards for toxic substances are being enforced varies; available data are summarized on Drawing No. 1.1. It is eviden; from this figure that existing sources are subject to less stringent regulatory programs relative to new/proposed sources. For carcinogens, the control approach most frequertly identified by STAPPA and ALAPCO utilizes a combination of control technology requirements, acceptable ambient levels and risk assessment. The principle method for implementing these programmes throughout the United States is the permitting process. Our discussions with various state and local air pollution control officials indicate a wide variance in interpretation of hovr PVC plants should be monitored. The majority of States with operating PVC plans have yet to impose ambient air quality standards (AAQS). On the other hand, at least 12 states have daily or long term ambient air quality standards or guidelines for vinyl chloride which would be thought of as stringent. o'connon associates SPI-01635 Within this group, only 1 state has a plant which is subject to the AAQS, 2 states have plants which are exempt from these standards ("grandfathered"), and the remaining 9 states have no PVC producers. One aspect of this trend is that the stringent regulations may become a deterrent to industry establishing PVC plants in these states. In Canada, the federal Vinyl Cl loride National Emission Standards Regulations became effective July 1, 1979, under Cmada's Clean Air Act. These regulations establish the point source limitations for viny chloride emissions; however, no emissions from fugitive sources are included under tl e CAA. Based on re-drafted regulations under the Canadian Environmental Prote :tion Act (Canada Gazette Part 1, Sept. 30, 1989), this situation appears unlikely to ch mge. Nonetheless, there is a Canadian "Code of Good Practice" which is designed to minimize fugitive emissions from the plant. The Ministry of Environment in Ontario has proposed interim AAQC and POI concentrations of vinyl chloride as follows: - 3 ug/m3 0.5 hr POI - 1 ug/m3 24 hr average AAQC - 0.2 ug/m3 annual average AAQC Our analysis of jurisdictions in Edrope, North America and Australia indicate that these interim standards, if promulgated, will be the most stringent in the world. 1 ug/m3 = 2.57 ppb at STP. c. SPI-01636 o'connon awociatcj 3 Quebec and Alberta, the only other provinces in Canada with PVC producing facilities, follow Federal Regulations Ti ble 1.1 , although Quebec has recently established an ambient air guideline which is rot as stringent as proposed by Ontario. 1.2 UNITED KINGDOM AND EUROPE Regulatory authorities in the United Kingdom use the BACT (Best Available Control Technology) approach without |ambient air quality guidelines. As in North America, there are limits for emissions released during reactor openings and following stripping. Of interest is the provision to make some allowance in standards based on the heat sensitivity of certain suspension grades. In Europe the regulatory approach is undergoing legislative changes, and the most comprehensive regulations at pre sent appear to be embodied in the German (GFR) TALuft, promulgated in 1986. The e regulations appear to be destined to be adopted in several other countries. From th<; ambient air quality perspective, the only country with any guideline is the Netherlands. 1.3 JAPAN AND AUSTRALIA Emission regulations are still unde r development in Japan, although industry stewardship is in place through the Japanese PVC Association. In Australia, the vinyl chloride regulations appear to be patterred after the EPA in the United States. Ambient fenceline monitoring requiremer ts have been set for the 1 plant for .which Esso Chemical Canada was able to obtpin data. SPI-01637 o'connon pnocmm 2.0 SURVEY RESULTS 4 Questionnaires were circulated to PVC manufacturers in North America and Europe* resulting in a total of 17 respoi tses. In the United States the Toxic Release Inventory (TRI) List was used as a mean' of scanning those companies reporting significant vinyl chloride emissions to the EPA. A total of 12 responses were received from the United States, spanning the spectrum olf small to large PVC producers (20 kT to 380 kT PVC annual production). Four respc nses were received from European producers, and 1 of these was indicated to be repres mtative of a large number of plants owned by the same company in 4 countries. 2.1 AMBIENT/PROPERTY-LINE AIR QUALITY AND COMPLIANCE Two companies indicated that AAQS limits ("standards! were established and enforced by the regulator) authorities through fenceline monitoring, An additional 2 companies indicated that AAQS guidelines were established and enforced through permitting using dispersion modelling. One country has a stringer t annual "strive value", monitored periodically by the government. A total of ten companies indicated that their plants were subjected to some form of fenceline monitoring (pei iodically or continuously) and/or dispersion modelling (based on risk analysis fact jrs) to demonstrate compliance or renew permits. `Including the United Kingdom. SPI-01638 o'connoR associates 2.2 EMISSIONS A' SOURCE 5 All respondents indicated that they were normally compliant with the existing regulations. Ten companies indicated they were required to demonstrate compliance continuously (mostly for recovery vents). Several indicated they were only asked to demonstrate compliance "on demand", ''only during permitting", "quarterly" or "semi-annually". Six companies indicates that in order to compare plant performance to the regulated limits, VCM missions were determined by direct measurement of concentrations and flow rates. The remainder indicated that flow rates were estimated. In terms of gauging th e need for technology change in response to new regulations, North American companies either had not assessed the impact of such changes, or indica<ed that they believed technology changes were not required. In contrast, all European respondents indicated that some technology changes would be require d. 2.3 CONTROL TECH NOLOGIES 2.3.1 Reactor Openings Eleven companies indicated they used closed reactors in combination with antifoulant technology. Ten companies indicated that reactor opening emissions were controlled by steam sweeping. SPI-01639 o'connon associate* iSb Six North American companies incinerated the reactor ventilation stream, whereas none of the Ei.ropean respondents used this technology. 23.2 Slurry Stripping and Post Stripping Technologies Continuous steam-stripf i:ng towers were employed by all respondents except 2. A variety of downstrear 1 technologies were employed including incineration of slurry blend tank vent;; (3), air stripping (2) or containment (1). Eight respondents indicated tfc at no post-stripping technologies were employed. 2.3.3 Recovery System Venting Eight companies utilize lefrigerated condensors, 6 of these in combination with incineration of the vent qtream, and 2 in combination with absorbers. Four companies use only [ncineration technology, and 3 companies use absorbers exclusively. 3.0 TOXIC CHEMIGIL RELEASE INVENTORY (TRU DATA The Toxic Chemical Release Inventory (TRI) data provide a basis for determining the performance of PVC producers ui , the United States. Despite some inherent differences in the manner in which such num|ers may have been generated, the emissions data offer a first basis for comparing plant performance. In order to normalize the data, w0 have ratioed the total emissions reported (in kg) on an annual basis as submitted to TtRT over the annual capacity (in metric tonnes) of the to o'connon awociate; SPI-01640 T 7 plant as reported by the Digesi of Polymer Development. The plant capacities reported in this document matched c osely the capacities reported by respondents to the questionnaire. These ratios, designated by O'Connor Associates as the "TRI Factors" are plotted on the accompanying Figure. Your pi mt has been highlighted in colour to give you a relative measure of performance. Nou that the proportions of suspension, emulsion, solution or bulk product are based on figures quoted in the Digest of Polymer Development, and may not be totally accurate. Respectfully submitted, O'CONNOR ASSOCIATES ENVIRONMENTAL INC. LAV. Curtis, Ph.D. SPI-01641 o'connon ahociate; T TABBE 1.X AMBIENT AIR QUALITY VINYL CHLORIDE GUIDELINES OR STANDARDS (ugm/m-3) UNITED STATES AND CANADA Jurisdiction Status California1 S Connecticut Kansas Massachusetts Michigan G North Carolina G Nevada New York G Pennsylvania G South Carolina South Dakota Vermont Virginia Quebec G She rt Term (< Lhr) 0.25 hr 150 Daily 24 hr) 24 hr 8 hr 26 50 24 hr 3.90 8 hr 238 24 hr 50 8 hr 50 24 hr 8 hr 1 50 Long Term VCM/PVC (Annual) Plant Yes1 3.85 0.4 0.38 0.4 6.18 0.2 No No No No No No Yes2 Yes2 No No No No Yes Ontario IS 0.5 Ilt 3 G 0.5 lr 560 24 hr 1 24 hr 280 0.2 Yes3 1. Guideline enforced; jurisdiction is SCAQMD, Rule 1163-1. 2. Guideline not enforced or existing VC/PVC plants, 3. Proposed change to guidel ine/standard. SPl-01642 S Standard G Guideline IS Interim Standard o'connon fwocrara Status of State Air Toxics Programs with Existing Source Review No Activity Limited Regulatory Program Comprehensive Policy Program I Comprehensive Epj|| Proposed 1 Regulatory Prog am Regulations j--) Informal and/or L--' Planning Program Status of State Air Toxics Programs with New Source Review | | Informal NSR Status of Air Toxic Programs United States ---- T Proposed Comprehensive Regulations SPI-01643 oconnon auociatcj JOB NO. : 10.1293 DRAWN B Y LWC DATE : 90/03/30 DWG. NO. : 1.1 TOXIC RELEASE INVENTORY (TRI) DATA, NORMALIZED TO CAPACITY FOR UNITED STATES' PVC PLANTS 1987-1988