Document RJj0K5kvybzYejJMzJv3YdKVk

X , - ,.JK ,i fv .* if -*c_ fMa.H.i.1. m. f\ O. I'<oc ?1S? HtwsJWi, Ttxw. 77001 February 12, I97& Emissions Standards and Engineering Division Environmental Protect ion Agency Research Triangle Park, North Carolina 27?H Attention Hr. Don R. Goodwin Dear Hr. Goodwin: Conoco Cht fo i ta 1 s wfsffMo participate in ard for vinyl chloride (VC) submitting these ca^sienl oposed As we have indicated previously (see attachment), Conoco Chemicals believe^ it Is in the public interest to reduce the rmi ss ions sure of the surroundings to VC. The strict Occupati 1 1 Safety ~-nd Health Adminisirat ion (OSHA) standard has already significantly reduced this exposure in the work glace* Although concenttat tons measured in environ merits su r round i fro plant sites have always been icw compared to the work place, further redyction wi11 benefit the public and the environreht by ieducing further the possibility of harm Mom VC. Thr object of chit c meat is to help develop the best standard possible which provioes srapl and significant, protect Jot* with efficient use of society's resources t this. Consider first the establishment of the safe ac&ient concentration. In 6 1 1 our review of the standard as welt as the background and source informa tion, we have been unable to find where VC has caused harmful health effects in the environment outside our plants at past and present levels of control. Indeed from the Environmental Protection Agency (EDA)* study, we learned that a study was static of mortality f i om llvef $ fates, and it found that "the number cf cases josat coma in the United in our study, fZl tt,fb , is close to tihre expected 10-year total of 260, and the three possible angiosarcoma cases within five miles of vinyl chloride plants would probably match wel 1 with the fi-5 cases expected...11 "...If the presence of the vinyl chloride plant contributed no risk factor pre-rii spos iog people to the disease.11 We also learned that "Ihis survey has produced no evidence that living around vinyl chloride plants is a risk factor in the occurrence of liver angiosar- coma," The E FA he^g* attempted to determine the human liver angiosarcoma mortality expectation by statistical treatment Of a nx>del that uses data determined on rats. The proof of the pudding of any such p study is whether the conclusions of the model are borne out by the experimental evidence. They were not. As the study said, "Ho conclusion can be drown firan our 1 A, H. n and ft. . HcGaughy, "Quantitative Risk for f oreuunity Exposure to Vinyl Chloride,11 EPA, December 5 &u(J<U/9 On Th* Pfcfct ^^ .r j* r -r -r f II^LM f I C ICis^-s^.-ov.-r/,yy>'y.vx>' i%j }w..ivijuvyu/s;v\..vi/, mfir.cih ma nea'iinV . bul ie ve the GSHA standard is sufficclent and this measure of safety should be provided to 9]1 geop1e. Consequently, we rc coamend adjust irrg the OSHA eight-hour standard for workers so the maximum safe ?6~hour envi ronmental exposure is no greater than 16/ ppb {& hours * 26 hour's x 500 ppb = 16? nob) Controls to assure attainment of this concentration should be installed bPy the Industry, i t. of this level on any control strategy cannot he fully assessed ^^-tause E-PA s muni toring studies are incomplete-. Keeping In mind, however EPA's published monitoring data-* and using the EPA model,* we propose this analysis: Monitoring data justified the model's assumption that in the 0 - 1/2 mi Ur annulus around it PVT plant the average concentration of vinyl chloride would be 3?3 ppb. Accordingly the maximum c lowed 2. Occupational Safety snd Health Act of 1970, P.L. 91-596. 3- ocienf i f i c ejn d Tcchn 1 to 1 Assct Rc^jot t on Vi ?iy I Ch IorIde and Polyvinyl Chloride,11 U-Sr [nvi iwimehlcil Protect ion Agency, Office of and Development, Washington, D.C. 20660. m VV l*OlVv"o v>' (e s' H' i J- f>." . k tP' * rt'.rfP.-Vr rV TJ . pS ,Hr r W* " f.WM.-- ri -ft . r*r* -: Emissions Stemdards and l nq I nee r i nq Division (EPA) P aq e 2 F eb ma ry , 1976 .L 4 .. , *M- /v* 4j-'-= b H * -l r VI*. * survey at its present stage of cample IIon*11 Therefore, this study cannot properly be used to set the stringency of control because the ass woptions. sIbi1ity for error and Jack of correlation with ne r imentaI idence y cause it to dictate control much too strictly. This would grossly escalate the cost to provide an unneeded intteispht of risk reduction. no health effects have been found outside of VC or PVC plants, we conclude that control could occur anywhere on the coo 11 nut between no detectable emissions and current emissions, whlcfi result from pre- regulat ion controls in place (no and} t i ona f control). Experience in industry, plus inconclusive but disturbing reports of adverse health effects at lew concen trations in animal studies, htwevei, cause us to endorse additional controls significantly more stringent than tbos practiced by industry today Ws The EPA have chosen tire same course. We Interpret their reasoning to say that nondetectahle emissions represent a o>ntr*l point whose cost to Indus try and society would be un I us t if i a b 1 v excess i ve. Thus, the EPA balanced theft cost-fIsk^benefit by choosing a control point represented by "best ava i 1 ab Ie technoIogy." 1 * < 'r t f * ~n 4*.' bi it Mm 1t t A.. 1 3: .*1 I -4 y ff *> A % if > \i s' \ i 4 r i cal s with the PA their determination that some con trol poi u. between the exteas be chosen. However, we be^li^ye ^th^i there `` ^ control points Than the one chosen by the f PA-tS^bet a I an ce the benefit,, risk, and cost involved in this proposed regulation. Our sug- oes control point Is based on the OSHA standard, whose 11 itc t i on level11 Is an eight-hour t irae-w-e iqhied average c/nosure of no more than bOO ppb The OSHA 1 imit was chosen after copious expel t temment about where the 1 e ve I should be set to 1'assure so far as possible every working man and woman In the nation safe and I Ithful working conditions and to preserve our human resources. For [F'A to set a esre stringent level would imply that the 0SHA standard was insufficient to protect workers* safety and health. We believe the fiSHA standard is sufficient and this measure of safely should be provided to all people. Consequently, we recommend adjusting the OSHA eight-hour standard for workers so the maximum safe 2^-hour environmental exposure is no greater than 167 ppb (8 hours * 2^ hours x 500 ppb * 167 ppb) . Controls to assure attainment of this concentration should be installed by the I nous try. The impact of this level on any control strategy cannot be fully assessed because CF*A*s monitoring studio^ are incomplete. Keeping in mind, hcjwever, fPA*s published Bx>nltoring data^ and using the tPA rfiode 1 , * we propose this analysis: Monitoring data justified the model's assumpticm that in the & " i/2 i h annulus around a f'VC plant the average conrc-nt rat i on of vinyl chloride would be 323 ppb. Accordingly, the maximum ccwicent i at i on "allowed. II **4Pfi r * i if *< ' f "Cl: * * -t.. it. Lr t?r f p.. t VI jf, <! \k` ti t9" Hr h V. V f' i 2. Occupational Safety and Health Act of 1970, P-L. 91-59& 3- "Scientific and Technical Assessment Report on Vinyl Chloride and Polyvinyl Chloride," U.S. Fnvi ronmenla 1 Protect i cm Agency, Office of R^b^PQiL205216 and Development, Wasfi i nqt on, D.C. 20^60. scc * ;< Emissions Standards -and Engineering Division (ETA) 3 February , 1976 considering the 05HA standard, would be \GJ ppb. To reach a level where everyone outside the plant is provided the same protection or better than workers inside ti*e plant, additional cont rciLs fjeoy i t i nq 5251, not 90+&, will be required (100 x 16? * 323 * !>2) , - t Vi no additional con- trots are needed around vinyl chloride plants to give populations outside the plant equivalent or better protection. Next, consider the effect of the Section 112 approach on trying to respon* sibly run a plant. Federal enforcement under the Clean Air Act singles out for specially strict and heavy penalties those who violate Section 112(c) In Section 113(c)(1) "any person who knowingly-"-(L) violates...Sect ion i!2(c) shall be punished by a fine of not more than $25,000 per day of violation by imprisonraent for not more than one year or by both,1' Harsher penalties exacted for subsequent violations. Because of this, there is the poten* tial for punishment for every notification in the semiannual report of emissions in excess of the proposed standard provided the plant management did not iimsediately shut down the plant. In the preamble of the proposed EFA standard, casual comment about the expectation of these violations implies that ETA fully expects them as part of the normal conduct of opera* *'-rc as even the best of them struggle with the requirement*, of these pro* renuIa tions. The reduction in the slringency of ccniiol we recommend, though still giving sufficient protection to people and the environment, allows a control strategy under Section 112 that is sensible and does not put responsible componies in the position of ''breaking the low** no matter hew hard they try. hoot cJbotCt self / n cr''w\ ' w *-f-f o*\ *[ Consider further that FPA, in their supporting Inforiaation,hn indicate their assessment of the control capabilities of "best available' technology*1 is based on sketchy data. Phrases like ".-.recently been experimenting with," --. _ * ^ theoretically {ossihle, 'at least one polyvinyl chloride manufacturer is currently operating a carbon adsorption unit," and many other comments of this nature shew that the technology being fequiled has not been adequately tested in general use long enough at enough different conditions in different kinds of plants to assess its reliability. it is, therefore, arbitrary for FPA to base a standard cm the operation of exper imentol or infrequently used control devices required by the standard to operate el their best efficiency 100% of the All plant processes break down and require maintenance- So do control Since the proposed regulation requires operators to run control at peak efficiency 1002. of the time, eitlicr we must put in duplicate equipment or shut down the plant during control device malfunctlohs, The additional cost will be grossly excessive to obtain only a small addi tional control of VC. i eSp EPA imply' that although some of the control technology is still In its Infancy, by the time the regulations go into effect, this technology will be well proven and the control levels easily met. They even indicate that A r ,j- ij ' I; \Jj fv y 3 '(Vi ri" i:- s* * i i, 1 *fr A .J- I' % & 1' <F. ih j7-. >i . ' i. * -i! if k: % 'i \ rn -Ti y s * i i-rV, SI ' n-* r y !t I' 5- *i V * d -2 l V *t. Standard Support and fnvlronmental Statement: Emission Standard for Vinyl Chloride, U.S. Environmental Protection Agency, Office of Air and Waste Management, Office of Air Quality Planning and Standards, Resea rchp nnni?n^?i7 Triangle Park, North Carolina 27711, October 1975- r |S k I  Fk:.r ,,*.*- 1frJ- tn Ji- r*jr H_ i. -> - , *-' <V ^r-r. i -1- n r1 .-^..'liiL* :;_ ^ X [miisic>?i3 Standards and fnqi.Qeetuif}- Oivl F isqir- h wvwi ' , 1976 (TP&) wf W _rs 4- |w. a d dlJLi o?va I T>-> -Sve--pv s*s\>d~he~-Kn*e~pfctr~irf^^tf ~1 I s~e f f oct i vg y*h i eh wj ) | t} gh fa.'S?. cent . tonco be* 11 eye& * f important it> poini irub 16 t PA lha r The coottot eq71 pmeril required i s complex und extensive_and wi i j take the full Time avai-lab !e_ under Section U2 to p!c?n, ties 1 qn, const Mitt , install, and prove to be ih comp I i ante. Designs mus t be 1 `frozen*1 jrnedia!eiy upon pf cwtulgat son of the standard to be able to <to this. Constant modi f I rat i on cannot be made during the time between now and t-oap 1 iaricf;, Long delivery Hrees are expected from suppliers, especially if many plants opt for the same type* of control equipment, for instance, incinerators. We believe at Conoco that we have Insufficient data to create a design that we are 5-ure w* I} work when it is in place. Our engineers never design on the basis of such sketchy data and guarantee s result. i.. 1 m- ItA | K. r .l' r <V ' 'v i* I l rJ_ * A* %It J,. *M \ This previous discussion causes us to believe that, operators will be put into the impossible position of spending large sums on extra cwtrol devices or constant ly start ing up and shutl log du/.*n their plants if they do not meet The unttiGVsn_T&ve I s of -$ ?aot? c! that they hope t o obta irv -by iir:-. 1 i f?7g The ''best available techno fogy.11 Watching over all this will be f PA through the vehicle of the semiannual report to deteimine If the shutdown response was insufficiently rapid to charge the operator with a knowing violation* Ihe fPA can merely add up the number of these notices of violations reported semiannually and send the company a bill. If he wishes to stay in business, even the best-i silent i oned operator will likely become a perpetual criminal if LPA's assessment of the capability of "best available technology11 i s i believe there is ample protection of people and the environment jt obtaining the 90+* emission control using the restrictive and un~ proven nr,oposecl..by_f*A.i To put this in perspective, consider Table ) of the proposed standard,-* Ir\.cach section the eur-r-scut--cra?>T>ra Wr>u 1 d require the sum of the emissions to equal 10 or less, With Conoco1 s pro*- 1 the sum of the emissions can equal SO and sti1} provide adequate . With this Increment to work with, v#e propose the following changes. t r f* f& *w ir. 3/ > > ,t * *& I ih $ i * In 61.61(ft) we understand LPA to me using woffle of the common hydrocarbon de tec tors currently commonly found in chemical plants for monitoring. it 1 s ou r ience that these instruments will meet FPA*s sensitivity require me nt ovcr par t of tfi e i r ope rating r a nge but not when there f rferrnces or they beyond the sensitive portion of their scale. We retemmend, the ref ore that the requi red sens i t ivi ty be ch cinged f r ci b to 10 ppm and that this - ms i l i v i t y be 1 cqu i r ed on 1 y uve r the 0 - 50 ppm range- f`rcof of this ssensitivity should be the responsibility of t Im* ifirifni facturer or unit should require if'A approval siiatlar to the system maintained by the National Institute of Occupational Safety and Health (HfOSH). t t 11 Hot iwial fiI ssion Standards Standard for Vinyl Chloride,11 Federal (December 2h. 10/S). for Hazardous Air Pollutants, Register, Volujne* ^0, Ho. 2kSt Proposed p. 35 VAB.0001205218 f 4, l t V- t Emissions Standards and tnginegtinQ Division (LPA) Fage 5 February , 13 76 In 61.62(a), 61.63(a), and 61.64(a)(1), (b), <t), (d) and all other sections in the standard that require vent inn VC containing stre<*ns through a control device that reduces the VC content to less than !0 ppm, ire st rongiy encourage CPA to build a "stream factor15 in the regulation to ac the inab<1itv of process and control equipment to run perfectly all the time (Alternate 1) iopposing a 30 ppn limitation r enui reJnent. I f me~v?e i ghted average (Alternate 2) Requiring the control device to operate at 20 ppei 6Sc of the time, hii ppm 302' of the time, and 100 ppm for V<" of the (Alternate 3) Venting all stress containing more than 10 ppm VC through one or more control devices whose cumulative emissions of VC do not exceed 0.0k lbs./100 lbs. of VC or FVC produced with the requirement that these control devices be maintained in good opera ting order with a minimum stream factor of 0-3- Out engineers estimate the additional emissions ftten our two PVC plants would be only 22 1bs./yr,/plant from EPA*s proposed standard to either Alternate 1 or 2. in 61.64(a)(2) there is an error in the calculation used to arrive at the standard of 0*001 lbs. of VC/KlO lbs. of VC produced. it otcurs In the calculation on page 4.7! of the standard support document^ where a reporte result of 8, ODD pom of VL Is used as 0.008 lbs, /lb. The reported anal vs is w* -a. is in iso1n pff _^ vo t ume percent, not in weight percent. tp order to convert to weiqht > it is necessary to multiply by the ratio of the no 1ecu far wc ioh ts' of VC end air (62.5/28.8 -- 2-17)* Performing the calcu'T--' 1st ion correel ly gives a figure of 0,002 lbs./100 lbs. of VC, and 61.64(a)(2) and t hg i f'iags i nde r of the standard should be corrected to this figure. The pa r aq r apfi shou 1 d li(2) the reactor opening loss from each react or is not to kilogram VC/100 kilograms (0.002 lbs. VC/100 Ihs.) of PVC product* etc....15 In 61.66(b)(5) we recom&end a provision be made to allow raanual venting to the atmosphere if it is apparent that an emergency leading to a massive release will occur. emergencies where primary control systems, such as short stops or auxi liary printer, fa I l and a truly massive, disastrous release is leminent. At this point manual venting is almost the last resort to bring the reaction under control again. because of the danger r " - , 11 f , it would he unsafe to vent the manual releases into a gas holder. if raanua! venting occurred, there would be relea?,e of V6; but manual venting would likely prevent a much larger, perhaps explosive, release of a runaway reaction. If it Is apparent to the oj>erator that much greater emergency, leading to a much more massive release, will occur without the manual venting, a provision perm! 11 i rg this would allow him to take prudent action without breaking the law. VAB.0001205219 (-&'! si, i ons S t cjfiOii r Pi and fnginrei f r*Q Division { fP A) I'age 6 f cb t U3I V W6 Ir, 6l.G^(b)(7) this pari should be changed to allow the plant the flexibility to empty VC sample vessels any way they choose so long as there are no VX emissions or any possible VC missions have been scrubbed in a proper con trol dey* ce. F1 in 61 * c>5 (b) ($} {v S ) the standard has a provision for each operate a del Inition for a leak using some measure of VC concentration < grouno levels In the fixed point monitoring system. We believe this interest mg approach is rendered Inoperable because l) change?, in wind direction an conditions will cause the background levels at some toon it or in points to fluctuate widely and ?) the intermittent batch nature of norma J ,r\^'rall0nV#l U tau*? w*de variation of vinyl chloride concentrations oepeoding on what operations arc- occurring. We believe this will cause the background variation to be similar to the vinyl chloride Increment measured when a leak occurred, so it would be difficult to separate a leak from fluctuation of the norma! background. We re that PA delete this section and let each plant handle hew 1 vSks shdll be detected subject to the approval requited in 6l*65(b)(). In 0.65(i>)(9)(i) we i ec-omKnd that the- tonerntrat ion of VC in each in-process waste water stream before control is requited be returned to the 100 ppm shotted In a previous draft of the standard. This adjustment wf f f cut , vo^Ly5^ in-process waste Water that must be t rented wh i le not significantly increasing the amount of VX emissions to t he a tmosphe re, kfonts will not be required to spend s additiona 1 jrduction of risk. the ! mge extra cost to obtain this As o rs apply theu ingenuity to comply with this very specific pro- standard, it will be apparent to many where alternate control methods not specified in the standard will do an equivalent fob. Thus under 61.66 both CPA and operators may find the requirements of handling so many of 1I A1 |! - ' * g Tt t ^ ` I O very t i rive* - cons um i nq. W.ih the restrictive time limit of Section !!2 of the Clean Air Act governing cc^iip 1 ^nce, opinions on equivalent equ ipment and procedures must be quickly ^patched or the operator's, sbiiiiy to cftp!y in <lw will t.e compriwised. ir' heIrri0,.e' 'tcotfiraef,t? tha` 8 paragraph he added to (,!.(,(, Indicating that ---- : uCM^s , not jtc^jjpon^ a request I ot use of equ3 va lent egui pment or Vf k*Lyyrt`s v? *. t hi n b*0 d ay s_ of _ t he re quest,, the r e q ie St IdYeTi perator be aTTowed to proceed with his alternates Conoco encourage EPA to t(tonsitier theit contio! point and accept the one sped flee cy us. Further, we encourage fFA to consider with us how the industry, diversified os they ore, wilt actuoMy carry out each of the steps the restrictive proposed standard requires, tPA should accept all our proposed modi! feat ions because each is des igned to implement sufficie control whh the* leas t disr upt ion. In our judgment, the additional emis sions from all the modifications r ecofnaepded move the control point only f- J J. -* I. If-. -t . Vo l *ji>: V 4. h }, ai? u V1. f!* J- .v t * i* * A . r- %* ( $ *t tr I, 5 ti f3. V ./ r a-' l *1 a 4?_ '* IS' It- -b ^$ *+ J; f', tr .r t w. * ak d * -fc t VAB.0001205220 J. 4 U. I ' 'V y^ 5 ''**'&," j'.-J; ^.' r t ^--V-S'* ". . . -J r ' T-/L- ,, ; v. V.,;; :. V J ^ yf*.- 'T "' "" \ . -rf- ^.'-" ': ' -*. J/ Mjg?' iji' 'he7^.-1 k"^Fr. j- *< ,*; '3?X; } r- i :'" -=1* i^l - v jt..r Dfllsslons Standards and Engineering Division (tPA) Page ? February , 1976 slightly from the "best available technology11 used by tPA and ketip it well within the control point we recotanend based on the SHA standard. Sincerely, ....__ . ... _ -F- I *: r? David A. Kuhn Director of feiceiedicai and E nv i r onfisen t a 1 Affairs rj f IT i"4 V 4^ i I r-. r * t. I. ^ n y>'.^ d-^-F-P,P ^ r* -* j- ^ xy v1 p+v .*w*w*-r irl VAB.0001205221