Document RaQqmRQ0M9J89vaBrG3kXkKXE

CERTIFIED M"AI L RETURN' RECEIPT REQUESTED BORDEN INC ISO CAST BBCIAO STREET. COLUMBUS. OHIO 43215 December 9, 1976 RECEIVED LAW DRT. DEC 1 41976 H. A. ROSENZWEIG {Mid , bailey BARTON ENVIRONMENTAL OEP ARTMEnT MAN ACER CORPORATE ENGINEERING Regional Administrator - Region I U. S. Environmental Protection Agency John F. Kennedy Federal Bldg. - Room 2303 Boston, Massachusetts 02203 * Re: Borden Chemical, Division of Borden Inc. 511 Lancaster Street Leominster, Massachusetts 01453 Subject: Request for Waivers Polyvinylchloride Manufacturing Facilities Pursuant to 40 CFR Part 61 - Standard for Vinyl Chloride Gentlemen: In accordance with the October 21, 1976 promulgation of Subpart F - National Emission Standard for Vinyl Chloride and previously promulgated Subpart A - General Provisions of 40 CFR Part 61 (NESHAPS), Borden Chemical, Division of Borden Inc. submits the subsequent and attached reports and requests the following waivers for the referenced PVC manufacturing location: Waivers of compliance for specific facilities as detailed in Appendix A, pursuant to Parts 61.10 and 61.11. Waiver of emission testing pursuant to Part 61.13 for these facilities until the compliance programs specified in Appendix A are completed. e Waiver to delay submission of the final Formal Leak Detection and Elimination program provided under Part 61.65(b)C8), pursuant to Part 61.11. Details of an interim program, however, are provided in Appendix B. e Waiver to delay submission of Equivalent Equipment and Procedures, provided under Part 61.66, as a reasonable consequence of compliance waivers pursuant to Parts 61.10 and 61.11. We request the 30-day submittal period be extended to 240 days to allow time to obtain data necessary to support equivalency. Appendix C outlines the proposed procedure for which equivalency will be sought. BOR 013198 Regional Administrator - Region I USEPA/Boston December 9, 1976 Page Two In accordance with Part 61.10(a), we state that: (1) The owner of the sources detailed in Appendix A is: Borden Chemical, Division of Borden Inc. 180 East Broad Street Columbus, Ohio 43215 (2) The location of the sources detailed in Appendix A is: 511 Lancaster Street Leominster, Massachusetts (3) The hazardous substance emitted by the stationary source is: Vinyl chloride monomer (4) The stationary sources are (See Flowsheets Nos. 1 and 2A - Appendix A): A 110 million pounds-per-year design capacity general purpose homopolymer suspension resin manufacturing line (See Flowsheet Nos. 1 and 2A). 9 A 40 million pounds-per-year design capacity specialty suspension resin manufacturing line. (See Flowsheet Nos. 1 and 2A). A 25 million pounds-per-year design capacity copolymer suspension resin manufacturing line. (See Flowsheet Nos. 1 and 2A). A 20 million pounds-per-year (wet) design capacity PVC Latex suepension resin manufacturing line (See Flowsheet Nos. 1 and 2A) . (5) Over the past twelve months, these sources have received and processed approximately 13.5 million pounds per month of vinyl chloride monomer. (6) Detailed descriptions of existing emission points, control devices, and related equipment are found in Appendix A and on Flowsheet No. 1. The information on Flowsheet No. 1 is in the nature of a trade secret and Borden Inc. requests confidential treatment of this information. (7) Borden Chemical, Division of Borden Inc's Leominster, Massachusetts polyvinylchloride manufacturing facility cannot comply with all requirements of the standard BOR 013199 Regional Administrator - Region I USEPA/Boston December 9, 1976 Page Three promulgated under Subpart F within ninety (90) days of October 21, 1976 (or January 19, 1977) except as stip ulated in Appendix A. Fundamental reasons for the inability to comply by January 19, 1977 include: new equipment must be designed, ordered, received, installed, and started up. existing equipment must be modified, including in some cases, dismantling and rearranging major piping and vessels. the results demanded by the regulation require several such modifications and/or installations be done on a sequential schedule to produce emissions or intermediate processed material meeting the specifications. the programs and procedures involved in the regulation require, in addition to the foregoing, re-training of operating personnel and revision to standard operating manuals. This must be sequenced to permit available personnel to perform current tasks as well as those both temporarily and permanently imposed by.the regulation. even with the most judicious planning, scheduling, and execution of projects, there are inevitable adjustments which must be made to achieve the desired goal. The regulation imposes changes involving new equipment, modifications to existing equipment and retraining of personnel--the combination of which makes this program more vulnerable to problems than any one alone normally would entail* As regards Part 61.10(b), these details are provided for individual equipment and areas in Appendix A. Flowsheets illus trating the revamp proposals are attached to Appendix A and designated F2-A (Process Modifications) and F2-B (new holding, recovery, and final gas cleaning). In-process wastewater will also be collected and stripped in the new, separate equipment building planned for the F2-B facilities. The information on these flowsheets is in the nature of a trade secret and Borden Inc. requests confidential treatment of this information. Compliance schedules for various equipment modifications and new installations are provided in Appendix A based on individual group and area designations logically subject to such construction approaches. However, the entire revamp project will be initialized by a single contract award--to be made by April 1, 1977. BOR 013200 Regional Administrator - Region I USEPA/Boston December 9, 1976 Page Four The compliance schedules in Appendix A are based upon current delivery estimates by suppliers of equipment. They cannot take into account possible delays resulting from abnormal increases in equipment orders caused by all PVC producers' efforts to comply with the vinyl chloride emission limitations. Moreover, acts of God, natural disasters, or other factors beyond Borden's control may prevent strict adherence to the schedules. Naturally, we will advise the Administrator at the earliest possible date should such an event occur. We are also aware of the legal challenge to the Vinyl Chloride Standard filed by the Environmental Defense Fund in the U. S. Court of Appeals for the District of Columbia. In the event the status of the final regulation is not clarified by April 1, 1977, we may wish to defer entering into final contractual arrangements which could subject Borden Inc. to substantial legal liability for cancelling the contract. As various individual, group and area compliance schedules are completed, it is anticipated that the interim emission control progress'cited in Part 61.19Cb)(3) will occur. We urge that the Agency consider these interim completions as the "steps" described in that section. We would request that the final completion date of the revamp project, i.e. that of the last component of the planned systems, be considered by the Administrator should it become necessary to establish a single compliance date for our Leominster Plant--as compared to individual waivers. In any event, we are available to review any aspect of this material which requires additional supporting information. Written communications regarding this waiver request should be sent to all of the following: (1) Mr. H. A. Peed, Vice President S General Manager Borden Chemical, Div. of Borden Inc.--Thermop1 astics Dept., 511 Lancaster St., Leominster, Mass. 01453 C2) Mr. H. R. Jepsen, Operations Manager Borden Chemical, Div. of Borden Inc,--Thermop1astics Dept., 511 Lancaster St., Leominster, Mass. 01453 (3) Harvey A. Rosenzweig, Esq. Borden Inc. - Law Department 180 East Broad Street, Columbus, Ohio 43215 .... and the writer. BOR 013201 Regional Administrator - Region I USEPA/Boston December 9, 1976 Page Five I would also request that the agency date stamp and return to me the enclosed extra copy of the cover letter. WBB;11c cc: Mr. John Courcier Air Compliance Branch U. S. Environmental Protection Agency John F. Kennedy Federal Bldg. - Room 2303 Boston, Mass. 02203 Massachusetts Department of Environmental Quality Engineering Division of Air Quality Control 600 Washington Street Boston, Mass. 02111 J. V. Lynn H. A. Peed H. R. Jepsen J. R. Degenfelder S. Moll H. A. Rosenzweig^ H. L. Schmidt, Jr. BOR 013202 Appendix A Part II - PVC Manufacturing Facilities - Leominster, Massachusetts A. CurrentStatus - Flowsheet FI The Leominster location is divided into two main PVC manu facturing sites. At site no. 1, three product lines are in operation producing general purpose homopolymer, copolymer, and specialty resins. At site no. 2 only one product line exists producing PVC latex. At the present time the general purpose and specialty lines at no. 1 site, and the PVC latex line at the no. 2 site have installed stripping systems capable of meeting EPA 61.64 (e)(1) (ii) . The balance of the emission control program required by the standard is currently being engineered as part of a major compliance revamp project now underway. Efficacy of existing "control" equipment includes a 97% total material efficiency based on VCM gas converted to solid PVC, and a monomer recovery Of at least 90% of VCM entering the recovery equipment. B. Revamp Project - Flowsheets F2A and F2B The revamp project has certain major features which will be described. Production of copolymer will be discontinued at site no. 1 leaving only two product lines in operation at this location. Polymerization equipment of the copolymer line will be reassigned to operate in either the general purpose or specialty line. No additional stripping operations will be required. A vacuum purging operation will be intro duced for each of the lines for monomer removal to clear reactors and other process vessels for entry or opening to meet 61.64(a)(2) and 61.65(b)(6). A new site centralized gas handling and recovery system will be installed to process gases generated by purging operations, degassing operations, strip ping operations, and non-condensib1e blowdowns. This cen tralized system will be characterized by a gas holder to receive gas and provide for surge capacity, a compression/ condensing train to liquify the VCM, and a carbon adsorption section to separate non-condensib1es from VCM; this will provide for compliance with 61.64(d). Wastewater accumulated in recovery operations will be stripped in a separate site centralized stripping operation to comply with 61.65(b)(9)(i). C. Pilot Plant - Flowsheet F3 The Leominster pilot plant involves 2-300 gallon reactors used for product development. There is currently no recovery of vented gases. Flowsheet F3 shows the connections which will be made to the Flowsheet F2-B system to bring these units into compliance with 61.64(a)(1), (b), (c) and (d). BOR 013203 !i -1- -- i FVC MANUFACTURING FACILITIES - LEOMINSTER, MASS. VCM JNLOAlH- VCM (by railcar) FLOWSHEET FI - CURRENT STATUS ! _IJL VCM [STOR iiii iit: Ml CONFIDENTIAL Notes: v = vent j " \ ww = wastewater rvcm = recycle vinyl chloride monomer AGE I ` .! . r t .; -i I -SITE [ NO. 1 : 3 LINES iroiv degas . v .i r VCM to POLYM. (SPEC. HOMO (8) TfPOLYMER ww L r VCM RECOV-1 ERY rvcm w SLURRY i < VCM to COPOLYMER POLYM (4) .11 <ii SLURR) BLEND TANKS 1 ' t SPECIALTY HOMOPOLYM0T . CENT1DKT1 - FUGE 1 bRYINC , billsi PROD. COPOLYMER o 1 UK-- AGE 1- 1- i ! 1 r TLI- I ww degas -4-- - VCM to! ^ POLYP VCM (15) r GENERAL PUR- r n crmr ERY rvcm POLYMER w SLURRY STRIP FEED 1TMLS. L:J STRIP DRIER PER FEED TANK ww CEN TRI TFUGE ww 1 1RYINC FINISH PROD. GENERAL PUR STOR. POSE -AGE. HOMOPOLYMER SITE < <NO. 2 1 LINE VCM to! POLYM, ------------------------------ pm (3) PVC LATEX 1 U * STRIP..............y PER IAKKS- BOR 013204 PROD. cTnn_ FVC LATEX AGE _L *-- l. i1 i I WW ww CONFIDENTIAL II t iI PVC MANUFA' FLU NG FACILITIES - LEOMINSTER, MASS. ET F2-A - FUTURE STATUS ri VCM UN LOAD. VCM (by railcar) Notes: vs = vent meeting standard wws = wastewater meeting standard It i j + 4r -(iI VCM STOR AGE r t\ :t i ; CONFIDENTIAL o:ww = wastewater to stripping = see numerical designation on Flowsheet F2-B POLYM (8) \ | ; STRIP (strip- -- FEED -------- ^1 PER tank-<; 1 vs DRIER FEED TANK . CENTRIfuge. DRYINi . 5 FINISJ vs i PROD. STORU1CF-, SITE | - NO. 1 ! (MODIFIED)./ !T i ! i 1 WWS ft Li i POLYP (4) t .f 1 1! , STRIP. pppn rANKS * wws \~ "i T wws --U - .J i > :rr i - ;i SITE Li POLYR (15) I wws I' STRIP FEED TANKS STRIP PER vs L DRIER FEED TANK CEN TRI FUGE r wws i vs ; t' DRYIN( " FINISI vs PROD. STOR. -AGE_ BOR 013205 <NO. 2 (MODIFIED) vs < lI P0LYM (3) WWS STRIP :oRom. 'LTLPLJY. r \ COMONOMER RECYCLE ww CONFIDENTIAL prod. 1 STOR_MLE_ FLOWSHITT ) rio > -t r CURRENT STATUS CONFIDENTIAL V I. VCM WEIGH- (2) --------------------- V -- POLYM 300 \1AL.(2; SLURR' HANDLING nr ww i )RYINC -H 6 :INISH Development Products FUTURE STATUS Notes: VCMIVEIGH (2) v vs ww wws 0 1 ?M (2) ------------- vs Slurry HAND LING V wws vs t )RYING FQ :INISH vent - - - - ------- . vent meeting standard wastewater _ wastewater meeting standard see numerical designation on Flowsheet F2-B Development Products -+-- --I ~Uj--+CONFIDENTIAL - ii - j -i i !j 4 -| - _____ i____*______ _____|_ 1 i j 4r __ ;i BOR 013207 Appendix A Leominster, ` Massachusetts DESCRIPTION OF CONTROL FACILITIES TO BE ADDED IN REVAMP PROJECT Site No. 1 - Modifications - 1. 61.64(a)(1) - Polymerizer Vent Loss - No new installation needed for polymerizers (27 units) since there is no normal process- vent gas discharge to atmosphere from these units. 2. 61.64(a)(2) - Polymerizer Opening Loss - 27 Emission Points Installation of steam/vacuum purge system to clear VCV^* from 27 existing polymerizers to specified residual levels prior to opening. This task involves the installation of a new vacuum header system with ties to 27 polymerizers, hot water supply piping, new vacuum equipment with dis charge to new gas holder/recovery operation, 3. 61.64(a)(3) - Polymerizer Manual Vent Valve Discharge27 Emission Points - No new installation required. Existing manual vent system on 27 polymerizers is strictly for use in emer gency condition. 4. 61.64(b) - Stripper Vent Loss - 2 Emission Points - Installation of tie line piping to route process vent gas from 2 continuous strippers (general purpose line, specialty line) to new gas holder/recovery operation. 5. 61.64(c) - Mixing, Weighing, Holding Containers Vent Loss (Non-Recovery Equipment) - 4 Emission Point Installation of tie line piping will be required to route process vent gases from unstripped slurry hold vessels (4 units) to the new gas holder/recovery operation. 6 additional slurry tanks currently on unstripped slurry service will be reassigned to other duties. 6. 61.64(d) - Monomer Recovery System Vent Loss - 2 Emission Points - Installation of tie line piping to route process vent gas from 2 existing RVCM* storage tanks to a new carbon adsorption system fot VCM/non-condensibles operation. * VCM, as used throughout, means vinyl chloride monomer RVCM, as used throughout means recovered VCM BOR 013208 Appendix A 7. 61.64(e)(1) - Stripping - General Purpose Resin Stripping - 1 Unit Installation of this facility has been completed, and the equipment has been operational for several months. Per formance data taken, indicates that the unit can comply with 61.64(e)(1). Specialty Resin Stripping - 1 Unit Installation of this facility has been completed and the equipment is currently in a start-up phase. Copolymer Resin Stripping No new stripping installation will be installed for this product line because this line will be phased out. 8. 61.65(a) - Relief Valve Discharge - 59 Control Points - No new installation required. Existing relief valve system to atmosphere on all vessels in VCM service strictly operates only in an emergency condition. 9. 61.65(b)(1) - Loading and Unloading Lines (5 Stations) 15 Emission Points - Installation of three shutoff valves in unloading lines of each of 5 existing stations to reduce the volume of released VCM gas at disconnect to the specified level. 10. 61.65(b)(2) - Slip Gauges - No new installation required. us ed . Slip gauges will not be 11. 61.65 (b) (3) (i) - Leakage from Rotating Pumps - 15 Control Points - Installation of double mechanical seals and seal fluid units for 9 existing centrifugal pumps in the tankfarm, and 6 pumps in the process area. 12. 61.65 (b)(3)(ii) - Leakage from Reciprocating Pumps - No installation required. used . Reciprocating pumps are not 13. 61.65(b)(3)(iii) - Leakage from Rotating Compressors 4 Control Points (4 Future) - Installation of double mechanical seals and seal fluid units for 2 new recovery compressors, 2 new vacuum pumps, and phase out of existing compressors and vacuum pumps. BOR 013209 Appendix A 14. 61.65 (b) (3) (iv) - Leakage from Reciprocating Compressors 4 Control Points - Replacement of refurbishment of 4 existing reciprocating compressors to effect an adequate shaft sealing system and tie line piping which routes any VCM leakage to the new gas holder system. 15. 61.65 (b)(3)(v) - Leakage from Agitators - 32 Control Points All agitation equipment in VCM polymerizer service or unstripped slurry service is currently equipped with double mechanical seals. Refurbishment of seals and installation of seal fluid systems are required to make the seals operational on 4 unstripped slurry agitation tanks. Polymerizer agitator seals are in an operational state. 16. 61.65(b)(4) - Leakage from Relief Valves - 59 Total Control Points - 23 Points Requiring Rupt. Disc. Installation Installation of rupture discs below relief valves on each of two relief systems per sphere for 2 VCM storage spheres. Installation of rupture discs below relief valves for 4 unloading compressors, 4 - unloading com pressor knock-out tanks, and possibly miscellaneous plant filters. All other plant relief equipment in VCM service is currently equipped with rupture discs below relief valves. 17. 61.65(b)(5) - Manual Venting of Gases - Installation details covered in 61.64(c)(d) for those items where venting is required. 18. 61.65(b)(6) - Opening of Equipment - 32 Control Points - Installation of vacuum purging system to clear VCM from 32 existing miscellaneous vessels to specified residual levels prior to opening. This task involves the instal lation of a new vacuum header system with ties to the existing vessels, new vacuum equipment with discharge to new gas holder/recovery operation. 19. 61.65(b)(7) - Samples - No formal program developed at this time. 20. 61.65(b)(8) - Leak Detection and Elimination - Installation of additional detector heads, G.C., and read-out equipment to extend the the existing system currently in operation pliance. sampling units; capability of for OSHA com BOR 013210 Appendix A 21. 63.65(b)(9) - Wastewater Handling -*4 Emission Points - Installation of 4 wastewater collection and pumping units and tie-line piping to receive contaminated water from 4 emission points and route it to new wastewater stripping operation. BOR 013211 Appendix A Site No. I - New - 1. 61.65(b)(9) - Wastewater Control - Site Installation of centralized site wastewater collection and stripping operation to receive wastewater from the No, 1 and No. 2 areas and strip to specified residual levels before discharge to sewer. This is an entirely new major installation requiring design, procurement and construction efforts. 2. Gas Holder and Recovery - Site Installation of a centralized site gas holder and com pressor/condensing system to receive and recover VCM generated by stripping, purging, some degassing, and venting operations, from site no. 1 and no. 2 as described in 61.64(a) (1) (2) ; 61.64 (b) (c) (d) ; 61.65(b) (3iv) (5) (6) (9) . This is an entirely new major installation requiring design, procurement and construction efforts. 3. Carbon Adsorber - Site Installation of centralized site carbon adsorber system to separate VCM from non-condensib1e gases from site no. 1 and no. 2 so that the non-condensib1es can be discharged to atmosphere at specified residual VCM levels as described in 61.64(d). This is an entirely new major installation requiring design, procurement, and construction efforts. 4. Vacuum Purge - Site No. 1 - Installation of a precondenser, 2-vacuum pumps and ancillaries system discharging to gas holder - for purging of polymerization vessels and other vessels in the No. 1 area to specified levels of residual VCM before opening. This system is needed for compliance with 61.64(a)(2), and 61.65(b)(6). This is an entirely new major installation requiring design, procurement, and construction efforts. BOR 013212 t c Appendix A Site No. 2 - Modifications 1. 61.64(a)(1) " Polymerizer Vent Loss - No new installation needed. Polymerizer operation has no normal process vent gas discharge to atmosphere. 2. 61.64(a)(2) - Polymerizer Opening Loss - 3 Control Points Installation of steam vacuum purge system to clear VCM from 3 polymerizers to specified' residual levels prior to opening. This task involves the installation of a new vacuum header system with tics to 3 polymerizers, hot water supply piping, new vacuum equipment with discharge to new gas holder recovery operation in site no. 1 (new). 3. 61.64(a)(3) - Polymerizer Manual Vent Discharge 3 Control Points - No new installation required. Existing manual vent on 3 polymerizers is strictly for use in eme-gency condition. 4. 61.64(b) - Stripper Vent Loss - 2 Control Points - Installation of yard piping system to route process vent gas from 2 existing PVC latex line batch strippers to new gas holder/recovery operation at site no. 1. (new). 5. 61.64(c) - Mixing, Weighing, Holding Container Vent Loss (Non-Recovery Equipment) - No new installation is required for 3 - VCM weigh tanks currently in service since there are no normal operating vents from this equipment. 6. 61.64(d) - Monomer Recovery System Vent Loss - Not applicable to site no. 2. monomer recovery operation.at will be pipelined over to the recovery system for recovery. There will be no VCM the no. 2 site. RVCM gas no. 1 site gas holder/ 7. 61.64(e)(1) - Stripping - 2-batch stripping units have been installed and are currently in operation. Performance data taken seems to indicate that the units can comply with 61.64(e)(1). The installation of a comonomer recovery system at the No. 2 site will be required as an ancillary system for the stripping operation. BOR 013213 Appendix A 8. 61.65(a) * Relief Valve Discharge -'13 Control Points - No new installation required. Existing relief valve systems to atmosphere on all vessels in VCM service strictly operate only in an emergency condition. 9. 61.65(f)(1) - Loading and Unloading Lines - Not applicable to site no. 2, completely at site no. 1. Site unloading is done 10. 61.65(b)(2) - Slip Gauges - Not applicable to site no. 2. 11. 61.65(b) (3) (i) - Leakage from Rotary Pumps - 3 Control , Points - Installation of double mechanical seals and seal fluid units for 3 existing monomer circulation pumps. 12. 61.65(b) (3) (ii) - Leakage from Reciprocating Pumps - No new installation required. are not used. Reciprocating pumps 13. 61.65 (b) (3) (iii) - Leakage from Rotating Compressors 4 Control Points (2 Exist. 2 Future) - Installation of double mechanical seals and seal fluid units for 2 existing stripper vacuum pumps and 2 new purge vacuum pumps, 14. 61.65 (b) (3) (iv) - Leakage from Reciprocating Compressors - Not applicable to site no. 2. 15. 61.65(b) (3) (v) - Leakage from Agitators - 5 Control Points - All agitation equipment in VCM polymerizer service or unstripped latex service is currently equipped with double mechanical seals and is in an operational state. 16. 61.65(b)(4) - Leakage from Relief Valves - 13 Total Control Points - 1 Point requiring Rupt. Disc. Install. Installation of rupture discs below relief valves for several plant filters may be required. All other plant relief services for equipment in VCM service are currently equipped with rupture discs below relief valves. 17. 61.65(b)(5) - Manual Venting of Gases - Installation details covered in 61.64(c) (d) for those items where venting is required. BOR 013214 Appendix A 18. 61.65(b)(6) - Opening of Equipment - 12 Control Points Installation of vacuum purging system to clear VCM from 12 existing miscellaneous vessels to specified residual levels prior to opening. This task involves the instal lation of a new vacuum header system with ties to all existing vessels, new vacuum equipment with discharge to new gas holder/recovery operation. 19. 61.65(b)(7) - Samples No formal program developed at this time. 20. 61.65(b)(8) - Leak Detection and Elimination Installation of additional detector heads, sampling units, G.C. and read-out equipment to extend the capability of the existing system currently in operation for OSHA compliance. 21. 61.65(b)(9) - Wastewater Handling - 3 Emission Points Installation of a 1 wastewater collection and pumping unit and tie line piping to receive contaminated water from 3 control points and route it to new wastewater stripping operation at the no. 1 site. 22. Vacuum Purge - Site No. 2 Installation of a precondenser, 2-vacuum pumps and ancillaries system discharging to gas holder - for purging polymerization vessels and other vessels in the no. 2 area to specified levels of residual VCM before opening. This system is needed for compliance with 61.64(a)(2) and 61.65(b)(6). This is an entirely new major installation requiring design, procurement, and construction efforts. BOR 013215 Appendix A Lcomi nstor, M3sj^nchusetts DESCRIPTION OF CONTROL FACILITIES TO FF ADPED IN REVAMP OF THE. . PILOT PLANT Modif j rations 1. 61.64(a)(1) - Polymerizer Vent Loss Polymerizers (2 units) will also be used as strippers. lation described under section 61.64(b). Instal 2. 61.64(b) - Stripper Vent Loss - 2 Control Points - Installation of tie line piping to route process vent gas from the two polymerizer/strippeTs to the manufacturing facility gas holder/recovery operation. 3. 61.64(c) - Mixing, Weighing, Holding Containers Vent Loss (non-recovery equipment) - 2 Control Points - Installation of tie line piping will be required to route evacuation gas from monomer weigh tanks (2 units) to -the manufacturing facility gas holder/recovery operation. 4. 61.64(d) - Monomer Recovery System Vent Loss - This is covered under the Leominster manufacturing facility section of this appendix. BOR 013216 APPENDIX A COMPLIANCE SCHEDULES - LEOMINSTER, MASS. The following pages detail compliance dates currently developed from suppliers and engineers. BOR 013217 FVC MANUFACTURING FACILITIES LEONINSTER, MASSACHUSETTS site :;o. 1 SCHEDULE OF EPA REGULATIONS COMPLIANCE DATES EP^ REGULATION PARAGRAPH NO. 6l.64(a)(l) 61.64(a)(2) 61.64(a)(3) 61.64(b) 61.64(c) 61.64(d) ol. 61s (e)(l) 61.63(a) 61.65(b)(l) 61.65(b)(2) 6l.55(b)(3)(i) 6l,c5(b)(3)(ii) DESCRIPTION Polymerizer Vent Loss Polymerizer Opening Loss Polymerizer Nanual Vent Dischare Stripper Vent Loss Nixing, Weighing, Holding Containers Vent Loss (non-recovery equipment) Monomer Recovery System Vent Loss Stripping Relief Valve Discharge Loading & Unloading Lines Slip Gages Leakage from Rotating Pumps Leakage from Reciprocating Pumps CONTRACT AWARD CONSTRUCTION COHHENC ENENT CONSTRUCTION COMPLETION MECHANICAL COMPLIANCE ACHIEVED ' COMPLIANCE WITH STANDARD i April-77 ! SepT 77 1 Ao 76 en B1 5 is Seft 76 S 7 A T1 ppil77 \ Sgp 77 1 AO<r ia 1 Sj ibgpt7S 1 _______ 1 r 1 Sept 76 1 OCT 76 isoc-rva 1 April77 1 ocrr 77 15 NloV 77 fSDee.17 f A I JpN pril 17 7 1 SdRR ia 15 fips^TS 1 MnY.7& -- ARprs'nr \ BOR 013218 EPA REGULATION PARAGRAPH NO. 1 61.65(D)(3)(iii) 61.65(b)(3)(iv) 6l,65(b)(3)(v) 61.65(b)(4) 61.65(b)(5) 61.65(b)(6) 61.65(b)(7) 61.65(b)(8) 61.65(b)(9) Fv'C MANUFACTURING FACILITIES LEOMINSTER t MASSACHUSETTS SITE NO. I SCHEDULE OF EPA REGULATIONS COMPLIANCE DATES DESCRIPTION CONTRACT AWARD CONSTRUCTION COMMENCEMENT CONSTRUCTION COMPLETION KEChAi.iC AL COMPLIANCE ACHIEVED COMPLIANCE WITH STANDARD Leakage from Rotating Compressors Leakage from Reciprocating Compressors Leakage from Agitators Leakage from Relief Valves Manual Venting of Gases Opening of Equipment Samples Leak Detection & Elimination Wastewater Handling 1 Apj=2 IL 77 lJp)H IIAbr 78 !5Rpr78 1 MnY 76 71 > E PT 7 1 Kug 76 I 5ePi7fi /5iEfT7<B 1 ifiH 70 1 MflR 73 is'Ppr'TB l MrY 1 Jrio ie> 1 Rpr7<3 13 MkY7S> 1 1 c-pt 77 l_______ _________________ --------- 1-------- 1 (\oS7S l............ 1 Spt78 \BSzpr7& li I l77 t MPY ~73 11 ------------ %------------- \SePT 77 I July 76 l hoe ie> \5flu<s78 tFT78> .1 SePiTS IBStPT 78 C BOR 013219 > PVC MANUFACTURING FACILITIES LEOMINSTER, MASSACHUSETTS SITS NO. 2 SCHEDULE OF EPA REGULATIONS COMPLIANCE DATES EPA REGULATION ' PARAGRAPH NO. 6l.64(a)(l) 61.64(a)(2) 61.64(a)(3) 61.64(b) 61.64(c) 61.64(d) 6l,6'j(e)(l) 61.65(a) 61.65(b)(1) 61.65(b)(2) 6l.65(b)(3)(i) '6l.65(b)(3)(i"i) DESCRIPTION Polymerizer Vent Loss Polymerizer Opening, Loss Polymerizer Manual Vent Discharge Stripper Vent Loss Mixing, V/aighing, Holding Containers Vent Loss (non-recoverv equipment) Monomer Recovery System Vent Loss Stripping Relief Valve Discharge Loading & Unloading Lines Slip Gages Leakage from Rotating Pumps Leakage from Reciprocating Pumps CONTRACT AWARD CONSTRUCTION COMMENCEMENT CONSTRUCTION COMPLETION MECHANICAL COMPLIANCE ACHIEVED ' COMPLIANCE WITH STANDARD f April 11 1 9gpt 11 1 Aus78 is*pt7e> 1 April 77 \ se pa 1~J l ^06 78 \ r 7<3 \SSkPT7g> 1 April "77 i5GPT 77 \ Aos 7S> 15Scpt IQ? | ocr 76 1 Ap.pu-7 / 1 Jiqm 76 1 MfiR 78 \sQ?r1B 1 MflY. 4 BOR 013220 EPA REGULATION P6AlR.t6AG5R(ALPH)(3HO)(. iii) 61.65(b) (3Hivj 6l.65(b)(3)(v) 61.65(b)(L) 61.65(b)(5) 61.65(b)(6) 61.65(b)(7) 61.65(b)(8) 61.65(b)(9) P7C KAHUFACTURING FACILITIES LEOMINSTER, MASSAC USE!TS SITE K0.2 SCHEDULE OF EPA REGULATIONS COMPLIANCE DATES DESCRIPTION Leakage from Rotating Compressors Leakage from Reciprocating Compressors Leakage from Agitators Leakage from Relief Valves Manual Venting of Cases Opening of Equipment Samples &Leak Detection Elimination Wastewater Handling CONTRACT AWARD CONSTRUCTION COMMENCEMENT CONSTRUCTION COMPLETION MECHANICAL COMPLIANCE ACHIEVED COMPLIANCE WITH STANDARD 1 Apsl-l 77 1 JflM 13 1 Mbs 78 15 Apr78 (Mnr 7d 1 \ f\pR\U 17 | JfiM 7B 1 Apr 7& 15 MAY7S 1 Ji3n' 7d> 1 5eFT*n 1 AlkS 78 I Sept IB !55cPT 78 i1 <F t 1 ' 1 M RY 78 1 July IB 15 iScPi 78 1 I 7 7 1 Nu&78 | 5gpt76 1S&PT7S BOR 013221 > BOR 013222 BOR 013223 Q - RELEASE *OR cutfrr AWROVAl (T) - RELEASE RtON FOR iNOUflY fr' - RELEASE nJWCHASE ORDER ' IR -^flSLE*:E rOR vtLLCR SULK ORDER - RCCE^vED VENDOR OfJAiiViNCS ^7 ~ DECEIVE CLIENT aroval ^ - RELEASE FOR CONSTRUCT pOn O - DELIVERY -SCHtGULES * b' -RELEAS* rOR DETAILING FfcCCLSS tNC UiER tNC r,_ n i SCSITySST ARaANCE^S'iS 1 1 VESSELS 11 1 ascv-iJCA!. qji?>c;t Cirbo* B-rd ST3UC7V ?,.*!, - Four is tleis rrrr=s Field Fab Pressur? Tesctnj? D57KL-XFN7ATIO:; SLECTP-ICAL - DEL'VERY . ACTUAL fd- >: T *)J j: : p J. il _L j f n11 Vs j i iI 1 i f1 i i 1 | 5 i ii t i i 1 riSJUSTICH PArrrns FACRITItS ?757'':S ns ! i L_i i BOR 013224 BOR 013225 BOR 013226 BOR 013227 BOR 013228 BOR 013229 Q - RELEASE FCrf* CLIENT UNflOVU (0 - RECEIVED VlNOO 1 DRAWINGS 0 - RELEASE RE Q N ?CR !SOL'RV \y - TFCE:vE CL'"*T A^MO'^L 0 - RELEASE PL.rCHASE C90R ,fr, - RELEASE EOR VUL Or\ 9ULA ORDER (tf - RELEASE FOR DETAILING V RELEASE FORCC-NST''-.:1 O * *-|S3? E\C5NM;'Nfi - DE LivEHV 'jCh, r . .T'J rr snrai moruniyrNt -------DEI ivEHV AC'^'Al 1* -- ~m- ----- -H77- "<OCT NOV OIC JAN|FB^a .AY JUN JUL BOajjEN CHEMICAL Crawford & Russell LOCATED AT Incorporated 1 TVP OF PLAr.T____________________________ f C*3.\OMi scnvE^Y site an. t- PROGRESS SCHEDULE I CIV^NFR'SNO r<m--------- : . cr.t AT T50 r *_ 'L HAT JUJ1 JU'. Vic SEP >t?T9- INSTRUMENTS Panel Mounted INSULATION Ii J. C' ;f 1 [ T :rf i i T' JC^I i:ui ;A4rfel CJ U L KStJT- a rwnjviiii^Er ~ n. - *E\ G?.| >L a | EA|r- I ^ 'HI>1 tl - ZB^C 1 J 7/ v ^riCtr tracm ie: 1 t- -7Lr- A ^id^L COfH PU*r,*U. ^c!hii .'dip l-F i r *4ltU-.r ,A*I - J--s :~i i- i PAHtTINC FACILITIES TSSTU5 F'n Mo P5.3& VTS T ;i 1 _4 \ i JL ! i tj 1 i .. i [ ' i J. i v , ! i i ii 1l ii ii J.J1 4 It. J. t .iIiI- - -t- 41 il'Pl -Uir i -4wirrju-r.: -i- ii pi)! <-p>h\ Aje-r T t r r -i- +- 1 'T T -i. i t 4- _L 4 .. - L-. T 1 Hi iI -f i -i Li tI - L- t~- . L L1 _i_. ti Hi i BOR 013230 j&l 64 (bj | \g.6i (c) ) t;.vV'! }'. \&t 6 4(c) 'j I 1^1 &^(bX9)! i Crawford & Russell fneorporaltd > fe^(p)(4 ! j 1 l^ts(bXiX4 1 Utsftyvv:-/)! 1 l 1 t 1 l tsfbjft) .. . -- 4 COouscE iAL S>e<V-> Pd^t^re: Cr D'iKi l P = l,VAIN^- jUMLlAO' K . 013231 bob L*T*v>< i octp cton! SoROer-J ?HEW.Cf\L- pvc MA^*VlP,'\(i'TO':ftrO(S P AC!l LEOMIMSTc*?. k/ASS _ ' 6,-r^ t\! O. I :?y;rvf-AS- logic. H:f - ; -Ir -1 * ^ *\~c >c F^ 1 ;Vo4:!:TSS'v;gL - I ;c7~; CA |i.' 4't,) | \c. jj I* ^'b)'V * yyVqF stbX^Jj |s- w'OaK--.* j Mb) f Crawford & Russel) Incorporated Pt_"?6fc i COAX'D onJ S.MDLDeK & I*, fcg - yu A-- tr** ___ -5r *>' T^Vs.g> MC^A*UcAl __ fr- . v : Y> RecovGev ? Y.5TE M BOR 013232 I *-PYV KT" ~ [ DETfCT^ 12i.'J<`JAT'0.f' Bo(?Df!M Ch6^1C''-U FVC MftlJUFAO TOPlMG FACt'-lTliZ^ 1_EOM 1 N >"T & , , . >\-tel Nl o. 2 ^ & L~o<5'. <T. Ty f. - ,\ t_-', r ' 1` xT V t-r -- *T jl_ v _ + _ i t'So4f I 5^! - c. l * 'J O ! APPENDIX B. Interim Leek Pet cc! i p^ and Elimination - Border Chemical Leominster, Mass. Pursuant to 40 CFR Part 61.10(b)(3) and Part 61.65(b)(8), Borden Chemical's PVC manufacturing operation at Leominster, Mass, proposes to implement the following interim Leak Detection and Elimination Program: 1. Date of initiation: January 19, 1977 2. Steps to be Implemented: A. Detection using existing continuous monitoring system. 0, (1) Twelve (12) current sampling-recordjng points will be adapted to monitor: (a) Tank car unloading area at operating level approximately ten feet from coupling-dome. (b) VCM transfer pumps and compressors in the tank farm area: sample point to be located approxi mately six feet above grade and, insofar as possible, will be geometrically centered among this equipment. (2) Additional continuous monitoring is to be installed as a part of the revamp program (See Appendix A) to monitor additional outside areas for leaks, as neces sary. It is planned that each outdoor .set of pumps and/or compressors will have a sample point located geometrically among them to detect any leakage from seals, etc. B. Detection using portable Total Hydrocarbon Analyzer (1) For indoor areas, portable monitors are currently used ,to follow up any indications of leakage. Borden believes this program is working well and will con tinue to employ the portable equipment in this manner. (2) Outside the building, we currently monitor the perimeter weekly, using air bag samples. We propose to use the continuous monitoring system 2.A(2) above, to monitor operating outdoor pump and compressor seals. Portable detection equipment, as noted above, will be used for follow-up, 3. Definition of a Leak A. Continuous monitors--undoubtcd1y, installation of new points and collection of background data.will provide firmer support for such definition, but wc will use an BOR 013233 Appendix B 3. Definition of a Leak initial "working" definition of 25 ppm (volume) VCM ns a "leak." Once background levels are established for all "EPA" monitoring points, we expect to redefine a leak in terms of the slope of sequential samples--which should be more sensitive. B. Portable mon it ors - - ir. view of the fact that the hand-held sampler probe can be placed virtually "in" a leaking source, the smallest escape of hydrocarbon can result, in full-scale deflection of the meter. Accordingly, we will adopt a 25 ppm (volume) "hydrocarbon" level, measured at accessible points throe (3) feet equidistant from the source, as the "working," interim definition of a "leak" for this monitor. When Appendix A projo'is are completed, a revised definition is anticipated. 4. Action to be taken when a leak is detected will depend on the severity of the exposure and must be conducted under OSHA specifications. A. Severe (emergency) leak, e.g. "blown" seal or gasket, rupture of pipe or flange and, the like--the following will be the immediat e response: (1) Remove the source from service (2) Isolate VCM supply to the source (3) Initiate repair procedures (4) Monitor success of repair (5) Restore to service B. Non-emergency leak, e.g. equipment intact, but leakage detected, the following actions are contemplated: (1) Complete immediate cycle of use (hasten, if practical without worsening leakage) (2) Remove source from service, isolating from other active operations as necessary. (5) Tag cut "DO NOT USE UNTIL REPAIRED." (4) Initiate necessary maintenance (5) Monitor success of repair (6) Restore to normal service 5. Calibration of Instruments A. Continuous monitoring equipment--currently is automatically checked for 1 accuracy once each eight hours using a standard VCM gas. Technicial corrects any inaccuracies detected. We will continue this procedure. B. Portable Hydrocarbon Detcctors--currently are "zeroed" every eight usage hours, using Wheatstone bridge. We will continue this procedure. BOR 013234 Appendix R C. Calibration r,;i?--wc arc advis'd by a major supplier that the requirement of Part 6 1 . 0 f> ( b ) ( 8 ) ( i i i ) f 1'-) that, calibra tion gas be "traceable to the National Bureau of .Standards" (NB3) is not possible inasmuch as NBS has no standard reference gas for vinyl chloride monomer at this time. Accordingly, we must currently employ the available standard gas without assurance that this part of the standard will be met. BOR 013235 A