Document V3vgxLLYrZYek8wanRd4azzZ4

MEMORANDUM To: From: Date: Re: SPI Manufacturing Technology Committee Peter L. de la Cruzy^^_ March 23, 1983 Revised TRW Report Attached are the comments we filed with the Environmental Protection Agency (EPA) on a draft report by TRW, Inc. dated March, 1981. A revised report dated February, 1982 was officially released by EPA in February, 1983. The marginal notations on the comments indicate whether the Committee's comments are reflected in the revised report. The following abbreviations are used: v/ Comment incorporated in revised report NC No change in revised report PC Partially responsive change in revised report SL 105379 THE SOCIETY CF THE PLASTICS INDUSTRY, INC. COMMENTS ON "PHASE X REVIEW STUD? CF VINYL CHLORIDE NATIONAL EMISSIONS STANDARD" The Society of the Plastics Industry, Inc. (S?I) 1/ submits these comments on the TRW, Inc. draft report dated March 16, 1381, entitled "Phase I Review Study of Vinyl Chloride National Emissions Standard." I GENERAL COMMENTS 1. Need for Health Effects Analysis The Environmental Protection Agency (EPA) is presently" reviewing the National Emission Standard for Vinyl Chloride. 40 C.F.R. SS 61.60-61.71. According to the TRW draft report and the EPA staff, this review,was prompted by SPA's proposed airborne carcinogen policy. 44 Fed. Reg. 58642 (1979). while we do not disagree with the concept of periodic review of existing standards, which may be required by section 3(i) of Executive Order 12291 [46 Fed. Reg. 13195 (1981)1, we seriously question the propriety of basing a review of the vinyl chloride (VC) standard on a proposed policy. 2/ The Society of the Piastres Incustry, Inc. (SPI) is a corporation organized under the Not-for-profit Corporation Law of the State of New for*. Its 1400 member companies and individuals and 49 operating units include those, who supply raw materials, process or manufacture plastics or plastics products, engineer or construct molds or similar accessory equipment for the plastics industry, and encage in the manufacture of machinery used to make plastics products or materials of all types. SPI is the major national trade association of the*plastics industry. The majority of its members are the processors and converters of the plastic resins into end products which represent 75% of the dollar volume sales of plastics in this country. SPI's membership also represents 95% of all plastics materials and machinery manufactured in the United States. Th e s cate s were cremated y the Ma Tachnclec Tim. * ae c: SPI's PVC a f s ry j r SL 105380 2 The proposed airborne carcinogen policy was published in Cctcber 1973, and was the subject of expensive public comments that cast serious doubt on many of its provisions. Indeed, Z?A'i zhen-Acting Administrator has been quoted as recently caving testified before Congress that ''Cijt is uncertain whether or not this proposed policy would survive challenge in the courts." Inside ?A, May 3, 1981 at 3. E?A has not yet r2spondee to the comments but reportedly is in the process off changing the proposed policy. Inside E?A, May 3, 1981 at 12. It is not appropriate to base a review off the Vinyl Chloride Standard on a proposed policy that has not been finalized, that is being changed, and that E?A believes may be illegal, e also object to the application of the discredited philosophy of the proposed carcinogen policy to this review. The proposal, for example, endorses efforts to reduce emmissions to a zero level without regard for the resulting costs or benefits. As a result, the present review study tMS been deliberately restricted to engineering feasibility. It has ignored all other aspects of the situation based on adherence to a proposed guideline that will not be adopted in ^ *w ^* *------i- - -- -- Th e proper approach to the review off the VC standard is a costs d by statutory, executive and judicial guidance. :ticn 11*2 of the Clean Air Act, 42 C.S.C. 5 7412 , provides : w nat icnal emission standards for hazardous air pollutants (>n :ssap ) that present a threat off increased mortality or se. : ious irreversible illness. Emission standards are to be set to pr cv ice an "ample margin off safety," These statutory cr . ter i a must be satisfied through data showing the health ?Ct5 on the general population of vinyl chloride in the a zmespn ere at existing levels and through data shewing that a reducti cn in emissions would remedy significant adverse health effects Cnder section 2(a) of Executive Order 12291, a review of existing regulations must be based cn "adequate information concerning zhe need for and consequences of zhe proposed gevernmer.z action." Adequate information, as the order plainly stares, induces zhe pezentiai benefits and costs of SL 105381 3 In a somewhat similar situation/ the Supreme Court has vacated an agency rule that was not supported by evidence that tightening of the standard would result in the required health benefits. Industrial Union Department, APL-CIO v. American Petroleum Institute,__ U. 5. __ , 100 S. Ct. 2844 (1280) (Benzene case) . There, the Occupational Safety and Health Administration (OSSA) based its reduction of the permissible exposure limit for benzene from ten parts per million (ppm) to one ppm on a series of assumptions that the number of leukemia cases might be reduced. The court noted that OSHA did not base the stricter limit on the basis that exposure to ten ppm would cause leukemia while exposure to one opm would not. _Id. at 2860 . The series of assumptions on which OSHA acted in the 3enzene case parallel EPA's proposed carcinogen policy. EPA's proposed policy, which was formulated without the benefit of the Supreme Court's guidance, can no longer be considered a _ valid basis for reducing emission levels in the absence of defensible health effects data. 2. Inadequacy of Currently Planned Risk Assessment Based on the THW draft and our meeting of April 9, 1981, there does not appear to be any ZPA effort to develop the necessary monitoring and health effects data. This destroys any value which an engineering study alone might have. The Agency will be unable to evaluate the potential benefits of any proposal unless it is able to compare thos changes to resulting health improvements for the nation relative to present conditions. Present conditions must be determined by actual measurements. We understand that there are no monitoring programs underway as a part of the vinyl chloride review, and, although we understand some such efforts were previously made there has been no attempt to obtain or interpret this data. We do not believe chat another risk assessment by IPA's Car ci.ncgen Advi scry Group (CAG) will be useful unless, as a min imum, it is based cn a thcrouqh review of the literature. To be adequate, this review should include a new effort to cb: ai.n epicemio Logical data for the papulation surrounding iac ilities chat handle cr produce vinyl chloride. Moreover, such a risk escimat made, can only he interpreted in light cf actual measureme Without these efforts, any estimates e arser.ee - a ** 3 rt to devel copied with esticr.s ter new menits i.nc da % di = recart i exis nine toe er.cy' s SL 105382 4 3. Lack of As noted in the specific comments in section II/ the data base of the TRW retort is incomplete. It does not reflect adequately the Large amount of Information available through the regional SPA offices or other branches of the agency. Several pertinent reports and studies are emitted. This study generally has failed to avail itself of resources within SPA, other agencies and industry. Much of the data presented are not referenced properly. in addition, the draft report ignores the comments submitted by SPI on the development of the original standard and the 1S77 proposed amendments. If SPA is serious about performing a comprehensive review, these faults must be remedied. 4 The Existing Vinyl Chloride Standard In response to the requests by the Presidential Task Force on Regulatory Relief, SPI has suggested that the vinyl chloride standard be withdrawn. This proposal is based on our belief that withdrawal of the standard would not result in any adverse health effects. Our belief, in turn, is based on current industry practice, the operation of the OSSA vinyl chloride standard and other regulatory constraints. A copy of that submission is attached to these comments as Appendix "A". Absent withdrawal of the vinyl chloride standard, the Agency's current review should be redirected towards improving the administrative provisions of the standard, monitoring of vinyl chloride in the atmosphere, and development of health effects studies. '' We do net believe that the Agency can justify further expenditure of government or industry resources based on current vinyl chloride emiss icr.s and the absence of new health data or technology. Given i ts current regulatory status, we cannot believe that SPA cons iders vinyl chloride to present a hazard warranting signifies*-, t attention. The Agency*has itsel cremated a list of cresentlv unregulated substances that merit review. Moreover, the speci fic impetus of the proposed carcinogen policy has beer. r moved. -* * - A'* - t . - * 1 A 3 * :c5CU-:t - --a- w , to 0ri ** i:::v z - j - I a 3 V 1 t Z * ^ - * * * - - m ^ * m 4* ^ 4 m * r 5 * ~ z r. 47^iV Z ' * Z ? 1. A * - a -Cv z", 3 SL 105383 5 As distinguished from any potential health or engineering programs, there are several administrative changes in the reporting, record keeping and definitional sections of the vinyl chloride standard that merit prompt attention. Potential areas for review might include frequency of reporting, averaging of reactor opening losses and stripping levels, and clarification of such terms as "emergency" releases. Improvement in the administrative provisions would reduce the burden to both industry and the Agency. We stand ready to discuss these administrative areas with the Agency at any time. SL 105384 0 ri spscinc ccmmemts Chapter l Comment TPW states that the impetus toe this review is 3?A1s procosec airborne carcinogen policy. That policy was proposed in October 1979, public hearings were held in a number of sites, and extensive comments were tiled on the proposal. A number of comments specifically criticised the proposed provisions for periodic review of " regulations. SPA has not yet responded to the comments in the record and has not taken final action pn the proposal. Moreover, recent press reports quote the then-Acting Administrator as having testified before Congress that "(ijt is uncertain whether or not this areposed policy would survive challenge in the courts." Inside SPA, May 8, 1931 at 3. Press reports also indicate that the SPA staff is in the process of changing the proposal. Inside SPA, May 3, 1981 at 12. In light of SPA'S plans for the proposal, existing executive orders and policies, and relevant case law, it would be'inappropciate at this time to proceed tc the more-detailed Phase II stuev. In any event, any review ci emissions control technology must :e based on a need for additional regulation tc protect the oublic health. Cur under standing is that the Agency has net conducted a review tc determine whether or net such a need exists and dees .net new have plans tc conduct an adequate review. Therefore, it would not be tc crccsac tc tt *5 II s vedv at tit is ticis. w a 2 s'"C- A 4{ 5 . SL 105385 7 The report claims that changing from air to pure oxygen as a feedstock in the oxychlorination process results in reduced emissions from the oxychlorination vent. Section 3.2,2. is cited, but it contains no data substantiating this claim. For such a claim to be made, specific data on the amount of vinyl chloride monomer (VCM) contained in the oxychlorination vent from the air process should be compared with the amount of 701 from the pure oxygen process. The draft report states that the efficiency of vc reduction in flares has not been determined. We understand that the Agency has sponsored a flare efficiency study by John Zink Company that has measured the efficiency of flares and found it to be greater than 99.9%. This study and other" Agency data should be referenced here and in Chapter 4. Relief valve discharges that could not have been avoided are permitted by the VC Standard. Examples of some of the'causes of such discharges have been provided previously to the Agency. See letter from SPI's counsel (G. Saise) to SPA (0. Goodwin), dated Feb. 15, 1979. (A copy is attached as Appendix "3".) Nevertheless, because of the enforcement staff's subsequent interpretations, we agree with the need for a mere realistic definition of what constitutes an "emergency" relief valve discharge. The draft states that continuous stripping technology for dispersion resins is not as advanced as for suspension resins "probably because the demand for dispersion resins is not as great as for suspension resins." This statement should be modified to avoid any possible implication that the industry has net attempted to develop stripping systems for dispersion resins to the same extent as for suspension resins. Such an implication would be incorrect. SL 105386 3 Industry has devoted great efforts toward the development cf dispersion resin stripping technology. The fact that great advances have seen made is demons or a tad by industry's ability to sees the existing stripping requirements. Dispersion resins are simply mors difficult to strip than suspension resins. The draft dees net present any evidence that the demand for dispersion resin has adversely effected the development of stripping technology. The sentence noting that two bulk resin processors reported 6-month average stripping levels below 40 ppm should be deleted. This statement could be very misleading to the uninformed reader. The existing standard is based on a 24-hour average, net a 6-month average. If bulk resin stripping performance is to be included, it should be done on a 24hour basis. At the moment, a 3-month average is not relevant. The statement that fugitive emissions represent "one of the larger contributions to VC*amiss ions" is not substantiated by data and should be deleted cr modified. 5ee the discussion in section 4.4, pages 4-53 and 459, and our comments below on that section. 3ecause 2?A' s original section 114 letters requesting data were unclear, the industry responses may have been based on a misunderstanding cf the letters. In addition, the Agency arbitrarily doubled the fugitive emissions figure calculated by 23A's contractor. Moreover, the emissions figures were based on material balance calculations, and Z?A considered all "C t at was not accounted for to be fucitiv emissions. This, as industry has previ usly .toted, * " mme.tts te.tv a a ;m; 3 A J- - SL 105387 9 A major reason for variability among the leak patrol programs was the lack of response by EPA regional offices to the proposals submitted by the operators. Individual companies were left to their own resources unde: a short time frame for developing these programs. 6 21 The draft notes that control (reactor purging) selection is based on the polymerizaticn process used. This statement should be deleted. No evidence in this document substantiates that control selection for reactor opening loss is based on the polymerization process used. There is evidence that several different control techniques are employed. The selection is based primarily on operating preferences and economics, 7 18 The draft states that "new unregulated sources" include solid waste drying facilities and disposal sites (landfills). This statement is misleading and incorrect and should be deleted. Polyvinyl cloride (PVC) solid waste is not a new source. Solid waste was present during the initial development of the standard, and is regulated by the existing VC standard through the allowable residual vinyl chloride monomer (RVCM) levels. HPA considered further regulation of ?VC wastes in the development of-the hazardous waste regulations under the Resource Conservation and Recovery Act (RCRA). EPA proposed that PVC solid waste be listed as a hazardous waste, but in their final promulgation--after taking into account comments submitted--chose not to designate PVC sludge as a hazardous vasts. A Battalle Report cn voi emissions from a landfill was a major factor in ERA'S August 1379 prtpcsal to list RVC sludge and ocher related wastes as hazardous waste. 5PI submitted comments to IRA's Office of Solid Vasts that the Battalia information was cut ;f data unc was considered wnen IRA prepared SL 105388 10 its NZSEAF regulation for "CM. Subsequent industry tasting snows the existence of subs rantially Lower concentrations of 7CM at landfills, and the M23EA? stripping requirements ha?* resulted in lower RVCM levels in ?VC waste. A copy of these comments are attached as Appendix "C". The data cn emissions from the unidentified landfills should be presented here or in Chapter 6. 1-7 Section The draft summary should be modified -to 1.11 emphasize the impact of ether regulatory requirements. New and modified VC emission sources undergo new and detailed reviews to obtain permits that frequently result inchest available control technology (BACT) or lowest achievable emission cate (LAZB) controls more stringent than those in the standard. The summary also should discuss the Comprehensive environmental Response, Compensation/ and Liability Act of 1930 (Superfund)> the Occupational Safety and Health Administration (QSHA), the Consumer Product Safety Commission (CBSC), the Feed and Drug Administration (FDA)/ and state activities. The implication that delegation of N2SSAJS authority to states will reduce VC emissions is unsubstantiated. SL 105389 pace hi O' 2-1 2-2 Ai 11 Chapter 2 Line Comment 5 Again, the proposed policy for airborne carcinogens is cited as the impetus for reviewing the existing VC regulation. See our comments above on page 1-1, line 9 of the draft. 17 The draft states that industry was allowed two years to incorporate the necessary controls required by the existing standard. This statement is incorrect and misleading, and should 'oe deleted or revised. First, new or modified sources were subject to the standard immediately. Second, existing sources were subject to the standard except insofar as they obtained specific waivers.- Waivers and waiver terms varied. Only a portion of industry was allowed 2 years for compliance and only for a portion o the standard. * Section The draft indicates that TRW reviewed EJA's 2.2.1 October 1975 standard support document ar.d information submitted to 2PA under Section 114 of the Clean Air Act. 3efore issuing the draft report, TRW also should have reviewed the written comments and the hearing transcripts on the existing standard, the proposed amendments to the existing standard (42 Fed. Reg. 23154(1977)), and other pertinent documents. Table 2-3 Seven PVC plants are listed in New Jersey; the correct number is six. The error is from Table C on page C-2, There is no Piscataway plant. 34 The reasons for lest production capacity include (1) the time to purge equipment prior to opening and (2) the time to open equipment for maintenance and all other purposes. Lest capacity is not solely attributable to reactor cleaning and purging time, as the draft states. SL 105390 12 Wh11a it is true that the oxygen process produces a lower volume emission to be combusted/ there is no evidence that this aa:<es the combustion process easier, it merely ma!<ea the required combustor smaller, and that is net necessarily an advantage. Total plant configuration and steam needs must be considered in choosing between oxygen and air processes. Data are not shewn cor the statement in the draft correlating compliance levels with automation and computerization. See also the letter from SPI's counsel (G. Baise) to EPA (D. Goodwin), dated February 15, 1S79, (Appendix 3), on the subject of some causes of relief valve discharges. SL 105391 3-1 3-10 3-17 3-13 3-20 13 Chapter 3 Section The draft should state that the process 3.1 descriptions in this Chapter are extremely simplified. They co not adequately reflect the complexity of the processes or of the difficulties of compliance. 30 The draft states that no new emission data have been obtained from SEC/7VC plants since the regulation was promulgated. This is incorrect. Data have been presented to the SPA regional offices for permits and new plants. 24 No reference is provided to support the statement. So far as we are aware/ the practice of inhibiting VC polymerization Ql%h phenol was halted several years ago. A level of 100 ppm of phenol was never used. Normal levels were between 5 and 15 ppm. 16 (Section 3.4.3.) The sentence "Many of the vessels were open to the atmosphere prior to promulgation of the VC regulations . . . is incorrect and misleading. "Many" were neither open nor opened to the atmosphere. Certainly storage spheres/ storage tanks, weigh tanks/ gas holders, and knockout pots were not open or opened to the atmosphere, wastewater storage tanks may have been opened, if they even existed at that time, and surge tanks were if this term refers to blend tanks. The cited statement should be modified. 34 The agglomerates referred oo are more usually formed in the reactor, not the dryer. Generally, the larger agglomerates must be removed before the stripper, but seme smaller ones make their way to the dryer. 15 Strong agitation is not possible in latex prcduccion; it must be much milder than in suspension to avoid coagulation. This may be a reference to the kemegen i:arion step used in mixing mcncmer ar.c dispersion agents ir. seme processes, hue obis occurs before the SL 105392 14 The statement that "VC concentrations that are'emitted when the ?o-?o reactor is opened must be measured in order to meet the HCL standard" is incorrect. These emissions aay be calculated rather than measured, and the' standard so provides. \X3-23 25 The sentence stating that "The copolymer formed is not soluble in the solvent but forms a homogeneous solution" should, of course, read "The copolymer ijs soluble and forms . . . If it were not soluble, how could the solution be formed? 3-32 The recovery process for solution resin is more properly termed precipitation, not coagulation. 29 Contrary to the craft, the VC standard does not require that relief valves be connected to a control 'device. 24 Liquid VC is very resistant to reaction with water to form HCi. Some SCI is formed by thermal decomposition of the ?VC and other chemical reactions that occur in the reactor, but no significant amount ccmes from VC and water directly. 23 Change "compounding resins" to "compounding ingredients." The "fia:<ss" fail to absorb plasticizers, stabilizers and other compounding ingredients, net "compounding res ins." KIC- j-35 12 Cse of chemical treatment has been successful in preventing polymer build-up, but only in certain equipment. Wwi hile the subject is .U^ t- . .cant rests associated with chemical treatment are net given acecuate eonsiderazica. SL 105393 15 Chapter 4 The text of this chapter and tables 4-3 and 4-4 incorrectly state that the standard requires zero discharge for relief valves. The standard expressly permits discharges that are not avoidable. See 40 C.F.R. 55 61.63(a) and (b)(4). In developing and promulgating the standard, SPA expressly recognized that there will be discharges both from the relief valve when it operates as designed and from manual venting that attempts to prevent relief valve actuation. See 4Q C.F.R. 5 61.64(a)(3). This is a fundamental error throughout the report and it must be corrected. a We agree that the industry is performing better than required by the standard, and we believe that actual emissions are drastically less than reflected in this chapter. For. example, the "estimated actual emissions" column in table 4.4 (for a typical FVC suspension plant) should be revised, for the reasons discussed below, to include at most the following amounts. Source Sstimated Current Zmissions (!<g/vc) Primary control Relief valve discharges Combined sources after stripping 63 4,730 13,500 Fugitive emissions 23,300 Reactor cre.ninc less ^ 4* 7 450 -* ^ / ** - ^ SL 105394 IS Incinerators normally perform a: emission levels of veil below 1 ppm/ so a figure of 10% of the allowable amission is ta*en for primary control emissions. The estimated fugitive emissions are 'cased on a recent study by 3.?. Goodrich. That study is cited in the report cn page 4-59, lines 7-15, but incorrect figures are given. The correct figures are set forth below in these comments for page 4-59 . The reactor opening loss' in Table 4-4 was calculated on an average of 3.3 batches between openings at 3,300 ppm residual VC based on 3?A's 1975 Standard Support document. Various improvements in purging methods and decreases in opening frequencies lead us to believe that average actual losses are less than a quarter or that model. For purposes of estimating reactor opening loss emissions, we suggest assuming that reactors are opened after every 10 or 12 batches. The net improvement over the "regulated emissions* column in Table 4-4 is approximately 245 megagrams per year, or abcut an 34% reduction below the level cf amissions permitted under the present standard. Face v/ 4-1 line 7 Comment The craft stares char the level cf emissions from relief valve discharges is net lower than required by the current VC standard. Sc data are provided to support trie statement, -03^0; "iSt--~ ZZ ?t Z T55-I ZZ 33 1^1--l'*i**C di3C"3r*55 is * * c.5r zzi 3". 3Z f2 *i ' C * a *4 -v *S 2* * U C* 5z SL 105395 Me* 4-1 Aj C" 4-2 4-5 4-5 17 9 The craft states chat EDC/VCM plants using pure oxygen as a feedstock have reduced emissions below those set by the standard. While this may be correct (although Table 4-3 on page 4-5 -does not indicate such), it is unfair not to mention air-cased SDC plants which also control emissions to levels below the standard. Table 4-3 on page 4-5 presents data showing that actual emissions from airbased plants are substantially lower than regulated emissions. To prevent misleading implications, both types of plants should be addressed. Table 4-1 "Containment" is listed as a control technology for reactor relief valve discharges. This is not further discussed. However, several other comments in section 4.2.3.3 lead us to believe that this may _ reflect a misunderstanding of the process. Table V^The current standard for relief valve 4-3 discharges is not zero, and the "regulated emissions" are not zero, as listed in the table. This should be modified. , Me. The estimated actual emissions from the primary control are shown as being equivalent to the regulated emissions. This must be incorrect, particularly in light of the statement on page 4-1, lines 3-9, that actual emissions are "well below the 10 ppm level." A more appropriate figure for actual emissions is 315 !<g/yr, not 3150 kg/yr. Total emissions should be changed from 40,110 kg/yr to 37,265 !<g/yr. Therefore, estimated actual emissions are approximately 74% below those permitted by the standard. footnote "c" Should refer to Table 4-7 on page 4-22. In addition, the data in Table 4-7 dees not reacilv convert to the figure given in Table 4-3 . Table 4-4 As men estima icned above, it is u .fair to list :ne ad actual amissions :cr primary and the reactor epe ling loss to be * ^ - '* A - 1' * 3 * A -- emissions. As :m review of :3, both primary SL 105396 t/4"6 /vi C- 4-5 pC- 4-5 V7 4-7 la control and reactor opening loss amissions are substantially less than the regulated levels. These numbers should be revised to 53 :<g/yr far the primary control and 450 Xg/yr for reactor opening loss. The figure for estimated actual fugitive emissions should be chanced from 104,000 '<c/yr to 25,500 !<g/yr. See comments on pace 4-59, of the draft below. Total emission figures should be changed to 44,403 !<g/yr and [105,503 Xg/yrJ , respectively. The current standard for relief valve discharges is not tero, and the "regulated emissions" are not zero. This should be modified. footnote Should refer1 to Table 4-5 on page 4-21. The c* data in Table 4-5 does net readily convert to the figure given in Table 4-4. footnote Estimate of emissions after stripping is d" based on incomplete data. The semiannual reports should be reviewed and incorporated. The last line should be corrected to read "E2A 1975 estimates after control as recuired bv current NE3HA.PS regulation." The statement that "the current standard requires zero emission levels during periods of control equipment shut down. . ."is incorrect. The current standard does not require zero emissions curing times of control equipment shutdown. It dees net expressly allow exceptions for loss of control equipment but dees allow for hourly averaging in the test method. There is r.c zero requirement in the standard. -it n w me no e disc ur agec test id SL 105397 0 1 K> 4-12 ^4-12 \/"4- 12 C- 4-13 ^4-16 ^ 4-13 * 19 7 As noted above, we believe that SPA may have information on flare efficiency. 13 The capital cost for the flare stack is grossly understated. 20 The reference to "Neveril, 1930" either is incorrect or the full citation has not been provided on page 4-90. 23-35 The draft states that one company has a flare installed specifically for ?VC process emissions that was originally designed to accommodate emergency releases from two simultaneously-discharging reactors. We understand that this statement is a misquotation of the information given to TRW. Section We know of very few plants which are using 4.1.5 carbon adsorption successfully now. Problems with impurities and comonomers, especially vinyl acetate, are serious. In any event, the buildup of mechyl chloride requires a purge to an incinerator^ which, if present, may as well be used for the entire waste stream. Here again, a reference t a source for this statement should have been supplied. 10 The 945,000 capital cost and $1,000 operating cost is only for the heat exchanger and chiller, not the entire monomer recovery system. 9 The discussion in the draft of the relief valve discharge provision in the existing standard is inappropriate. The draft should be modified to reflect a neutral approach on this issue. It certainly is not appropriate, for example, for TRW to claim to identify (careccrically and without any cited support) just what "[t]he intention of Section SL 105398 20 51.55(a) was." Moreover, the abbreviated discussion cf the history of the relief valve discharge provisions coupled with the unsupported conclusions creates a serious misimpressior. of current requirements. As noted previously, the craft report erroneously states that no emergency relief valve discharges are permitted under' the present standard. The history of the development of the standard na!<es clear that SPA realized that "emergency relief discharges" would continue to occur and expressly provided that such discharges would not violate the standard. SPA further recognized and provided that a source need not take "all available measures" to prevent discharges. The proposal defined an " emergency relief discharge as "a discharge which could not have been avoided by taking all available measures to prevent the discharge." *40 Fed. Reg. 59345, col. 3 (Dec. 24, 1973). The final rule promulgated by SPA deleted the "all available*' language contained in the oroocsal. 41 Fed. Reg. 45555, col. 3 (Get. *21, 1975). This change in language demonstrates that seme relief valve discharges were anticipated and considered permissible by SPA under the standard. There simply is no basis for the statement in the draft report that "(t]he intention of Section 51.55(a) was to eliminate relief valve discharges ." SPA recognized the important safety functions cf pressure relief valves, and the standard clearly permits seme relief valve discharces. In the interest cf present report, the comments filed seme cf SPA's conclusions standard support document .g a balanced y SPX criticizing . the original culd be .noted. tns passages r zccics * SL 105399 4-18 4-19 33 5 Table 4-3 21 Section 4.2.2. claims teat S3A regional enforcement personnel indicate that the majority of relief valve discharges are preventable. No data are provided and no statements or documents are cited to support this statement. We believe that the majority of discharges are not preventable. They are caused by instrumentation failures such as controllers/ transmitters and automatic switches, other mechanical failures, or unprever.table operator error. Sven with the best operator training there will be an occasional, unpreventable error that results in a. discharge. It is unreasonable to assume that such discharges are preventable. Such a position could eventually require capital investment far in excess of any marginal emission reduction. * The statement that "with the change to larger reactor systems, the potential quantity of emissions from the relief valve is increased" is incorrect. No data are provided to support this statement, indeed, page 4*23, section 4.2.3.1 indicates that "newer reactor systems provide . . . fewer emissions to the atmosphere" and that larger reactors result "in a lessened probability of relief valve discharges." In addition, the first paragraph on page 4-42 states that one firm had "no reactor relief valve releases for 31,000 charges at their large reactor facilities". These citations refute the statement made on page 4-19. In addition, the word "potential" describes the possibility of an event. It may be that the amount of a potential release from a large reactor could be greater than that of a small one, but the probability c such an event is likely to be less. Most large reactors are in newer plants with mere accern safeguards so that the potential is lessened. Mere complete data could be assembled from existing reports submitted to Z?k. SL 105400 22 4-25 5 The thermal expansion cf vinyl chloride between 50 and 150*3? is about 13%. That of water in the same range is about 2%. Thus, the statement that "hydroful" conditions may result from a 20% expansion at the "7C liquid chares" appears to be in error. Mo reference is given for this statement. 23 The autoacceleration of the polymerization rata begins when the liquid phase is absorbed in the precipitated polymer, which occurs at 25-30% conversion. It continues until 73-30% conversion, then ceases. "Flashing" will not increase the internal pressure. It only occurs because of the equalization of pressure due to the hydraulic head in the liquid charge, and any vapor'generated is balanced by condensation or absorption iH other parts of the vessel. Further, flashing is a consumer of energy and thus tends to cool the system. No reference is given for the statements in this section. M C 4-23 1 pc 4-23 MC 4-23 An increase in temperature to 72C may or may not result in a relief valve discharge. This depends on the rupture dis!</relieff valve settings, which are a function of the design pressure of the reactor. Some polymerizations are run at temperatures in excess of 72C. The volume of the space charged has no bearing on the amount of discharge if a relief valve epens. The amount depends on the propelling force, which is a function of the unreacted monomer present, and many ether factors . The draft incorrectly implies that gasholder is the solution to a mu! problems but dees net "conclude" casholeers are ecor.cmicallv ieasl' A *|J* A at s. A Me 4-2c acecua telv oc >-aa "a state the value sm by failing to ..3; r3 \ -*a . ** *-- * SL 105401 4-34 N) C 4-35 /4-37 4-39 1/4-39 15 Table 4-10 13 1 30 23 Should be corrected to read: "One plant manually relieves pressure to Che monomer recovery system when a batch is out of control." It is ncc vented to a gasholder. The disadvantages of gasholders are generally understated. The table should indicate that the figures are in December 1979 dollars. In evaluating the $5 million cost of the 10,000 gallon gasholder, reference should be made to the statement on page 34 that many gasholders would be required. We consider the $3 million estimate to be reasonably accurate. We support TRW1s conclusion that a safety relief device vented directly to the atmosphere will always be required, ho matter what system or combination of systems Is required, tfe concur with the statement on page 4-17 that safety regulations and insurance companies require and strictly enforce Che use of safety relief devices on pressurized equipment to avoid any esplosion hazard, we would, however, object to the report's presumption that gasholders will stop and contain emergency discharges. Hydraulic testing of a rupture disk before a batch will not prove that it will not fail prematurely, only that it did not fail on that test cycle. 3esides being difficult to do accurately and requiring several hours, this test merely adds" one more cycle to the disk history and brings its ultimate failure that much closer. Pressure testing of ail reactors prior to charging to detect premature rupture disc failure is unreasonable. Rupture disc failure does not always result in a discharge since there may be a relief valve behind it. The operational procedure of evacuating the reactor after the high pressure testing would reduce productivity even further. Premature failures dc happen, tut with improved disc tecnnclcgv, proper selection cf materials and regular maintenance, the possibility of disc failure has been reduced. SL 105402 24 The statement that pressure tests can be run on the reactor prior :c cnargi.ng a new batch so as to prevent premature rupture disc failure is followed by procedures used by one plant to insure safe operation during the polymerioation reaction. The juxapositicn of these two sentences implies that this one plant pressure tests the reactor prior to charging a new batch. This is incorrect,. The paragraph should be rewritten to make it very clear that the rescuers and rupture discs are not pressure tested prior to charging each new batch. Pressure testing each reactor prior to charging a new'batch is infeasible, and any such requirement would have a devastating impact on the industry, 1-40 33 Equipment failure is noc "prevented" by an emergency generator. An emergency source of cower, from whatever origin, can keep sco equipment in`service if the normal power supply is lost, but equipment failures are not avoided. We rind this entire section 4.2 to be confusing and containing many minor errors. In particular, "hycrofui" conditions are not a primary cause of relief valve discharges. They are, as Conoco reported, caused primarily by high temperature excursions which are not controlled by the short-stc? system cr emergency cooling. C 4-47 15 The sole purpose of a gasholder in any recovery system is to provide surge capacity before the compressors. It is not, as so broadly stated, for venting compressor relief valves, pumps, weigh scales, condensers and knockout tanks. O 4 General Tire and -lube cnpa.ny ices net deliberate!'/ vent rel valves to the atmosphere. Thav mav :beratelv vent mane ly eperateo va_ ; - - a.-- "V 5 SL 105403 iC 4- 51 4-5 2 4-53 & L/ 4-59 4-65 25 34 The draft states that stripping to lower 3701 levels is prompted primarily by the VC standard. This statement makes no 3ense because if it were true manufacturers would not be stripping some resins to levels below the current requirements. Actually, other marketing reasons prompt producers to strip some resins below the levels set by the regulation. See the stripping levels given in Table 4-11 on page 4-53. 23 Other factors which affect the rate of stripping are the molecular weight (degree of polymerization) and porosity of the resins. As these factors decrease, the rate of stripping also decreases. Customers often have requirements for resin classes that strip with ouch more difficulty than do other classes. Table 4-11 This table is only partially complete. Since industry has submitted this data to SPA, the data should be included for all plants to represent ldo% of production. 10-13 The draft misstates the results of the 3. F Goodrich study. A corrected statement should indicate that fugitive emissions from small reactors were "0.034 kg/100 kg (0.034 lb/iooib) of PVC produced or approximately 20 percent of the SPA estimated controlled rate (the SPA predicted rate after implementation of the existing standard) . Fugitive emissions from new large reactor suspension orocesses were determined to be 0,0035 kg/lQQ kg (0.0085 lb/100 lb) of PVC or only 5 percent of the SPA estimated controlled rate." 10 As stated before, the standard exempts emergency manual venting from the emission limit of 10 ppm. SL 105404 l/*4-55 34 \f4-5" 7 11 25 the 3 cat aniens is incorrect. the slant has modified the unloading lines from railcars, not the transfer lines. thus, after purging the lines to recovery, the volume is less than the allowed volume under the standard, there was no general two-year waiver period for compliance, as the sentence implies. the review of leak programs referred to here was held only cor Regions III and tv. Region 71 held a different study. Instead of "the SPA Regions', the statement should read "a few of the 2PA Regions." VQ4 calibration gases are certified by the manufacturer. As a check, the plant can run a comparison test with their calibration "$as. Analysis by Method 105 is unnecessary. SL 105405 \l C 5,3 AiC 5-4 A/C 5-6 A/C- 5-7 27 Chapter 5 u Inprocess wastewater stripper effluent does not need continuous monitoring or daily sampling when it can be historically shown that the effluent is well below the 10 pcm level. 15 It is stated that "compliance with the regulations has drastically increased the quantity of in-process wastewater discharged from many plants". A reference is given for this statement; however, no details supporting the claim are given. Supporting details should be provided, or the statement should be deleted. " The report suggests that monthly or semiannual averaging of reactor opening loss would apply mainly to bulk processors and other plants stripping in the reactor. There is no reason for limiting this concept to bulk processors and other plants stripping in the reactor. It can and should be applied to all reactor openings. 20 Mew source performance standards (NSPS) should not be applied to existing sources unless they become new sources through plant modification or expansion. Section The discussion concerning dryer emissions is 5.9 somewhat misleading. The example given is based on dryer emissions for a new plant being equivalent to the current standard RVCM level of 400 ppm. The example given is based on one application for a prevention of significant deterioration (PSD) permit. Many recently issued PSD oermits (not applications) specify RVCM levels substantially less than these currently allowed by the existing standard. It`would be interesting to know the permit K7C24 level This discussion implies that indirect drying reduces emissions. This is incorrect and misleading. Met all P.VC is emitted from the SL 105406 aJc. / 1/5-7 si C ,_7 MC 3-7 N|c =.s 23 from the blend tanks and silos, vails seme remain in the resins. The figures also improperly assume than the resins will be at the 400 ppm .V/C4 level/ as ccpcsed to actual/ current levels. SPA considered regulating sources after the stripper during initial development of the standard. The required stripping levels vera selected, in part, to assure that sufcsecuent emissions would not exceed the 10 ppm level. In addition, S?I comments on the original standard reflected an industry preference to control emissions through stripping rather than through control of post-stripping emission sources. However, the draft report fails to note that the present standard gives an operator a choice between stripping and other control methods. See 40 5 31.54 (e) . 5 The prevention or significant deterioration (PSD) application should be identified. 0 The stated figure for the production off an average plant should be 90 gigagraas, not 90 megagrams. 3 Indirect drying would have little effect on emissicr.s here. It is cbsclete technology and does not apply to PSD situations.' 13 The draft should be factual and not judgmental. The suggested regulation of blend tanks and centrifuges is subjective and unsupported by referenced data. sect tor. The premise of the existing leak detection t > i section of the 7C standard is sit* specificity. I?A, however, did net provide guidance for the basic elements of a leak detection crecram. 24 and vents are t"*oica _ v ccera-*c ,iss ::0 hours = :* r.c the scre.tse 3 mcni ipmer.t -- - -a-- SL 105407 Pace 6-7 29 Chapter 6 Line Comment OSHA regulations apply to the transportation of vinyl chloride. 29 C.F.R. 1910.1017(a)(3). This, in turn, limits the amount of VCM in rail and tank cars sent to cleaning and repair facilities. We understand that cars are purged to control devices. Section The draft report states that PVC disposal 6.3.4 sites (landfills) are unregulated, represent a potential VCM emission source, and are an area of concern for regional SPA personnel. Such statements increase the likelihood o unnecessary regulation of PVC related wastes and landfills accepting such wastes under RCRA or the Clean Air Act. This concern is increased by TRWs plans to include landfills as an area of focus in their Phase II study. i An earlier 3attelle Recoct on VCM emissions from a landfill was a major factor in EPA's August 1979 proposal to list as hazardous waste PVC sludge and other related wastes. SPI submitted comments to SPA's Office of Solid waste, pointing out that (1) the 3attelle information was out of date, .(2) the 3attelle Report was considered when 2PA prepared its N2SHAP regulation for VCM, (3) subsequent industry testing shows the existence of substantially lower concentrations of VCM at landfills, and (4) the JT2SHAP stripping requirements have resulted in lower RVCM levels in PVC waste. Further consideration of this issue is unwarranted. SI i05408 He, MC. 7-3 A C 7-7 ^7-3 Ale 7_:: MC Chapter 7 Section In general/ the impact oc other regulations 7.1 is understated in this chapter. The Interagency peculator*/ liaison Group's (IRLG) "Hecuiatory",?.sport," Vol. 11, issue II (December, 1980) provides a review or the status cf pending regulatory actions. This can be updated through mere recently published regulatory agendas. CPA's agenda appears at 45 Fed. Peg. 23592 (April 27, 1981) . Section The viability of SPA'S airborne carcinogen 7.2.1 policy is highly questionable, as noted previously. 25 Implementation of the California South Coast Air Quality Management District (SCAQMD) requirements would present a great hardship to industry. This standard is not based on verified scientific evidence and should, therefore, not be implemented in any new areas. 4 The draft reocr t errs when it states tha California Rule 1005.1 on 7CM requires reactors and ot her equipment upstream of stripping to be equipped with automatic pressure reduction systems (APRS). Such a requirement, by the terms of Rule 1005.1, is contingent upon there being two violations per month of the ambient air concentration requirement in two consecutive menths caused ;v emergency relief valve discharges. Sec cr. 7.3 soussion ignores the status of JVC under RCPA and its relationship to suggested review of solid waste al under the Clean Air Act. ,rn A A a --^ i 2 c * r i - c SL ^05409 CONCLUSION Should the Agency conclude that further activity is needed, S?I recommends that the following steps be taken. 1. EPA should proceed to develop the needed administrative changes in the current standard on an expeditious basis. We are available immediately to assist the Agency wish this work. 2. Any substantive revision of the VC standard must be preceded by the development of health effects data that would demonstrate a public health benefit from reduced emissions. Any revision of the standard not supported by new health effects data would violate the "ample margin of safety" test_of Section 112 of the Clean Air Act, the provisions of Executive" Order 12291, and the guidance given by the Supreme Court in the Benzene case. Enormous strides have been made since 1975 in the epidemiology and pharmacokinetics of vinyl chloride. We do not believe that a simple calculation of risk by SPA's Carcinogen Assessment Group (CAG) can be adequate unless all available data are evaluated. We will-assist CAG in the gathering and evaluation steps if we will be permitted to do so. At a minimum, we request permission to comment cn the draft CAG report, new due in July, before it is issued in final form. 3. The Agency should address the admittedly incomplete data base in the TRW draft with emissions and compliance records from the Regional offices. If these reports are so difficult to acquire and utilize, the Agency should reevaluate the need for requiring them to be submitted. the submitted to ZPA as oart of the RC3A proceedings in 1979, health data wer surm; toed tc OSEA in 1930. There may well other scuroes o information. These available resources shc< be utilized in :v review of the standard. Me she. e aoclied toward as rent standard, espe areas. Altarnativ o r oce< 105410 V 32 which nay produce aqua! results at a lessar herder, to ERA ar.d the industry should he considered, This aftert will he necessary, if r ev iaw is continued/ to meet the requirements of Executive Order 12291. 5. ERA should consider the need for add itional flaid monitoring after available data are evaluated Certainly, decisicns'tc bring further activities under : eguiacion canno t be supported without actual measurements. A health effects studv will also be required. SRI appreciates this opportunity to comment on the TRW draft and the vinyl chloride review study and is willing to discuss these points with ERA in greater detail at any time. hay 13, 1931 SL 105411