Document VJO9pMpM8ogXb092n1yGZzJY4

April 30, 1980 Contract No. 68-02-3063 EPA PROJECT OFFICER Thomas M. Bibb PROJECT WORK PLAN PART 1: VINYL CHLORIDE REVIEW STUDY CONTRACTOR TRW, Inc. Environmental Engineering Division Progress Center, P.0. Box 13000 Research Triangle Park, North Carolina 27709 4Uq /, ISBno! 3unctr/t TRW PROJECT MANAGER Ronald A. Venezia TRW PROJECT ENGINEER James W. Bodamer, Jr. PREPARED FOR: U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 GENC 015845 TABLE OF CONTENTS Section 1.0 Introduction ........................................................................... 2.0 Project Objective and.Scope of Work.............................. 3.0 Project Description.............................................................. 3.1 Approach.......................................................................... 3.2 Task Outline.................................................................. 3.3 Project Critical Pathway......................................... 3.4 Project Scheduleand Milestones ........................... 4.0 Project Organization .......................................................... 5.0 Cost Schedule.......................................................................... Page 2 3 4 4 6 11 11 14 14 1 GENC 015846 PART 1: VINYL CHLORIDE REVIEW STUDY Project Work Plan 1.0 INTRODUCTION The U.S. Environmental Protection Agency (EPA) has contracted TRW Environmental Engineering Division to conduct a review study of the vinyl chloride emission standard. A recommendation to revise the current standard may result from this review study. The entire project, includ ing revision if necessary, will be accomplished in two parts as follows: t Part 1: Vinyl Chloride Review Study Part 2: Vinyl Chloride Standard Revision The vinyl chloride standard was promulgated in 1976 under Section 112 of the Clean Air Act, National Emission Standards for Hazardous Air Pollutants (NESHAP), and is applicable to new and existing sources of vinyl chloride. The proposed NESHAP "Policy and Procedures for Identify ing, Assessing, and Regulating Airborne Substances Posing a Risk of Cancer" (Carcinogen Policy - 40 CFR Part 61) would require that emission standards promulgated under Section 112 be reviewed at no more than 5-year intervals. On March 25, 1980, EPA requested that a draft project work plan for review of the vinyl chloride standard be submitted byApril 11, 1980. A draft work plan was submitted on that date to EPA for review. This project work plan "Part 1: Vinyl Chloride Review Study" represents the result of the EPA review and describes the work effort planned by TRW to complete a review study of the vinyl chloride emission standard. Contingent upon the need for a revision, the initial review study will provide most of the data base necessary to revise the standard and deter mine the level and direction of work effort required for "Part 2: Vinyl Chloride Standard Revision." At the end of the Part 2 study, a Background Information Document (BID) will be prepared which will provide the background information for revision of the standard. 2 GENC 015847 There are no published procedures presently available for the_ review and revision of an existing NESHAPy^Therefore, TRW has developed this "Part 1: Vinyl Chloride Review Study" work plan based somewhat on the Contractor's Procedures Manual for Development of National Emission Standards and assistance from EPA personnel experienced in this area. 2.0 PROJECT OBJECTIVE AND SCOPE OF WORK The existing vinyl chloride emission standard covers the production of ethylene dichloride (EDC), vinyl chloride monomer (VCM) and polyvinyl chloride (PVCj resin. The purpose of this study is to review the existing emission standard and collect data and information needed for revision of the standard. To accomplish this, the review study will concentrate on the following four major areas of concern: . 1. Control Technology. The objective will be to review, collect data on, and jassess "existing technologies" fused to control known emission points covered by the standard - process, fugitive and storage emissions. An assessment will also be made to identify anything beyond this level of "existing technologies". A preliminary cost analysis will be made of these technologies and the review will take into considera tion that levels of control may be different for new and existing sources of vinyl chloride. Results of these control technology assess ments during Part 1 will provide most of the data base needed for determining Best Available Technology (BAT) during Part 2 of the project. 2. Existing Sources Not Covered By The Standard. Additional sources of VCM were identified during the original study, but not included under the standard. These sources, which include fabrication operations that convert PVC resin to consumer products and miscellaneous sources such as those using VCM as a chemical intermediate or producing VCM as a byprodgrt- will be reviewed for possible regulation by the standard. Emphasis will be placed on the miscellaneous sources during this review study for several reasons. More data and information is avail able on fabrication plants from previous studies, and the PVC industry 3 GENC 015348 has concentrated on more efficient removal of residual VCM from the resins, which constitutes the major source of VCM from fabrication plants. 3. New Sources Not Identified During the Original Study. An attempt will be made to identify other sources of vinyl chloride not identified in the original study conducted for promulgation of the emission standard. 4. Enforcement Experience at the Federal and State levels. Enforcement of the vinyl chloride emission standard will be reviewed for identification of any problem areas. Included in this review will be an examination of the Federal and state permitting procedures used to implement the standard. Based on the review and analyses, where appropriate, of the above four major areas of concern, the ultimate objective of this review study is to provide a data base that can be used for revision of the existing standard and to determine the level of effort necessary for revision. Results of the review study plus recommendations for revision will be documented in a Part 1: Vinyl Chloride Review Study report submitted to EPA at the conclusion of Part 1. Submitted with the report will be a detailed work plan for the remainder of the project, "Part 2: Vinyl Chloride Standard Revision." 3.0 PROJECT DESCRIPTION The following sections describe the draft program plan for review of the vinyl chloride NESHAP. The approach that will be taken to ful fill the review objective will involve a step-by-step progression through specific tasks. Each of these major tasks will be further divided into subtasks. 3.1 Approach The approach to be taken to meet the review objective will include seven tasks. The seven tasks, as well as a brief discussion of each, follow: Task 1. Review Project History This task reviews the original vinyl chloride emission standard ^development work effort including interviews with key personnel involved in the original project and related projects. GENC 0\ 4 i Task 2. Collect and Assimilate Available Data/Information Included in this task will be literature searches, interviews and "" " ........ lTI^ - telephone contacts, with trade associations, vinyl chloride industries, and EPA regional and state enforcement agencies. Considerable time will be spent in this task to assure that all pertinent data and information is collected that will be needed for revision of the standard during Part 2. Task 3. Preliminary Data/Information Analysis The data and information collected during Tasks 1 and 2 will be reviewed and analyzed with regard to the following four major areas of concern given in Section 2.0: control technology; existing emission sources identified in the original study but not covered by the standard; new sources not identified in the original study; and enforcement experience at the Federal and state level. Task 4. Additional Detailed Data/Information Gathering Results of the Task 3 preliminary analysis will be discussed by EPA and TRW personnel to identify critical data gaps, select candidate sources for site visits and assure that the NESHAP review is targeted toward the important concerns and issues. Following this discussion, sources will be chosen for site visits and the enforcement agencies responsible for these sources will be notified and visited. Section 114 letters will be mailed to industries as necessary. All data gaps should be filled during this task. Task 5. Final Analysis of Data and Information Collected This task will make a final analysis of all data and information collected during Tasks 1, 2, 3 and 4 to determine the areas in which the standard needs revision. This task also will determine the extent of those revisions. Task 6. Submit Draft "Part 1: Vinyl Chloride Review Study" Report The "Part 1: Vinyl Chloride Review Study" report will contain the results of the above tasks. A detailed work plan for Part 2 of the project will also be submitted with the report. 5 GENC 015850 Task 7. Project Documentation Throughout the review study, data and information will be assembled and labeled as required in a central file. A review and discussion of the pertinent items in this file will be conducted with the EPA Lead Engineer. This task will allow smooth transition to docket development. 3.2 Task Outline Discrete subtasks and activities have been developed for each task described in the above discussion. In the following outline, these subtasks are identified and defined: Task 1.0 Task 2.0 TASK OUTLINE Review Project History 1.1 Interview EPA personnel responsible for development of the original emission standard. Gather references, reports, data, etc., from previous studies. Initiate literature search, including identification of new sources, new control technology and sampling and analysis procedures for VCM. 1.2 Review "Standard Support and Environmental Impact Statement: Emission Standard for Vinyl Chloride", Volumes 1 and 2. Other supportive documents to the EIS (e.g., A. D. Little studies on PVC fabrication, processing and miscel laneous sources, VC task force documents, etc.) will also be thoroughly reviewed. 1.3 Telephone interviews conducted with other EPA contractors for associated projects. Same concerns as 1.1, 1.4 Initiate contacts with trade associations (CMA, SPI, etc.) and related government agencies (OSHA, NIOSH, etc.). 1.5 Identify and contact other informational sources. Collect and Assimilate Available Data/Information 2.1 Review and critique "in hand" data and information. 2.2 Review important reference materials acquired through literature searches. 6 6ENC 015851 Task 3.0 2.3 Initiate industrial telephone contacts for development of the questionnaire that will be part of the Section 114 letters. t Industries will be initially contacted by telephone and mailed a Section 114 letter, if necessary, requesting specific information for use during Task 4. 2.4 Contact pollution control system vendors. Request applicable information and specifications on control systems. 2.5 Initiate Federal, state, and local agency contacts. Review enforcement problems. Evaluate permitting procedures and problems. 2.6 Assimilate data. 2.7 Identify data gaps. Preliminary Data/Information Analysis 3.1 Control Technology Review 3.1,1 Review, collect data on and |assess "existing technologies"/for control of emissions from vinyl chloride processes, fugitive sources and storage facilities as regulated under the existing standard, i Description of "existing technologies". Assess how technology has functioned if currently installed at plants. -- _______ Compare control technologies with Best Available I -ControLJechnoloqy (BACT) required by the standard. Assess feasibility of technology transfer. Identification of problem areas. Identification of present control efficiencies for VCM. Identification of control levels for new versus existing sources (e.g., retrofit problems). Preliminary assessment of control technologies beyond the "existing technologies" (e.g., those technologies in developmental stages). 7 GENC 015352  Preliminary cost analysis of existing standard (BACT) and other "existing technologies." 3.1.2 Analyze emission monitoring and compliance testing techniques. Review emission sampling methods, instrumentation and analytical procedures for VCM. Determine stack sampling methods for compliance testing. ' Costs of VCM sampling and analysis. 3.1.3 Review regulations for control of aqueous and solid waste discharges from VC and PVC plants.' Review and update experience with measuring residual VCM in water, slurry, resin, wet coke, and latex. 3.1.4 Assess historical and projected growth rate for the vinyl chloride industry. General description of the industry. Industry growth since promulgation of standard. Projected growth of industry for next 5 years. 3.2 Review of Existing Sources Identified But Not Covered By the Standard. 3.2.1 Polyvinyl chloride fabricating plants. Review emissions for significance and control by standard. Determine levels of residual VCM in PVC resins. 3.2.2 Miscellaneous sources of vinyl chloride. Analyze emission sources from plants using vinyl chloride as an intermediate and those that produce vinyl chloride as a byproduct. 0 Review control technologies at these plants, t Determine growth in these industries and total estimated emissions. 0 Assess need for regulatory control. 3.3 New sources of vinyl chloride not identified in original study. 0 Identify sources of vinyl chloride other than those discussed above. 0 Determine significance of emissions and need for control. 8 OENC 015353 3.4 Enforcement Experience at the Federal and state levels. 3.4.1 Review enforcement history and identify problem areas. 3.4.2 For example, enforcement problems and difficulties have occurred(Cnth safety valve relief discharges.^ Federal and state approaches to enforcement of NESHAPs. Procedures for determining applicability of NESHAPs to new and existing sources. EPA regional approach for control of NESHAP pollutants. State approach for control where EPA has delegated authority to the state (e.g., Permit to Construct, Permit to Operate,`etc.). Enforcement effectiveness through permitting systems. Compliance requirements, reporting and effective 3.4.3 ness. Review sampling techniques and analytical methods required for compliance determination. Review permitting of existing sources versus new sources. Identify problem areas. Task 4.0, Additional Detailed Data/Information Gathering. 4.1 Meet with EPA for review of preliminary analysis. Discuss data base. Identify data gaps. Review project scope to determine if "on track" regarding review study objective. 4.2 Select candidate industrial sites for field surveys. Screen plants with guidance from EPA. Contact industries by telephone. Determine need for field sampling. t Send Section 114 letters to selected plants. Select plants and conduct field surveys. 4.3 Enforcement office visits. Coordinate fipld cnrvpvs _to plants with visits to regulatory agencies responsible for these plants. 9 GENC 015854 4.4 Develop an outline for the report to be submitted at the conclusion of Part 1. The outline will be submitted to EPA for review and comment. Outline will be finalized. Task 5.0 Final Analysis of Gathered Data and Information. 5.1 Determine if new control technologies exist for the vinyl chloride industry. Preliminary environmental- impacts.of new technologies. Preliminary economic impacts of new technologies. 5.2 Other sources of vinyl chloride requiring control. Determine same impacts as 5.1. Recommend need for control or additional NSPS/NESHAP development work. 5.3 Discussion of existing enforcement problems. Determine how revision of the standard would solve current enforcement problems or ease future problems. 5.4 Identify data gaps and special problems or issues that have arisen during the review study or since promulgation of the standard. Recommend ways to address these items during Part 2 of the project. 5.5 Develop detailed work plan for "Part 2: Vinyl Chloride Standard Revision." The work plan will outline the level of effort necessary for preparation of a Background Information Document (BID) that will provide background information for revision of the vinyl chloride emission standard. Task 6.0 Submit Draft Part 1: Vinyl Chloride Review Study Report - the report will follow the generalized outline below: 1.0 SUMMARY Conclusions reached and recommendations for revision of standard and additional work. 2.0 INTRODUCTION Description of project, objective and scope including a discussion of the NESHAP program and proposed Carcinogen Policy. 10 GENC 015855 3.0 RESULTS OF REVIEW STUDY 3.1 Control Technology Review 3.2 Review of Sources Not Covered by Original Standard 3.3 New Sources of Vinyl Chloride 3.4 Enforcement Experience with Existing Standard 4.0 REFERENCES APPENDICES - Detailed work plan for Part 2 plus supportive data and information. As mentioned in subtask 4.4, this outline will be developed further after all available information and data have been gathered. Task 7.0 Project Documentation. 7.1 Assemble and label information as required. 7.2 Review and discuss pertinent items with EPA Lead Engineer. 7.3 Develop project docket. 3.3 Project Critical Pathway Figure 3-1 shows the critical pathway for the "Part 1: Vinyl Chloride Review Study" and indicates the interrelationship between tasks discussed in the Task Outline of the previous section. Also shown in Figure 3-1 are major EPA decision points where approvals are needed before the project can continue. Not indicated are the more frequent communica tions that will be maintained with the EPA Lead Engineer to report project status and acquire approvals from the EPA Lead Engineer. 3.4 Project Schedule and Milestones Figure 3-2 shows the project schedule and delivery dates for the following four major milestones: 1. "Part 1: Vinyl Chloride Review Study" project work plan. 2. Draft report outline. 3. Draft Part 1: Vinyl Chloride Review Study report. 4. Final Part 1: Vinyl Chloride Review Study report. Also shown are the approximate time periods to be spent on each of the tasks and related activities listed. 11 GEMC 015354 12 GENC 015S5? (1) Submit project work plan. (2) Submit report outline. (3) Submit draft Part 1: Vinyl Chloride Review Study. (4) Submit final Part 1: Vinyl Chloride Review Study. Figure 3-2. Project schedule and milestones. GENC 015858 - _ L_ Based on this project schedule for the "Part 1: Vinyl Chloride Review Study" and the typical time period required for an NSS Phase II as outlined in the Contractor's Procedures Manual for Development of National Emission Standards, TRW feels a new standard for vinyl chloride would be proposed during the 3rd quarter of fiscal year 1982 with promulgation probably occurring during the 3rd quarter of fiscal year 1983. 4.0 PROJECT ORGANIZATION Figure 4-1 shows the TRW project team selected for the "Part 1: Vinyl Chloride Review Study". Additional TRW personnel will be used in a supportive role as needed. 5.0 COST SCHEDULE Tables 5-1 and 5-2 indicate the projected labor hours and dollars, respectively, for the "Part 1: Vinyl Chloride Review Study". These labor hours and dollars are shown for each task and major activity and are exclusive of fee. 14 GENC 015859 GENC 015860 Figure 4-1. Project organization. TABLE 5-1 COST/SC! I HOULE HASH LINT. !WI-'-2) Contractor: TRW, Inc.Contrector project manager .name.title lleAc--VeH6Zl_cl---------------------------------------------------flcv;,jofi fj0 Environmental Engineering DivisionVinyl Chloride, Dots 4-11-80 EPA project officer:--Thomas--M.--Bijbb;!' 68-02-3063 Contract No. _____________ Task No. ______ C:l: _ Approval by CPA project officer4 111 Work breakdown struciure No. Noun description 121 Cumulative (31 Monthly budgeted cost of work scheduled (DCWS)0^ (SlOOO's) Tcost to date ($!0C0'slb Mo. j Yr. 3!B0" Mo. Yr. 60 !v.x Yr. 5 80 Mo. Yr. 6 _80 Mo. Yr. 00 =>! Mo. Yr. Mo. Yr. Mo. Yr. 8 JQ_ 9 .80. w_ Q_ (-11 Total budget ^ (S 1000'sl Task 0 Prepare Work Plan 0.9 1.8 2.7 Task 1 Review Project His tor / 1.8 8.3 7.6 17.7 Task 2 Data/Information Collection 3.T 7.9 3.0 14.0 Task 3 Preliminary Data/ Information Analysis 6.8 1.5 8.3 Task 4 Additional Data/ Information Collectiot 1 B.8 8.8 Task 5 Final Data Analysis 10.6 10.6 Task 6 Prepare Report 10.6 10.6 Task 7 Project Documentation 0.3 0.6 0.6 > 0.8 0.9 3.2 General 3nd administrative ODCs 1 Management reserve Total Cumuljtive total cost foe/uefinj ft;} * Ones the cost/s:hedule bate'in: hsi been approved, IP* figures mi'/ roi be changed without the approval of the EPA project officer, ^ All com shown art exclusive of fee. c Monily budgeted costs for entire contract-; 0.5 3.5 3.5 . 0.5 `11.2 14.7 . j1...JLEL_ 6.3 ' 'J 1 11.2 1 14.2. j 25.9 | 40.1 0.8 A... 1.5 __ T 11.2 n.3 51.3 62.6 .12^.9__ 75.5 .1.5 nn 88.5 12.6 88 5 TABLE 5-2 MANPOWER BASELINE o CO o 1to GO r~ ICO 1.. GENC 015362 Comrjctc-r: TRW. Inc.C. project nianajjr _B_\A:__V^JIjL!j-------------------- -' A evil ion Mo, Environmental Engineering Division __________________________________________________________ C3, r- Thomas M. Bibb , Du na ,i ,,v 4-^1_gp 68-02-3063 Cc,i tract \'o. (!) WorV breakdown structure S'o ------------ 111f---- N'oun description ---- (21 Cumulativej nun io oaie V.o.l Yr. 3 80 Task 0 (Prepare Work Plan 36 Task 1 [ Review Project History 90 Task 2 `Data/Information i Collection Task 3 [Preliminary Data/ j Information Analysis Task 4 [Additional Data/ jInformation Collection Task 5 [Final Data Analysis Task 6 iPrepare Report Task 7 jProject Documentation 1 ii 1 f 10 0;:te Approval PA projec (3) Monthly budoctcd hiv? c w or It schooled ( BCVVS! Me.1 Yr. ! Mo.! Yr. Mo. I Yr. Mo. 1 Yr. Vo. j Yr. Mo. ! Yr, Me.| Yr. 4 80 : 5 ' 80 6 i 80" r 7 rsoT 9 raP . 60 1 270 j 250 j 100 430 100 j ! i i 2 ! 20 ; ' 230 50 20 300 ' 370 370 30 30 !'>! : Total lira. I I 96 610 630 280- 300 370 370 110 s I 1. ( i i 1 1 G.-nto! md idminittrative Vanishment reserve Total KpPnv. j Bu.t.u! ; tivt tote! i ` Once t,v tv." r -cc'inibeen approved, iv,:y not be cb.jnrjod witr.ou; the approval -> C... j v Va :'t ;Y :1 136 350 136 486 i i ' ! .`i \ *v ' 350 ! 836 i 430 ! 1266 V'i;.;.. T.py'vP 7~r`l *Trrrn-lrr--r--" ................. i 350 ` 1616 [ 350 ! 1966 400 1 1 2366 1 400 * 2766 I 2766