Document Za8JogwoZBpNpQ5qV9kz890d

R&S 115167 -ft DOW CHEMICAL U.S.A. GOVERNMENT AFFAIRS OFFICE SACRAMENTO, CALIFORNIA April 12, 1978 BOB HETTLER, WALNUT CREEK CC: Bill Anderson, Pittsburg Chuck Kazmierski, 2020, Midland Attached is a copy of the iMHfeMMMtHrtF'being proposed for 777^ As you know, this matter will be heard April 27 in San Francisco. Jack Jones JJ :sg Attachment /fptr / AN OPERATING UNtT OP THE DOW CHEMICAL COMPANY R& s 115168 4 I. Introduction The adverse effects of vinyl chloride (VC) upon human health -- its role as carcinogen, mutagen and suspected teratogen -- have been discussed in detail inlHMhWMiMHBM#Staff Report 78-1-1 ('available for review upon request) and by several medical experts at the January 25, 1978, meeting of the Board. After reviewing a substantial body of medical, epidemiological and scientific literature dealing with the toxicity and carcinogenicity of vinyl chloride, the staff was unable to specify any level of exposure other than zero that could be considered safe. However, the staff reasoned that a regulation requiring an ambient level of zero would be, in effect, unenforceable, since violations in the range between zero and the limit of detection inherent in the measurement method selected for monitoring VC could not be detected. The lowest enforceable ambient standard that could be adopted will depend, then, on the monitoring method specified in the standard. The staff concluded that, if methodologies requiring elaborate, extremely expensive instrumentation are excluded from consideration, - standard at the level of about 0.010 ppm with an averaging time of several hours could be enforced using instrumentation that is readily available at a reasonable cost and can be operated by paraprofessional staff. On the basis of these considerations, the staff recommended that the Board establish, on an interim basis, a maximum allowable level for ambient concentrations of vinyl chloride within the range of 0.01 to 0.05 parts per million, twenty-four hour average. 1 -3- Other testimony given at the January meeting urged the Board to delay the setting of an ambient air quality standard until the federal NESHAP program is fully implemented in October 1978. Other concerns were expressed relating to the monitoring method proposed by the ARB staff. The Board requested the staff to evaluate the adequacy of the NESHAP program, to obtain additional air monitoring data in the South Coast Air Basin near facilities that emit vinyl chloride, and to notice a public hearing for March or April to consider the regulation of vinyl chloride. R&S 115169 II. Summary and Conclusions -A- In response to requests made by the Board at the January meetinq, the staff has carried out an analysis of the EPA's NESHAP regulations and prepared estimates of the maximum ambient levels of VC that can be expected when the largest VC facilities in California come into full compliance with these regulations. This report presents the results of this analysis along with the results of additional air monitoring work requested by the Board. In addition, an updated discussion of the measurement method proposed for adoption by the Board is presented. The staff, following a careful review of the federal NESHAP Standard, has reached the following conclusions: o NESHAP does not, in all cases, require the application of best available control technology. Indeed, some California VC processors are currently installing equipment that provides far more effective control of VC emissions than is called for under NESHAP. o Enforcement of NESHAP, because of the complexity of its requirements, is extremely difficult and would appear to place inordinate demands upon the regulatory agency charged with ensuring compliance. yo Fugitive emissions from miscellaneous sources such as tank cars and associated unloading facilities, pipe and hose joints, flanges, seals and packing glands are not adequately controlled under NESHAP. R&S 115170 -5- o NESHAP places no upper limit on the total emissions from the stacks of a VC facility; only a concentration limit is specified. o Although the regulations were developed under a general policy calling for a goal of zero emissions (and, presumably, zero ambient concentration), NESHAP does not assure that community exposure to VC will be maintained below any specified level. y/ o Finally, NESHAP does not deal adequately with the critical upset/breakdown question. There is no adequate mechanism to minimize such occurrences; there is no specification of measures to be taken to prevent community exposure to hiqh levels of VC when breakdowns occur. The staff has used air quality simulation modeling techniques to provide the Board with estimates of ambient levels of VC that may result from application of the federal NESHAP regulations. The following conclusions have come from this analysis: o Point source (stack) emissions from a facility just in compliance with the federal 10 ppm limitation (assuming mass flows scaled to plant throughput) produce maximum 1-hour levels of VC of about 0.01 ppm. Ground level maxima generally occur within 100m of the plant, because of the low bouyancy of the plumes. Twenty-four hour average values at a single monitoring site would be expected to be somewhat lower because of variations in wind direction and mass flow. R&S 115171 V -6- o Fugitive emissions of VC play a dominant role in determining ambient VC levels in the vicinity of the plants studied. Using current EPA estimates for fugitive emission rates, our calculations predict that worst case 24-hour average VC levels in excess of 1 ppm could occur inmediately downwind of the combined Stauffer - B. F. Goodrich facilities. o Comparison of these estimates with the results of recent air measurements in the vicinity of VC facilities suggests that the EPA emission factor for fugitive emissions is too hiqh. A more refined inventory of fugitive emissions is clearly desirable. o Our calculations show that if total emissions (fugitive and stack) from the combined Stauffer - Goodrich facility, potentially California's most critical location, can be reduced to about 0.5 kg/hr, ambient levels of VC outside the facility are not likely to exceed 0.01 ppm, 24-hour average (absent accidental releases of VC under upset/breakdown conditions). In response to the Board's request in late January, the staff resumed air monitoring activities in the vicinity of VC facilities in the Los Angeles area. In addition, data from monitoring programs conducted by B. F. Goodrich Chemical Company and Stauffer Chemical Company in Long Beach and Keysor-Century Corporation in Saugus have been made available to the staff. These data are discussed in Section IV-C of this report. i R&S 115172 -7- Although the unusual weather conditions that occurred during this period were not, on the average, conducive to the buildup of high concentrations of pollutants, a review of the monitoring data by the staff suggests several tentative conclusions: o Ambient levels of vinyl chloride in the Saugus community have dropped dramatically, relative to those observed in October and November 1977. Although meteorological factors may have accounted for some of the observed change, there appears to have been a substantial decrease in VC emissions from the Keysor-Century facility. o Air monitoring data from the Long Beach area continue to show VC levels comparable to those reported to the Board in January, with levels less than 0.10 ppm VC. o Ambient levels of VC in Saugus and Long Beach appear to be averaging well below the worst-case levels predicted by air quality models. This may indicate that fugitive emissions from VC facilities are lower than EPA estimates or, alternatively, that weather conditions have not been conducive to maximum buildup of VC emissions. R&S 115173 R&S 115174 -8- In Staff Report 78-1-1, we discussed several candidate methods that are available for sampling and analyzing ambient air to determine the concentration of VC. All of the acceptable methods rely ultimately on the use of a gas chromatograph to analyze the sample. They differed principally in the method of sample collection and in the amount of preparation required prior to analysis. The method developed by the staff of ARB's Atmospheric Studies Branch uses a bag sampler, followed by direct-injection gas chromatographic analysis. The method found to provide a minimum mwjsurahie vr level of about 0.010 ppm with a standard deviation of about + 0.005 ppm over the range between zero and 1.0 ppm with good linearity. The staff has done further work on the development of an accurate; reliable and precise measurement method that can be adopted for general use. The results of this work are summarized in Section V of this report. The staff has concluded that: o The ARB method using direct injection is sufficiently sensitive to provide reliable measurements at the 0.010 ppm level with a precision of + 0.002 ppm. o The ARB method can be made less sensitive to hydrocarbon interference by using a different gas chromatographic column than originally proposed. This will increase the ability of i -9- analysts to quantify low concentrations of VC in the presence of relatively high ambient concentrations of hydrocarbons. The staff, following discussions with analysts employed by the VC industry, has concluded that other sampling and analysis techniques may also be suitable for monitoring ambient VC. The industry has not yet demonstrated equivalency of it's methods to the ARB method. R&S 115175 -10- R&S 115176 III. RECOMMENDATION Following our original recommendation to adopt an interim air quality standard for vinyl chloride, the staff has explored other options that might be proposed to the Board to achieve essentially the same objectives. All of those with whom the Board and the staff have discussed the issue -- the State Health Department, the Air Quality Advisory Committee, the Board's ad hoc Panel on Atmospheric Carcinogens and other medical and public health experts -- agree that no exposure to vinyl chloride for any period of time at any level, other than zero, can be said with certainty to be safe. There is no known threshold level for its proven carcinogenic and mutagenic (bacterial effects and so little is known about dose-response relationships for materials such as vinyl chloride that the magnitude of risks associated with low level exposures simply cannot be quantified. There is unanimous agreement, however, among those mentioned that ambient levels of vinyl chloride should be % reduced to the absolute minimum -- ideally to zero -- as quickly as possible. Reliance on the federal NESHAP regulation for vinyl chloride, for which enforcement authority as now been delegated to the South Coast Air Quality Management District (SCAQMD), is one of the R&S 115177 -11- options available to the Beard. The staff cannot say with certainty how much full compliance with NESHAP will do to reduce community exposure, although it seems likely that some additional control of fugitive emissions will be required to meet an ambient standard in the range of 0.01 to 0.05 ppm, twenty-four hour average. Of more concern to the staff in making a recommendation on NESHAP are questions of enforceability, apparent loopholes that could permit total VC emissions to increase even while a facility remains in compliance, and inadequate incentive for facility operators to adopt operating and maintenance procedures that will prevent fugitive emissions. On balance, NESHAP's shortcomings and uncertainties about achieving any specified ambient level under its provisions cause us to recommend against California's relying solely on NESHAP to protect the public health from the adverse health effects of vinyl chloride. Adoption of an air quality standard for vinyl chloride or other known carcinogens presents other problems. An ambient air quality standard is generally taken to represent a safe or "no effect" level of exposure to the pollutant in question, at least for the vast majority of the population; this generalization R&S 115178 -12does not apply to vinyl chloride and most other chemical carcinogens. There is a risk, probably extra ordinarily small, but not precisely quantifiable, of grave consequences to ordinary individuals at any level the Beard might adopt for a standard. Moreover, since emission rates consistent with attaining an ambient standard vary substantially with prevailing meteorological conditions, a standard for a site-specific pollutant could represent, in industry's eyes, a "license" to pollute up to the level of the standard, absent carefully designed and vigorously enforced emission control regulations. On the other hand, adoption of a standard or other limits on maximum ambient concentrations of vinyl chloride will ensure that exposure to VC will not exceed a specified level at any location outside the facilities themselves, assuming the SCAQMD and/or the Board use a standard as a basis for developing, adopting and enforcing the appropriate emission regulations to augment, as necessary, the provisions of NESHAP. On balance, the staff's view is that an ambient standard provides a more effective way of ensuring that low levels of vinyl chloride will be maintained in the community. Therefore, the staff recommends that the Board adopt an ambient standard, to be designated as a significant harm level (a level never to be exceeded) in the range of 0.01 to 0.05 parts per million, twenty-four hour average. The staff further recommends that this standard be adopted pursuant to the Board's authority to establish ambient air qual standards for the protection of the public health Section 39606 (b) of R&S 115179 -13- the Health and Safety Code and to implement and interpret Section 41700, of the Health and Safety Code, which prohibits any person from discharging quantities of air contaminants which endanger the health of a considerable number of persons or the public. By including this latter authority, the Board will distinguish the significant harm level established in February, 1976 for sulfates, which are not associated with the more serious carcinogenic, mutagenic and possible teratogenic effects if vinyl chloride. By referencing 41700, the Board will be establishing a basis for immediate enforcement (.&, through legal action in a court or abatement proceedings before a district hearing board) which, in the staff's view is appropriate for pollutants with carcinogenic or other special health consequences. The staff recommends further that the Board require that suitable vinyl chloride air monitoring instrumentation be installed on or near the property lines of facilities using and/or producing vinyl chloride monomer to ascertain whether or not the significant harm level is being violated at locations to which the general public has access. It would seem fair that such instrumentation be installed and maintained by the operators of those facilities , as a part of their existing emission control programs. The staff recommends further that the Board specify the measurement method developed by the ARB staff and described In detail in Appendix 5 of this report as the one to be used in determining violations of the significant harm level. Although other methods may also be acceptable, equivalency with the ARB method with respect to accuracy, precision and specificity will need to be demonstrated before such methods can be approved. -14- Final ly, the staff recommends that the Board urge the SCAQMD to act expeditiously to formulate and adopt rules and regulations that will ensure that ambient vinyl chloride levels are reduced to and maintained at or, preferably, well below the level designated as a significant harm level. IV. Evaluation of the NESHAP Program At its January 25 meeting, the Board requested that the staff assess the adequacy of the NESHAP emission standard as a means of achieving acceptably low levels of vinyl chloride in the coranunity.. In addition, the staff was asked to resume its monitoring efforts in the Los Angeles area to gather.additional .data on current vinyl chloride levels. Section IV-A, below, provides a discussion of the NESHAP regulation and its enforceability. Section IV-B sumnarizes the results of air quality modeling calculations of projected ambient levels of VC in the vicinity of facilities in compliance with the NESHAP regulation. Section IV-C provides updated Information on ambient levels of VC now being observed in the Los Angeles area, along with a short discussion of the implications of these results with respect to the magnitude of the fugitive emissions problem. R&S 115180 R&S 115181 -15- A. NESHAP as an Enforcement Program The NESHAP Standard for control of VC emissions was adopted by the EPA and became effective on October 21, 1976. A copy of the Standard is attached as Appendix 2. Subsequently, on September 14, 1977, the South Coast Air Quality Management District (SCAQMD) adopted an equivalent regulation, Rule 1005 (Aopendix 3 of this report). The authority to enforce NESHAP was delegated to the District on November 23, 1977. Prior to this delegation, in order to meet certain requirements of NESHAP, the EPA issued individual waivers of compliance to each of the four affected facilities in California. The scheduled date for full compliance with NESHAP is October 21, 1978. 1. Existing NESHAP Program The following is a br^ef symmary of, NESHAP for control of VC emissions from ethylene dichloride (EDC), VC monomer and PVC plants. For EDC-VC plants, VC concentrations in gaseous effluents from control devices are limited to 10 ppm. In addition, emissions from the oxychlorination process in EDC plants are limited to 0.2 q/kq of EDC produced. For PVC Plants, VC nas concentrations in the effluent from control devices are also limited to 10 ppm for sources preceding the stripper and for the stripper V R&S 115182 -16- itself. PVC companies that choose not to strip the residual VC below 400 ppm are required to achieve an emission limitation of 0.4 g/kg of PVC produced for the processes imnediately following the stripping operations, namely the blending, centrifuging, drying and packaging. All four facilities in California have chosen the option of reducing residual VC in the resin to 400 ppm. Another requirement for PVC plants is to control VC emissions from reactor openings to 0.02 q/kq of PVC produced. In EDC-VC and PVC plants, the regulations require that fugitive emissions be captured and controlled. Discharqes from relief valves and manual venting of gases are prohibited, except under emergency conditions. As part of the requirement to control fugitive emissions, it is required that a leak detection and elimination program be implemented. Iri addition, the regulations'require extensive monitoring, sampling, analyses, record keeping, and reporting. The orginal intent of NESHAP for VC was to compel industries to utilize best available control technology (BACT) on emission sources, because VC is a carcinogenic pollutant and- is therefore to be controlled to the maximum extent possible. Our analysis of the regulation indicates that in many cases NESHAP does not require BACT and further -17- control measures could be used. This is supported by the fact that some companies have voluntarily achieved emission rates well below current limitations. For example, one of the PVC plants located in Long Beach has achieved greater than an order of magnitude reduction o* residual VC content below limitation levels for some of its resin formulations with the VC stripping process. Moreover, some of the waivers of compliance issued by EPA require installation of control equipment above and beyond the basic requirements of NESHAP, which provides further indication that NESHAP does not represent BACT in all cases. Table IV-1 sunmarizes the emission sources in facilities that emit VC, their respective emission limitations and the potential for further emission reductions: R&S 115183 R&S 115184 TABLE IV-1 COMPARISON OF EXISTING NESHAP REQUIREMENTS AND AVAILABLE ADDITIONAL CONTROL FOR VINYL CHLORIDE EMISSIONS Emission Source Current Limit Potential Limit Oxychlorination reactors .2 g/kg product By incineration, approach nondetectable (ND) level. Railroad tank cars No regulation No leaks. Opening of mixing, weighing and holding containers 10 ppm Vent to incinerator, approach ND. Polyvinyl chloride reactor opening .02 g/kg product By cleaning reactor while closed or ducting losses to incinerator, approach ND. Reactor exhaust gases 10 ppm By incineration, approach ND. Monomer recovery exhaust system 10 ppm By incineration, approach ND. Stripper Exhaust Gases 10 ppm By incineration, approach ND. Sources following stripper* . 400 ppm residual in slurry Variable depending on type resin being stripped (10-400 ppm). a) blend tanks b) centrifuge Controlled by stripping re quirement Controlled by stripping re quirement Vent head space emissions to incinerator, approach ND. Enclose system and vent to incinerator, approach ND. c) dryer Controlled by stripping re quirement Enclose system and vent to incinerator, approach ND. i *i f /* tI TABLE IV-1 (continued) d) packager Controlled by stripping re quirement Enclose system and vent to incinerator, approach ND. Relief, and manual vent valve discharges 0 (except emergency) Hood and vent to incinerator. approach ND. Fugitive sources Capture and Maintain to prevent leaks; control on control systems approach ND. i a) unloading line .13 cubic feet VC at std. temp, and pressure during opening Vent VC to incinerator, approach ND; or install valves to decrease volume of VC released. b) rotating pumps Double mechanical seals; or control to 10 ppm No leaks. 1 c) reciprocating pumps Double outboard seals; or control to 10 ppm No leaks. d) rotating compressors Double mechanical seals; or control to 10 ppm . No leaks. e) reciprocating compressors Double outboard seals; or control to 10 ppm No leaks. f) agitators Double mechanical seals; or control to 10 ppm No leaks. g) equipment opening <_ 2J0 percent volume VC or 25 gallons at stand ard temperature and pressure (whichever is larger) Vent to incinerator, approach ND; strip waste.water used to backfill and clean, approach ND. R&S 115185 R&S 115186 TABLE IV-1 {continued) h) inprocess waste water 10 ppm Strip, approach ND. i) leaks (i.e. all valves, flanges, fittings, etc.) Detect and eli minate Weld threaded fittings no leaks. *If any residual VC remains in resin after stripping then steps a-d should be implemented. -21- The potential reductions shown in Table IV-1 are based on a limited amount of source test information and a limited number of plant inspections. Further engineerinq evaluation must be performed to determine the precise method and extent of implementing these or further reductions. . / Another area of the regulation that needs to be considered concerns emergency or accidental releases of VC. Appropriate procedures should be adopted whereby during such a release of VC the air pollution control officer of the District is iimiediately notified in order to have an opportunity to take appropriate action. 2. Proposed Changes to NESHAP for VC As a result of a lawsuit filed by the Environmental Defense Fund, EPA proposed changes to the NESHAP regulation on June 2, 1977 (See Appendix 4). These proposed changes include: a. A reduction of VC in exhaust gases from control equipment from 10 pDm to 5 ppm for EDC-VC and PVC plants. The purpose of this requirement is to optimize existing control equipment; however, if a company were not able to meet the requirement without additional control equipment, an interim emission limit would be set and reviewed every three years. R&S 115187 -22- b. A reduction in residual VC from the slurry in PVC plants to one quarter of the current limitation. This would apply only to those qrades of resin which had not been produced by the plant on or before June 2, 1977. c. A reduction of VC emissions from oxychlorination reactors to 5 ppm from the present limit of 0.2 g/kg of EDC produced. This would apply only to reactors which were constructed after June 2, 1977. d. Outright prohibition of increases in emissions within a 5 mile radius of an existing source due to new construction. This would include plant expansions and new facilities. The offset provision* d. above, of the proposed regulation will have the effect of allowing no plant expansion without emission trade-offs. Industry's opposition to this provision of the proposed regulation and EPA's consideration of changes in its general carcinogen policy are apparently the major stumbling blocks delaying adoption of the proposed augmented regulation. The staff's view is that the trade-off provision is important and should be adopted immediately by the SCAQMD so that ambient levels of VC do not increase around present facilities. R&S 115188 R&S 115189 -23- Enforceability The NESHAP regulations for facilities using.or Droducing VC requires them to sample for, analyze, record, and report VC emissions and concentrations in the facility. In accomplishing this general objective, firms are required to do the following: a. Implement a VC leak detection and elimination program through means of stationary and portable in-plant monitoring. The levels are recorded and reported when levels of VC are found to be above the level defined as a leak. Programs for detection vary from plant to plant. b. Determine and report reactor opening losses from oxychlorination and PVC reactors. c. Determine residual VC levels in each batch of PVC ~ siUrry after It has been stripped. d. Monitor all exhaust gases that must meet l!:e 10 ppm VC limit and report VC levels over the limit. e. Record emergency releases from manual vent valves on PVC reactors and from relief valves. This information is required to be reported within 10 days after the occurrence. -24- The SCAQMD receives and reviews semi-annual reports with the above information included and has access to other records that are maintained for two years by the companies. The District can perform, when it deems necessary, plant inspections and/or source testing. 3U CO The requirements of the regulation are very detailed and cn complex; they necessitate constant surveillance by a -i (O o regulatory agency to ensure they are being complied with. More importantly, the federal regulation places no upper limit on the total mass emissions of VC from these facilities or the total amount of VC exhausted through stacks. These two shortcomings, along with what many view as too heavy a reliance on self-monitoring of compliance, combine to provide little assurance that comnunity levels of VC can be maintained at acceptably low levels under the federal regulations as they are now written. 1 -25- Estimates of Community Concentrations of Vinyl Chloride with the NESHAP Program Introduction In response to the Board's request, a preliminary study has been undertaken by the ARB Modeling Section to assess the air quality impacts from polyvinyl chloride (PVC) and vinyl chloride monomer (VC) plants in Los Angeles County on receptor areas in their vicinity, and to determine the probable degree of compliance of these facilities with the proposed ARB air quality standard for vinyl chloride when they come into full compliance with NESHAP emission standards. At the present time, four PVC or VC facilities are operating in the Lcs Angeles area. These are the .Keysor-Century PVC plant at Saugus, the B.F. Goodrich PVC and Stauffer Chemical Company PVC and VC plants at Long Beach, and the Union Carbide PVC plant in Torrance. The B.F. Goodrich and Stauffer Chemical facilities are located adjacent to one another on a north-south axis with the B.F. Goodrich plant to the south and Stauffer Chemical to the north. Emission estimates for these facilities were compiled by the ARB Enforcement Branch based on data supplied by B.F. Goodrich, Keysor-Century and EPA, and the following analyses were performed: o An evaluation of the effects of typical PVC and VC point sources on downwind receptors (point source releases are limited to 10 ppm in stack concentration by FDA NESHAP regulation). R&S 115191 -26- o An evaluation of the effects on adjacent receptors of the three of the four facilities described above using both point and area source emission estimates. 1. Study Methodology and Data Description Due to time constraints and the preliminary nature of the data gathered to date, it was decided that a Gaussian dispersion model was best suited for this study. Gaussian models incorporate the following assumptions: a. Steady state emission sources and wind fields b. Bimodal Gaussian distribution of pollutants vertically and horizontally c. No vertical wind shear d. Uniform vertical temperature stratification e. Flat or gently rolling terrain f. No aerodynamic downwash effects attributable to buildings g. Chemically inert pollutants h. Effective stack height based on Briggs' buoyant plume rise formula (1). The impacts from the PVC and VC facilities investigated here involve short range transport of a relatively inert pollutant from sources with little or no plume rise. Pollutant dispersion under these conditions should be well characterized by Gaussian type models. The only assumptions which might be questionable 1) No analysis was made of receptor sites near the Union Carbide facility. R&S 115192 -27- R&S 115193 are numbers e, f, and h. Assumption e, that the terrain is relatively flat, is satisfied at the Long Beach sites, but not at Saugus. This will increase the uncertainty of the results obtained for the Keysor-Century plant. The assumption that no aerodynamic downwash or building effects occur may also be incorrect for these facilities since the pollutants are emitted close to ground level. Downwash and building effects can be important at high wind speeds, but it is expected that the increased dilution of the pollutants under these conditions will offset whatever increases the aerodynamic effects might cause. Assumption h was tested by comparing both momentum and buoyant plume rise formulas using the point-source parameters provided for theflpBH^Mfffand * ^he two different formulations were found to coincide for a.lmdst all conditions tested to within a meter or two. In those cases where the two calculations differed significantly, the buoyant plume rise formulation was found to be the correct method of describing the height of pollutant release (2). The data used in this study were compiled by the ARB Enforce ment Branch and consisted of a point source inventory for the B.F. Goodrich and Keysor-Century plants, and estimated fugitive emissions for all three facilities based on EPA factors for R&S 115194 -28- typical PVC and VC facilities (3). These values were scaled according to plant production capacity. The staff was unable to obtain point source emission estimates for the Stauffer Chemical plant. Since the estimated point source emissions from the B.F. Goodrich plant were found to comprise approximately 0.5 percent of the total plant emissions, it was decided that a reliable estimate of the Stauffer plant impact could be made using only the value for the fugitive emissions. Point source emissions were also neglected for the B.F. Goodrich facility, except that one simulation using a point source having the maximum allowable vinyl chloride concentration of 10 ppm was run to assess the type of impacts expected from such controlled point sources. The data used in this study are listed in Tables IV-2 and IV-3. Preliminary runs to determine meteorology for cases corresponding to maximum one hour levels were made using the EPA Gaussian model PTMAX. This program computes the maximum downwind concentrations from point source emissions for a variety of wind speeds and atmospheric stabilities. The worst case meteorological conditions for each stability class were determined from these calculations and are shown in Table IV-4. The ARB program, HRSTAB, was then used to determine the typical stability-distribution in the Los Angeles area for a winter (January) and a summer (July) day with clear skies and low wind speeds. The stability distributions are also listed in Table IV-4. -29- Worst case meteorological scenarios were then formulated by combining the worst case meteorological conditions for each stability class and weighting them by their exoected frequency of occurrence in each 24-hour scenario. These meteorological conditions, combined with the point and fugitive source emissions, were also run using the EPA program PTDIS. PTDIS computes downwind concentrations from point source emissions at distances specified by the user. The fugitive emissions for each facility were treated as a uniformly distributed area source with a release height of 3m. The area of the Keysor-Century plant was assumed to be 100m x 100m, while the B.F. Goodrich and Stauffer plants were each assumed to be 120m x 120m. Area sources are treated by the use of virtual point sources in PTDIS. A virtual source of release for the area source emissions upwind from the actual location of the area source is specified such that thehorizontal spread of the virtual plume, characterized by the parameter o^, obeys the elation 0ysL/4.3 where L is the length of one side of the area source at the center of the area source. As described by Turner (4), this value of 0^ represents treatment of the area source as a crosswind line source with a normal distribution of pollutant about the center line of the plume. R&S 115195 -30- Values for the worst case meteorological conditions in Table IV-4 were run using PTDIS for each stability class represented in the 24-hour stability distributions for both winter and sunnier days. Seperate runs were,made for the point and area source emissions. These results were combined, using each stability type, to produce worst case 24-hour averages. Twenty-four hour average values were also computed for meterological conditions typical of the Los Angeles area. These conditions represent sea breeze meteorology during the day and drainage flow conditions (toward the ocean) at night. All these results are given in Table IV-5. In the case of the Keysor-Century plant, maximum 24-hour values representing worst case meteorological conditions for both the point source and the area source (fugitive) emissions were calculated. (The values calculated for the vicinity of the B.F. Goodrich and Stauffer plants represent worst case conditions for fugitive sources alone, because"point source contributions were assumed to be negligible, on the basis of the data currently available). 2. Results and Conclusions The results give in Tables IV-5 show that, under current conditions, the air quality impacts of controlled point sources (stack) are insignificant in relation to the impacts from fugitive sources, if EPA emission rates are assumed. The worst case 24-hour average vinyl chloride concentrations R&S 115196 R&S 115197 -31- predicted at the plant boundaries range from 0.316 ppm at Saugus to 1,18 ppm in the vicinity of the Stauffer and B.F. Goodrich facilities. For the more typical meteoroloqical scenarios, which include sea breeze and drainage flow conditions, these worst case values are reduced to 0.247 ppm at Saugus and 0.709 ppm at the Long Beach facilities. These values represent the best estimate that can be made at the present time, considering the uncertainty involved in estimating fugitive emissions from PVC and VC plants. There are several reasons to believe that these results represent upper limits on the concentrations actually to be expected. These reasons are: a. The EPA fugitive emissions estimate is conservative, since it is based on a mass balance calculation which does not specify loss mechanisms for vinyl chloride other than emission into the atmosphere. * b. Gaussian models tend to over-predict ground level concentrations. c. Wind directions were held constant over multi-hour averaging periods. -32- d. The release height assumed for the fugitive emissions is probably a lower limit for the actual release height. The following facts should also be considered when attempting to relate these predicted values to actual air quality measure ments. R&S 115198 a. Downwind concentrations fall off substantially with distance from the plant. For example, at 0.5 km down wind, the worst case concentration values calculated for the Long Beach facilities are approximately 0.1 to 0.2 ppm. b. Atmospheric concentration values depend linearly on the emission source strength. * c. Emission rates for fugitive emissions are probably of order of magnitude accuracy and are conservative,i.e., likely to be higher than actual, rather than lower. d. The assumed spatial and temporal uniformity of fugitive emissions is probably not correct. In addition, the release height of these emissions will vary from source to. source. -33- These results should, therefore, be considered order of magnitude estimates of the air quality impacts involved largely because of uncertainties in the emissions data available to the staff at the time the calculations were performed. Be fore any final results can be obtained, a more refined emissions inventory of these facilities should be conducted. The results of these preliminary calculations demonstrate that ambient levels of vinyl chloride in the vicinity of VC and PVC facilities are largely determined by fugitive emission rates. Stack emissions, even at the 10 ppm upper concentration limit allowed under NESHA contribute very little to the totals. Additional calculations corresponding to fugitive emission rates of 50% and 10% of the EPA estimates were carried out. These results are summarized in Table IV-6. These results lead to the conclusion that concentrations of vinyl chloride in the range suggested by the proposed significant harm level can be , achieved at all of the facilities studied even under the most unfavorable meteorological conditions, if fugitive emission rates can he reduced to about.0.5 Jca/hr (1.1. Ib/hr) and the proposed 5 ppm upper limit on VC concentrations in stack effluent.is pro mulgated. (These estimates apply to the comhined plants at the Long Beach location.) R&S 115199 -34- Table IV-2 Keysor-Century Source and Emission Data Point Source Height Temperature Source Strength Vol. Flow Rate 9.75m (32 ft.) 310 K (100F) 0 .289 g/sec (lOppm in stack) 11.81 m3/sec Area Source (fugitive)* Height 3m (9 ft.) Temperature ambient Source Strength 0 .797 -g/sec Dimensions 100m x 100m PVC Production Capacity 15 MM kg/year These emission strengths are based on EPA fugitive emission estimates of 3.61 g/sec (29 lb/hr) for a plant with produc tion capacity of 68MM kg/year (3). R&S 115200 R&S 115201 -35Table IV-3 B, F. Goodrich and Stauffer Chemical Source and Emission Data Point Source (BFG typical source) Height Temperature Source Strength Vol. Flow Rate 24.4m (~80 ft.) ambient 0.16 g/sec 3 6.6m /sec Area Sources (fugitive)* Height Temperature Source Strength Dimensions PVC Production 'Capacity VCM Production Capacity 3m ambient 2.68 g/sec (BFG) 4.06 g/sec (Stauffer) 120m x 120m 50MM kg/year (BFG) 70MM kg/year (Stauffer) 75MM kg/year (Stauffer) These source strengths are based on EPA emission estimates of 3.6 g/sec for a PVC plant with 68MM kg/year capacity and 1.2 g/sec (9.7 lb/hr) for a VC plant with 316MM kg/year capacity (3). V -36- Table IV-4 Worst Case Meteorology 30 fio and Stability Distributions W cn N3 No> Worst-Case Conditions For Point Source (Stack) Twoact (summer) No. of Hours Stability Windspeed (m/sec) 5 A1 4 B4 2 C4 1 D4 12 F* 1 Worst-Case Conditions For Area Source (Fugitive) Impact ,.Jio. of Hours Stability Windspeed (m/sec) winter 7 1 16 C2 D2 F* 1 summer 5 4 2 1 12 A1 B1 C2 D2 F* 1 For Long Beach F stabilities have been increased to E to account for the urban heat island effect --1 Table IV-5 Maximum 24-Hour Ambient Concentrations of Vinyl Chloride Under Various Weather Conditions (ppml Results for B.F. Goodrich and Stauffer Chemical 1 Hour Worst Cases for Area Source (Fugitive) Impact m onn> Stability Mind Soeedtm/sec) 1 1 2 2 1 STAUFFER Plant Boundary 0.1 fan 0.5 km 1.24 1.10 0:412 0.341 0.674 0.34 0.50 0.29: 0.22 0.62 0.050 0.070 0.060 0.090 0.220 B. F. 6 0 0 D RICH P lant Boundary Q.1 km 0.5 fan 0.817 0.724 0.271 0.225 0.444 0.224 0.329 0.191 0.145 0.408 0.033 0.046 0.040 0.059 0.145 24 Hour Worst Case Conditions For Area Source (Fugitive) Inpact (at the boundaries of the combined BFG and Stauffer facilities) 24 hour northerly flow typical meteorology* * davtlme recent.orS nlghtlme receptors winter 6TW n.lOfi ( R hnursl 0.709 (16 hours) summer TT8 n.fid? (}? hours! 0,532 (12 hours) s R&S 115203 I NOJ| R&S 115204 Table IV-6 Twenty - Four flour Worst Case Concentrations (ppm) for Reduced Fugitive Emissions at Long Beach (results at the combined plant boundaries) Meteoroloqical Conditions ' Season * 24 hour northerly flow winter summer 50% emission** reduction 0.459 0.590 90% emission** reduction 0.092 0.118 Typical winter Meteorology (daytime receptors)* summer Typical Meteorology winter (nightime receptors)*summer 0.098 (8 hours) 0.32 (12 hours) 0.355 (16 hours) 0.266 (12 hours) 0.020 (8 hours) 0.064 (12 hours) 0.071 (ifi hours) 0.053 (12 hours) tVIoIO These values are based on sea breeze meteorology during the day and drainage flow meteorology at night. The night of hours each receptor is exposed under these conditions Is given in parenthesis. Daytime wind direction is from the south, and nighttime wind direction Is from the north. Percentage reductions are scaled down from the EPA estimate of fugitive emissions from the corrbined facilities. If actual fugitive emission are lower than the EPA estimate, maximum ambient levels of VC would decrease to correspondingly lower values. References 1. G.A. Briggs, Plume Rise U.S. Atomic Energy Comission, 1969 2. R.H. Schultze, Notes on Diffusion Modeling Trinity Consultants, Dallas Texas, 1976, p.61 3. Point source emission estimates were supplied to ARB from B.F. Goodrich and Keysor-Century. Fugitive emission estimates were obtained from : EPA Supplement Document #28155, and plant production capacities were obtained from "Standard Support and Environmental Impact Statement: Emission Standard for Vinyl Chloride? EPA-450/2-75-009, October 1975, Table 3-3 4. D.B. Turner, Workbook of Atmospheric Dispersion Estimates EPA, Research Triangle^Park, 1970, p. 38. -41- C. Recent Ambient Vinyl Chloride Data The ARB monitored the vinyl chloride concentration in the ambient air at the Saugus School, located near the Keysor-Century plant, on 38 days from January 30 through March 22, 1978. The sampling period was 24 hours on 35 days, and 12, 16 and 20 hours on 3 days. On the three partial days, none of the sampled concentrations exceeded the minimum measurable concentration of 0.01 ppm. Four of the 35 days had 24 hour average values that reached or exceeded 0.01 ppm. (On those days 24-hour averages were computed by substituting one-half the detectable limit for those samples whose concentration was below the detectable limit*). On those four days the 24-hour average concen trations were 0.01, 0.01, 0.012, and 0.064 ppm. The maximum concentration observed was 0.18 ppm in an 8-hour sample on February 6, 1978 (1600-2400). Other sample concentrations above 0.01 ppm include: 0.05 for four hours, two 6-hour samples of 0.02, and a 4-hour sample of 0.012. All other samples were 0.01 ppm or less. In addition to the continuous monitoring several instantaneous "grab" samples were obtained in the vicinity of the three other Diants emitting vinyl chloride in southern California. On February 8, 1978, at approximately 1930 hours, two syringe samples were taken on 223rd Street, Long Beach immediately adjacent to the northern boundary of the Stauffer Chemical facility This procedure follows "Guidelines for the Evaluation of Air Quality Data", OAQPS No. 1.2 - 015, EPA, February 1974. However, in these cases more than 25% of the observations are less than the minimum detectable, and the Guidelines advise that no statistics should be computed. R&S 115206 R&S 115207 -42- and about'200 meters north of the B.F. Goodrich plant. The concentration of vinyl chloride in the samples was 0.375 ppm and 0,058 ppm. Weather conditions included rain with a southeast wind estimated at 5 to 10 knots. Three samples were obtained at approximately 1030 hours on the same day in the vicinity of the Union Carbide Company in Torrance. The concen tration of vinyl chloride from a sample taken on Prairie Avenue, west of the plant was less than 0.001 ppm. A sample from 190th Street, north of the plant contained 0.004 ppm. A sample taken at the Torrance Children's Center, approximately one-half mile north of the plant had a concen tration of 0.002 ppm. The wind was southwest at 1 to 2 mph. B.F. Goodrich - Stauffer Monitoring Results B.F. Goodrich and Stauffer Chemical are conducting a cooperative air monitoring effort in the vicinity of their facilities, in the Long Beach - Carson community and at several remote locations. These data were made available to the staff and are presented as received in the accompanying table (Table IV -7), Compared with the staff's modeling estimates, these levels are somewhat lower than might have been expected. A single notable exception to this is the value of 0.098 ppm (24-hour average) reported for the Long Beach site 3 miles southeast of the plants. A simultaneous measurement at the southeast comer of the Stauffer facility shows a much lower reading, so this result is all the more surprising. The companies have not been able to account for this discrepancy. 1 TABLE IV--7 B F GOODRICH CHEMICAL DIVISION STAUFFER CHEMICAL DIVISION VINYL CHLORIDE COMMUNITY MONITORING PROJECT 3/13/78 -43 R& s 115208 DATE 2/2/78 2/7/78 2/16/78 2/22/78 2/23/78 3/7/78 2/2/78 2/7/78 2/9/78 2/14/78 2/16/78 2/22/78 2/23/78 2/28/78 3/2/78 2/2/78 2/7/78 2/22/78 2/23/78 3/7/78 2/2/78 2/7/78 2/9/78 2/14/78 2/16/78 2/22/78 2/23/78 2/28/78 3/2/78 2/2/78 2/7/78 2/14/78 2/16/78 2/2/78 2/7/78 2/16/78 2/22/78 2/3/78 2/7/78 2/10/78 LOCATION 100 yds. NW of Source 11 l It N II VI H VI It VI (Fire Station) BFG Samples SE Corner of Stauffer Property M VI 1 VI Stauffer II M Samples ft n t VI It VI It * It w One Mile East in Carson Community II It 1 VI BFG It N Samples ft at Three Miles SE in Long Beach Community If l II n Stauffer M VI Samples II Vi 1 w VI H II VI II VI Eighteen Miles SE in Huntington Beach Community It M H N Stauffer VI t| Samples Thirty-eight Miles SE: in Mission Veijo BFG It H Samples - Colorado River Near Blyth, Calif. (BFG) Snowmass, Colorado (BFG) 11 " (3 hr. sample, BFG) VC(ppb) 6.2 13.0 8.9 10.3 10.4 8.9 28.1 N.D. 10.5 1.0 94.0 52.4 2.0 0.7 0.2 2.8 N.D. 0.6 0.2 5.9 3.9 N.D. 5.9 < 1.0 < 1.0 1.0 < 1.0 98.0 1.0 7.9 N.D. 0.6 < 1.0 0.5 N.D. 1.9 0.2 < 0.1 0.2 < 0.1 All samples collected continuously for 24 hours beginning at 6 A.M. on the date indicated. -44- Keysor - Century Monitoring Results The Keysor - Century Company monitored vinyl chloride concentrations in the ambient air at three sites in the vicinity; the Saugus School, the Mohawk Gas Station and the railroad station (see Figure 1). Sampling was performed daily on three 8-hour shifts from January 27 through March 22, 1978 except for approximately a dozen samples lost at various sites on various shifts because of malfunctions. Concentrations at or below 0.05 ppm are not detectable with the measurement system employed. Concentration values above 0.05 ppm were observed on twelve days during this time period. On each of those twelve days the concentration exceeded 0.05 ppm only on one shift at one of the three sites. Each of the three shifts had four of the excesses. Three of the values were at the Saugus School, four at the railroad station and five at the Mohawk Gas Station. Comparison of ARB and Keysor - Century Measurements at Saugus School The Saugus School was the only sampling site used by both the ARB and Keysor - Century. Keysor - Century reported values above the detectable limit of 0.05 ppm at the site on February 3 (0.09 ppm), February 19 (0.06 ppm) and March 5, 1978 (0.08 ppm). ARB reported no detectable values on February 3, or on March 5. The ARB did not monitor on Februai^ 19. 9? ^ cn 8 <0  -45- FIGURE 1 Keysor-Century and Air Resources Board Ambient Air . Sampling Locations Source: ARB Enforcement Branch R&S 115210 -46- On February 6, ARB recorded a concentration of 0.18 ppm for the time interval 1600 - 2400 hours, at the Saugus School. Keysor-Century reported a non-detectable level for that same time interval at Saugus School, but reported a simultaneous reading of 0.07 ppm at the Mohawk Gas Station. The staff has prepared a number of standard samples for analysis in the ARB's Haagen-Smit Laboratory, the Keysor-Century Laboratory and an independent referee laboratory. A comparison of results obtained by the three laboratories shows good agreement. This suggests that the discrepancy may be traced to the calibration standard currently in use at Keysor-Century. The staff is continuing to explore the reasons for this apparent lack of agreement. These recent data suggest that, even prior to full compliance with NESHAP, ambient levels of VC in the vicinity of these facilities are averaging well below the calculated levels based on the EPA's emission factor for fugitive emissions. The staff finds this result encouraging, in that it suggests that fugitive emissions of VC may be reduced to a level'that approaches that required under the proposed ambient standard when these facilities are in full compliance with NESHAP. Further reductions, if any, needed to meet the proposed ambient standard should be relatively easy to achieve. H ZSU S *U R&S 115212 APPENDICES Appendix 1 - Basic VC Monomer and PVC Production Processes Appendix 2 - Environmental Protection Agency - National Emission Standards for Hazardous Air Pollutants, Standard for Vinyl Chloride, October 21, 1976 (41 FR 46560) Appendix 3 - South Coast Air Quality Management District (SCAQMD) Rule 1005 - Emission Standard for Vinyl Chloride, Adopted September 14, 1977 Appendix 4 - EPA Proposed Rule for Vinyl Chloride, June 2, 1977 (42 FR 28154) Appendix 5 - ARB Method - Vinyl Chloride in Air (March 13,1978) Appendix 6 - Glossary - Appendix 7 - ARB Staff Report No. 78-1-1, Effects of Airborne Vinyl Chloride Appendix 8 - Public Hearing Notice R&S 115213 APPENDIX I Basic VC Monomer Production and Polymerization Processes Figures 1 and 2, taken from the reference below*, illustrate the basic elements and the flow of materials in the production of VC monomer and the production of VC polymers. Each step in the process may have associated with it pumps, compressors, agitators, columns, and similar apparatus common to the chemical industry, and these pieces of equipment must be considered as possible sources of VC emissions. The types, numbers and arrangement of such equipment will vary from plant to plant and are not shown on the simplified diagrams. Vinyl Chloride Monomer Production Nearly all vinyl thloride manufacture begins by either oxychlorination of ethylene or direct chlorination of ethylene to produce ethylene dichloride. In the oxychlorination process, ethylene dichloride is made by the reaction of air and hydrogen chloride (HC1) with ethylene in a catalytic process. . In the direct chlorination process, ethylene dichloride is made by the reaction of ethylene and chlorine. The crude ethylene dichloride produced by these processes is then purified by scrubbing, drying and fractionating as indicated in Figure 1. The purified ethylene dichloride then enters a cracking furnace, where vinyl chloride and HC1 are produced. The HC1 is then removed from the furnace and recycled to the oxychlorinator. *SRI International, Cancer Control Monograph: Vinyl Chloride. Prepared for National Cancer Institute (in press). R&S 115214 The fractionating column following the cracking furnace separates the residual ethylene dichloride from the vinyl chloride monomer. The ethylene dichloride is recycled into the purifying system and the monomer is transferred to storage. Polymerization Process As indicated in Figure 2, vinyl chloride monomer for the polymerization process is obtained from a storage tank. The storage tank is supplied from tank cars or from a monomer production facility at the same site. Although different types of polymerization processes are used, most PVC resin is produced by loading VCM, water, and other materials, such as emulsifying agents into polymerization vessels commonly called "reactors". The reaction proceeds under controlled conditions of temperature and pressure. After polymerization the mixture of resin and liquid, called "slurry", is transferred to the stripping device. (In some plants stripping is carried out in the reactor.) The stripping process, by the use of heat and reduced pressure, drives most of the unreacted monomer out of the slurry. The extracted monomer is introduced into the VCM recovery system where it is processed for recycling into the polymerization process. The stripped slurry is sent to a blending tank to be combined with slurry from other reactors, in order to obtain the desired product composition. From the blend tank the slurry enters a centrifuge where most of the water is removed. From the centrifuge the polymer enters a flash dryer which removes the remaining water. The dry polymer resin is screened and shipped, either.in bulk or packed in bags. 1 Recycle HC# FIGURE ] SIMPLIFIED "TYPICAL" PROCESS FOR PRODUCTION OF VINYL CHLORIDE MONOMER (VCM) Source: SRI International, Cancer Control Monograph: Vinyl Chloride. Prepared for National Cancer Institute (in press). R&S 1152 9LZSI4 S9U FIGURE 2. SIMPLIFIED "TYPICAL" POLYMERIZATION PROCESS \ Source: SRI International, Cancer Control Monograph: Vinyl Chloride. Prepared for National Cancer Institute (in press). APPENDIX 2 THURSDAY, OCTOBER 21, 187S PART II: 37 Co t.'.J.Jia ENVIRONMENTAL PROTECTION AGENCY - ' `* NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS Standard For Vinyl Chloride V * V* T \ 1C5C0 RULES AND REGULATIONS Till* 40--Protection of Environment CHAPTER I--EriVIR01MENTAL PROTECTION ACr.NCT are required to be captured and con trolled. JlLALTlt AND ENVIRONMENTAL IMPACTS SUBCKA.TCX C--Ain PROGRAMS EPA prepared a document entitl'd the IITL C1U-1] Quantitative Sisk Assess/rant for Corn- PART Cl--NATICNAL EMISSION STAND ARDS FOR HAZARDOUS AIR POLLUTANTS Stand arJ for Vinyl Chloride vminity Exposure to Vm..' Chloride which estimates the rLsl: from vinyl chloride exposure to populations living in toe vi cinity of vinyl chloride-omitting ) l.-iits On December 24, 1075, under section before and after implementation of con 112 of the Clean Air Act. as amended (42 trols to meet the standard. There arc no 0.S.C. 1C37), tlic Environmental Protec dose-response data for the concentra tion Agency (EPA) added vinyl chloride tions of vinyl chloride found in the am to the list or hazardous air pollutants bient air. Therefore, assessments of risk <40 lit 50477) and proposed a national at ambient levels of exposure were ex emission standard lor It (40 FR 50532). trapolated from dose-response data from The standard covers plants which manu higher levels of exposure using both a facture ethylene dichloride, vinyl linear model and a log-prohit model. chloride, and/or polyvinyl chloride. Extrapolations made with each of these EPA decided to regulate vinyl chloride models entailed using different sets of because it has been implicated as the assumptions. Because different assump causal agent of angiosarcoma and other tions can be made In extrapolating to serious disorders, both carcinogenic and low doses, the health risks are reported unncarcinogcnlc. in people with, occupa in ranges. tional exposure and in animals with ex It was estimated that 4.6 million peo perimental exposure to vinyl chloride. ple live within fi miles of ethylene dlcho- Reasonable extrapolations from these ride-vinyl chloride and polyvinyl chlo findings cause concern that vinyl chlo ride plants and that the average ex ride may cause or contribute to the same posure around these plants before instal or similar disorders at present ambient lation of controls to meet the standard air levels. The purpose of the standard is Is 17 parts per billion. The exposure to minimize vinyl chloride emissions levels lor uncontrolled plants were cal from all known process and fugitive culated based on estimated 1974 emis emission sources In ethylene dichloride- sion levels. Using the linear dose-re vinyl chloride and polyvinyl chloride sponse model. EPA found that the plants to the level attainable with best rate of initiation of liver angiosarcoma available control technology. This will among people living around uncontrolled have the effect of furthering the protec plants Is expected to range from less than tion of public health by minimizing the one to ten cases of liver angiosarcoma health risks to the people Uvlng in the per year of exposure to vinyl chloride. vicinity of these plants and to any addi The log-problt model gave predictions tional people who are exposed as a result that are 0.1 to 0.01 times this rate. This of new construction. wide range is an indication of the un Interested parties participated In the certainties in extrapolation to low doses. rulemaking by sending comments to EPA. Due to the long latency time observed in The comments have been carefully con cancer cases resulting from vinyl chloride sidered. and where determined by the exposure. Increases initiated by exposure Administrator to be appropriate, changes this year will not be diagnosed until the have been made to the regulation as pro- 1990's -or later.1 Vinyl chloride is also es mulgated. timated* to produce an equal number of Summary or nix Standam primary cancers at other sites, for a total of somewhere between less than one and In ethylene dlchlorlde-vinyl Chloride twenty bases of cancer per year of ex plants, the standard limits vinyl chloride posure among residents around plants. emissions from the ethylene dlehloride The number of-these effects is expected and vinyl chloride formation and puri to be reduced at least in proportion to the fication processes to 10 ppm. For the ox- reduction in the ambient annual average yehlorinatlon process, vinyl chloride vinyl chloride concentration, which is emissions are limited to 0.2 g/kg of ethyl expected to be 5 percent of the uncon ene dichloride produet. trolled levels after the standard is im In polyvinyl chloride plants, the stand plemented. ard limits vinyl chloride emissions from Changes In the standard since pro equipment preceding and including the posal do not affect the level of control stripper in the plant process flow to 10 required. Thus, the environmental Im ppm. Emissions from equipment follow pact of the promulgated standard Is. ing the stripper are to be controlled by with one exception, the same as that stripping dispersion resins to 2000 ppm. described in Chapter 6 of Volume I of and other resins to 400 ppm, or by using the Standard Support and Environmen equivalent controls. Vinyl chloride ends- tal Impact Statement. According to data slons from reactor opening are to be re submitted by the Society of Plastics In duced to 0.03 g/kg polyvinyl chloride dustry, Inc. (SPI), the impact on water product. consumption in the draft environmental In both ethylene dlchlorlde-vinyl impact statement was overstated. In es chloride and polyvinyl chloride plants, timating the impact on water consump relief valve discharges and mnnunt vent tion, EPA baaed Its estimates on worst ing of gases are prohibited except under case conditions. That Is, EPA assumed emergency conditions. Fugitive emissions that those control systems with the greatest water usage would be employed and that there would be no recycling of water. There h no regulation which would require water recycling. Accord ing to SPI, the control system utilizing the most water will not be used gener ally by ttic Industry and economic fac tors will cause plants to recycle much of the water. Therefore, according to SPI the impact of the standard on water consumption will be negligible. The environmental Impacts of the promulgated standard may be summar ized as follows: The primary environ mental impacts of the standard are ben eficial and will consist of vinyl chloride emission reductions of approximately 94 percent at ethylene dlchlorlde-vinyl chloride plants and SO percent at poly vinyl chloride plants. Percentage num bers for both source categories are based on an estimated 90 percent reduction in fugitive emissions and 1974 emission levels. The potential secondary environmen tal impacts of the standard are either insignificant or will be minimized with out additional action, except lor one ad verse impact. Hydrogen chloride is al ready emitted by process equipment at ethylene dlchlorlde-vinyl chloride plants and by other petrochemical plants in the complexes where ethylene dlchlorldevinyl chloride plants are typically lo cated. An incinerator used to attain the standard at an ethylene dlchlorlde-vinyl chloride plant could increase hydrogen chloride emissions by several fold. Typi cally. however, due to the corrosion prob lems which would otherwise occur both on plant property and in the community, plants use scrubbers to control already existing hydrogen chloride emissions. Hydrogen chloride emissions resulting from control of vinyl chloride emissions are expected to be controlled for the same reason. If even a moderately effi cient scrubber (98 percent control) were used to control the hydrogen chloride emissions resulting from incineration of vinyl chloride emissions, the Increase In hydrogen chloride emissions from a typ ical ethylene dlchlorlde-vinyl chloride plant due to the standard would be re duced to 35 percent. However. EPA plans to further evaluate the need to control hydrogen chloride emissions, since dif fusion model results indicate that under "worst-case" meteorological conditions, the hydrogen chloride emissions from the process equipment and the incinera tor combined would cause maximum am bient concentrations of hydrogen chlo ride hi the vicinity of ethylene dichlo ride-vinyl chloride plants to be in the same range or somewhat higher than existing foreign standards and National Academy of Sciences (NAS> gtiidrtines for public exposure. Economic Impact In accordance with Executive Order 11821 and OMB circular A-107. EPA carefully evaluated the economic and inflationary impact of the proposed standard and alternative control levels and certified tills in the preamble to the proposed standard. These Impacts are KOftAl UCIIUS, VOL 41. NO, JOS--THURSDAY, OCTOtil II, IV76 DO fi8 V) tn IO 1 RULES AMD REGULATIONS IfiGSl discussed In Chapter 7 or Volume I of Act. a public hearing was held on the the Standard Support end TXviron.Tr.cit~ proposed standard on February 3. 197G. tel Impact Statement. Comments on the In v/ashlngtun. D.C. Presentations were proposed ilanclard have resulted In only made by the Environmental Defense one major change in the economic im Fund, the Society of the Plastics Indus pact analysis. EPA estimated that there try. Inc., Dow Cl:""''cal Company. Dia would be lour plant closures as a result mond Shamrock Coriioratlon, and Air ol the promulgated standard. O! the lour Products and Chemicals. Inc. Comes of plants identified as possible closure can the comment letters received, the public didates. one has Given notice that It no hearing record, and a summary of the longer produces polyvinyl chloride and comments with EPA's responses are the other three have Indicated that they available for public inspection and copy do not Intend to close ns a result of the ing at the EPA Public Information Ref standard. erence Unit, Room 2922 (EPA Library), The economic Impacts of the promul 401 M Street, S\V, Washington. D.C. In gated standard may be summarized os addition, copies of the comment sum follows: The total capital cost for exist mary and Agency responses may be ob ing plants to meet the standard Is esti tained upon written request from the mated to be $198 million, of which $15 Public Information Center (PM-215). million is lor ethylene dichlorlde-vinyl Environmental protection Agency, 401 chloride plants and $183 million is lor M Street. SW. Washington, D.C. 20400 polyvinyl chloride plants. EPA estimates (specify Standard Support and Environ that these plants will have to spend $70 mental Impact Statement, Emission million per year to maintain the required Standard for Vinyl Chloride, Volume II). emission levels. In addition, the total capital cost for existing plants to meet the EPA's 1983 water effluent guideline SlGHinCAMT COMMENTS AND ClTANGES TO thx Ptoroszr Regulation limitations Is expected to be $33 million (I) Decision to list vinyl chloride as a and the total annualized operation cost hazardous air pollutant. In general, the Is $17 million. The costs to the industry commenters did not contest EPA's deci of meeting the OSHA standard cannot be sion "jo list vinyl chloride as a hazardous quantified at this time, but they are ex air pollutant. However, three comment- pected to overlap to some degree with the era (two companies and one Federal costs to meet EPA's fugitive emission agency) argued that EPA placed undue regulations. The costs of meeting the emphasis on factors suggesting that vinyl fugitive emission regulations are included chloride presented a health risk and in the total costs cited above for meeting Ignored factors suggesting that no sig the promulgated regulation. Broken out nificant risk was Involved/Under section separately, the capital cost of meeting 112, however. EPA could remove vinyl the fugitive emission regulations Is $37 chloride from the list of hazardous air million and the annualized cost 1$ $25 pollutants only if information were pre million. sented to EPA that shows, that vinyl The standard is not expected to deter chloride is clearly not a hazardous air construction of new ethylene dlehlorlde- pollutant. As discussed more fully In the Tinyl chloride plants or most types of comment summary, the commenters did new polyvinyl chloride plants. For one not provide conclusive evidence that vinyl type of polyvinyl chloride plant (disper chloride Is not a hazardous air pollutant sion process) that represents 13 percent which causes or contributes to death or Of the industry production, the standard serious illness, nor did they conclusively would significantly deter the construe-, prove that the health risk factors em tlon of smaller plants. phasized by EPA were insignificant. It is estimated that the price of poly Several, other commenters agreed with vinyl chloride resins will rise by approxi EPA's decision to list,vinyl chloride as a mately 7.3 percent in order to maintain hazardous air pollutant, but argued that precontrol profitability and also to re EPA had overstated the health problem, cover the total annualized control costs, the emission levels, and the projected necessitated by the standard at ethylene ambient air concentrations around un dichlorlde-vinyl chloride plants and poly controlled Plants. With regard to the al vinyl chloride plants. This Increase Is leged overstated health problem, the estimated to translate Into a maximum commenters stated, for example, that the consumer price increase in goods fabri U.S. worker EPA discussed as having cated from polyvinyl chloride resins of been exposed to vinyl chloride levels low approximately 3.5 percent Recovery of er than those usually encountered in effluent annualized costs plus mainte polyvinyl chloride production has been nance of precontrol profitability Is esti dropped from the National Institute of mated to add approximately 2 percent to Occupational Safety and Health's listing polyvinyl chloride resin prices and result of workers with angiosarcoma. EPA In an additional maximum consumer agrees that there arc questions concern price Increase of 1 percent ing the level of exposure and in some Public Paxticifatiok cases the pathology of these cases not involved directly in polyvinyl chloride During the public comment period. 50 and vinyl chloride production. These un comment letters on the proposed stand certainties arc stated In the appropriate ard were received. There were 24 from footnotes of the Scientific and Technical mdusti7; 3 from environmental groups; Assessment Deport on Vinvl Chloride and 15 from Federal. State, and local agen Polyvinyl Chloride (STAR) where the cies; and 8 from Individual cittsens. As angiosarcoma eases ate listed. However. required by section 112(b) (1) (B) of the In spite of these uncertainties. In view of the possible exposure patterns, these coses cannot be Ignored In the e\ luuav.on of the potential public health problems. With recard to the alleged overstated emission levels, the uncontrolled emis sion levels reported by EPA were based on 1974 .data. This qualification was stated wherever emission data were pre sented. IFA rccoznhcs that emissions have been reduced since that time, and stated this In the preamble to the pro posed standard. EPA decided not to gather more recent data on emission levels, because these emission levels are expe-ted to change, and gathering the data would take considerable time both on the part of EPA and on the part of Industry. Since the purpose of the stand ard Is to minimize emissions, these more current data would not effect the stand ard itself. The 1974 emission levels were also used in diffusion modeling to project maximum ambient air concentrations around uncontrolled plants. These maxi mum air concentrations would probably be lower If 1976 emission levels were used. This would reduce the relative Impact of the standard below that described in the Standard Support and Environmen tal impact Statement, but would not alTect the basis of the standard Itself. (2) Approach tor Regulating Vinyl Chloride Under Section tit. Two ap proaches other than using best avail able control technology were suggested by the commenters for regulstinz rinyl chloride under section 112. The first was to ban polyvinyl chloride products for which substitutes ore currently available and to gradually phase out other poly vinyl chloride products os substitutes are developed. In the preamble to the proposed stand ard EPA specified Its reasons for not set ting a zero emission limit for vinyl chloride, as follows: (1) There are bene ficial uses of vinyl chloride products for which desirable substitutes are not read ily available; (2) there are potentially adverse health and environmental im pacts from substitutes which have not been thoroughly studied: (3> there are a number of employees, particularly In the fabrication Industries, wh would be come -` least temporarily unemployed: and (4> control technology Is available which Is capable of substantially reduc ing emissions of vinyl chloride Into the atmosphere. EPA agrees that substitutes do exist or could be manufactured for most poly vinyl chloride uses. However, In general, these substitutes do not have some of the more drslrable characteristics of poly vinyl chloride, such as nonflsmmablllty. If vinyl chloride and polyvinyl chloride were banned, other substitutes with these more desirable characteristics would likely be developed. There is a risk that these substitutes would also havo adverse health or environmental effects. Since control measures are available which c.ui reduce vinyl eldoride emis sions by 90 percent or more. It does not seem prudent to reduce emissions by the remaining percentage and take Uic risk of Introducing new untested chemicals Into the environment, 4 R&s 115219 EEDESAl RECISTCB. V t. 4*. NO JOS--THuriDAV, OCTOBER >1. IVTA / .105C2 RULES AND REGULATIONS Another reproach eiivgcal'/d by the capacity of no more than 0.10 m* <50 venting will be permitted as a lust report (ommcntcrs wis to bate the tlr.T.dard lor gal;. Reactors In this size range can gen before the relief valve opens. The same r:\r.h ludMd'rJ emtrlfm rwhit on cost erally bo found In a laboratory, whereas notification procedures are required for icr.OLS bcr.i'fit, Several of '.hr fugitive the larrcr reactors are typically pilot manual vtniirv: to the atmosphere ?r ar* emPaion rouice* were namcu ipcclAcally scale facilities. EmLrdons from labvralory required for relief discharges. as onu lor which the co.ts of control scale equipment arc relatively small. and There are several changes In the nu r.crc substantially higher than the bene- application of the controls required by merical cmivaion limits in the promul (Its. Although EPA did determine a cost- the standard would lie expensive inti im gated slimsard. Except for the standard benefit ratio for the controls required practical. EPA also decided to exempt re for reactor opening ices, these changes tor a number of emission points. EPA search and dev ' patent faciliUve con simply involve conversion to the Interna docs not believe such a ratio Is an appro taining reactors greater than C.10 m* (50 tional System of Units (SI). There was priate bn.'is on which to set a standard. gal/ and no more than 4.07 m* (1100 gal) an error involved in the original calcula Section ill of the Clean Air Act provides in capaclty.from nil parts of the standard tion used to derive the standard for re.'.c- for the development of standards based except the 10 ppm limit for reactors, tor opening. Correcting this error dou on best control technology (considering strippers, monomer recovery systems, and bles the allowable emissions. It Is em costs). Even under section 111. however, mixing, weighing and holding containers. phasized that the change In this stand standards are sot based on a fisc bal- EPA decided not to require these facili ard Is a correction, and not a change in - aucing of costs versus benefits. Instead, ties to meet other ports of the standard the Intent for the degree of control re costs are considered in terms of the af because of the technical problems in quired. fordability of the control technology re volved in doing so. For example, the The proposed standard required the quired to achieve a given emission level standard for reactor opening is based In Installation of a rupture disc beneath and the economic Impact of possible part on reducing the frequency of open each relief valve to prevent leakage from standards on the Industry In ques ing the reactor. Research and develop the relief valve. A provision has bten tion. Unlike section 111. section 112 does ment reactors have to be opened after added to the promulgated standard so not explicitly provide for consideration of costs, so It would clearly he Inappro every batch for thorough cleaning. Also, stripping technology Is developed Indi that a rupture disc Is not required II the relief valve is tied into a process line priate to consider costs to a greater ex vidually for each resin In research and or recovery system. In this case, any tent under section 112 than would be development equipment Therefore, at leakage from the relief valve would be done under section 111. As discussed in the preamble to the proposed standard for vinyl chloride, SPA believes costs may be considered under section 112, but only to a very limited extent: Le. to assure that the costs of control technol ogy are not grossly disproportionate to the amount of emission reduction achieved. In comparison with other emission points, the costs of controlling the fugitive emission sources mentioned by the commenters are relatively small compared with the amount of emission reduction achieved. _ several commenters recommended addlnr to the regulation a provision for excess emissions during startup, shut down. and malfunction. EPA considered this comment, and decided that this addition is not necessary for the vinyl tainment of the stripping limitations in the research and development equipment would not always be possible. The 4.07 m*' (1100 gal) figure was selected os an upper cut-off point because there are no commercial reactors smaller than this. (4) emission limits. The only major change in the emission limits between proposal and promulgation is the addi tion of a provision for emergency manual venting of vinyl chloride from reactors to the atmosphere. The proposed stand ard prohibited all manual venting to the atmosphere. In the preamble to the pro posed standard. EPA Invited Interested persons to comment on whether permit ting manual venting to the atmosphere could result in overall lower emissions. There ore several methods available tor preventing relief discharges from reac contained. The regulation for obtaining vinyl chloride samples has been changed to an operating procedure. The proposed standard stated that there were to be no emissions from taking the samples. Several commenters pointed out that the use of the word "no" would make this regulation impractical to enforce. There fore. the promulgated standard specifies the operatine procedure which EPA orig inally Intcixled to be used to control this source. This revision Is only a change In wording and does not represent a change in the level of the standard. The regulation for taking samples has also been revised to apply only to sam ples containing at least 10 percent by weight vinyl chloride. This Is consistent with the other parts of the standard Chloride standard. Startup and shutdown of the process has essentially so effect on emissions to the atmosphere for poly... vinyl chloride production, and technology tors, one of which Is manual venting of part'of the Reactor contents for purposes of eoollng and reduction in pressure within the reactor. The higher the tem which apply to equipment. "In vinyl chloride serriee."*Tn vinyl chloride serv ice" distinguishes -between situations where vinyl chloride Is clearly Involved exists to avoid excess emissions during perature and pressure within the reac and situations where vinyl chloride Is a startup and shutdown at ethylene di- tor. the greater the amount 'of vinyl minor component or contaminant, and Chloridevtnyl chloride plants. We do not chloride which has to be removed to as defined tn promulgated |6l.0l(l) believe plants should be allowed to emit bring the reaetor under control. Manual means that a piece of equipment con excess emissions during malfunctions, venting can be done at a lower pressure tains or contacts either a liquid that is and therefore are requiring them to shut than the pressure required to open the at least 10 percent by weight vinyl chlo down Immediately. relief valve. For this reason manual vent* ride or a gas that Is at least 10 percent (3) Selection of source categories. In' `Ing can result In lower emissions than by volume vinyl chloride. the preamble to the proposed standard would occur by allowing the reactor to Tho proposed standard required a vinyl EPA recognised that some small research discharge through the relief valve. Fur chloride monitoring system tor continu and development facilities may, exist thermore, a manual vent valve is under ously measuring vinyl chloride levels both where the emissions of vinyl chloride are the control of an operator and can be within the plant (for leak detection) and insignificant and covering these facilities closed. A relief valve may become clogged within stacks. The proposed standard did under the standard would be unnecessary with resin and not close. The result not outline required specifications forjhe and Inappropriate. However, EPA did not would be loss of all the reaetor contents. monitoring system, except that It was to have sufficient Information available to The contents of a reactor can be man analyze the samples with gas chromatog clearly define which facilities should be ually vented to a gasholder or other hold raphy, or If all hydrocarbons were as excluded from the standard, and ing veasel. However, in some cases, such sumed to be vinyl chloride, with Infrared encouraged interested parties to submit ns durtng severe weather conditions, sev spectrophotometry, flame Ion detection, such Information during the comment eral reactors may be out of control at or equivalent. It required that each plant period. Based on the Information sub one time. There would be Insufficient submit a description of Its monitoring mitted. EPA decided to exempt poly holding capacity under these conditions system to EDA. so that EPA could deter vinyl chloride reactors and associated equipment from applicability of all parts to manually vent the contents of all the reactors to a gasholder. Therefore, when mine whether It was acceptable or not. Comments wens received indicating a need for EPA to specify some criteria for of the standard If the reactors are used all other measures to prevent reller valve Judging the acceptability of monitoring In research and development and have a discharges have been exhausted, manual systems. The accuracy of the monitor- KDEKAL MfilStn, VOL. 41, NO. 10$--1HUSSOAT. OCTOSft It, IV* R&S 115220 ~- >**.-W, RULES AND REGULATIONS Inc system would be related to the fre (g)(3)(H). and cl.70*e)(2)(D so that made the same as for other resins and quency of calibration. Therefore, EPA measurement of the vinyl chloride levels others requested that they be made less lias included in Lhc promulgated stand In the resins Is to be made immediately stringent. EPA decided not to make the ard requirements for the frequency of after stripping Is completed rather than standard for stripping dispersion resins calibration and procedures to be carried as the resin Is being transferred out of the same as for other resins because there out in the calibration of tlie moiutorlnc the stripper. This oliov." a plant to carry is sufficient evidence to indicate that instruments. The portable hydrocarbon detector re- o\it operations In a stripper alter strip these resins arc more difficult to strip ping has been completed but before it Is than other resins. With regard to mak uuired by the proposed Ktandand was re transferred out of the stripper. Tnis Is ing the stripping levels for dispersion quired to have a sensitivity of 5 ppm. consistent with the original intent of the resins less stringent, only one of the eight Comments were received indicating that standard. manufacturers of dispersion resins spe Instruments lzi this sensitivity range arc The regulation for loading and unload cifically commented that the dispersion 37 delicate and require continuing mainte ing lines In SGl.GSfbKl) has been re rosin standard should be made less nance. The portable hydrocarbon detec vised to clarify that it applies only to stringent Only two of several grades of CO tor is required for leak detection and for lines that are disconnected after each dimension resins made by this company measuring vinyl chloride concentrations loading or unloading operation. Perma caimot meet the 2.000 ppm limit. Tire inside the equipment before opening It. nently installed pipelines that are opened proposed standard takes Into considera A S pjfm sensitivity Is not needed In Infrequently for inspection or mainte tion that some resins are more difficult either case, and the required sensitivity nance, for example, are covered by the to strip than others by providing for has been changed to 10 ppm In the pro opening of equipment regulation rather averaging among different resins. mulgated standard. than the loading and unloading line (5) Testing) reporting, end record- The proposed standard contained a regulation. keeping. There are several relatively single regulation for compressors. The The regulation for lnprocess waste- minor changes In the testing, reporting, promulgated standard has separate regu water In the proposed standard could and recordkeeping requirement*. A pro lations lor rotating and reciprocating have been misinterpreted to require In vision has been added to I 61.67 which compressors. This Is consistent with hav dividual treatment of wastewater requires that stack gas camples taken ing separate regulations for rotating and streams. Section 61.65(b) (0)(1) at the with Test Method 106 are to be analyzed reciprocating pumps m both the pro promulgated standard clarifies that within 34 hours. This Is consistent with posed and promulgated standards. wastewater streams that are required to the requirements in the proposed Test Section 61.66 of the proposed standard be treated (l.e,, those containing greater Method 106. The promulgated standard provided for the use of equivalent meth th'm 10 ppm vinyl chloride) can be com also specifies that in aversping the re ods of control which hare been approved bined to be treated. However, waste- sults of the three runs required by Test by EPA. The promulgated standard re water streams that contain greater than Method 106, a time-weighted average is quires that the plant owner or operator 10 ppm vinyl chloride cannot be com to be used. ' submit a request for determination of bined with wastewater streams that con One commenter requested that the equivalency within 30 days of the pro tain less than 10 ppm vinyl chloride be oxygen content and moisture content be mulgation date If the alternative control fore treatment; leTM dilution cannot be specified for the 10 ppm concentration method is intended as the Initial means used to meet the standard. standards. The proposed standard speci of control. The purpose of this Is to pro The commcntexs recommended several fied that the vinyl chloride concentration vide time for EPA to evaluate the method changes in the emission limits which Is to be corrected to 10 percent oxygen before the plant has to be In compliance have not been Incorporated Into the (wet basis) If combustion Is used as the (for existing sources, SO days after the promulgated standard. These are dis control measure. In the promulgated promulgation date). EPA also suggests cussed in the following paragraphs. standard, this requirement has been ex that this request for determination of Zt was recommended that the require panded to all control measures. equivalency be accompanied by a re ment tor double mechanical seals on A provision has been added to the quest for waiver of compliance pursuant pumps, compressors, and agitators be re promulgated standard which states that to section 112(e) (1) (B> Cll) at the Act moved because the single seals currently if a reactor 1$ also used as a stripper, the The request for a waiver far compliance used on this equipment have small emis reactor opening emissions may be deter should provide for the case where EPA sions and are more reliable than double mined immediately following the strip determines that a method Is not equiv mechanical seals. SPA Is aware that each ping operation. If a reactor Is also used alent and 'the plant needs to purchase fugitive emission source, such ns one as a stripper, the resin is in the reactor other equipment - In no ease will the pump, taken by Itself causes relatively when It Is opened. This means that vinyl waiver of compliance be extended beyond small emissions. Fugitive emissions con chloride In the resin which has already two years from the date of promulga sidered as a whole are a significant been stripped to acceptable -levels can tion. source of emissions, however, sad the In esc o from the resin and become part Them are severe! wording clarifica tent of the standard Is to reduce these. of the reactor opening loss. It Is EPA's tions which have been made In the pro Double mechanical seal pumps are com Intent that once a resin has been stripped mulgated standard. The definition for monly used in the industry for emission to the required levels, that additional "In vinyl chloride service" ({60.61(D) reduction. Sealless pumps or equivalent controls are not required. Under the new has been clarified by stating that It systems are available as options to double provision, vinyl chloride escaping from means equipment that contacts vinyl mechanical seals. the resin after It has been stripped to chloride as well as equipment that eon- The commenters recommended In acceptable levels Is not counted os part tains vinyl chloride. This would include creasing the averaging time for the 10 of the reactor opening loss. such equipment as agitators. ppm limits and the emission limits for A section requiring continuous moni Words have been added in || 61.63, 61.63, and 61.64 to clarify that the 10 ppm emission limits do not have to be met when equipment has already been opened m compliance with the regula tion for opening of equipment. Equip ment that has met the opening of equipment regulation can contain more Ilian 10 ppm vinyl chloride and would be m violation of the standard If this statement were not Included. The requirements for stripping poly vinyl chloride resins to specified levels reactor opening and stripping to 30 days. Some of the eommenters apparently thought that the 10 ppm limits had to be met on an Instantaneous basis. However, since the performance test for determin ing compliance consists of three runs for a minimum of an hour each, the aver aging time for the 10 ppm limit Is at least three hours. Increasing the averaging time to 30 days lor any of the emission limits would permit higher peak emis sion levels. EPA has determined that this Is neither desirable nor necessary. Some commenters requested that the toring of stack emissions has been added to the promulgated standard. The con tinuous monitoring of stack emissions was required in the proposed standard. The addition of a specific paragraph for emission monitoring serves only to clarify the requirement. The standard has been revised so that the Initial report requires a "description" rather than a "detailed description- of the equipment used to control fugitive emissions. Severn! commenters pointed out that a detailed description would com..in proprietary information.. KI'A have been revised In If 61.64(c), *1.67 stripping levels for dispersion resins be agrees that a detailed description to the FEDERAL irCISTi*. VOt. SI, NO. SOS--THURSDAY, OCTOBER 31. TV/* R&S 115222 4&A RULES AND REGULATIONS report is unnecessary. If wldl- In section 6.4 of Test Method 106 toe (2) vinyl chloride by any process, information Is needed, El'A cut requirement for an automatic integrator ftnd/cr oV~\In It under section 114 of too Act and has been replaced with a requirement for (3) One or more polymers containing tij*, ;iVmt can request confidential treat a disc integrator or planimcLcr for meas any fraction of polymerized vinyl chlo ment la accordance with 40 CIT. Part 2 uring ptnk area. Tlds change Is in re ride. for Information It believes to be sponse to a comment which slates that <1>> This subpart does not apply to proprietary. Tno proposed standard required that automatic integrators ore unnecessarily elaborate and expensive. equipment used in research and develop ment ir the reactor used to polymerise a semiannual report be submitted every A new section 6.5 has been added to the vinyl chloride processed In the equip ICO days. Tire promulgated standard Test Method 10C which requires deter ment has a capacity of no more than specifies dates for the submittal of the mination of the water vapor content of 0.19 m* (50 gal). reports. It also specifies that the first toe sampling bag by measuring toe am (c) Sections of this subpart other than semiannual report does not have vo bo bient temperature and pressure near toe ! 61.54(a) (1), (b), (c). and (d> do not submitted until at least sU months after bag. ThO vinyl chloride concentration of apply to equipment used In research and the initial report Is submitted. the bag can then be reported on a dry development if the reactor used to po The standard has been revised to elim basis. A provision for checking toe rigid lymerize the vinyl chloride processed in inate tlie requirement to record the cause container for leaks has been added to toe equipment has a capacity of greater of any leak detected by the vinyl chlo section 7.4 of Test Method 105. than 0.19 m* (50 gal) and ho more than ride detector, the action taken to repair The only change In Test Method 107 Is 4.07 m' (1100 gal). the leak, and the amount of time re the provision In Section 5.3.2 for use of 61.61 Definition*. quired to repair the leak. EPA is con C&rbopak C as well as Carbopak A. cerned only that leaks are detected and repaired. That this has been done can bo Aothokitt: Section 113 ot the Clean Air Act *4 added by sec. 4(a) of Pub. U 61-604. established by looking at the strip chart M 8tat 1GSS (43 VjC. 18570-7; Section 114 record of measurements made by the or the Clean Air Act, as added by sec. 4(n) vinyl chloride detector. These records are still required for the portable hydrocar bon detector however. - Several commentators recommended that tbe companies be allowed an extra two weeks to submit to EPA data from the initial performance teat They also ot Pub. I- S1-6M, 04 Stat. 1687. and amended by Pub. L. 63-316. M. 6(a) (4). 88 Stat. 259 (43 U.S.C. 1857C-6); Section 831(a) or the Clean Air Act. as amended by eee. 15(c) (3) of Pub. I- 81-004. 34 Stat. 1713 (43 CS.C. 16573(a)). Dated: October 12,1976. recommended that they submit the data by regular mall rather than registered John Qoaklxs, Acting Administrator. ma!L EPA has not adopted either of these recommendations. A source Is supposed to be in compliance with the standard within 90 days of the promulgation of the standard. The standard requires that the emission testa be done within the SO day period, and permits on extra 30 days for determination of results. The Part 61 of Chapter I. Title 40 of toe Code of Federal Regulations is amended ' as follows: The table of sections for Part '61 Is amended by adding a list of sections for sew Subpart F and Part 61 is mended by adding a new Subpart P reading os follows: purpose of using registered mall is to P--Nettaoal Emission SUnderd lor vinyl document the fact that emission data have been sent and received. This way See. 61A0 Chloride Applicability, If the results are lost in the mail, there 6101 Definitions win be no question that they were sent 6102 Emission standard for ethylene di- (6) Test method. Test Method 106 has chlorldo plants. -been changed to recognize that on a gas 6103 XmtraXm standard for vinyl chloride chromatograph equipped with a Chromosorb 102 < column, acetaldehyde may. 6104 Interfere with the vinyl chloride peak. When a sample is expected,to contain 103 plants.' Emission standard for polyvinyl chlo ride plants. emission standard for ethylene dlchloride, vinyl chloride and poly acetaldehyde, a secondary column as de vinyl chloride plants. scribed in section 4.3.2 must be employed. 6106 Equivalent equipment and procedures. Mass spectroscopy or another absolute 6107 Emission tarts. analytical technique is required to eonfirm the vinyl chloride peak obtained with the gas chromatograph, only If peak resolution with the secondary column Is 6106 Emission monitoring. 109 Initial report. 61.70 Semiannual report. 1.71 Becordkeeptng. ~~ not successful. In section 4.1.4, aluminized Mylar bags can be substituted for Tedlar bags. EPA now has data to allow this substitution, provided that the samples are analyzed within 24 hours of collection. Aosuuairr; Section 113 of the Clean Air Act as added by see. 4(a) of Pub. L 81-634, 64 Stat. 1635 (43 TX.S.C. 18S7C-7); section 114 of tbe Clean Air Act. os added by sec. 4(a) of Pub. X- 81-634. 84 Slot. 1087, and amended by Pub. L. 63-318. see. 6(a) (4). 83 Slat. 359 (43 U.S.C. 18570-6); section 301(a) of the In section 5.1.3 of Test Method 106 Clean Air Act, as amended by see. 15(e) (3) the requirement to use "oxygen gas" has Of pub. L. 01-604, 84 Stat. 1713 (43 P.S.C. been replaced with "oxygen gas or air, as 1857g(n)). required by toe detector." Several corn- Subpart F--National Emission Standard mentors stated that most gas chromato for Vinyl Chloride graphs are designed to use hydrogen and air for their flame detectors. When used S 61.60 Applicability. In tots way, they are capable of detect (a) This subpart applies to plants Terms used In this subpart are defined In the Act, In subpart A of this part, or In this section os follows: (a) "Ethylene dichloride plant" In cludes any plant which produces ethyl ene dichloride by reaction of oxygen and hydrogen chloride with ethylene. (b> "Vinyl chloride plant" Includes any plant which produces vinyl chloride by any process. (c) "Polyvinyl chloride plonV Includes any plant where vinyl chloride alone or in combination with other materials is polymerized. ` (d) "Slip gauge" means a gauge which has a probe that moves through the gas/ liquid Interface In a storage or transfer vessel and Indicates the level of vinyl chloride tn the vessel by the physical state of the material tbe gauge dis charges. (e) "TVpe of resin" means the broad classification of resin referring to the basic manufacturing process for produc ing that resin. Including, but not limited to. the suspension, dispersion, latex, bulk, and solution processes. , (f) "Grade of resin" mean&fhe sub division of yesin classlfication which de scribes it as a Unique resin. le,, tbe roost exact description of a resin with no fur ther subdivision. (g) "Dispersion resin" means a resin manufactured in such away as to form fluid dispersions when dispersed in. a plasticizer or plastlcfxer/dJlueat mix tures. (h) "Latex resin" means n resin whleh is produced by a polymerization process which initiates Irom free radical catalyst altos and is sold undried. U> "Bulk resin' means a resin which is produced by a polymerization process in which no water is used. tj) "Inprocess wastewater" means any*, water which, during manufacturing or processing, comes into direct contact with vinyl chloride or polyvinyl chloride or results from the production or use of any raw material, intermediate product, finished product, by-product, or waste product containing vinyl chloride or polyvinyl chloride bnt which has not been discharged to a wastewater treat ing 0.5 ppm vinyl chloride in air. This is which produce: ment process or discharged untreated as sensitive enough for monitoring toe 10 (1) Ethylene dichloride by reaction of wastewater. ppm emission limits stipulated tn the oxygen and hydrogen chloride with <k) "Wastcwnter treatment process" standard. ethylene. -- includes any process which modifies rtottAi gtcisrct, vol i. no. 701--tni/dat. octose* ?i, ivr* . . - _ VJW,V*<wi i * * 9 i ] 73 9t> </) ui to 10 w i J i j V ;] i V. RULES AND REGULATIONS IGaGo Chirac LerisMca such as BOD, COD, TSS, aiul uit, usually lor the purpose of meetlac cSuent guidelines and standards; It doe* nut Include any process the purpose cl which is to remove vinyl chloride from water to meet requirements of this subpart. (l) '"In vinyl chloride service means that a piece of equipment contains or contacts either a liquid that Is at least 10 percent by weight vinyl chloride or a gas that Is at least 10 percent by volume Vinyl chloride. (m) "Standard operating procedure" means a formal written procedure offi cially adopted by the plant owner or operator and available on a routine basis to those persons responsible for carrying out the procedure. to) "Run" means the net period of time during which an emission sample is collected. (o) "Ethylene dicblorlde purification" Includes any part of the process of ethyl ene dlchloride production which follows ethylene dlchloride formation and in which finished ethylene dicblorlde is produced. - (p) "Vinyl chloride purification" in cludes any part of the process of vinyl chloride production which follows vinyl chloride formation and in which finished vinyl chloride is produced. (q) "Reactor" includes any vessel in which vinyl chloride is partially or totally polymerized Into polyvinyl chloride. (r) "Reactor opening loss" means the emissions of vinyl chloride occurring when a reactor is vented to the atmos phere lor any purpose other than an emergency relief discharge as defined in I 61.65(a). (s) "Stripper" includes any vessel in which residual vinyl chloride is removed from polyvinyl chloride resin, except bulk resin, in the slurry form by the use of beat and/or vacuum. In the case of btOfc,rosin, stripper includes, any vessel which is used to. remove'residual vinyl chloride from polyvinyl chloride resin immediately following the polymeriza tion step in the plant process flow, | 61.62 Emission standard for elliylcne dicliloride plants. An owner or operator of an ethylene dicblorlde plant shall comply with the requirements of this section and f 61.65. (a) Ethylene dlchloride purification: The concentration of vinyl chloride in all exhaust gases discharged to the at mosphere from any equipment used in ethylene dlchloride purification is not to exceed 10 ppm, except as provided in I61.C5(a). This requirement does not apply to equipment that has been opened, is out of operation, and met the requirement In {61.65(b) before being opened. (b) Oxyehlorlnation reactor: Except as provided In { 6l.G5ta>, emissions of vinyl chloride to the atmosphere from each oxyehlorlnation reactor arc not to exceed 0.2 g/kg the 100 percent ethylene dlchloride product from the oxychlorlnation process. 61.63 KiiimIvii standard fur vinyl chloride plauta- An owner or operator of a vinyl chlo ride plant shall comply with the require ments of this section and i 61.65. (a) Vinyl chloride formation and puri fication: The concentration of vinyl chloride In ail exhaust gases discharged to the atmosphere from any equipment used In vinyl chloride formation and/or purification is not to exceed 10 ppm, ex cept os provided In {61.65(a). Tilts re quirement docs not apply to equipment that has been opened, is out of operation, and met the requirement in S 61.65(b) (6) (1) before beln| opened. 61.61 Eininiiun standard fur P<>1> vinyl cliluridc plant*. An owner or operator of a polyvinyl chloride plant shall comply with the re quirements of this section and S 61.65. fa) Reactor: The following require ments apply to reactors: (1) The concentration of vinyl chlo ride in all exhaust gases discharged to the atmosphere from each reactor is not to.exceed 10 ppm, except as provided In paragraph (a)(2) of this section and {61.65(a). (2) The reactor opening loss from each reactor is not to exceed 0.02 g vinyl ehloride/Kg (0.00002 lb vinyl chloride/ lb) of polyvinyl chloride product, with the product determined on a dry solids basis. This requirement applies to any vessel which Is used as a reactor or as both a reactor and a stripper. In the bulb process, the product means the gross product of prepolymerization and postpolymerization. (3) Manual vent valve discharge: Ex cept for an emergency manual vent valve discharge, there is to be no discharge to the atmosphere from any manual vent valve on a polyvinyl chloride reactor in vinyl chloride service. An emergency manual vent valve discharge means a discharge to the atmosphere which could not have been avoided by taking meas ures to prevent the discharge. Within 10 days of any discharge to the atmosphere from any manual vent valve, the owner or operator of the source from which the discharge occurs shall submit to the Ad ministrator a report In writing contain ing information on the source, nature and cause of the discharge, the date and time of the discharge, the approximate total vinyl chloride loss during the dis charge, the method used for determining the vinyl chloride loss, the action that was taken to prevent the discharge, and measures adopted to prevent future dis charges. (b) Stripper; The concentration of vinyl chloride in all exhaust gases dis charged to the atmosphere from each stripper is not to exceed id ppm, except as provided in (61.65(a). Tills require ment docs not apply to equipment that has been opened. Is out of operation, and met the requirement In | 61.65(b) (6> (1) before being opened, (c> Mixing, weighing, and holding containers; The concentration of vinyl chloride in alt exhaust gases discharged to the atmosphere from each mixing, weighing, or holding container in vinyl chloride service which precedes the stripper (or the reactor II the plant lias no stripper) in the plant process How is not to exceed 10 ppm. except os provided In { Cl.G5(a>, This requirement does not apply to equipment that has been opened, is out of deration, and met the requirement In ( 61.65(b) (6) (1> before being opened. (d) Monomer recovery system. The concentration of vinyl chloride in all ex haust gases discharged to the atmos phere from cacli monomer recovery sys tem is not to exceed 10 ppm. except as provided in { 61.65(a). This requirement docs not apply to equipment that has been opened, is out of operation; and met the requirement In ( 61.65(b) <6> Ci) belo.-c being opened. <e) Sources following the stripperf*': The following requirements apply to emissions of vinyl chloride to the at mosphere from the combination of all sources following the stripper(s) lor the reactor(s) if the plant has no stripper(s>) in the plant process flow in cluding but not limited to, centrliugcs. concentrators, blend tanks, filters, dry ers. conveyor air discharges, baggers, storage containers, and inprocess wastewater: (1) In polyvinyl chloride plants u*ln? stripping technology to control vinyl chloride emissions, the weighted average residual vinyl chloride concentration in all grades of polyvinyl chloride resin processed through the stripping opera tion on each calendar day, measured Immediately after the stripping opera tion Is completed, may net exeecd: (1) 2000 ppm for polyvinyl chloride dispersion resins, excluding latex resins; (11) 400 ppm for all other polyvinyl chloride resins, including latex resins, averaged separately for each type of res in; or (2) In polyvinyl chloride plants con trolling vinyl chloride emissions with technology other than stripping or in addition to stripping, emissions of vinyl chloride to the atmosphere may not txcccd* <i)2 g/kg (0.002 lb/lb) product from the stripper(s) tor resctor(s) ll the pis'"* has no stripper(s) 1 for dispersion polyvinyl chloride resins, excluding latex resins, with the product determined on a dry solids basis; (11) 0.4 g/kg (0.0004 Ib/lb) product from the strippers tor reaetorfs) if the plant has no stripper(s){ for all other polyvinyl chloride resins, including latex resins, with the product determined on a dry solids basis. 61,65 F.mi--ton fr rlliili'iir flirlilvriilr, vinyl rlilvridr and ji,,ly* * iny I rliloriUc iiluiit*. An owner or operator f an ethylene dichloridc, vinyl chloride, and/or poly vinyl eliloride plant shall comply with the requirements of this section. (a) Relief valve discharge: Except for an emergency relief discharge, there Is to be no discharge to the atmosphere from any roller valve on any equipment In vinyl eliloride service. An emergency relic, discharge means a discharge which could not .have been avoided by taking measures to prevent the discharge. With in 10 days of any relief valve discilarge, FEDEKAl Kl KITE*, VOL 41, NO. 30S--THUSSOAT, OCIOSI t 31. IW* R&S 115224 1G5GG RULES AND REGULATIONS the owner or operator 0/ the source from which the relief vulvo dLtchr.rie occurs ehftll submit to the Administrator a re port in wjitsits containing information on the source, nature and caure ol the system from which the concentration of Vinyl chloride In the exhaust gases does riot exccctl JO ppm: or equivalent a* provided In ) Cl.CG. (ill) Rotating compressor: Vinyl discharge. the date and rime of the dis- chloride emissions from seals on all ro charge. the approximate total vinyl ehlo- - tating compressors in vinyl chloride ride lost curing the tlL-eharh-. u.e meth service are to be minimized by installing od ured fer determining the vinyl chlo compressors with double mechanical ride loss, tlie action that was taken to seals, or equivalent es provided In : Cl.CG. present the discharge. and measures If double mechanical seals are used, vinyl adopted to prevent future dhcharges. clUoride emissions from tire seals arc to <b> Fugitive emission sources: be minimized by maintaining the pres U) Loading and unloading lines: Vinyl sure between the two seals so that any chloride embiioris from loading and un- leak that occurs is into the compressor: leadJtg hues which are opened to the by ducting any vinyl chloride between atmosphere after each loading or un the two seals through a control system loading operation are to be minimized from which the concentration of vinyl as follows: chloride in the exhaust gases does not (1) After each loading or unloading' exceed 10 ppm; or equivalent as provided operation and before opening a loading in {61.66. or unloading line to the atmosphere, the (tv) Reciprocating compressors: Vinyl quantity of vinyl chloride in all parts of chloride emissions from seals on all re eaeh loading cr unloading line that are ciprocating compressors in vinyl chloride to' be opened to the atmosphere is to be service are to be minimized by Installing reduced so that the parts combined con double outboard seals, or equivalent as tain so greater than 0.0038 m* (0.13 It*) provided in {61.66. If double outboard of vinyl chloride, at standard tempera seals are used, vinyl chloride emissions ture a&d pressure; and from the seals are to be minimized by (11) Any vinyl chloride removed from maintaining the pressure between the a loading or unloading line In accord two seals so that any leak that occurs is ance with paragraph (b)(1) (i> of this into the compressor: by ducting any section is to be ducted'through a control vinyl chloride between the two seals system from which the concentration of through a control system from which the vinyl chloride In the exhaust gases does concentration of vinyl chloride in the sot exceed 10 ppm, or equivalent as pro exhaust gases does not exceed 10 ppm; vided in | 61.66. or equivalent as provided in 5 61.66. (2) Slip gauges: During loading or un (v) Agitator: Vinyl chloride emissions loading operations, the vinyl chloride from seals on all agitators in vinyl chlo emissions from each slip gauge In vinyl ride service are to be minimized by:in chloride service are to be minimized by stalling agitators with double mechani ducting any vinyl chloride discharged cal seals, or equivalent as- provided in from the slip gauge through a control j 61.66. If double mechanical seals are system from which the concentration of used, vinyl chloride emissions from the vinyl chloride m the exhaust gases docs seals are to be minimized by maintaining not exceed 10 ppm, or equirslent ss pro the pressure between the two seals so vided in 161.66. that any leak that occurs is into the agi (3) Leakage from pump, compressor, tated vessel: by ducting any vinyl chlo and agitator seals: ride between the two seals through a (I) Rotating pumps: Vinyl chloride control system from which the concen emissions from seals on-all rotating tration of vinyl chloride In the exhaust pumps in vinyl chloride service are to be gases does not exceed 10 ppm: or equiva minimized by installing sealless pumps,' lent as provided In 161.66. pumps with double mechanical seals, or- (4) Leakage from relief valves: Vinyl equivalent as provided In 161.66. If chloride emissions due to leakage from double mechanical seals arc used, vinyl each relief valve on equipment in vinyl chloride emission from the seals are to chloride service are to be minimized by be minimized by maintaining the pres Installing a rupture disk between the sure between the two seals so that any equipment and the relief valve, by con leak that occurs Is Into the pump; by necting the relief valve discharge to a ducting any vinyl chloride between the process line or recovery system, or equiv two seals through a control system from alent as provided In f 61.66. which the concentration of vinyl chlo (5) Manual venting of ga*rs: Except ride in the exhaust Eases does not ex as provided in f 61.64 to M3*, all cases ceed 10 ppm; or equivalent as provided which are manually vented from equip in | 61.66. ment in vinyl chloride service are to be (II) Reciprocating pumps: Vinyl chlo ducted through a control system from ride emissions from seals on all recipro which the concentration of vinyl chloride cating pumps In vinyl chloride service In tiie exhaust gases docs not exceed 10 are to be. minimized by installing double ppm: or equivalent as provided, in 161.66. outboard seals, or equivalent as provided D Opening of equipment:- Vinyl m 161.66. If double outboard seals are chloride emissions from opening of used, vinyl chloride emissions from the equipment (Including loading or unload seals are to be minimized by maintaining the pressure between the two scaIs so ing lines that arc not opened to the at mosphere after each loading or unload ing operation* are to be minimized as that any leak that occurs Is Into the follows: pump; by ducting any vinyl cliloride be (1) Before opening any equipment for tween the two seals through a control any reason, the quantity of vinyl chlo ride Ls to be reduced so that the equip ment contains no more than 2 0 i--rccnt by volulnc vinyl cldoridc or 0.0630 m* (25 gall of vinyl chloride, wliiche-.cr is larger, nt standard temperature and pressure; and (lii Any vinyl chloride removed from the equipment m accordance with para graph (b)(6) fl> of this section Is to be ducted through a control system from which the concentration of vinyl chlo ride in the exhaust gases does not exceed 10 ppm, or equivalent as provided in i 61.66. <1> Samples: Unused portions or sam ples containing at least 10 percent bv weight vinyl chloride are to be returned to the process, and sampling techniques arc to be such that sample containers in vinyl chloride service are purged into a closed process system. *8 Leak detection and elimination: Vinyl chloride emissions due to leaks lrom equipment in vinyl clUoride service are to be minimized by instituting and implementing a formal leak detection and elimination program. The owner or operator shall submit a description of the program to the Administrator for approval. The program ls to be sub mitted within 46 days ol the ellective date of these regulations, unless a waiver of compliance Is granted under I 61.11. If a waiver of compliance is granted, the program is to be submitted on a date scheduled by the Administrator. Ap proval of a program will be granted by the Administrator provided he finds: (1) It Includes a reliable and accurate vinyl chloride monitoring system for de tection of major leaks and identification of the general area of the plant where a leak is located. A vinyl chloride monitor ing system means a device which obtains air samples from one or more points on a continuous sequential basis and ana lyzes the samples with gas chromatog raphy or. If the owner or operator as sumes that all hydrocarbons measured are vinyl chloride, with infrared spectro photometry flame ion detection, or an equivalent or alternative method. ^(U) It includes a reliable and accurate portable hydrocarbon 'detector to be used routinely to find small leaks and to pin point the major leaks indicated by the vinyl chloride monitoring system. A portable hydrocarbon detector means a device which measures hydrocarbons with a sensitivity jif at least 10 ppm and 1$ of such design and size that it can be used to measure emissions from local ized points. (iti) It provides for an acceptable cali bration and maintenance schedule for the vinyl chloride monitoring system and portable hydrocarbon detector. For the vinyl chloride monitoring system, a daily span check is to be conducted with a concentration of vinyl chloride equal to the concentration defined as a leak ac cording to paragraph (bHSHvt) of this section. The calibration Is to be done with cither: (A* A calibration gas mixture pre pared from the gases specified In sections 5.2.1 and 5.2 3 of Test Method 106. or SIOftAl etCISTit. VOL. 4|, NO. *OJ--TMUtSOAT, OCIOltt 11, 1976 RULES AND REGULATIONS JC35T (Bj A calibration nns cylinder conUdn- vinyl chloride in' equipment '.-4.75 m* of emission test results and oilier data Inc the appropriate concentration of 01200 gal in volume 1or which tuv mis needed to determine emissions. vinyl chloride. If p. calibration gas cylin der is u-.cd, Uie uiv.ilyf.e: mn.:t be trace* able to the National Bureau of Stand ards or to n cravlnietriesilly calibrated vinyl chloride permeation tube. tiv> The location and number of points sion limit is piv scrily-d in 5 01.55(b) (5) <l> prior to Ojjcniaz Live equipment and vising Test Method ICC, :i portable hydrocat bon detector, or ;ui equivalent or al ternative method. The method of meas (g) Unlc.r, otherwise specified, the owner or operator shall vise test Test Methods In Appendix n to this part lor each test as required by paragraph* (gXli, (q><2'' <gH3>. <11141, ami (g) <3 of this section, unless an equiva to be monitored and llie frequency of monitoring provided for in the program are acceptable when they are compared urement is to meet the requirements In S 61.67(g) <5) (i)(A) or (gX<5)(lXll). lent method or an alternative mc:!;0'i lias been approved by the Administrator. If the Administrator finds reasonable with the number of pieces of equipment In vinyl-chloride service and the size and 61.66 Equhuli'iil equipment mid pro. ml lire*. grounds to dispute the results obtained by an equivalent or alternative method, physical layout of the plant- Upon written application from an own lie may require the use of a referonrr (v) It contains an acceptable plan of action to be taken when a leak is de tected. (vl) It contains a definition of leak er or operator, the Administrator may approve use of equipment or procedures which hove been demonstrated to his method. II the results of the reference ana equivalent or alternative methods do not agree, the results obtained by the reference method prevail, and the Ad which is acceptable when compared with satisfaction to be equivalent in terms of ministrator. may notify the owner or the background concentrations of vinyl reducing vinyl chloride emissions to the operator that approval of the method chloride in the areas of the plant to Umonitored by the vinyl chloride monitor ing system. Measurements of background concentrations of vinyl chloride in the areas of the plant to be monitored by the vinyl chloride monitoring system are to be Included with the description of the program. The definition of leak for a given plant may vary among the differ ent areas within the plant and is also to change over time as background con centrations in the plant are reduced. (0) Inprocess wastewater; Vinyl chlo aLmosphere to those prescribed for com pliance with a specific paragraph of this subpart. For an existing source, any re quest for using an equivalent method as the initial measure of .control is to be submitted to the Administrator within 30 days of the effective date. For a new source, any request for using an equiva lent method is to be submitted to the Administrator with the application for approval of construction or modUlcatlofi required by $ 61.07. previously considered to be equivalent o alternative is withdrawn. <1> Test Method 10G is tn be used to determine the vinyl chloride emissions from any source for which an emission limit is prescribed in H 61.62(av or *b> I 61.63*a*, or It 61.64(a)(1). (b). (c*. or <d>, or from any control system to which reactor emissions are required to be ducted In ; 61.G4<a) (2)'or to which fugi tive emissions are required to be dueled in H 61.65(bXlX!l>. <bU2>, (bX5>. (b)(6*(11),or (b)(9) (11). ride emissions to the atmosphere from 61.67 Emission tests. (1) For each run, one sample Is to be lnprocess wastewater are to be reduced as follows: <i) The concentration of vinyl chlo ride in each lnprocess wastewater stream containing greater than 10 ppm vinyl chloride measured immediately as it leaves a piece of equipment and before being mixed with any other lnprocess (a) Unless a waiver of emission testing Is obtained under i 51.13. tho owner or operator of a source to which this sub part applies shall test emissions lrom the source. (1) Within SO days of the effective date In the case of an existing source or a new source which has an initial startup collected. The sampling site is to be at least two stack or duct diameters down stream and one half dinmeter upstream from any- flow disturbance such as a bend, expansion, contraction, r visible flame. For a rectangular cross section an equivalent diameter is to be determined from the following equation: wastewater stream is to be reduced to'no more than ID ppm by weight before being mixed with any other lnprocess wastewa date preceding the effective date, or (2) Within SO days of startup in the case of a new source, iidtial startup of equivalent dii.mtf-r-2 i(-l'e?n5g5t5h")U(will* li) leaftb-i-widili* ter stream which contains less than 10 ppm vinyl chloride; before being exposed to the atmosphere, before being dis charged to a wastewater treatment proc ess; or before being discharged untreated as a wastewater. The paragraph does which occurs after the effective date. (b) The owner or operator shall pro vide the Administrator at least 30 days prior notice of an emission test to afford the Administrator the opportunity to have an observer present during the test. The sampling point In the duct is to be at the centroid of the crass section. The sample is to be extracted at a rate proportional to the gas velocity at the sampling point. The sample is to be taken over a minimum of one hour, and apply to water which is used to displace vinyl chloride from equipment before it (c) Any emission test is to be con ducted while the equipment being tested is opened to the atmosphere in accord is operating at the maximum production ance with 161.64(a)(2) or paragraph rate at which the equipment will be op (b) (6) of this section, but does not apply erated and under other relevant condi to water which is used to wash out equip tions os may be specified by the Adminis ment after the equipment has already trator based on representative periorm- been opened to the atmosphere tn ac ance of the source. cordance with 161.64(a)(2) or para (d) Each emission test is to' consist graph (b) (6) of this section. of three runs. For the purpose of deter (il) Any vinyl chloride removed from mining emissions, the average of results the lnprocess wastewater In accordance of all runs is to apply. The average is to is to contain m minimum volume of 50 liters corrected to standard conditions. <t' For gas streams containing more than 10 percent oxygen, the concentra tion of vlnyle chloride as determined by Test Method 106 is to be corrected to n> percent oxygen for determination of emissions by using the following equa tion: r* ..*,' _10 * _ rfc r* 2U.ll - |wiil (.: with paragraph (b) (9> (1) of tills section be computed on a time weighted basis, **lev. Is to be ducted tljrough a control system (e) All samples are to be analyzed from which the concentration of vinyl wlilvtn 24 hours, and vinyl chloride emis Cqr*t*tri"Tli* rflwvnlratlon vinyl V.*, I- tv tltarftli**i f.l*-*, ptfnl-l |,t I |-r* T-vtinttetyeni. chloride in the exhaust gases docs not exceed io ppm, or equivalent as provided tn I 61.66. sions arc to be determined within 30 days after the emission test. The owner or operator shall report the determinations ft-Tlw ccnrcniratiitn t< vinyl rl '-til ,t ni-:-urcd liy Tna SMI'***! !!. 9U*rnnt etyurfi In IU nml.t.-.i ,..r m Muhl'lMurttHUinn*. <ci The requirements in paragraplis to the Administrator by a registered (bull. tb>(2). (b)(5). <b><6>. (b)(7) letter dispatched before the close of live and it (8> of tills section ore to be In next business day following the deter corporated into a sinmiorrt operating mination. 10.?--INr'it #yjv lii lit* wl.i-i.l .jf jt Miunlvrd ciMtdifkitiv. mM< u>* i t |vnviit ni)|m Innlihh It',a.rr---. Ilnn li tfb.t mvln. IVfeiii O,-IVr.rm ntyvon In II** -tl-.n.l r ,< at 1*1 llrtinvv >1. iiiAj j t,, procedure, onr made available uixm re (f) The owner or operator shall retain AplviiJU Aot l'3ltMUlHir)u|.|.n. quest (or tnsi*ection by the Administra at the plant and make available, upon (Ill) For ihose emission sources where tor. The standard operating procedure Is to Include provisions for measuring the request, for hisiKrtlon by the Adminis trator. for a minimum of 2 years records the emission hmlt is prescribed In term* of nvi.js rather than concentration, unu ftOtRAl REGISTER, V L* 41. NO. 305--THUMDAY. OCT BEK 3V. 1974 f 4CjCS' BUIES AND REGULATIONS emission? In fcg/JCO krr product are to be ilclrm'.nctl by using Urn following equation: tr, (2.QQ) o io-) nooj Ciz*-- z that Is also used as a stripper, the deter mination may be made immediately fol lowing Use stripping 0!>eration. (1) Except as provided in paragraph (g> (6) (li) of this section, toe reactor opening loss is to be determined using detection, or an equivalent or alterna tive method. Tile vinyl chloride monitor ing system used to meet the requirements In { C1.65(b) (S) (l) may be used to meet the requirements of this section. (c) A daily span check is to be con the following equation: OOfttaakle|V4 vrsrnl.Wifvli^'iMr/)ifGt'f lvxjiipj-f)*luet. u liK*4Ufcd ljr 1 r?s I1**. c,, ---W-----(-2-.-6--0-)--(-1--0----*-)--(-C---L-) ducted for each vinyle chloride monitor ing system used. For all of the emission sources listed in paragraph (a) of this ;.($at>r.*iy ol vlhvi cutwld* at On* ftiuic*phr* tad :ii*C in fca/ffi*. C'*VDi^r,t*flc f uto In tu'/hr m dtt-virJnM bf Wh*rr, section, except the one for which an emis sion limit is prescribed in 1 61.62(b), the Jl*r*r#fw> .M'lbwd 2 ul Append!* a to I'uri Cd C-M vinych<*Mofn>i9slon5,\;producU dally span check Is to be conducted with triAUttaitUr. JO <*Conf*P<i; L>z\nr lor wm. 2T^l*ro<iti;bvii r*u (Wfc/Uo, I Ihv rector In jh*. ltoI>tn*iiy of vinyl titled* M on* almo<.p*itn* n<l a concentration of vinyl chloride equal 3u* Cm hf/m*. to 10 ppm. For the emission source for (2) Test Method 107 is to be used to determine the concentration ol vinyl J/HConvfnCoi tator torpjim, 0**|>pin by volumv \inylcMvld* m by Trt ftUlhod Kd or * j*xUb!* bydfoc-erboh which an emission limit is prescribed in } Gl.G2<b>, toe daily span check Is to be chloride in each Inprocess wastewater stream lor which an emission limit is detector which tocasurr* hydrocarbon* conducted with a concentration of vinyl with a gtasltlvlty .of ot lean 20 V^Smabar of batch** uv reactor vai Un chloride which is determined to be prescribed in i Ol.CS(b) (0) (1). (3) Where a stripping operation is cptiwl to tb ouuo'tibof^- determined to be equivalent to the emis r-Av*r*t* ke of polyvinyl chlftHd* P?wdUiv<J i*r battb In Mt* number of baten Alice iti? rcoctoc sion limit for that source based on the used to attain the emission limit in f 61.- Vw Iasi opened to U* OLcitosphcrc- emission test required by 167.67. The 01(e), emissions are to be determined using Test Method 107 as follows: (i) The number of strippers and sam (A) If Method 106 is used to deter mine the concentration of vinyl chloride calibration is to be done with either: (1) A calibration gas mixture pre pared from the gases specified in sections ples and the types and grades of resin to (Cb), the sample is to be withdrawn at 52,1 and 22 of Test Method 106, or be campled are to be determined by the a constant rate with & probe of sufficient (2) A calibration gas cylinder con Administrator for each individual plant length to reach toe vessel bottom from taining the appropriate concentration of at the time of the test based on the the manhole. Samples are to be taken vinyl chloride. If a calibration gas plant's operation. 'for 5 minutes within 6 inches of toe ves cylinder`is used, the analysts must be (11) Each sample is to be taken imme sel bottom, minutes near the vessel traceable to toe National Bureau of diately following the stripping operation. center, and S minutes near toe vessel top, Standards or to a gravbrietrically cali (ill) The corresponding quantity cf <B) If a portable hydrocarbon detec brated vinyl chloride permeation tube. material processed by each stripper is to tor is used to determine toe concentra 61.69 Initial rrporl. be determined on a dry solids basis and by a method submitted to and approved by the Administrator. (lv) At the prior request of the Ad ministrator, the owner or operator shall provide duplicates of the samples re quired to paragraph (g)(3)(1) of this section. (4) Where control technology other than or to addition to a stripping opera tion is used to attain the emission limit in f 61.64(e), emissions are to be deter mined as follows: (1) Test Method 106 a to be used to determine atmospheric emissions from all or the process equipment simultane tion of vinyl chloride (Cb), a probe of sufficient length to reach the vessel bot tom from toe manhole is to be used to moke the measurements. One measure ment will be made within 6 inches of the vessel bottom, one near toe vessel center and one near toe vessel top. Measure ments are to be made at each location until the reading is stabilized. All hydro carbons measured ate to be assumed to be vinyl chloride. , <C> The production rate of polyvinyl chloride (Z) is to be determined by a method submitted to and approved by toe Administrator. (il) A calculation based on toe number - (a) An owner or operator of any source to which this subpart applies shall submit a statement to writing notifying toe Administrator that toe equipment and procedural specideations In {} 61.65 (b)(1), (b)(2), (b)(3), (b)(4), (b)(5). (b)(6), (b)(7), and (b)(6) are being implemented. (b)(1) In the case of an existing source or a new source which has an initial startup date preceding toe effec tive date, the statement is to be submit ted within 00 days of the effective date, unless a waiver of compliance Is granted under 16121, along with the Informa tion required under < 6120. If a waiver ously. The requirements of paragraph of evacuations, the vacuum involved, and ' of compliance is granted, the statement (g> (1) of this section are to be met. the volume of gas in the reactor is hereby is to be submitted on a date scheduled <10 Test Method 107 Is to be used to determine the concentration of vinyl chloride to each inprocess wastewater stream subject to the emission limit pre scribed to 161.64(e). The mass of vinyl approved by-the Administrator as an al ternative method for determining reac tor opening loss for postpolymeriration reactors in toe manufacture of bulk resins. by toe Administrator. (2) In too case of a new source which did not have an initial startup date pre ceding the effective date, the statement is to be submitted within 00 days of the chloride to kg/100 kg product in each { 61,68 Enilulton monitoring. initial startup date. in process wastewater stream Is to be de termined by using the following equa tion: c_ 1C* li 10~*1 tlOO] z vlirrr: ' C> * *\t tlnjl ehVtrldr.lQA kg ptfclwi. {onemiAUifei *>t vinyl fhJuriU* u fut<uurc4 bf T*l Method |<77, Jt wttft flew ta:* in l/tv, determined In iftftrJam* %Kb i method nlfJeh lui brni whuitthl In 10 '1Couv*f&Mpp0rnnv(vaul bryluthc%ppAitdt-ndtdUftkior* rtsU (kfrfir), determined In sore *1th method which hv been submitted nd by U* AlmluUlriiUtf* (a) A vinyle chloride monitoring sys tem is to be used to monitor on a con tinuous basis the emissions from the sources for which emission limits are pre scribed In l 61.63(a) and (b). f 61.63(a), and f A4(a)(l). <b>. (c),and (d).and for any control system to which reactor emission are required to be ducted In f 61.66(b)(1X11). and (b)(3), (b)(5). (b) (6) (If>. and (b) (9) (U>. <b) The vinyl chloride monitoring sys temic) used to meet the requirement in paragraph (a) of this section Is to be a (c) The statement Is to contain toe following information: (1) A list of toe equipment installed for .compliance, r* (2) A description of the physical and functional characteristics of each piece of equipment. <3) a description of toe methods which have been incorporated into the standard operating procedures for meas uring or calculating the emissions for which emission limits are prescribed in H 61.65 (b) (1X1) and (bXGXi), (4) A statement that each piece of (5) The reactor opening loss for which device which obtains air sampols from equipment is Installed and that each n emission limit is prescribed In {Cl.64 one or more points on a continuous piece of equipment and each procedure (a) (2) is to be determined. The number sequential basis and analyzes the samples is being used, of reactors lor which the determination is to be made is to be specified by toe Administrator for each individual plant with gas chromatography or, if the owner or oiwrator assumes that all hydrocar 2 61.70 Roniijiiinual ri*|Hrt. ta) (2) is to be determined. The number at the time of toe determination based bons measured arc vinyl chloride, -with source to which this subpart applies shall on the plant's operation. For a reactor infrared spectrophotometry, flame ion submit to the Administrator on Soptcm- R&S 115226 MOftAl MClSTW.'vflt. 41, NO. *05--THUMDAr, OCTOtt* *1, 1974 I RULES AND REGULATIONS IGJG'I bcr 15 ami March IS of each year a report lu writing conU'.inucr the Information required by this aecilon. The first semi annual report Is to be submitted follow ing the first full C month reporting period . after the Initial report Is submitted. (b) fl > In the case of an existing source or a new source which has an Initial startup date preceding the effective date, the first report is to Lo submitted within 180 days of the directive date, unless a waiver of compliance is granted under {61.11. If a waiver of compliance is granted, the first report Is to be sub mitted on a date scheduled by the Ad ministrator. (2) In the case of a new source which did not have an initial startup date pre ceding the ellectlve date, the first report is to be submitted within 180 dajs of the initial startup date. (c) Unless otherwise specified, the owner or operator shall use the Test Methods in Appendix B to this part to conduct emission tests as required by paragraphs tc) (2) and (c) (3) of this section, unless an equivalent or an alter native method has been approved by the Administrator. If the Administrator finds reasonable grounds to dispute the results obtained by an equivalent or al ternative method, he may require the use of a reference method. If the results of the reference and equivalent or alterna tive methods do not agree, the results obtained by the reference method pre vail, and the Administrator may notify the owner or operator that approval of the method previously considered to be equivalent or alternative is withdrawn. (1) The owner or operator shall in clude in the report a record of any emis sions which averaged over any hour period (commencing on the hour) arc in excess of the emission limits pre scribed In if 61.02(a) or (b), 161X3 (a), or II 61.64(a) (1), (b), (c), or (d). or for any control system to which reactor emissions are required to be ducted in 161.64(a) (2) or to which fugitive emis sions are required to be ducted in I 61X5 (b> (1) (11), (b) (2), (b) (5), <b> (6) UD. or (b) (9) (U) .The emissions are to be meas ured in accordance with I 61.68. (2) In polyvinyl chloride plants for which a stripping operation is used to attain the emisison level prescribed in 161.64(e), the owner or operator shall include In the report a record of the vinyl chloride content In the polyvinyl chloride resin. Test Method 107 is to be Used to determine vinyl chloride content as follows: (I) if batch stripping Is used, one rep resentative sample of polyvinyl chloride resin is to be taken from each batch of each grade of resin immediately follow ing the completion of the stripping, and grade and the date and time the batch is completed. The corresponding quantity of material processed in each stripper batch is to be recorded and ident HW by resin type and grade and the dale and time liie batch is completed. 'll* If continuous stripping is used, one representative sample of polyvinyl chloride resin is to be taken for each grado of resin processed or at inter'*a\i of 8 hours for each grads of resin which is being processed, whichever is more fre quent. The sample Is to be taken ns the resin flows out of the stripper and iden tified by re.-in type and vrr.de and the date and time the sample was taken. The corresponding quantity of material processed by each stripper over the time period represented by the sample during the eight hour period, is to be recorded and Identified by resin type and grade and the date and time it represents. (ill) The quantity of material proc essed by the stripper Is to be determined on a dry solids basis and by a method submitted to and approved by the Ad ministrator. (lv) At the prior request of the Ad ministrator. the owner or operator shall provide duplicates of the samples re quired in paragraphs (c) (2) (1) and (c) (2) (11) of this section. (v) The report to the Administrator by the owner or operator Is to include the vinyl ehloride content found in all the samples required in paragraphs (e)(2) (1) and (c) (2) (i!) of this section, aver aged separately for each type of resin, over each calendar day and weighted ac cording to the quantity of each grade of resin processed by the stripperU) that calendar day, according to the following equation: may be made immediately following llic stripping operation. (i1.71 JtrVordkrvIHiig. (a) Hie owner or operator of any source to which Utls subpart applies shall retain the following information at the source and make It available for inspec tion by tlie Administrator for a mini mum of two years: (1) A record of the leaks detected by the vinyl chloride monitoring system, us required by I Gl.COib) (8*. including the concentrations of vinyl chloride ns measured, analyzed, and recorded by the vinyl chloride detector, the location of each measurement and the date and ap proximate time of each measurement. (2) A record of the leaky detected during routine monitoring with the portable hydrocarbon detector and the action taken to repair the leaks, as re quired by 161.65(b)(8), including n brief statement explaining the location and cause of each leak detected with the portable hydrocarbon detector, the date and time of the leak and any action taken to eliminate that leak measured in accordance with 161.68. (3) For the relief discharges Iran reactors subject to the provisions of 161.65(a), a dally operating record for each reactor, Including pressures and temperatures. ibPcM0. 2. Appendix B is amended by adding Test Methods 106 and 107 as foil ws: Pc, Mo, + Po} |V*|+ +Po.M,m Urhn 108--Drmtnt.vavion or Vinyl CstMiiM vaost Station**! Soever* ixnoovCTiox " Q-- Performance or this method should r.ti attempted by person* unfamiliar with iho A*344iour tverts* eooceotrstloo *i type t, rule la ppm. (-Tcttl ptouctloo of type T\ reeks mrtttMMH period. Id t(. T,-Typ of wHu; /!(( i i w WllW* M If total operation of a gs* chromatograph, nor by thoie who are unfamiliar with souret *.impltag. as them are many details that nr-' beyond the scope of this presentation. Care number et rule trim produced drum* IS* St* hour period. XI-Conceauttloo el vinyl chlntt* la on* samnl* *t cmdo 0< note. In ppm. P-Production t fad* O, rule npMNM by Um MSipfeetft kf. Ct~OtoDfrMia,*.K,ObGhAnd6i: , n-Totsl number M (tow el rule produced Coring . . Jibe li-beor period. must be exercised to prevent wpure of aampUag personnel to vinyl chloride, a car cinogen. 1. Principle and Applicability. 12 An integrated bag sample of arack gat containing vinyl chloride ' (chlotoethrirne i 1* subjected to Chromatographic analysis. <vi) The owner or operator tain at the source and make shall re available ' using a flame tonlratlou'detector, 12 The method Is applicable to the m*a- v-ement of vinyl chloride lu stack gases from for inspection by the Administrator for oiaiylene dlchlorlde, vinyl chloride and poly a minimum of 2 years records of all data vinyl ehloride manufacturing procc-e*. ex needed to furnish the information re cept where the rluyl chloride U contained in quired by paragraph (c)(2)(v) of this particulate matter. section: The records are to contain the following information: (A) The vinyl chloride content found in all the samples required in paragraphs 2. Range and Sensitivity. The lower limit of detection will vary ac cording to the chromatograph used. Yaiwi reported include 1 y. !0- mg and 4 x'm < mg. (c) (2) (1) and (c) <2> (11> of this section, 3. Interference*. identified by the resin type and grade Acetaldehyde, which can occur in w and the time and date of the sample, and vtnyi chloride eourem. will Interfere with :i. (B> The corresponding quantity of polyvinyl chloride resin processed by the stripper(s), identified by the resin type and grade and the time and date it represents. vinyl chloride peak from the Chromo-orb ins column. Sec setliou* 4.32 and G.4. If it-. ,luUon of the vinyl chloride peak Is still not satisfactory for a particular aampie. then chromatograph parameters can be further altered with prior approval of the Admin (3) Tlie owner or operator shall in istrator. If attornlion of the ehroniv-egraph clude in the report a record of the emis parameters fall* to resolve the vinyl chloriila sions from each reactor owning for which an emission limit is prescribed In t 6i.G4(n) (2). Emissions nre to be deter mined in accordance with i Cl.C7(g) (5). except that emissions tor each reactor are to be determined. For a reactor that is peak, then supplemental eocflrmetloa of the vinyl ehloride peak through an absolute analytical technique, such as mans speettofcccspy. must he iH-r/orincd. 4. Apparatus. ..1 Sampling (Figure 11. 4.1.1 Probe--Slainlens steel. Pyrrr glsM, also used as it stripwr, the determination or Triton tubing according to stack temper- FiDFtAL ttCISTEX, VOL 41. NO. 105--THUtSOAY, OCtOtFX 31. IV7A V 4G570 RULES AND REGULATIONS nture. tiwh equipped with * clma wool plug to remove n .rl'ctilate matter, 4.12:*i.xplo line--Tenon. 0.4 mm outside diameter, of sufficient le.ifrth to connect pro.* to l,a;;. A new uiiu.m.-u piece la employed lor cteli xirlr-. of baj sample* that coastliutn on rml'slon teat. 4.1.3 Mi.lc O) end female (2) stainless etcel qulcli-foiinect.*, with hall checks folio pul.' without) located *a thown In Figure 1. 4.1.4 Teller bags, 100 liter capacity--To contain temple. Teflon bai;a are not accept able. Alumtallied Mylar bags may be used, provided that the samples are analyzed within 24 hours or collection. 4.12Ulpid leakproof container* for 4.1.4, With covering to protect contents from sun light. 4.1.C Kccdle valve--To adjust sample flow rate. 4.1.7Pump--Leak-free. Minimum capac ity 2 liters per minute. 4.12Charcoal tube--To prevent admis sion of vinyl chloride to atmosphere In vicin ity of samplers. 4.12Mow meter--For observing sample flow rate; capable of measuring a flow range from 0.10 to 1.00 liter per minute. 4.1jo Connecting tubing--Teflon, 8.4 mm outside diameter, to assemble sample train (Flguro l). 4.1JI Pitot tube--Type 8 (or equivalent). attached to the probe so that the sampling flow rate can be regulated proportional to the stack gas velocity. 42 Sample recovery. 4.2.1 .Tubing--Teflon, 8.4 mm outside diameter, to connect bag to gas chromato graph sample loop. A new unused piece la employed for each series of bag samples that constitutes an emission test, and is to be dis carded upon conclusion of analysts of those bags. 4J Analysis. 4.3.1 Gas Chromatograph--'With flame Ionization detector, potentlometrlc strip chart recorder and lJO to 6.0 ml heated sam pling loop in automatlo samplo valve. 422 Chromatographic column--Stainless steel, 2JO x *-2 mm. containing 80/100 mesh Chromosorb 102. a secondary colum of GE BP-06. 20% on 60/80 mesh AW Chromosorb P, stainless steel, 2.0 m x 32 tom, will be required If acstaldchyd* is present. If used, the SF-0S column Is placed after the Chronroeorb 102 column. The combined columns should then be operated at 110'C. 422 Plow instore (2)--Rotameter type, 0 to 100 ml/min capacity, with now. control valves. '> 4.3.4 Gas regulator*--Tor required gas cylinder*. 4.3 8 Thermometer--Accurate to one de gree centigrade, to measure temperature of heated samp!* loop at time of sample injec tion. 42.6 Barometer--Accurst* to 8 mm Hg, to measure atmospheric pressure around gas chromatograph during sample analysts, 42.7 Pump--Leak-fraa. Minimum capac ity 100 ml/mln. 4.4 Calibration. 4.42 Tubing--Ttflon, 6.4 tom ouUlde diameter, separate piece* marked for each calibration concentration. 4.42 Tcdiar bag*--Sixteen-Inch square alae, separate bag marked for sach calibra tion concentration. 4.4,3 Syringe--0.5 ml. got tight > 4.4.4 Syringe--60al, gas tight. Mention of trade names on specific prod ucts does not constitute endorsement by the Environmental protection Ageney. 4.4.5 Plow meter--Rotameter type. 0 to 1000 ml/mln range accural* to -.1%, to meter nitrogen In preparation of standard gav mixtures. 4.4.6 Ctop watch--Of known accuracy, to time gas flow la preparation of standard gas mixture*. 6.Reagents. It is nccef-wy that all rea gents bo of chromatographic grade. 6.1 Analysis. 5.1.1 licllutn gas or nitrogen gas--Zero grade, for chromatographic carrier gas. 6.1.2 Hydrogen gas--Zero grade. 5.12 Oxygen gas, or Air, as required by the detector--Zero grade. 52 Calibration. 62.1 Vinyl chloride. 82.2+%--ror prep* araliou of standard gas mixtures. 522 Calibration cylinders (3), optional-- Ono each of 50, 10 and 6 ppm vinyl chloride In nitrogen with certified analysis. Analysis must be traceable to NliS (National Bureau .of Standards) or to a gravlmetitcally cali brated vinyl chloride permeation tube. 622 Nitrogen gas--Zero grade, for prep aration of standard gas mixtures. c. Procedure. 6.1 Sampling. Assemble the sample train as in Figure 106t-l. Perform a bag leak check according to Section 7.4. Observe that all connections between the bag and the probe arc tight. Place the end of the probe at the centroid of the stack and start the pump with the needle valve adjusted to yield a flow of 0.5 1pm. After a period of time suffi cient to purge the line several times has elapsed, connect the vacuum line to the bag and evacuate the bag until the rotaroeter indicates no flow. Then reposition the sample and vacuum lines and begin the ac tual sampling, keeping the rate proportional to the stack velocity. Direct the gas exiting the rotameter away from sampling personnel. At the end of the sample period, shut off the pump, disconnect the sample line from the hag. and disconnect the vacuum line from the bag container. Protect the bag container from sunlight. 62 Sample storage. Semple bags must be kept out of direct sunlight. When at all pos sible, analysis Is to be performed within 24 hours of sample collection. 62 Semple recovery. With a piece of Tef lon tubing Identified for that bag. connect a bag Inlet valve to the gaa chromatograph sample valve. Switch the valve to withdraw gas from the bag through the sample loop. Plumb the equipment so" the^sample gas passes from the sample valve to the leak-free pump, and then to a charcoal tube, followed by a 0-100 ml/mln rotameter with flow con trol valve. 6.4 Analysis. Set the column temperature to 100* O the detector temperature to iso* C, and the cample loop temperature to 70* C. When optimum hydrogen and oxygen flow rates have been determined verify and main tain those flow rates during all ebromato-graph operations. Using aero helium or nitrogen as the carrier gas, establish a flow sate In tha rang* consistent with the manu facturer's requirements for satisfactory de tector operation. A flow rata of approxi mately 40 ml/mln should produce adequate separations. Observe the base line periodi cally and determine that the noise level has stabilized and that base line drift bas ceased. Purge the sample loop for thirty seconds at the rote of 100 ml/mln, then activate the sample valve. Record the Injection time (the position of the pen on the chart at the time of sample Injection), the sample number, the sample loop temperature, the column tem perature, carrier gas sow rote, chart speed and tlic allcnualor setting. Record the 1.1b. or.iicry preumre. From the chart, select the pea); hating the retention time correspond ing to vinyl chloride, at determined la Sec tion 72. Me.isttre the peak area. A-, by uio of H-, and n dine Integrator or a plnnJmetcr, Measure the peak height: II,. Record A, cr.d the retention tune. Repeat the Injection at least two tunes or until two consecutive vinyl chloride pcults do not vary in area more than 5%. The average value for these two areas v.111 bo used to compute the hag concentra tion. Compare the ratio of H> to A- for the vinyl chloride cample with the same ratio for the standard peak which Is clotw. in height. As a guideline, If thee* ratios differ by more then 10%, the vinyl chloride peak may nc-t be pure (potslhiy acetaldehyde Is present) end the secondary column should be em ployed (see Section 422). 6.5 Measure the ambient temperature and barometric pressure near the bag, (Assume the relative humidity to be 106 percent.) From a water saturation vapor pressure table, determine the record and water vapor con tent of the bag. - 7. Calibration and Standards. 7.1 Preparation of vinyl chloride standard gas mixture*. Evacuate a sixteen-inch square Tedlxr bag that has passed a leak check (described in Section 7.4) and meter in 5.0 liters of nitrogen. While tbe bag Is filling, use the 02 ml syringe to Inject 250si of 09.2-1- % .vinyl chloride through the wall of the bag. Vpoa withdrawing the syringe needle. Im mediately cover the resulting hole with a piece of adhesive tope- This gives a concen tration of 50 ppm of vinyl chiarid*, in a like manner use the other syringe to prepare dilu tions having 10 and 5 ppm vinyl chloride concentrations. Place each bag on a smooth surface and alternately depreee Opposite aides of the bag 50 times to further mix the gases, 72 Determination of Ttnyl chloride re tention time. This section can be performed simultaneously with Section 72. Establish chromatograph conditions identical with those In Section 62, above. Set attenuator to X l position. Flush the sampling loop With aero helium or nitrogen and activate the sample valve. Record the Injection time, the sample loop temperature, the column temperature, the carrier gas flow rate, the chart speed and the attenuator setting. Record peaks and detector ketponscs that occur in the absence of vinyl chloride. Main tain condition*. With the equipment plumb ing arranged identically to Section 62. flush the sample loop for 30 seconds at the rate of 100 mi/min with one of tbe vinyl chloride calibration mixtures and activate the sample valve. Record tbe injection time. Select tbe peak that corresponds to vinyl chloride. Measure the distance on tbe chart from the Injection time to the time at which the peak maximum occurs. This quantity, divided by the Chart speed. Is defined as tbe retention time. Record. 72 Preparation of chromatograph cali bration curve. Make e gas cbtematographlo measurement or each standard gas mixture (described In Section 7.1) ruing conditions Identical with those listed In Section 62 above. Flush the sampling loop for 30 seconds at the rate of 100 ml/mln with each standard gee mixture and activate the sample voire. Record C,, the concentrations of vinyl chl^ ride Injected, the attenuator setting, chart peed, peak area, cample loop temperature. Column temperature, carrier gas flow rate, and retention time. Record the laboratory pressure. Calculate A,, the peak area multi- ZD Co CO Ol KOUAl ItCIltM, VOU 41, HO. 2--THUtJOAT, CIO6U 21, 19/4 - * e** * . . . 'ra. RULES AND REGULATIONS 40.171 piled by the attenuator .-`ttlN- Kop-.it pnl;l two Injection areas ore v.KMn 6%, thou plot rbeoe points vs C,. When the other coaven- Vrallons have boon phllhl. drew & smooth curve through the polntn. J'erlorm ciwli.ara- tlon daily. or before nud otter cncbstt of bug r.amplej, whichever In more Iruj ^ot. 7A hog leak eiuo-ti. While performance Ot this section In required euh-tequvnt to br.-f 'li e, It la also advised tint It ho performed prior to bag tine. After each line, uiut.o sure a bn; did r.ot develop Icuks os follows. To lea's Chech, connect a water rnenometer and prt.nMtrUe the hr.; to 5-10 cm H.O 12-4 In H.O). Allow to stand for 10 minute*. Any displace ment In the water manometer Indicate* a leak, Abo check the rigid container for leaks In this maimer. (Note: An alternative leak check method Is to pressurize the bag to 5-10 cm H.O or 2-4 In. HtO and allow to stand overnight. A deflated ba; Indicates a leak.) For each sample bag in Its rigid container, ploe* a rotameter In-line between the bag ami the pump Inlet. Evacuate the beg. Failure of the rotameter to register zero sow when the has appear* to be empty indicates a leek. S, Calculations. *4 Determine the sample peak area as follows; a Win *f Bah law aa a?actfla intau 4w art IIIIIIHII aMW I* |M MnaaiUl tncaulaa It III/. Am At Mrnvon 107--DcTsawnfATioK or Vwn Crmo- mg and 4X10" mg. With proper calibration, Equation 105-1 ame Comttoi op iMvaoccss Wasrzwana the upper limit tuny be attended as needed. A,--Tba sampta peak ares. A---7'ha maasuied pack arm. A/--The aiucoatlmi iaeter. Stmct. am* Vom. CeojOUde Context or 8. Precision and Reproducibility. Polttovti. CatotM Besik, Sutskt, Wet An intcrlaboratory oomparUon batween Coke, ANO Latex Eutria seven laboratories of three resin samples, U Vinyl chloride oonceatratlone. from the calibration curve described In Section TJ, above, select the value of O, that correeponda to A,. the nample peak area. Cal culate Ct as follows: tMTVOOVCnOK Performance of this method should not be attempted by persons unfamiliar with the operation of a gee ebromnto^nph. nor by those who are unfamiliar with sampling, os each split into three parts, yielded a standard deviation of 2.03% for a sample with a mean of 2,09 ppm. 4.10% for a sample with a mean of 1.00 ppm. and 030% for a sample with a mean of 0230 ppm. 4. Safety. C C.P.T, PtTmil-Bwt) there are many detail* that.are beyond the Do not release vinyl chloride to the labora eoope of this presentation. Care must be tory atmosphere during preparation of stand exercised to prevent exposure of sampling ards. Venting or purging with VCM/aIr m.ls- Equation 105-3 personnel to vinyl chloride, a carcinogen, 1. Principle and Applicability. . turct must be held to a minimum. When they are required, the vapor must be touted / Where: S.l-Tba water vapor muleotef the bee samUe.'ea eoalyted. CiTta eeaeaattsUea ef vioyl cbkxlda la the bee ample la ppm. C.--The eooecbtiatten of vioyl cblarlde indicated by the y*s ebrcicatcymph, la pptn. P.-Tba iwimnot praaciia, the labontery pnenu* iseerdtd during eaUbraUoe, nun Ur. r<*Tbe sample leap temp-mars oa the st--olats _ stale at theliaie ef aaslysb, *K. P,TbUsp.laboratory pratsure at Uma ef acalyds, n T. -Tba islanae* tenparslure, the rampie loop temperature (needed during calibration,'`k* S. Beference*. 1. Brawn, D. W, Loy, E. W. and Stephen son, M. K. "Vinyl Chloride Monitoring Beer the B. P. Goodrich Chemical Company In IauIstUI#, Kentucky." Be;ton TV, VS. Envi ronmental protection Agenoy, SurreUianco and Analyab Division, Athena, Georgia, June 21, 1974. 2. "Evaluation or A Collection and Analy tical Procedure far Vinyl chloride in Air." by G, D. Clayton and Assoclatea, December 13, 1974. EPA Contract No. M-03-1408. Tank Order Bo. 3. EPA Report ON. 75-VCIr-l. 3. "Standardization of Stationary Source 1.1 The basis for this method relntee to the vapor equilibrium which Is established between BVCM, FVC, resin, water, and air In a closed system. It has been demonstrated that the BVCM in a FVC resin will equili brate In n doled vessel quite rapidly, pne vided that the temperature of tho pvo renin Is maintained above the glass transition temperatureof thatepedflc resin. , 13 This procedure Is suitable for deter mining the vinyl chloride monomer (VCM) content of lnproeese wastewater samples, and the residual vinyl chloride monomer (BVCM) content of polyvinyl chloride (FVC) wains, wet cake, slurry, and latax samples. It cannot be used lor polymer In fuaed form, such aa sheet or cube*. If a resolution of the vinyl chloride peak 1* not satisfactory for a particular sample, then chromatograph parameters may be eltered with 'prior ap. proral of the Administrator. If there le rea son to believe thet some otbor hydrocarbon with an Identical retention time le present In the sample, then supplemental confirma tion of the vinyl chloride peak through an absolute analytical technique, such ae mass spectroscopy, should ho performed. 2. Bange and Sensitivity. to outside air. Vinyl chloride, even at low ppm levels, must nerar ba vented Insloe the laboratory. After viols have been analyzed, the pressure within the vial must be vented prior to femoral from the Instrument turn table. Vials must bo vented into an activated charcoal tube using a hypodermic needle to '-prevent release or vinyl chloride Into the laboratory atmosphere. The charcoal must be replaced prior to vinyl chloride break through. 8. Apparatus. 5.1 Sampling. 6.1- Bottles--CO ml (3 oz), with waved lined screw on tops, for PVO samples. 8.13 Vlale--SO ml Hypo-vials.1 seeled with Teflon faced Tuf-Bond disc* for water cam ple*. 6.13 Electrical tape or equivalent, to provent loosening of bottle tops. 63 Sample recovery. 63.1 Vl*l--With seels and caps, PerkinElmer Corporation No. 106-0113, or equiva lent. 633 Analytical balance--Capable M weighing to *0301 gram. 633. Syringe, 100 pi--Precision Series "A" Ba 010026. or equivalent. Embalon Method for Vinyl Chloride," by Mid The lower limit of detection of vinyl chlo west Reeeareh Institute, J07. EPA Contract Bo. 66-02-1098, Task Order No. T. ride win vary according to the chromato graph used. Values reported include 1X19* Mention ef trade names oa specific prod ucts dace hot constitute endorsement by the Environmental Protection Agency, KDUAL 2EOI5TU, VOL 41, NO. J0J--THUttoAV, CTOBEt 21, 1976 . L 30 0) trno to <o 4G572 RULES AND REGULATIONS 8J>.4 VIiU r-alor. Port.lo-Mmer Jlo. 105- sealing and weighing, using a 100 rl syringe. tor--ignite the detector according to the 0103 cr equivalent. 63 At--U. 5^,1 o*.t In the cans of dispersion Wiluv, Woe cup manufacturer'* Instructions. cannot he uacd. TLlje cample h Instead 73.1.4 Amplifier balance--Dslanoe the l*frtln-P.ner weighed approximately In an aluminum dish, amplifier according to the manufacturer's Oorj>tri'.ti'.,ii MwSol >'-l0 Lewl**poe an*- transferred to the tured vial and wclyhcd Instraction*. lj-e,-, Ho. ibt-CviOL, or equivalent, accurately in the vlaL The cample is then 733 Programming the chromatoprspii-- 633 C.'.ito;t.Mo/rt.p!i;e column--Staln- placed in the perkln-Elmer bead tpace ana Program the chromatograph u follows; j-.j fct/.v!. 3 r.t>:33 mm. contalr.lu 0.4* lyzer (or equivalent) and conditioned for one a. I--Doting time--The normal setting Is CarlKivmx tW) on CurbopaV A, Pcrfcla-Elmrr hour at 60*C. 3 seconds. Corporation Ho. 103-0133, or equivalent- Note: Bom* aluminum vial caps have a b. A--Analysis time--The normal Betting Carbopab C enn bo used la pine* oI Cwbopok center section which must be removed prior Is g minutes. Certain types of samples con A. to placing Into sample tray. If not removed, tain hlgb boiling materials which can cause 5.3.3 tr/.TrtAOtncter--0 to 100* C. accurate serious damage to ths Injection needle will interference wtlh the vtnyt chloride peek on to d.0.1* C. Fcrkln-Kimer llo. 105-0109 or occur. subsequent analyses. In thsae cases tbe equivalent. 733 Suspension resin slurry and wet cake analysis time must be adjusted to eliminate 6.3.4, fismple tray thermostat eystem-- samples--Blurry must be filtered using a tbe Interference. An .automated becknush perkln-Hsir-sr Ho. 105-0103, or equivalent. small Buchner funnel with vacuum to yield system can also be used to solve this prob 6.3.5 --Sandwich typo, lor auto wet cake. The filtering process mutt be con lem. matic docUsc. 1J mm, Pcrkln-Llmer No. 105- tinued only as long as a steady stream of C..B--Flushing--The normal setting Is 03 1006. or equivalent. water is exiting from the funnel. Excessive minutes. 63.6 JouqtaUTT - recorder -- Hewlett - filtration time could result In coma loss of d. \V--Stabilization time--Ths nomal set Packard Model 3330A. or equivalent. VCU- The wet cake sample (0.10 to 43 grains) ting la 03 minutes. 63.7 Filter drier assembly (3)--Perkln- Is added to a tared vial (Including septum e. X--Number of analyses per sample--The rim.r no. 230117, or equivalent. and aluminum cap) and Immediately sealed, normal setting Is 1. 633 Soap nim flowmeter*--Hewlett Pack fiamplo weight Is then determined to 3 deci 733 Preparation of sample turntable--Be- ard No. 0101-0113, or equivalent. mal places. The sample la then placed In the fora placing any sample Into turntable, be 6.4 Calibration. Pcrkin-Elmcr heed apace analyzer (or equiva certain that the center section of the alu 6.4.1 Regulator*--lor required gas eyln- lent) and conditioned for one hour at 90*C. minum cap has bean removed. The numbered dor*. A sample of wet cake Is used to determine sample bottles should ba placed in the cor 0. Reagents. C.l Analysis. 0.1.1 Hydrogen gas--eero grade. TS (total solids). This Is required lor calcu respondini numbered positions In the turn lating the RVCM. table. Insert samples in the followlna order: 733 Dispersion Ksln slurry camples,-- Positions I it 3--Old 3000 ppm standards 033 Nitrogen fa--eero grade. This material should not be filtered. Sample for conditioning. These ere necessary only 03J Air--aero grad*. . 03 Calibration. .must bo thoroughly mixed. Using a tared after the analyzer has not been used for 34 vial (Including septum end aluminum cap) hours or longer. 03.1 Standard cylinder* (4)--one each add approximately a drop* (03S to 035 Position 3--50 ppm standard, freshly pre of 60, 600, 2000, and 4000 ppm Vinyl chloride grama) of slurry or latex using a medlclns pared. In nitrogen, with certified analytic. dropper. This should be dona immediately Position 4--600 ppm standard, freshly pre- 7. Procedure. . 73 Sampling. after mixing. Seal the vial aa soon a* possible. Determine sample weight accurate to 0301 Position 6--3000 ppm standard, freshly grama. Total sample weight must not exceed prepared. 733 PVO sampling--Allow the resin or 030 grams. Condition the vial for one hour Position 6--4000 ppm standard, freshly pre lurry to flow from a tap on the tank or alio at 00*C Ip tbe analyzer. Determine the TS pared. until the tap line baa been wall purged. Ex on the alurry ----pi- (Section 733). Position 7--Sample No. 7 (This la the first tend a CO ml sample bottle under the tap. Oil. 73.4 Inproeeee wastewater samples-- ample of the day, but Is given as 7 to be con and Immediately tightly cap the bottle. Wrap Using a taxed vial (Including septum and sistent with tbs turntable and the Integrator electrical tape around the cap and bottle to aluminum cap) quickly add approximately printout.) prevent tbe top from loosening. Place an 1 ee of water using a medicine dropper. Seal After all samples have been positioned, in identifying label on each bottle, and reoord tbe vial aa soon aa possible. Determine sert tbe second act of 60. 600. 3000, end 4000 the data, tune, and sample location both on aampla weight accurate to 0301 gram. Con ppm standard*. Semples, including stand the bottles and In a log book. dition the vial far two hour* at 90*C In the ards must be conditioned in the bath of 733 Water sampling--Prior to use. the analyzer. 0 ml rials (without the discs) must be 73 Analysis. SO* O for 1 bow (not to exceed 6 hours). 73.4 Start chromatograph program-- capped with aluminum foil and mufSed at 733 Preparation of gaa chromatograph-- When all samples. Including standards, have 400*0 lor at least one hour to destroy or Install the chromatographic and con been conditioned at 90* C for 1 how, start remove any organic matter that oould In dition overnight at 160*0. Do hot connect the the analysis program according to the manu terfere .With analysis. At the sampling loca exit end of the,column to the detector while facturers' .Instructions. These Instructions tion fill, the vials bubble-free, to overflowing conditioning. must be carefully followed when starting so that a convex meniscus forms at the. top. 7333 Plow rate adjustments--Adjust 'and stopping program to prevent damage to The exceas water I* displaced as the sealing flow ratee aa follows: the doting assembly. . disc Is carefully placed. Teflon aide down, on the opening of the vlaL Place the aluminum a. Nitrogen carrier gas--Set regulator on cylinder to read 60 pstg, set regulator on - 733 Determination of total solids (TS). For wet cake, slurry, resin solution, and seal over the disc and the neck of the vial and crimp Into place. Afhs an Identifying label on the bottle, and record tbe date, time, and sample location both on the vials and chromatograph to 13 kg/em'. Normal flowa at this pleasure should be 35 to 40 ec/minute. Chock with bubble flow meter. b. Burner air supply--Set regulator on cyl PVC latex samples, determine TS for each sample by accurately weighing approxim ately 3 to 4 grains of aampla In an aluminum pan before and after placing in a draft in a log book. All samples must be kept re inder to read 60 pslg. Set regulator on oven (105 to 110* C). Samples must be dried frigerated until analysed. chromatograph to supply air to burner at a to constant weight. After Drat weighing re 73 Sample recovery. Samples must be run . rata between 360 and 300 cc/mlnute. Check < within 34 hour*. with bubble flowmeter. 733 Resin sample*--The weight of the resin used must be between 03 end 43 grams. An exact weight must be obtained (0301 gram) for each aampla In the case of sus pension resins a volumetric cup can be pre pared which will bold tbe required amount of aampla. The sample bottle la opened, and the cup volume of resin Is added to the tared ample vial (Including septum ut alumi num cap). The vial is immediately scaled and the exact cample weight is then obtained. Report this value on the data sheet as It U required for calculation of RVCM. In the 3. Hydrogen supply--Set regulator on cyl inder to reed 30 pslg. Set regulator on chromatograph to supply approximately 335 cc/mlnute. Optimize hydrogen flow to yield tbe moat sensitive detector response without extinguishing the Same. Check flow with bubble meter and record this flow 73.13Temperature , adjustments--Set temperatures as follows: a. Oven (chromatographic column), 60* C. b. Dosing Una, 140* O. c. Injection block. 140* C. cate of relatively dry resin samples (water d. Semple chamber, water temperature, turn the pan .to the oven tor a abort pe riod of time and then rewetgh to verify com plete dryness. TS la then calculated aa the final sample weight divided by sam ple weight. 6. Calibration. Calibration *le to be performed each eight- how period when the Instrument la used. Each day. prior to running sample*, the col umn should ha conditioned by running two of the previous days 3000 ppm standards. 6.1 Preparation of Standards. Calibration atandards are prepared by fill ing the vials with the vinyl chloride/nitro gen standards, rapidly sealing the septum and seating with the aluminum cap. Use a stainless steel line from the cylinder to tbe content <03 weight *). 100 ,1 of distilled 00* C13* C. vial. Do not use rubber or tygon tubing. Tbe water must bo Injected Into the vial, after 73.13 Ignition of flame ionization detec ample line from the cylinder must be 3J fi (/> cn to CO o R0I3AI. KEOKUK, VOL 41, NO. 105--THURSDAY, OCTOSII 31, 1974 RULES AND REGULATIONS purged (1aU> li<yl) /or several minute* prior to fUllcjr vials. After purging, reduce the flow rete to approximately 500-1000 ee/ndu. Piece end of tubing Into v:l (near bottom) nod after one minute slowly remove ttilling. Place septum In vial M soon ns possible to minimire mixing sir wltli sample. After the stand ard vlnlj aro scaled. Inject 100^,1 of distilled water. 6.2 Preparation of chromatograph calibra tion curve. prepare two 00 ppm, two 500 ppm. two 2000 ppm, and two 40C0 ppm standard r.mr.plcs. l;un the calibration samples In exactly the same manner as regular samples. Plot A., the Integrator area Counts for rwh standard ample vs C,. the concentration of vinyl chloride In each standard cample. Draw a line of best lit through the poiuts. 9, Calculations. B.l response factor. Prom the calibration curve described in Section 8.2, above, seiget the value of C< that corresponds to A, for each sample. Com pute the response lector. Rt, tor each sample, as follows: bi Equation 107-1 9.3 Residual vinyl chloride monomer con centration. or vinyl chloride monomer eoncentrattou. Calculate Cr, as follows: Cm Af.v t+KT,') wt| R Equation 107-2 Cl,,-Conevntr*Uoa el vtnyl ehloctde la Ox Hieph, to ppm. P,--laboratory atSMSpbm |*w*uie. mm II(. . Ti--IIoots teiaperstnn. *JC. M^sMdtmlu weight elVCM (Ri). V,--Volamt of vapor phase (vtet volume lem temple volume). eu--'Weifht el tempi*, crams. A--Qei cotuteat t<34ti)). A'-Beory-t law constant (or VCM Is PVC at *o*c. A'-M2xio-*-x, tor vcm i* i (epproiimsU) wasteweter temple el PTC, JC-SCXllr'-XIWKftullibrsUee lemperehm. *. If the (eOewlec eendltlent ti* met, Equation IJf-1 * ma be apafied as lebewK l r.-zro ras* jcn" A Ti -B7- 0 (SoT K). A P.-750 mm. He- vM Vv**Vltl tolumt, fi. B&aipl* efratalc* Way ti**n 0J% w*Ur 107X10"*+ 5,0S3XlQ-\ m, J Equation 107-3 TM fuIk>u(nK f*n*r*t c*ui M u.*M far my *rh*1U which tout*in* VCW, 1*VC *n4fDf WAUr, c,,, X/C.(7'A-; T. t A'-fl-rSjrtJ when: Equation 107-1 T,-Total ultd*. Note: If. must be determined. Results calculated using Kquatlon 107-4 represent concentration booed on lbs total eunpte. To obtain results based on dry PVC content, divide by TS. Fore 1 ec Upproxlmete) westovtWmtsple, Kocedes 107-4 een be tlwpblled to the loUowlaf: [S10-+ (2.006X 10-*)] Equeiiob 107-5 10. References. 1. Residual vinyl Chloride Monomer Con tent of Polyvinyl Chloride Reams and Wet Cake Semples, B. P. Qoodrich Chemical Co. Standard Test Procedure No. 1005-T. B. F. Goodrich Technical Center, Avon Lake, Ohio. January 30, 1875. 3. Boren*. A. XI, The Solubility of Vinyl Chloride in Polyvinyl Chloride." ACS-Divlslon of Polymer Chemistry, Polymer Pre prints IS (3): 197,1874. 3. Barons, A. R, "The Diffusion of Vinyl Chloride in Polyvinyl chloride." ACS-Dlvlslon of Polymer Chemistry, Polymer Pre prints IS (3): 303,1974. 4. Berens. A. R, L. 8. Crider, C. 3. Tomenek and J. M. Whitney, Analysts tor Vinyl Chloride In PVC Powders by Heed-Space Oas Chromatography," to be published. (PRDoc.76-30849 Filed 10-30-75:3:45 am] :e;73 R&s 115231 KDCtAl lECiStEK, VOL 41. MO. 103--THUtSDAT. OCTOStt 31, 187* APPENDIX 3 RESOLUTION NO. 77-40 A Resolution of the South Coast Air Quality Management District Board enacting Rule 1005, Emission Standard for Vnyl Chloride. BE IT RESOLVED that the South Coast Air Quality Management Board in regular session assembled on September 14, 1977, hereby adopts Rule 1005 as attached hereto. That rule to become effective upon the date that the United States Environmental Protection Agency delegates authority to implement and enforce this rule to the South Coast Air Quality Management District. DATED: SEPTEMBER 14, 1977 Ayes: Beam, Geoghegan, Hansberger, Harwood, Heii.aheimer, Raver, McCandl Noes: None Absent: Braude, Haley, Meade f R&S 115232 R&S 115233 SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT Proposed Rule *1005 Emission Standard for Vinyl Chloride For Hearing on September 2, *1977 t ADOPTED toy V* Couth Cont Air Quality |^nafnit Di*trtet Boirtl Resolution No. 77-40 ' Rule 1005 Emission Standard for Vinyl Chloride R&S 115234 (a) Applicability (1) This rule applies to plants which produce: (A) Ethylene dichloride by reaction of oxygen and hydrogen chloride with ethylene, (B) Vinyl chloride by any process, and/or (C) 'One or more polymers containing any fraction of polymerized vinyl chloride. (2) This rule does not apply to equipment used in research and development if the reactor used to polymerize the vinyl chloride processed in the equipment has a capacity of no more than O.19 (50 gal). (3) Sections of this rule other than (e)(1)(A), (2), (3) and (4-) do not apply to equipment used in research and development if the reactor used to polymerize the vinyl chlopide processed in th * equipment has a capacity of greater than 0.19 m^ (50 gal) and no more than 4.07 (1100 gal). (b) Definitions * (1) ETHYLENE BICHLORIDE PLANT includes any plant which produces ethylene dichloride by reaction of oxygen and hydrogen chloride with ethylene. (2) VINYL CHLORIDE PLANT includes any plant which produces ' vinyl chloride by any process. (3) POLYVINYL CHLORIDE PLANT includes any plant where vinyl chloride alone or in combination with other materials is polymerized. R& s 115235 (A) SLIP GAUGE means a gauge which has a probe that moves through the gas/liquid interface in a storage or transfer vessel and indicates the level of vinyl chloride in the vessel by the physical state of the material the gauge discharges. (5) TYPE OF RESIN means the broad classification of resin referring to the basic manufacturing process for producing that resin, including, but not limited to., the suspension, dispersion, late;*:, bulk and* solution processes. (6) GRADE OP RESIN means the subdivision of resin class ification which describes it as a unique resin, i.e., the most * exact description of a resin with no further subdivision. (7) DISPERSION RESIN means a resin manufactured in such a way as to form fluid dispersions when dispersed in a plasticizer or plasticizer/diluent mixtures. (8) LATEX RESIN means a resin which is produced by a polymerization process which initiates from free radical catalyst sites and is sold undried. (9) BULK RESIN means a resin which is produced by a polymerization process in which no water is used. (10) INPROCESS WASTEWATER means any water which, during manu facturing or processing, comes into direct contact.with vinyl chloride or polyvinyl chloride or results from the production or use of any raw material, intermediate product, finished product, "by-product, or waste product containing vinyl chloride or polyvinyl chloride but -which has not been discharged to a wastewater treatment process or discharged untreated as wastewater. (11) WASTEWATER TREATMENT PROCESS includes any process which modifies characteristics such as BOD, COD, ISS and pH, usually j'or the purpose of meeting ffluent guidelines and standards; it does not include any process the purpose of which is to remove vinyl chloride from water, to meet requirements of this subpart. (12) IK VINYL CHLORIDE SERVICE means that a piece of equip ment contains or contacts either a liquid that is at least 10 percent by weight vinyl chloride or a gas that is at least 10 percent by volume vinyl chloride. (13) STANDARD OPERATING PROCEDURE means a formal written procedure officially adopted by the plant owner or operator and available on a routine basis to those persons responsible for carrying out the procedure. (14) RUN means the net period of time during which an emission sample is collected. (15) ETHYLENE DICHLORIDE PURIFICATION includes any part of the process of ethylene dichloride production which follows ethylene dichloride formation and in which finished ethylene dichloride is * produced. (16) VINYL CHLORIDE PURIFICATION includes any part of the process of vinyl chloride production which follows vinyl chloride formation and in which finished vinyl chloride is produced. (17) REACTOR includes any vessel in which vinyl chloride is partially or totally polymerized into polyvinyl chloride. (IS) REACTOR OPENING LOSS means the emissions of vinyl chloride occurring when a reactor is vented to the atmosphere for any purpose other than an emergency relief discharge as defined in (f)(1). (19) STRIPPER includes any vessel in which residual vinyl chloride is removed from polyvinyl chloride resir., except bulk resin, in the slurry form by the use of heat and/or vacuum. In the case of R&S 115236 R&S 115237 "bulk resin, stripper includes any vessel which is used to remove residual vinyl chloride from polyvinyl chloride resin immediately following the polymerisation step in the plant process flow. (c) Emission standard for ethylene dichloride plants. * An owner or operator of an ethylene dichloride plant shall comply with the requirements of this section and section (f). (1) Ethylene dichloride purification: The concentration of vinyl chloride in all exhaust gases discharged to the atmosphere from any equipment used in ethylene dichloride purification is not to exceed 10 ppm, except as provided in (f)(1). This requirement does not apply to equipment that has "been opened, is out of operation, and met the requirement in (f)(2) before being opened. (2) Oxychlorination reactor: Except as provided in (f)(1), emissions of vinyl chloride to the atmosphere from each oxychlorination reactor are not to exceed 0.2 'gAg (0.0002 lb/lb) of the 100 percent ethylene dichloride product from the oxychlorination process. (d) Emission standard for vinyl chloride plants. An owner or operator of a vinyl chloride plant sh-11 comply with the requirements of this section and section (f). Vinyl chloride formation and purification: The concen tration* of vinyl chloride in all exhaust gases discharged to the atmosphere from any equipment used ir. vinyl chloride formation and/ or purification is not to exceed 10 ppm, except as provided in (f)(1). Tnis requirement does not apply to equipment that has been opened, is out of operation, and met the requirement in (0(2)(F)(i) before no i.ng opened. I (e) Emission standard, for polyvinyl chloride plants. An owner or operator of a polyvinyl chloride plant shall comply with the requirements of this section, and section (f). R &s 115238 (1) The following requirements apply to reactors: (A) The concentration of vinyl chloride in all exhaust gases discharged to the atmosphere from each reactor is not to exceed 10 ppm^ except as provided in paragraph ("0(B) of this section and section (f)(1). (B) The reactor opening loss from each reactor is not to exceed 0.02 g vinyl chloride/Kg (0.00002 lb vinyl chloride/lb) of polyvinyl chloride product, with the product determined on a dry solids basis. This requirement applies to any vessel which is used as a reactor or as both a reactor and a stripper. In the bulk process, the. product means the gross product of prepolymeriz^^m and postpolymerizatioii. * (C) Manual vent valve discharge: Except for an emergency manual vent valve discharge, there is to be no discharge to the * atmosphere from any manual vent valve on a polyvinyl chloride reactor in vinyl chloride service. An emergency manual vent valve discharge means a discharge to the atmosphere which could not have been avoided by taking measures to prevent the discharge. Within 10 days of any discharge to the atmosphere from any mar^ai vent valve, the owner or operator of the source from winch the discharge occurs shall submit to the Air Pollution Control Officer a report in writing containing information on the source, nature and cause of the discharge, the date and tine of the discharge, the approximate total vinyl chloride lore during the discharge, the method used for determining the vinyl chloride loss, the action that v/as taken to prevent the discharge, and measures adopted to prevent future discharges. (2) Stripper: The concentration of vinyl chloride in all exhaust gases discharged to the atmosphere from each stripper is not to exceed 10 ppm, except as provided in (f)(1). This requirement does npt apply to equipment that has been opened, is out of operation, and met the requirement in (f)(2)(F)(i) before being opened. (5) Mixing, weighing, and holding containers: The concen- * tration of vinyl chloride in all exhaust gases discharged to the atmosphere from each mixing, weighing, or holding container in vinyl chloride service which' precedes the stripper (or the reactor if the plant has no stripper) in the plant process flow is not to exceed 10 ppm, except as provided in (f)(1). This requirement does not apply to equipment that has been opened, is out of operation, and met the requirement in (f)(2)(F)(i) before being R&S 115239 opened- (4) Monomer recovery system: The concentration of vinyl chloride in all exhaust gases discharged to the atmosphere from each monomer recovery system is not to exceed 10 ppm, except as provided in (f)(1). This requirement does not apply to equipment that has been opened, is out of operation, and met the requirement in (f)(2)(F)(i) before being opened. (5) Sources following the stripper: The following require ments apply to emissions of vinyl chloride to the atmosphere from the combination of all sources following the stripper (or the factor if the plant has r.o r.trirpor) in plant r-roccr.s flow including but not limited to, centrifuges, concentrators, blend tanks, filters, dryers, conveyor air discharges, baggers, storage containers, and inprocess wastewater: (A) In polyvinyl chloride plants using stripping technolo^^ to control vinyl chloride emissions, the weighted average residual vinyl chloride concentration in all grades of polyvinyl chloride resin processed through the stripping operation on each calendar day, measurec immediately after the stripping operation is completed, may not exceed: (i) 2000 ppm for polyvinyl chloride dispersion resins, excluding lateX resins; (ii) 400 ppm for all other polyvinyl chloride resins, including latex resins, averaged' separately for each type of resin; or (B) In polyvinyl chloride plants controlling vinyl chloride emissions with technology other than stripping or in addition t stripping, emissions of vinyl chloride to the atmosphere may not exceed: (i) 2 g/kg (0.002 lb/lh) product from the stripper (or reactor if the plant has no stripper) for dispersion polyvinyl chloride resins, excluding latex resins, with the product determined on a dry solids basis; (ii) 0.4 gAg (0.004 IbAb) product from the stripper (or reactor if the plant has no stripper) for all other poly vinyl chloride resins, including latex resins, with the product determined on a dry solids basis. (f) Additional standards for 'ethylene dichloride, vinyl chloride and % polyvinyl chloride plants. In addition to other requirements in this rule, an owner or operator of ar. ethylene dichloride, vinyl chloride, and/or polyvinyl chloride plant shall comply with the requirements of this section. R&S 115240 linn I Hi HHWUBW sat mu v (1) Relief valve discharge: Except for an emergency relief discharge, there is to be no discharge to the atmosphere from any relief valve on any equipment in vinyl chloride service. An emergency relief discharge means a discharge which could not have been avoided by taking measures to prevent the discharge. V/ithin 10 days of any relief valve discharge, the owner or operator of the source from* which the relief valve discharge occurs shall submit to the Air Pollution Control Officer a report in writing containing information on the source, nature and cause of the * discharge, the date and time of the discharge, the approximate total vinyl chloride loss during the discharge, the method used for determining the vinyl chloride loss, the action that was taken to prevent the discharge, and measures adopted to prevent future discharges. R&S 115241 (2) fugitive emission sources: (A) Loading and unloading lines: Vinyl chloride emis sions from loading and unloading lines which are opened to the atmosphere after each loading or unloading operation are to be minimized as follows: (i) After each loading or unloading operation and before opening a loading or unloading line to the atmosphere, the quantity of vinyl chloride in all parts of each loading or unloading line that are to be opened to the atmosphere is to be reduced so that the parts combined contain no greater than 0.00?Q (0.15 ft^) of vir.yl chloride, at standard temperature and pressure; and (ii) Any vinyl chloride removed from a loading or nnlonctrc line in accordance with parnr-r.'cch (?)(R)(n) of thir cc'rMor. * is to be ducted through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed TO ppn, or equivalent as provided in (g). (B) Slip gauges: During loading or unloading operations, the vinyl chloride emissions from each slip gauge in vinyl chloride service are to be minimized by ducting any vinyl chloride discharged from the slip gauge through a control system from which the concen tration of vinyl chloride in the exhaust gases does not exceed 10 ppm, or equivalent as provided in (g)- (C) Leakage from pump, compressor, and agitator seals: (i) Rotating pumps: Vinyl chloride emissions from seals on all rotating pumps in vinyl chloride service are to be minimised by installing sealless pumps, pumps with double mechanical seals, or equivalent as provided in (g). If doubl mechanical seals are used, vinyl chloride emissbn from the seals ar to he minimized hy maintaining the pressure between the two seals so that any leak that occurs is into the pump; by ducting any vinyl * chloride between the two seals through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm; or equivalent as provided in (g). (ii) Reciprocating pumps: Vinyl chloride emissions from seals on- all reciprocating pumps in vinyl chloride service are to be minimized by installing double outboard seals, or equivalent as provided in (g). . If double outboard seals are used, vinyl chloride emissions from the seals are to be minimized by main taining the pressure between the two seals so that any leak that occurs is into the pump; by ducting any vinyl chloride between the two seals through a control system from which the concentration e,*' vir.yl chloride in the exhaust gases does not exceed 10 port; or equivalent as provided in (g). R&S 115242 B&S 115243 (iii) Rotating compressor: Vinyl chloride emis sions from seals on all rotating compressors in vinyl chloride service are to he minimized hy installing compressors with double mechanical seals, or equivalent as provided in (g). If double mechanical seals are used, vinyl chloride emissions from the seals are to be minimized by maintaining the pressure between the two seals so that any leak that occurs is into the compressor; by- ducting any vinyl chloride between the two seals through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm; or equivalent as provided in (g). (iv) Reciprocating compressors: Vinyl chloride emissions from seals on all reciprocating compressors in vinyl chloride service are to be minimized by installing double out board seals, or equivalent as provided in (g). If double out- * board seals are used, vinyl chloride emissions from the seals are to be minimized by maintaining the pressure between the two seals so that any leak that occurs is into the compressor; by ducting any vinyl chloride between the two'seals through a -ontrol system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm; or equivalent as provided in (g). (v) Agitator: Vinyl chloride emissions from seals on all agitators in vinyl chloride service are to be minimized by installing agitators with double mechanical seals, or equivalent as provided in (g). If double mechanical seals, are used, vinyl chloride emissions from the seals are to be minimized by maintaining the pressure bet ween the two seals so that any leak o::'..-.: \uK'. by d a:L i .'.g a::y vinyl uh'-.C between the two seals through a control system from which the *-4-JM  > R&S 115244 concentration of vinyl chloride in the exhaust Eases does not exceed 10' ppm; or equivalent as provided in (g). (D) Leakage from relief valves: Vinyl chloride emis sions due to leakage from each relief valve on equipment in vinyl chloride service are to be minimized by installing a rupture disk between the equipment and the relief valve, by connecting the relief valve discharge to a process line or recovery system, or equivalent * as provided in (g). (E) Manual venting of gases: Except as provided in * (e)(1)(C), all gases which are manually vented from equipment in vinyl chloride service are to be ducted through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm; or equivalent as provided in (g). (F) Opening of equipment: Vinyl chloride emissions from opening of equipment (including loading or unloading lines that are not opened to the atmosphere after each loading or un loading operation) a!re to be minimized as follows: (i) Before opening any equipment for any reason, the quantity of vinyl chloride is to be reduced so that the equip ment contains no more than 2.0 percent by volume vinyl chloride or 0.0950n? (25 gal) of vinyl chloride, whichever is larger, at standard # temperature and pressure; and (ii) Any vinyl chloride removed from the equip ment in accordance with paragraph (2)(F)(i) of this section is to be ducted through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm, or equivalent as provided in (g). (G) Samples: Unused portions of samples containing at least 10 percent by weight vinyl chloride are to be returned to the process, and sampling techniques are to be such that sample containers in vinyl chloride service are purged into a closed process system. (H) Leak detection and elimination: Vinyl chloride emissions due to leaks frem equipment in vinyl chloride service are to be minimized by instituting and' implementing a formal leak detection and elimination program. The owner or operator shall submit a description of the program to the Air Pollution Control Officer for approval. The program is to be submitted within 45 days of the effective date of these regulations. Approval of a program will be granted by the Air Pollution Control Officer provided he finds: (i) It includes a reliable and accurate vinyl chloride monitoring system for detection of major leaks and identification of the general area of the plant where a leak is located. A vinyl chloride monitoring system means a device which obtains air samples from one or more points on a continuous sequential basis and analyzes the samples with gas chromatography or > if the owner or operator assumes that all hydrocarbons measured are vinyl chloride, with infrared spectrophotometry flame ion detection, or an equivalent or alternative method. (ii) It includes a reliable and accurate portable hydrocarbon detector to be used routinely to find small leaks said to pinpoint the ma^cr leaks indicated by the vinyl chloride monitoring system. A portable hydrocarbon detector means a device which measures hydrocarbons with a sensitivity of at least "10 ppm and is of such design and size t`-?t it c^n bo used to no sure * emissions from localized uointi.. R&S 115245 (iii) It provides lor an acceptable calibration and maintenance schedule lor the vinyl chloride monitoring * system and portable hydrocarbon detector. For the vinyl chloride monitoring system, a daily span check is to be conducted with a concentration of vinyl chloride equal to the concentration defined as a leak according to paragraph (2)(H)(vi) of this section. The calibration is to be done with either a calibration gas mixture prepared from the gases specified by the Air Pollution Control Officer, or a calibration gas cylinder containing the appropriate concentration of vinyl chloride. If a calibration gas cylinder is used, the analysis must be traceable to the National Bureau of Standards or to a gravimetrically calibrated ` vinyl chloride permeation tube. (iv) The location and number of points to be monitored and the frequency of. monitoring provided for in the program are acceptable when they are compared with the number of pieces of equipment in vinyl chloride service and the size and physical layout of the plant. (v) It contains an acceptable plan of action to be taken when a leak is detected. (vi) It contains a definition of leak which is acceptable when compared with the background concentrations of vinyl chloride in the areas of the plant to be monitored by the vinyl chloride monitoring system. Measurements of background concentrations of vinyl chloride in the areas of the plant to be monitored by the vinyl chloride monitoring system are to be included with the description of the program. The definition of leak for a given plant may vary among the different; areas within the plant and is also to change over time as background concentrations inthe plant are reduced. R&S 115246 R&S 115247 (I) Inprocess Y/astewater: Vinyl chloride emissions to the atmosphere from inprocess wastewater are to be reduced as follows: (i) The concentration of vinyl chloride in each inprocess wastewater stream containing greater than 10 ppm vinyl chloride measured immediately as it leaves a piece of equipment and before being mixed with any other inprocess waste- water stream is to be reduced to no more than 10 ppm by weight before being mixed with any other inprocess wastewater stream which contains less than 10 ppm vinyl chloride, before being dis charged to a wastewater treatment process, or before being dis charged untreated as a wastewater. This paragraph does apply to v/ater which is used to displace vinyl chloride from equipment before it is opened to the atmosphere in accordance with (e)(1)(B) or paragrpah (2)(F) of this section, but does not apply to water which is used to wash out equipment after the equipment has already been opened to the atmosphere in accordance with (e)(1) B) or paragraph (2)(F) of this section. (ii) Any vinyl chloride removed **rom the inprocess wastewater in accordance with paragrpah (2)(I)(i) of this section is to be ducted through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm, or equivalent as provided in (g). (?) The requirements in paragraphs (2)(A), (2)(B), (2)(c), C^)(l''), (?)(G) and (2)(H) of this section are to bo incorporated into a standard operating procedure, and made available upon rorpor.t for inspection by thr- : Control Officer. * standard operating procedure is to include provisions for measuring i- R&S 115248 the vinyl chloride in equipment which is A.75 m^ (1250 gal) -in volume or greater, for v;hich an emission limit is prescribed in (f)(2)(P)(i^^ prior to opening the equipment and using a portable hydrocarbon dector, or an equivalent or alternative method. The method of measure ment is to meet the requirements specified by the Air Pollution Control Officer. (g) Equivalent equipment and procedures. The Air Pollution Control Officer may approve use of equipment or procedures which have been demonstrated to his satisfaction to be equivalent in terms of reducing vinyl chloride emissions to the atmosphere to those prescribed for compliance with a specific paragraph of this rule. For a new or modified source, any * request for using an equivalent method is to be submitted to the Air Pollution Control Officer with the application for authority to construct and permit to operate. * (h) Testing'procedures. (1) Unless a waiver of emission testing is obtained under Rule 1001 (b) each owner or operator of a source subject to the standard in Rule 1005 shall test emissions from that source. Such tests shall be conducted in accordance with the procedures set forth 'below. (2) Emissions shall be tested according to methods specified by the Air Pollution Control Officer: (A) The test shall be performed within 90 days of the effective date of these regulations in the case of an existing source or a new source which has an initial startup date preceding the effective date.  R&S 115249 (E) The test shall be performed within 90 days of start up in the case of a new source which did not have an initial startup cate preceding the effective date. (3) The Air Pollution Control Officer shall be notified at least 30 days prior to an emission test, so that he may, at his option, observe the test. (4) All samples shall be analyzed within 24 hours, and vinyl chloride emissions shall be determined within 30 days after the stack test. Each determination shall be reported to the Air Pollution Control Officer by a registered letter dispatched before the close of the next business day following such determination. (5) Records of emission test results and other data needed to determine total emissions shall be retained at the source and shall be made available for inspection by the Air Pollution Control Officer for at least two years. (i) Emission monitoring. 4 (1) A vinyl chloride monitoring system is to be used to monitor on a continuous basis the emissions from the sources for which emis sion limits are prescribed in (c)(1) and (2); (d)(1),- (e)(1)(A), (2), (3) and (4) and for any control system to which reactor emission are required to be ducted in (f)(2)(A)(ii) and (2)(B), (2)(E), (2)(F)(il) and (2)(I)(ii). (2) The vinyl chloride monitoring system(s) used to meet the requirement in paragraph (1) of this section is to be a device* which obtains sir samples from one or more points on a continuous sequential basis and analyzes the samples with gas chromotogi^phy,or, if the cw.ier uf operator 'a/it .1 hp or* ?.{'. one iw-trurod .?*-_ /ii.yj. chloride, with infrared spectrophotometry, flame ion detection. R&S 115250 tl or an equivalent or alternative method- The vinyl chloride monitoring system used to meet the requirements in (f)(2)(H)(i) , may be used to meet the requirements of this section. (3) A daily span check is to be conducted for each vinyl chloride monitoring system used. For all of the emission sources listed in paragraph (1) of this section, except the one for which an emission limit is prescribed in (c)(2), the daily span check is to be conducted with a concentration of vinyl chloride equal to 10 ppm. For the emission source for which an emission limit is * prescribed in (c)(2), the daily span check is to be conducted with a concentration of vinyl chloride which is determined to be equivalent to the emission limit for that. source based on the emission test required by (h). The calibration is to.be done with either: (A) A calibration gas mixture prepared from the gases specified by the Air Pollution Control Officer; or (B) A calibration gas cylinder containing the appropriate concentration of vinyl chloride. If a calibration gas cylinder is used, the analysis must be traceable to the National Bureau of Standards or to a gravimetrically calibrated vinyl chloride permeation tube. (3) Initial report. (1) An owner or operator of any source to which this rul applies shall submit a statement in writing notifying the Air Pollution Control Officer that the equipment and procedural epecifications in (f)(2)(A), (2)(B), (2)(C), (2)(), (2)(E), (2)(F), (2)(G) and (2)(K) are being implemented. f (2) (A) In the case of an existing source or a nev; source which has an initial startup date preceding the effective date, the statement is to be submitted within 90 days of the effective date. (B) In the case of a new source which did not have an initial startup date preceding the effective date, the statement is to be submitted within 90 days of the initial startup date. (3) The statement is to contain the following information: (A) A list of the equipment installed for compliance. (B) A description of the physical and functional characteristics of each piece of equipment.' (C) A description of the methods which have been incorporated into the standard operating procedures for meas uring or calculating the emissions for which emission limits are prescribed in (f)(2)(A)(i) and (2)(F)(i). * (4-) A statement that each piece of equipment is installed and that each piece of equipment and each procedure is being us d. R&S 115251 (k) Semiannual report. (1) The owner or operator of any source to which this rule applies shall submit to the Air Pollution Control Officer on Septem ber 15 and March *15 of each year a report in writing containing the information required by this section. The first semiannual report is to be submitted following the first full 6 month reporting period after the initial report is submitted. (2) (A) In the case of an existing source or a new source which has an initial startup date preceding the effective date, the firnfc report is to be subc. t ted within 100 days of the effective date. (B) In. the case of a new source which did nob have an initial startup date preceding the effective date, the first report is to be submitted within 180 cays of the initial startup date. (5) Unless otherwise specified, the owner or operator shall use the test methods specified by the Air Pollution Control Officer to conduct emission tests as required by paragraphs (3)(B) and (3)(C) of this section, unless an equivalent or an alternative method has been approved by the Air Pollution Control Officer. If the Air Pollution Control Officer finds reasonable grounds to dispute the results obtained by an equivalent or alternative method, he may require the use-of a reference method. If the results of the reference and equivalent or alternative methods do not agree, the results obtained by the reference method prevail, and the Air Pollution Control Officer may notify the owner or operator that approval of the method previously considered to be equivalent or * alternative is withdrawn. (A) The owner or operator shall include in the report a record of any emissions which averaged over any hour period *' J3 (commencing on the hour) are in excess of the emission limits fio (/) prescribed in (c)(1) or (2), (d)(1) or (e)(1)(A), (2), (3), or (4) * * cron or for any control system to which reactor emissions are required Oi N> to be ducted in (e)(1)(B) or to which fugitive emissions are required to be ducted in (f)(2)(A)(ii), (2)(B), (2)(E), (2)(F)(ii) or (2)(l)(ii). The emissions are to be measured in accordance with (i). (B) In polyvinyl chloride plants for which a stripping operation is used to attain the emission level prescribed in ( )(5) the owner or operator shall include in the report a record of the vinyl chloride content U: the polyvinyl chlo'icie resin. Test methods V specified by the Air Pollution Control Officer are to be used to determine vinyl chloride content as follows: (i) If batch stripping is used, one representative sample of polyvinyl chloride resin is to be taken from each batch of each grade of resin immediately following the completion of the stripping, and grade and the date and time the batch is completed. The corresponding qualtity of material processed in each stripper catch is to be recorded and identified by resin type and grade and the date and time the batch is completed. (ii) If continuous stripping is used, one represen tative sample of polyvinyl chloride resin is to be taken for each, grade of resin processed or at intervals of 8 hours for each grade . of resin which is being processed, whichever is more frequent. The sample is to be taken as the resin flows out of the stripper and identified by resin type and grade and the date and time the sample was taken. The corresponding quantity of material processed by each stripper over the time period represented by the sample during the eight hour period, is to be recorded and identified by resin type and grade and the date and time it represents. (iii) The quantity of material processed by the * stripper is to be determined on a dry solids basis and by a method submitted to and approved by the Air Pollution Control Officer. (iv) At the prior request of the Air Pollution Control Officer, the owner or operator shall provide duplicates of the samples required in paragraphs (5)(B)(i) and (5)(B)(ii) of this section. (v) The report to the Air Pollution Control Officer by the owner or operator is to include the vinyl chloride content found in all the samples required in paragrpahs (3)(B)(i) R&S 115253 115254 <z> and (3)(B)(-ii) of this section, averaged separately for each type of resin, over each calendar day and weighted according to the quantity of each grade of resin processed by the stripper(s) that calendar day, according to the following equation: AI?i = nn r pg Gi i=l pGl % + pg2 %2 + + P`Gn "Gn A 24-hour average concentration of type T^ resin in ppm. Q = Total production of type resin over the 24-hour period, in kg. * Type of resin i=l ,2,.. .m where m is total number of resin types produced during the 24-hour period. M * Concentration of vinyl chloride in one sample of grade resin, in ppm ? * Production of grade resan represented by the sample, in kg- * Gj: = Grade of resin, e.g., G^, G2, and G^. n = Total number of grades of resin produced during the 24-hour period. (vi) The owner or operator shall retain at the sourc sr.d make available for inspection by the Air Pollution Control Officer for a minimum of 2 years records of all data needed to furnish the information required by paragraph (3)(B)(v) of this ruction: The* records are to contain following in formation: (I) The vinyl chloride content found in all VBV-j) and fBVfOCii) of this R&S 115255 section, identified by the resin type and grade and the time and date of the sample, and (II) The corresponding quantity of poly vinyl chloride resin processed by the stripper(s), identified by the resin type and grade and the time and date it represents. (C) The owner or operator shall include in the report a record of the emissions from each reactor opening for which an emission limit is prescribed in (e)(1)(B). Emissions are to be determined in accordance with (h), except that emissions for each reactor are to be determined. For a reactor that is also used as a stripper, the determination may be made immediately fol lowing the stripping operation. (1) Recordkeeping (1) The owner or operator of any source to which this rule applies shall retain the following information at the source and make it available for inspection by the Air Pollution Control Officer for a minimum of two years: (A) A record of the leaks detected by the vinyl chloride monitoring system, as required by (f)(2)(H), including the concen trations of vinyl chloride as measured, analyzed,, and recorded by the vinyl `chloride detector, the location of each measurement and the date and approximate time of each measurement. (B) A record of the leaks detected during routine monitoring with the portable hydrocarbon detector and the action taken to repair the leaks, as required by- (f)(2(K), including a brief statement explaining the location and cause of each leak i-e tr.r.-od with the portable hydrojarbon detector, the- date and time of the leak and any action taken to eliminate that leak measured * i / *> (C) For the relief discharges from, reactors subject to the provisions of (f)(1), a daily operating record for each reactor, including pressures and temperatures. (n) Effective Date This rule is effective upon the date that the United States Environmental Protection Agency delegates authority to implement and enforce this rule to the South Coast Air Quality Management District. R&S 115256 * `( _ 5 ' 281,5-1 APPENDIX 4 PROPOSED RULES ENVIRONMENTAL PROTECTION additional actions. These Include a re be achievable only by banning vinyl chlo AGENCY [ 40 CFR Part 61] statement f EPA's policy for regulating ride emissions completely. That, in turn, carcinogens under section 112 of the would require closing the entire Industry. Clean Air Act: the proposal of amend As explained In the eaiiier rulemaking it inu, V3S-S] ments which would require Increased Is not clear that Congress would have VINYL CHLORIDE efficiency of existing control equipment, Intended this result, so Instead EPA re require more stringent control at new quired the lowest level achievable using National Emission Standards for Hazardous Air Pollutants sources, and prohibit increases in emis sions within the vicinity of an existing technological means. (See 40 FR 59534 and 41 FR 45562). AGENCY: Environmental Agency. 'ACTION: Proposed rule. Protection source due to new construction; and the initiation of a review of the vinyl chlo ride standard three years after the pro mulgation of the amendments. In order to insure that the standard continues to approach the only level of emissions which Is known to be abso lutely protective of health, namely zero SUMMARY: The proposed amendments are being made to the vinyl chloride standard which has promulgated Octo ber 21, 1976,' and would apply to new and existing ethylene dlchlorlde. vinyl chloride, and polyvinyl chloride plants. The standard add the proposed amend- ments implement the Clean Air Act and are based on the Administrator's deter mination that vinyl chloride Is a hazard ous air pollutant. The Intended effect of the proposed amendments Is to require improved effectiveness of control tech nology at existing plants. Impose more stringent emission limits on new sources, and prohibit an emission increase within the vicinity of an existing source due to the construction of a new source. DATES: Comments must be received on or before August 1,1977. Zao Emission goal The vinyl chloride standard has been criticized for allegedlv placing unwar ranted emphasis on technological rather than hcaUh considerations. Although EPA disagrees with this criticism; it svemv appropriate to restate EPA's ap proach to the regulation of carcinogens In general and under Section 112 of the Clean Air Act. and to explain bow the vinyl chloride standard and the pro posed amendments are consistent with this approach and with the protection oI public health. On Mav 25. 1976, EPA published in terim procedures and guidelines for health riik and economic Impact assess ments of suspected carcinogens (41 FR 21402), whlcn define EPA's approach to regulatory action for suspect carcino emissions, EPA Is proposing amendments which require more efficient use of exist ing control technology at existing plants and more effective controls at new plants, and which encourage technology to reach this goal without banning vinyl chloride. More SnuNczirr Standards rot Existing Souxcxs EPA is proposing amendments which would require sources presently subject to a io ppm emission limit to reduce emissions to 5 ppm within three years of promulgation of the amendments. The affected sources include ethylene dlchlo rlde purification; vinyl chloride forma tion and purification; reactors, strippers; mixing, weighing, and holding contain ers; monomer recovery systems; and fugitive emissions which have been cap ADDRESSES: Comments should be sub gens. As Indicated in that publication, tured In accordance with the existing mitted (preferably In triplicate) to the there are two steps involved in the ded-' regulation.* If the owner or operator of Emission Standards and Engineering Division, Environmental Protection slon-maVing process with regard to the regulation of a potential carcinogen. Al a source believed that a control system would not be capable of meeting the 5 Agency. Research Triangle Park, North though different EPA statutory author ppm limit, he would be able to request Carolina, Attention: Mr. Don R. Good win. All public comments received may be Inspected and copied at the Public In formation Reference Unit CEPA Li brary), Room 2922, 401 M Street, 8W., Washington. D.C. ities Impose different requirements, in general two decisions must be made with regard to each potential carcinogen. The first decision is whether a particular sub stance constitutes a cancer risk. The second decision is what regulatory ac tion, If any, should be taken to reduce that risk. that the-Administrator approve an in terim emission limit for that source. Such requests would have to be made one year before the compliance date. In re questing an interim emission limit, the owner or operator would have to submit supportive data and meet with EPA to discuss his particular problems in attain FOR FURTHER INFORMATION CON In deciding whether a cancer risk ing compliance. Hie meeting would be TACT: exists, EPA will consider a substance a announced in the Ftberai. Racism and Don R. Goodwin, Emission Standards and Engineering Division, Environ mental Protection Agency. Research Triangle Park. North Carolina 27711, Telephone No. 919-688-B146, ext. 271. SUPPLEMENTARY INFORMATION: presumptive cancer risk when it causes a statistically significant excess incidence of benign or malignant tumors In hu mans or animals. In the case of vinyl chloride. EPA evaluated all available data and concluded that a cancer risk exists. In deciding bow and whether to any interested party would be allowed to attend and submit written or oral com ments. If an Interim emission limit were granted to the souroe, the required emis sion level would be specified In a written notification from EPA and -In the Fxdxrsi Rxgxstzx. ^ach source granted an Background On October 21,1976, EPA promulgated a standard for vinyl chloride under the authority of section 112(b) (1) (B) of the Clean Air Act, as amended (41 PR 46561). The standard applies to ethyl ene dlchlorlde. vinyl chloride, and poly vinyl chloride plants. On November 19. 1976, the Environ mental Defense Fund (EDF) petitioned the United States Court of Appeals for the District of Columbia Circuit to review regulate. EPA examined section 112 of the Clean Air Act. Section 112 of the Act requires that emission standards be set "at the level which In the judgment of the Administrator provides on ample margin of safety to protect the public health from such hazardous air pollut ants." This requirement appears to as sume that each pollutant regulated will have a threshold level of effects below which no health effects will occur. As explained In the documentation for the current standard (40 FR 59532, Decem Interim emission limit would be reviewed every three years to determine whether emissions could be reduced to 5 ppm, or at least to a lower interim emission limit. In proposing the reduction from 10 to 5 ppm, it is not EPA's intent that a con trol system which has been installed to *As an explanatory note, paragraph (b) Of | 81.05 contains nine fugitive emission regu lations. For several of these, the fugitive emissions are required to be captured and ducted to a control device meeting 19 ppm. the standard. Motions to intervene were ber 24, 1975 ; 41 FR 46560. October 21, According to the proposed amendment*, the subsequently filed on behalf of the So 1976), it has not been possible to deter emissions from this control devle* would ciety of the Plastics Industry, Inc., the Goodyear Tire and Rubber Company and Air Products and Chemicals. Inc., and were granted by order of the Court on January 18. 1977. On March 24, 1977, EDF and EPA moved to dismiss the mine If there is a threshold level of effects for vinyl chloride and it is not certain that such a threshold may be determined In the near future. In the absence of strong evidence to the con trary, then, the only level of vinyl chlo have to b# reduced to S ppm in the same way any other source currently required to meet 10 ppm would have to do. Rather than in corporating both the 5 and 10 ppm emission limits In each paragraph in |Sl.S5(b), a separate paragraph (cj containing these emission limits is being added to I 81.85. All proceedings In view of a settlement ride which would appear to be absolutely the other paragraphs in (h) are cross- agreement requiring EPA to take certain protective of health Is zero, which may referenced in pan -aph (c). FEDERAL REGISTER, VOl *1, NO. 108--THURSDAY, JUNE 2, 1977 33 C/3 cn to cn -4 t mOPOSED RULES 28155 meet the 10 ppm emission limit be re cycling and oxygen feed methodolgy Is rather than the equipment. The same moved end replaced with another more considered feasible for new oxychlorina equipment can be used to process differ efficient control system or that a second tion reactors because it can be Incorpo ent resin grades. Variations in the emis control system be added behind the first rated at the time of construction. Since sions from the equipment an a function control system. The purpose of the pro the use of technology would elimin or the resin being processed rather than posed amendment Is to force owners and ate the supplemental fuel problem re the characteristics of toe equipment. The operators to maximize the effectiveness ferred to above. It Is EPA's Judgment that control technology which Is used for toe of existing control systems. new oxychlorlnation reactors should be equipment following the stripper Is like controlled to the same extent that is wise more directly linked to the resto Mon Bzxivgxnt SnnUM roe New proposed for other emission sources. than the equipment. Stripping is used to Bodeces The proposed amendment also includes control the emissions due to the vinyl The proposed amendments would also a mart stringent emission limit for new chloride to the resto before the resin is require more stringent controls far sew polyvinyl chloride resins being processed processed to the equipment. sources; Le, sources for which construc In equipment following the stripping Before the hazards of vinyl chloride tion Is commenced after the date of pro operation. That Is, the amendment became known, stripping technology was posal of these amendments. According would apply to resins for which produc employed by polyvinyl chloride manu to I 61.03 of the General Provisions, tion for the purpose of marketing was facturers to recover raw materials for "commenced" means that an owner or commenced after the proposal of the economic purposes. As 'a result of a operator has undertaken a continuous .Tn.Tirfm.nt The .mnmiment would re standard promulgated by the Occupa program at construction or modification quire all new rosins except new disper tional Safety and Health Administration or that an owner or operator has entered sion. rosins to be stripped to 100 ppm and (30 FR 35890), some companies investi into a contractual obligation to under new dispersion redos to be stripped to gated Improvements to stripping meth take and complete, within a reasonable M0 ppm. These limits for new products odology for emission control purposes. time, a continuous program of construc would be one-fourth of the limits con (J>. tion or modification. New sources of types which would be subject to the 10 ppm emitsInn limit tained In the standard for existing prod ucts. Consistent with the current stand ard. ** ym.nrfm.nt would permit the Optimum stripping consists of a set of Operating conditions which must be de veloped experimentally on an individual under the currant standard would bo required under the amendments to meet a 5 ppm *rniinn limit at tha time of startup. With new sources there would be no provision allowing requests lor EPA approval of an Interim emission limit. New sources would be required to meet the more stringent emission limit at the use of control devices rather than strip ping *--frimingv to meet the emission limit, in this case equipment being used to process aU new rosins except new dis persion rosins would have to be con trolled to 0.01 kg/kg product and the equipment used for new dispersion rosins would have to be controlled to 0.05 kg/kg basis for toe many resins. In developing the current standard, EPA recognized that stripping technology for dispersion rosins had not been refined to toe same extent as It had been for other resins and 'that there was more difficulty to strip ping dispersion rosins than other rosins. For this reason a less stringent tmL^sian time of startup, because they have an product. ___ limit was established for dispersion res opportunity to design their equipment to meet the 5 ppm emission limit at the time construction Is commenced. Existing sources, on the other hand, require time m wiTtwiw the effectiveness of their control systems. The proposed amendment would also require ethylene dichloride-vinyl chlor ide plants to control emissions Xromnew oxychlorlnation reactors to 5 ppm. This A "new source" Is defined to 40 CFR 61.02 as a stationary source; the con struction or modification of which is commenced after proposal of a standard. There was some question based on this wrr,mn as to whether the amendment to the stripping standard for new sources should apply to new polyvinyl chloride rosins or the installation of'new equip ment following the stripper. If the ap ins. Dispersion resins are permitted a higher emission limit under the proposed amendment for toe same reason. EPA believes that for some resins, companies have already developed strip ping technology which would meet the proposed amendment. (2) For other resins, toe proposed standard would re quire additional Improvement to strip ping technology. If stripping technology requirement Is based on Installation of a recycling and oxygen feed system with an Incinerator or equivalent control de vice. The current standard limits emis sions from the oxychlorlnation reactor to 0.2 g/kg (0.0002 lb/lb) of the 100 per cent ethylene dichloride product from the oxychlorlnation reactor. This emis sion limit can be met by changing proc ess parameters, rather than Installing a control device. During the development of the current standard EPA considered requiring existing sources to control emissions with an Incinerator or equiva lent technology, but rejected this ap proach because a large quantity of fuel would be required .to reduce mwimuwm from a relatively small source. An exist ing oxychlorlnation reactor typically has a large volume, low hydrocarbon effluent gas stream, and large quantities of sup plemental fuels would be required lor combustion of Its emissions. plicability of the amendment for new sources were based on the installation at new equipment following the stripper. It would be difficult to determine what con stitutes a new source at an existing plant. This is based onto* reasoning that the stripping standard requires that all equipment following the stripper to the process be controlled es a unit The series of equlpmmt following the stripper in cludes pumps and conveying equipment which might be expected to be replaced on a frequent and routine basis. Replac ing one of these pieces of equipment would to effect cause the whole series of equipment following the stripper to have to meet the standard for new sources. In other words, all resins processed to the series of the equipment would have to meet the lower standard even though only a minor part at the equipment bad beat replaced. EPA decided that a more reasonable has not been developed to toe extent necessary to meet the proposed amend ment for a particular resto, the manu facturer would have the option of de veloping the technology or not producing the rosin. The current standard, unlike the proposed amendment, was not based on the premise that an owner or operator would have the option of not producing a particular resto. It Is EPA's Judgment that the owner or operator making a new product has more freedom of choice than the owner or operator already making a particular product to selecting those resins which are to be produced. EPA's standard would be included to the variables under consideration when decisions are being made as to which rosins are to be produced. The proposed amendment would apply to any new source, whether It constituted replacement of an existing source to an A new plant can reduce the volume of and direct approach was to. make the existing plant, the expansion of an exist Its effluent gas stream and make It more proposed amendment apply to the pro ing plant, or part of an entirely new concentrated by recycling the gas stream duction of new polyvinyl chloride resUs. plant. That Is, If a new oxychlorlnation and using oxygen Instead of air to feed This Is based on the reasoning that emls- reactor or a new polyvinyl chloride re Into the process. (3. 4) the current elone from the equipment following the actor were Installed at an existing plant, standard was not based on this technol atripper ere a function of the amount of it would be subject to the emission limits ogy because it was not considered feasi vinyl chloride left to the rosin after the for new sources. This means that as ble to retrofit existing plants to that they stripping operation Is completed; 1a, eristlng sources are gradually replaced could use oxygen of air. The jn- the resto Is the source of the ""i"lnn* with new sources to an existing plant. R&S 115258 KDIKAL IOIJTII, VOL 42, NO. 10*--THUKSOAT, JUNE 2, 1927 ' W- 1 *-. I 28156 PR POSED RULES 5 % 1 !2 the overall emission level from, that bad been attained by each existing ethylene dichloride-vlnyl chloride plant existing plant w uld be reduced. source. The allowable emission rate for and an existing average-sized polyvinyl Emission Orrsrr each source would be based on the maxi chloride plant, which contain other mum production rate at which that sources than the ones required to meet Because the present' vinyl chloride source would be operated in the future. a 5 ppm emission limit, it Is estimated standard focuses on reducing emissions Also. If the emissions from an existing this will have the effect of reducing total rather than attaining a particular am source were already below the emission emissions by less than one percent. Emis bient air quality concentration, there Is limit applicable to It, the proposed sions at existing plants would be further no provision for limiting the size of amendment would give the source credit reduced as existing oxychlorination re plants or the clustering of plants in a for the difference between the emission actors are replaced with new oxychlori- geographical area. The doubling of the limit and the actual emission level. That natlon reactors and as new polyvinyl size of an existing plant or the coostruc- is the baseline emission rate would be chloride resins are produced to replace tico of a new plant beside an existing based on the standard rather than on an existing ones. plant would considerably Increase the emission test. It Is EPA`s Judgment that Under the proposed amendment, emis ambient air concentrations of vinyl this Is a more equitable approach than sions from new plants would be consider chloride in the vicinity of the plantCs) even If the vinyl chloride standard was penalizing a source which has already taken measures to reduce emissions below ably lower t*n.n they would be under the current standard. For a typical new met. EPA determined at the time of the standard. Such a source would have average-sized ethylene dichloride-vlnyl promulgation of the current standard less room for further reducing emissions. chloride plant (318x10* kg/yr or 700 that the costs of prohibiting the produc The emission limits applicable to both Xio* lb/yr produced), the hourly emis tion of vinyl chloride and polyvinyl the existing and new sources Involved sions would be S.l kg (ll.S lb) Instead chloride were too high and the continued In the offset arrangement would be con of 10.3 kg (23.1 lb). For a typical new operation of existing plants should be tained in the approval of new construc average-sized dispersion polyvinyl chlo allowed. EPA believes, however, that the tion granted by the Administrator under ride plant (46x10* kg/yr or 100x10* standard should Include a mechanism 40 CHS 61.08. lb/yr production), the emissions would for prohibiting an Increase In ambient EPA believes that a policy of no net be about 9 kg/hr (20 lb/hr) instead of concentrations of vinyl chloride due to Increase in emissions due to new con 17A kg/hr (39 Ib/hr) and for a typical new construction In areas where existing sourcee are already located. ' Accordingly, EPA Is proposing an amendment which would prohibit an In crease in emissions within 8 kilometers (km) (approximately five miles) of an existing source due to the construction Of a new enlseton source. This means that if a new source wen added to an existing plant, the Increase In emissions due to that new source would have to be offset tv a reduction In emissions from other existing sources within that plant or at other plants within 8 km of the construction site of the new source. Simi larly, a new plant could not be con structed within 8 km of an existing plant(s) unless the emission increase due to the new plant were offset by an emission reduction at the existing plant or plants. This provision may result m few existing plants being expanded and few new plants being constructed M the - struction Is Justified because of the haz ardous nature of vinyl chloride. How ever. EPA recognizes the potential diffi culties In implementing such a policy and Interested persons are urged to sub-mlt comments and factual Information relating to this policy. Itsraw or Seamus EPA plans to Undertake a full-scale review of Subpart P of 40 CFR Part 81 beginning three years from the promul gation of any amendments. In the, study EPA will review information concerning .technological advances In the control of viniyl chloride emissions to determine what further changes might then be ap propriate to move toward the goal of. aero vinyl chloride emissions. EPA will also consider recent health data to de termine whether the approach for regu lating vinyl chloride should be altered. Ewvtxonxxvtal Impact new average-sized suspension polyvinyl chloride (68x10* kg/yr or 150X10* lb/yr production) the emissions would be 13.5 kg/hr) (30 lb/hr) Instead of 16 kg /hr (36 Ib/hr). These emissions are calculated based on the emission factors pub lished in the documentation for the ex isting standard. (f) Ambient air concen trations are expected to be reduced proportionately. The only negative environmental im pact would be an Increase In hydrogen chloride emissions at ethylene dlehloride-rlnyl chloride plants if incineration were used to control emissions from new oxychlorlnation reactors. However, due to the corrosion problems which would otherwise occur on plant property and In the community, plants are exoected to use scrubbers to control the hydrogen chloride emissions. The proposed amend ment is not expected to have a signifi cant Impact on energy consumption. vicinity of exintiTig plants.' However, the proposed amendment does not preclude this possibility. The offset provision would apply only, to new construction which results In an Increase in production rate. Replacing or adding equipment such as pumps, com pressors, agitators, sampling equipment and unloading hoses is a routine practice at existing plants. Additions of equip ment of this nature would, in and of it self. be expected to result in little. If any, increase in emissions. In ERA'S Judg ment, a plant should not be required to prove this fact each time one of these The proposed amendment. In contrast to the current standard, would encourage : the development of new technology andImprovements m existing technology and would have the following three positive environmental Impacts: (1) further re duction of emissions at existing plants, (2) no Increase In emissions within 8 km of an existing source, and (3) lower emissions from new sources than would be accomplished through the current standard regardless of the construction site. These environmental Impacts would provide progress toward the ultimate goal of zero emissions-without banning . - Economic Ixtact The potential economic Impacts of the proposed standard are: .(1) Costs for research and develop ment of Improved methodology for oper ation of exisoug control technology so that It can be used to meet the 6 ppm emission limit. (2) Costs for research and develop ment of Improved stripping techniques to meet the standard for new polyvinyl chloride resins. (3) Cost of research and development or licensing for converting over to the pieces f equipment is added. The addi tion of this type of equipment In con vinyl chloride, and In the process would provide additional protection of public oxygen system for a new oxychlorlnation reactor. junction with major process equipment, health by further minimizing the health (4) Possibly Increased transportation however, is likely to result in both an In risks to the people living in the vicinity costs of raw materials In the case that crease In emissions as well as an In of existing plants and to any additional the offset policy results In the construc crease In production rate, and Is there people who are exposed as a result of new tion of a new plant farther from an fore covered by the offset provision. construction. existing plant than It otherwise would If the offset provision were adopted, Specifically, for those existing sources havg been. the reduction in. emissions could be which are currently subject to a 10 ppm (5) Costs of building a new plant more achieved In the production rate of an emission limit, emissions would be re than 8 km from an existing plant In the existing source or sources. The baseline duced by half within three yean after event that the offset requirement pre emission rate would be determined based the promulgation date of these amend cluded the expansion of an existing on the maximum production rate which ments. At both an existing average-sized plant. -. rencsai neisTfr, vr'L i, no. ioe--tnussoay, juni i, 1*77 _ a. - 'r -f . . ~ .A t PROPOSED RULES 28157 (6> Delay in the production of ft par ticular resin due to time spent develop ing stripping technology for that resin. (7) No growth in the production of a particular resin due to the Inability to ' (3) "Goodrich Report*' Xmpreulv* Pragma in Solving Vinyl Chloride Problem," Ameri can Point and COatingr Journal. Vol. 60, No. 31, January 13,1376, p. 34. (3) W. Wlmer and B. E. Feather*. "Oiygtn Olvt* Low Cost VCM," Hydrocarbon (a) Vinyl chloride formation and Pu rification: Except as provided In t 61.65(a), the concentration of vinyl chloride in all exhaust gases discharged to the atmosphere from any equipment 30 fio CO strip that resin to required levels. The types of costs which have been named would be difficult to quantify. The costs would be expected to.vary consider ably from one plant to another depend ing on the amount of research and de velopment than had already been done, the extent to which technology could be transferred from other plant* and proc esses, and the plans for new construction. One' area In which cost estimates can be generated is the use of an oxygenrecycle oxychlorination process as op posed to an air-based system. The pro posed amendment does not require the use of the oxygen-recycle system, but many plants would be expected to em ploy this system to avoid the high costs of incinerating the high volume gas stream from a typical air-based system. The primary cost of using the oxygen- Processing, March 1376, pp. 81-84. (4) Pater Belch, "Air or Oxygen For VCM?." Hydrocarbon Procuring, March. 137Si pp. 85-89. It Is proposed that Subpart F of 40 CFR Part 61 be amended as follows: 1. In I 61.08, paragraph (b) Is revised, to read as follows: { 61.08 Approval by the Administrator. (b) If the Administrator determines that a stationary source for which an application pursuant to f 61.07 was sub mitted will nqt, If properly operated, cause emissions in violation of the standard or violation of 161.73, he will approve the construction or modification of such source. . ' * 2. Section 61.62 is revised to read as used in vinyl chloride formation and/or purification is not to exceed the appro priate emission limit as follows: (1) Each source, for which construc tion had commenced on or before June 2. 1977, 10 ppm until (date three years af ter promulgation of these amendments) and 5 ppm after (date three years after promulgation of these amendments). (2) Each source for which construc tion- commenced after June 2, 1977, 5 ppm. 1 (b) The requirements of this section do not apply to equipment that has been opened. Is out of operation, and met the requirement in f 61.65(b) (6) (1) before being opened. 4.Section 61.64 is amended by revis ing paragraphs (a)(1), (b). (c), (d) and (e)and by adding paragraph (f) as follbws: cn ro o recycle system Is the cost of the oxygen follows: , S 61.64 Emission standard for polyvinyl Itself. The cost of the oxygen lor a par ticular plant would depend on whether the plant was located where there is a considerable demand for both the oxygen and nitrogen products of air separation. According to one recent article. If It Is assumed that such a demand exists, the cost of the oxygen (514.34/ton) would be approximately equivalent to the cost of compressing air for use In the air- based system. (1) Another report In which this assumption was not made and the economies of the air and oxygen ays-, terns were being compared. It was con cluded that overall production economies "favor the oxygen process even If vent gas incineration would not be required lor an air-based plant since the sum of all remaining advantages offered, by oxygen-based plant operation more than outweighs the Incremental cost for the oxygen feed." C3> ` Miscellaneous: The Administrator In vites comments on all aspects of the pro posed amendments. i. - (Section tlS Of tM Clean Air Act. mo. 4(a) of Pub. L. 91-604. *4 Stst. 1B8S (43 U.S.C. 1867c7) and section 301(a) of the Clean Air Act. sec. 3 of Pub. L. No. 00-148, at Btat. 804 aa amended by aec. (IS) (c) (3) of Pub. L. 31-804, 84 Stat. 1713 (43 UA.C. 1867 g(a)). Bees. 61.67 and 61.68 also proposed under the au thority of section 114 of the Cleon Air Act. a* added by aec. 4(a) of Pub. L. 31-604. 34 Stat. 16S7 and amended by Pub. L. 33-319, *ee. 6(a) (4), SB Stat, 363 (43 UAjC. 1S67C-S).) 61.62 Emmion standard for ethylene dichloride plant*. An owner or operator of an ethylene dichloride plant shall comply with the requirements of this section and f 61.65.' (a) Ethylene dichlorlde purification: Except as provided to-"* 61.65(a), the; concentration of vinyl chloride In all exhaust gases discharged to the atmos phere from .any equipment Used In ethylene dichlorlde purification is not to exceed the appropriate emission limit as follows: (1) Each source for which construc tion had commenced on or before (date of proposal of these amendments), 10 ppm until (date three yean after pro mulgation of these amendments) and 5 ppm after (date three years after the promulgation of these amendments). (2) Each source for which construc tion commenced after June 2, 1877. 5 ppm. (b) Oxychlorlnation reactor: Except as provided In 161.65(a), emissions of vinyl chloride to the atmosphere are not to exceed the appropriate emission limit as follows: (1) Each source for which construc tion had commenced on or before (date of proposal of these amendments), 02 g/kg (0.0002 lb/lb of the 100 percent ethylene dichloride product from the oxychlorination reactor. (2) Each source for which construc chloride pi-"1- An owner or operator of a polyvinyl chloride plant shall comply with the re quirements of this section and f 61.65. (a)Reactor: The following require ments apply to reactors: - (1) Except-as provided In paragraph, (a) (2) .of this section and 161.65(a), the concentration of vinyl chloride to all ex haust gases discharged to the atmos phere from each reactor Is not to exceed the appropriate emission umit ns fol lows; (I) Each source for which construction had commenced on or before June 2,1977 10 ppm until (date three years alter pro mulgation of these amendments) *v4 $ ppm after (date three years after pro mulgation of these amendments). (II) Each source for which construc tion commenced after June 2. 1977. 5 ppm. ' (b) Stripper: Except as provided to 161.65(a), the concentration of vinyl chloride to all exhaust gases discharged to the atmosphere from each stripper is not to exceed the appropriate emission limit as follows: (1) Each source for which construc tion had commenced on or before June 2, 1977 10 ppm until (date three years after promulgation of these amend ments) and 5 ppm "after (date three years after final promulgation of these amendments). Not*.--The Environmental Protection tion commenced after June 2, 1977, 5 Agency has determined that this document Ppm. (2) Each source for which construction commenced after June 2.1977, 5 ppm. does not contain a major proposal requiring (c) The requirements of this section (c) Mixing, weighting, and holding preparaUon of an Economic Impact Analytic under Executlee Order* 11831 and 11343 and OMB Circular A-107. do not apply to equipment that has been opened. Is out of operation and met the requirement In f 61.65(b) (6) (1) before containers: Except as provided Jn I 61.65(a), the concentration of vinyl chlo ride to all exhaust gases discharged to Dated: May 37.1877. being opened. the atmosphere from each mixing, weigh Douglas M. Costlx, Adminittrator. Bmuxa (1) Standard Support and Environmental Impact Statement; fmlulon Standard for 3. Section 61.63 is revised to read-as fellows: S 61.63 Emi*sion standard for vinyl chloride plant*. An owner or operator of a vinyl chlo ing, or holding container In vinyl chlo ride service which precedes the stripper (or the reactor if the plant has no strip per) to the plant process flow is not to exceed the appropriate emission limit as follows: Vinyl Chloride. EPA-460 13-76-003, October, ride plant shall comply with the require (1) Each source, for which construc 1975. ment! of this section and ! 61.65. tion had commenced on or before (date HOEIAL KlOimt, VOL 41, NO. 104--THVtSOAV, JUNf 2, 1*77 . at . '* *i 28158 PI POSED RULES % proposal of thee* amendments), 10 resin aH of which had been produced by od of measurement is to meet the re im until (date three yean alter pro the plant on or before June 2,1977: quirements in I 61.67(g) (5) (D (A) or mulgation of these amendments) and 5 (A) 2 g/kg (0.003 lb/lb) product from (g)(6) (D CB). ppm after (date three yean after pro the stripperIs) [or reactor(a) if the 6. m I 61.67, paragraph (a) is revised mulgation of these amendments). plant has no stripper(s) 1 for dispersion to read as follows: (2) Each source for which construc tion commenced after June 2, 1277, 5 polyvinyl chloride resins, excluding latex resins, with the product determined on { 61.67 Fmi--inn teat*. ppm. a dry solids basis: (a) Unless a waiver of emission test (d) Monomer recovery system. Except (B) 0.4 g/kg (0.004 lb/lb) product ing is obtained under < 61.13, the owner as provided In 161.65(a), the concentra from the stripper(s) `(or reactor(s) If or operator of a source to which this tion of vinyl chloride in all exhaust gases the plant has no stripper(s)) for all subpart applies shall test missions discharged to the atmosphere from each other polyvinyl chloride resins, including from the source as follows: monomer recovery system Is not to ex latex resins, with the product deter (1) For an eadsttag source or a new ceed the appropriate eancenlratlon as mined on a dry solids basis. source which has an initial startup date follows: (U) Fur sources being used to process preceding October 21,1976: (1) Each source for which construc any grade of polyvinyl chloride resin not (D Within 90 days following October tion bad commenced on or before (date produced by the plant on or before June 21.1976, and of proposal of these amendments), 10 2, 1977: (ID For those sources subject to ppm until (date three years after pro (A) 03 g/kg (0.0005 lb/lb) product II 61.62(a); 61.63(a); 61.64 (a)(1), (to), mulgation of these amendments) and 6 from the strlpperts) (or reactorU) If the (c), and (d); and/or 61.65(b)(1), (b> ppm after (date three years alter pro plant has no stripperCs)) for dispersion (2), (b)(3), (b)(5), (b)(6). and/or (b> mulgation of these amendments). polyvinyl chloride resins, excluding la (9), within 90 days following (date three (2) Each source-lor which construc tex reams, with the product determined years after the promulgation date of tion commenced after June 2. 1277, qp | diy bft&ls; these ammhnmitB). fpflj (B) 0.1 g/kg. (0.0001 lb/lb) product (2) For a new source for which Initial (e> Sources following the tripper(s): from the strippers (or reactor(a) If the startup ooeurs after October 21, 1976. The following requirements apply to plant has no strtpper(a)) for all other within 90 days of startup. emissions of vinyl chloride to the atmos polyvinyl chloride resins, toeluding phere from the T--wMnann of all aonrcea following the strlpperts) [or the reactar(s) If the plant has ho stripperl later resins, with the product deter mined on a dry solids basis. (f) The raqurements of paragraphs . 7. In t 61,68, paragraph (c) is revised to read as follows: hi the plant process flow lrtchirttng. hot (b). <c). and (d) of this section do not | 61,63 Full--Inn monitoring. * *not limited, to centrifugm, concentra apply to equipment that has best . tors, blend tanks, Alters, dryers, conveyor opened, is out of operation and met the - (c) A dally span check Is to be con air discharges, baggers, storage con tainers, and Inprocess wastewater. (1) In polyvinyl chloride plants using __ ssvtnrippppming technology to control vinyl ^hebtorid3ee emissions: (1) pVtar a grade or grades of polyvinyl rchloride resin which have been produced by the plant on or before June 2. 1277, the weighted average residual vinyl chloride concentration In all the grades processed through the stripping opera tion on each calendar day, measured im mediately after the stripping operation Is completed, may not exceed the appro requirement In 161.55(b) (6) (O before being opened. 5. Section 61.65 is amended as follows: A. By replacing the phrase "10 ppm" with the phrase "the appropriate emis sion limit specified in {61.65(e)" in paragraphs (b)(1) (ID, (b)(2). (b)(3) (D. (b)(3) (ID. (b)(3) (liD, (b)(3) Uv), (b)(3)(v), (b)(5), (b)(6)(U). and (b> (B) (ID; B. By revising paragraph (c) and add ing paragraph D as set forth below. 6 61.65 ' riiamlmi standard far aibyleae ducted for each vinyl chloride monitortog system used. For aH of the sources bated to paragraph (a) of this section, except for the one for which an emission Emit Is prescribed to I 61.62(b)(1), the dally span check Is to be conducted with a concentration of vinyl chloride equal to the concentration emission limit appli cable to it. For a source subject to the emission limit prescribed to {61.62(b) (1), the daily span check is to be con ducted with a concentration of vinyl chloride which 1s determined to be equivalent to the emission limit for that priate emission limit as follows: (A) 2,000 ppm for polyvinyl chloride dispersion resins, excluding latex resins; (B) 400 ppm for all other polyvinyl chloride resins, including latex resins, averaged separately far each type of resin; (11) For a grade or grades of polyvinyl iCiUwUe, vinyl chloride, and poly- vinyl chloride plant*. (e) The emission limit which is not to be exceeded is as follows: (1) Each source, for which construction had com menced on or before June 2, 1277, 10 ppm until (date three years after pro source based on the emission test re quired by ( 6L67. The calibration is to be done with either: 8. A new {6L72 Is added to read as follows: 161.72 Keqomt for interim mMoa chloride resin which have not been pro mulgation of these amendments) and limit. duced by the plant on or before June 2, 1977, the weighted average residual .vinyl chloride concentration in all the grades proeened through the stripping operation on each calendar day, meas ured Immediately after the stripping op eration is completed,"may not exceed the appropriate emission limit as follows: (A) 500 ppm for polyvinyl chloride dispersion resins, excluding latex resins; 5 ppm after (date three years after pro mulgation of these amendments). (2> Bach source for which construc tion commenced after June 2, 1277, 5 ppm. (d> The requirements in paragraphs (b)(1), (b)(2), (b)(5), (b)(6). (b)(7) and (b) (S) of this section are to be in corporated Into a standard operating procedure, and made available upon re . (a) If to the opinion of the owner or operator of an existing source, that source will be unable to comply with the 5 ppm emission limit to II 61.62(a) (1); 61.63(a)(1); 61.64 (a)UXi), (bXl). (c)(1), (d)(1); and/or 61.65(c)(1) on or before (date three years after pro mulgation at throe amendments), the owner or operator at that source may re quest that the Adminstrator approve an (B) 100 ppm for all other polyvinyl quest for inspection by the Administra interim emission limit for that source. chloride resins, including latex resins, tor. The standard operating procedure The request is to be to writing and is to averaged separately for each type of is to Include provisions for measuring be submitted to the Administrator within resin; or ' the vinyl chloride in equipment &4.7S six months prior to (date two years after (2) In polyvinyl chloride plants con m* (1250 gal) in volume for which an promtdgatimi of these amendments). trolling vinyl chloride emissions with mission limit is prescribed in I 61.65 The request is to Include: technology other ttasn stripping or In <b)(6)(l) prior to opening the equip (1) The reasons the source Is In to stripping: ment and using Test Method 104, a port capable of i*1"' in compliance with the (1) For sources being used to proems a grade or grades of polyvinyl chloride able hydrocarbon detector, or an equiv alent or alternative methoL The meth 5 ppm emission Bmlt and data to support those reasons, and mssAt ucirra, vol. , mo. ioj--xmuxsoay, Juki % i77 33 W cn ro o> PROPOSED RULES 28159 (2) A suggested Interim emission limit, und description of the methodology lor nUutning that limit.' (b) Any owner or operator of a source who has submitted to the Administrator a written request for an interim emls* sion limit In accordance with S 01.72(a), shall within 00 days of the date of the written request meet with the Admin istrator concerning the information con tained in the request. The meeting Is to be open to Interested persons, who are to be allowed to submit oral or written testimony relevant to compliance of the source. (c) The Administrator will within 120 (f) The emission limits applicable to both the new source(s) and the source(s) at which emissions are being reduced to balance the Increase in emissions due to the new construction are to be estab lished by the Administrator In the ap proval for construction required by t 61.06. (Bscs. 112 and 301(a) of the Clean Air Act. sec. 4(a) or Pub. L. No. B1-S04. 84 Suit. 1863; mc. 3 of Pub. L. No. 00-148, 81 3tat. S04 (43 VAC. 1865C-7. 1867g(a)). Secs. B1.S7 and 81.68 also Isned under sec. 114 or the Clean Air Act. sec 4(a) of Pub. L. No. 31-604. 84 8tat. 1687 (43 OAC. 18670-3).) [Ktt Doc.77-16673 Piled 0-1-77:8:46 am] November 6, 1973). Fart 163a (section 335 of Pub. L. 94--482) contains those provisions applicable to the program of collection, analysis, and dissemination by the Commissioner of career informa tion and exemplary materials. To the ex tent the Commissioner proceeds by con tract, as authorised by section 335 of Pub. L. 94-482, the program will also be gov erned by the applicable provisions of the Federal Procurement Regulations. 41 CFR Chapters 1 and 3. To the extent the Commissioner proceeds by grant, the ap plicable provisions of 45 CFR Fart 106a* (38 FR -30662, November 6. 1973) will apply. days of receipt of the written request required by paragraph (a) of this sec tion, notify the owner or operator in writing of approval or denial of approval of an Interim emission limit. (d) If an Interim emission limit is ap proved the notification is to include the level of the Interim emission limit, which may be the level requested or a more stringent one. - (e> A determination to deny approval of an interim emission limit is to set forth the specific grounds on which such denial is based. * (f) Approval for any interim emission Omit granted for any source under DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE Office of Education [45 CFR Parts 163 and 163a] CAREER EDUCATION AND CAREER DEVELOPMENT * Addition of Programs AGENCY: Office of Education, HEW. ACTION: Proposed rule. SUMMARY: The Commissioner of Edu cation, with The approval of the Secre tary of Health. Education, and Welfare, (b) Comments and responses. In the Notice of intent to Issue Regulations (published In 41 FR 51550 on November 22, 1976) the Commissioner requested public comment on a number of specific issues in addition to Inviting expressions of public sentiment on any issue consid ered worthy of comment. In the thirty days afforded interested persons In which to make their views known. 64 State and national organizations, associations, and agencies and 3 individuals submitted comments. The comments on the specific Issues listed In the Notice of Intent are summarized below: (1) Given the apparent overlap be { 61.72(c) shall expire three years from the date of Issuance. The owner or op proposes to add two new career educa tion programs as enacted by the Educa tween the planning authorities contained in section 406(f) (2) of Pub. L. 93-380 and erator may request an extension of ap proval for an interim emission limit or a tion Amendments of 1976. Part 163 con tains provisions for a new one-year pro sections 331-34 of Pub. L. 94-182, how can the latter program be designed to lower interim emission limit, The re gram of financial assistance to states and avoid duplication of the former pro quest is to be in writing. Is to be sub other allottees far Fiscal Year 1978 to gram? (a) Should planning under sec mitted within six months prior to a year plan for the improvanent and develop tions 331-34 focus on career education before the expiration date and is to in ment of career education and career de for individuals beyond the secondary clude the Information listed in I 61.72 velopment programs and activities for school level? (b) Should States.be re (b), (c). <d). and (e) are to apply. Individuals of all ages. Fart 163a con quired to explain the relationship be 9. A new 161.73 is added to read as tains provisions for the Commissioner of tween activities carried out and proposed follows: . tr- ' Education to conduct a number of career under the two authorities? g 61.73 Offset of emission* doe is new construction. /- information activities during Fiscal Year 1978. including the collection, analysis, and dissemination of information per The commenters were overwhelmingly supportive of the view that duplication of activities conducted under -both au (a) No owner'or operator is to con taining to career trends and options In thorities (Pub. L. 93-380 and Pub. L. 94- struct a new source which alone or In the United States as well as exemplary 482) should be as limited as possible. combination with other sources being materials from the career p education They clearly thought the regulation constructed at the same time results in field. Both these programs are'new au Should require a Careful HTplarmtinn of an increased production rate unless be thorizations far which no funding has the relationship between these two plan demonstrates to the Administrator's sat been requested by the Administration. ning efforts, it was suggested that plan- isfaction that such construction will not cause an increase in vinyl Chloride emis sions within 8 km of any other source BATES: Comments must be received on or before July 5,1977. nlng activities conducted pursuant to Pub. L. 94-482 might properly extend and augment the planning already begun which is subject to this subpart. ADDRESSES: Comments should be ad under Pub. L. 93-380. It was also noted (b) Reduction in production rate is dressed to Sidney High, UM. Office of by several commenters that State plan an allowable mechanism for attaining an Education, .7th and D Streets, S.W., ning already being conducted under Title offset in emissions. -- Room 3108-A, Washington, D.C. 20202. I and Title X of the Higher Education <c) The baseline emission rate is to be determined based on the level of emis sions allowable by the standard. (d) Reducing emissions from an in FOR FURTHER INFORMATION CON Act of 1965 (20 UJS.C. 1001 et aeq.) should TACT: also be coordinated with planning efforts Sidney High. 202-345-2331. conducted pursuant to Pub. L. 94-482 be` cause those titles deal with the continu terim emission limit to the standard for a SUPPLEMENTARY INFORMATION: ing education of adults and, therefore, source is not an acceptable means of (a) Organization. Part 163 (sections are closely related to the concept of achieving an emission offset. 331-334 Of Pub. L. 94-482), as set forth career education for individuals of all (e) In the application for approval of. In this proposed rule, contains thaoe pro ages. The. proposed- i 163.6(b) attempts construction required by f 61.07. owners- visions which are applicable to the pro to avoid duplication by requiring the or operators of sources subject to this gram of Federal assistance to States and allottee to explain the relationship be subpart shall include, in addition to the other allottees to enable them to plan for tween planning activities carried out un information required by i 01.07, the fol the development of career education and der Pub- L 93-380 and proposed under lowing information: ' career development programs. The as Pub. L. 94-482 In the event that the plan (l) The name, address, and location sistance provided under this Part is also ning is addressed to the same age groups. or any plant subject to this subpart subject to the applicable provisions con - On the related question of priorities which is located within 8 km of the pro tained in the Office of Education General between K-12 and postsecondary plan posed location of the source to be con Provisions Regulations published In 45 ning. while the majority of commenters structed. v CFR Farts 100 and 100b (38 FR 30654. Identified the need for cooperation be- . . -. ,RDCKAl ItOISTEt, VOL 42, NO. 104--THUSSOAY, JUNI 3, 1*77 5 t JO & 03 IO fo to' * fc R&S 115263 V APPENDIX 6 GLOSSARY Terms used in the NESHAP regulation for vinyl chloride are defind as follows.* (a) "Ethvlene dichloride plant" includes any plant which produces ethylene dichloride by reaction of oxygen and hydrogen chloride with ethylene. (b) "Vinyl chloride plant" includes any plant which produces vinyl chloride by any process. (c) "Polyvinyl chloride plant" includes any plant where vinyl chloride alone or in combination with other materials is polymerized. (d) "Slip gauge" means a gauge which has a probe that moves through the gas/liquid interface in a storage or transfer vessel and indicates the level of vinyl chloride in the vessel by the physical state of the material the gauge discharges. (e) "Type of resin" means the broad classification of resin referring to the basic manufacturing process for producing that resin, including, but not limited to, the suspension, dispersion, latex, bulk, and solution processes. (f) "Grade of resin" means the subdivision of resin classification which describes it as a unique resin, i.e., the most exact description of a resin with no further subdivision. (g) "Dispersion resin" means a resin manufactured in such a way as to form fluid dispersions when dispersed in a plasticizer or plasticizer/ diluent mixtures. (h) "Latex resin" means a resin which is produced by a polymerization process which initiates from free radical catalyst sites and is sold undried. (i) "Bulk resin" means a resin which is produced by a polymerization process in which no water is used. (j) "Inprocess wastewater" means any water which, during manufacturing or processing, comes into direct contact with vinyl chloride or polyvinyl chloride or results from the production or use of any raw material, intermediate,product finished product, by-product, or waste product containing vinyl chloride or polyvinyl chloride but which has not been discharged to a wastewater treatment process or discharged untreated as wastewater. *Federal Register, Volume 42, page 29006, and Volume 40, page 59544 and 59545. R&S 115264 GLOSSARY (continued) (k) "Wastewater treatment process" includes any process which modifies characteristics such as BOD, COD, TSS, and pH, usually for the purpose of meeting effluent guidelines and standards; it does not include any process the purpose of which is to remove vinyl chloride from water to meet requirements of this subpart. (l) "In vinyl chloride service" means that a piece of equipment contains either a liquid that is at least 10 percent by weight vinyl chloride or a gas that is at least 10 percent by volume vinyl chloride. (m) "Vinyl chloride detector" means a device which obtains air samples from one or more points on a continuous sequential basis and analyzes the samples with gas chromatography or, if the owner or operator assumes that all hydrocarbons measured are vinyl chloride, with infrared spectro photometry, flame ion detection, or an equivalent or alternative method. (n) "Portable hydrocarbon detector" means a device which measures hydrocarbons with a sensitivity of at least 5 ppm and is of such design and size that it can be used to measure emissions from localized points. (o) "Standard operating procedure" means a formal written procedure officially adopted by the plant owner or operator and available on a routine basis to those persons responsible for carrying out the procedure. (p) "Run" means the net period of time during which an emission sample is collected. (q) "Ethylene dichloride purification" includes any part of the process of ethylene dichloride production which follows ethylene dichloride formation and in which finished ethylene dichloride is produced. (r) "Vinyl chloride purification" includes any part of the process of vinyl chloride production which follows vinyl chloride formation and in which finished vinyl chloride is produced. (s) "Reactor" includes any vessel in which vinyl chloride is partially or totally polymerized into polyvinyl chloride. (t) "Reactor opening loss" means the emissions of vinyl chloride occurring when a reactor is vented to the atmosphere for any purpose other than an emergency relief discharge as defined in 61.65(a). (u) "Stripper" includes any vessel in which residual vinyl cloride is removed from polyvinyl chloride resin, except bulk resin, in the slurry form by the use of heat and/or vacuum. In the case of bulk resin, stripper includes any vessel which is used to remove residual vinyl chloride from polyvinyl chloride resin imnediately following the polymerization step in the plant process flow. t f GLOSSARY (continued) (v) "Standard temperature" means a temperature of 20 C (69 F). (w) "Standard pressure" means a pressure of 760 mm of Hg (29.92 in. of Hg). (x) "Oxychlorination" is a process for the production of ethylene dichloride which is made by the reaction of air and hydrogen chloride with ethylene in a catalytic process.** ** Defined by ARB staff. SSZSLL 20 & CO APPENDIX 7 EFFECTS OF AIRBORNE VINYL CHLORIDE Air Resources Board Staff Report 78-1-1 Available upon request from the Air Resources Board R&S 115266 r &S 115267 APPENDIX 8 State of California AIR RESOURCES BOARD NOTICE OF PUBLIC HEARING TO CONSIDER ESTABLISHMENT OF STATE AMBIENT AIR QUALITY STANDARDS AND/OR SIGNIFICANT HARM LEVELS FOR VINYL CHLORIDE NOTICE IS HEREBY GIVEN that the Air Resources Board, pursuant to the authority vested by Section 39601 of the Health and Safety Code, and to implement, interpret or make specific Sections 39606(b) and 41700 of the Health and Safety Code, will conduct a public hearing, at the time and place specified below, to consider the establishment of one or more state ambient air quality standards or significant harm levels (levels never to be exceeded) for vinyl chloride. On January 25, 1978, the Board received a status report from its staff and comments from interested persons on this item. As a result of information received on January 25 and subsequent thereto, the Board is proposing to take one or more of the following actions with respect to vinyl chloride air pollution: i -- Pursue enforcement of the emission regulations for vinly chloride monomer and related substances promulgated by the Environmental Protection Agency (EPA) on October 21, 1976 pursuant to Section 112 of the Clean Air Act [National Emission Standards for Hazardous Air Pollutants (NESHAPS)], and defer further state regulatory action until the NESHAPS emission regulations are fully implemented in October 1973. -- Pursue enforcement of the NESHAPS emission regulations for vinyl chloride and related substances and adopt a state ambient air quality standard or standards for vinyl chloride or designate a Significant Harm Level or Levels for vinyl chloride on the basis of existing scientific evidence. The ambient air quality standard would be attained or exceedances of the Significant Harm Level(s) would be prevented by means of rules to be adopted subsequently by the South Coast Air Quality Management District (SCAQMD). Tliese rules could be enforced, for example, by an air measurement program that includes con tinuous or frequent intermittent monitoring of vinyl chloride levels at the boundary line of vinyl chloride facilities to be conducted by the operators of such facilities, and/or by specific emission limitations. If the action taken is to set a Significant Harm Level, enforcement under Health and Safety Code Section 41700 could also be taken, through district permit requirements and/or legal action before a court of competent juris diction. The Board requests evidence and testimony relating to the effects of vinyl chloride exposures on health, illness, and irritation to the senses. The Board also seeks information relating to the appropriateness of a 24-hour or other averaging period, and appropriate test methods. Staff analysis of comments received during and subsequent to the January 25, 1978 Board meeting will be presented. (L 2- - R&S 115268 If one or more new state ambient air quality standards and/or Significant Harm Levels for vinyl chloride are established, the Board will make appropriate amendments to its regulations in Section 70200, Title 17, California Administra tive Code, relating to ambient air quality standards. The time and place for public hearing on this matter are as follows: DATE: April 27, 1978 TIME: 10:00 a.m. PLACE: Crystal Ballroom Hotel San Franciscan 1231 Market Street San Francisco, CA Copies of the staff report on this matter will be available for inspection at, or may be obtained from, the headquarters office of the Air Resources Board, 1102 Q Street (P.0. Box 2815), Sacramento, California 95812, Attention: Public Information Office, at least 30 days prior to the scheduled hearing date. All documents reviewed by the staff in connection with its consideration of the issues in the staff report, together with written comments received from Interested persons, if any, will also be available for inspection and copying. NOTICE IS FURTHER GIVEN that any Interested person may present oral or written statements at the public hearing referred to above. The Board requests that Interested persons who have written statements on this matter submit 10 copies of the same at least seven days prior to the scheduled hearing date in order to provide adequate time for staff analysis and conment, and to allow early review by the Board. Interested persons- > are further advised that the Chairman may require oral testimony to be limited In scope or duration; however, all persons will be allowed at least five minutes for presentation of oral testimony. Following com pletion of the public hearing, the Air Resources Board, on Its own motion or at the instance of any Interested person, may establish one or more ambient air quality standards and/or Significant Harm Levels for vinyl chloride. The Air Resources Board has determined that this action creates no additional cost to local government pursuant to Section 2231 of the Revenue and Taxation Code. March 22, 1978