Document dnKOjpvyaReeyaRG1aLwJppwb

mammies EPA - Emission Standards & Engineering Division Durham, North Carolina VCM/PVC PRODUCERS GROUP EPA TECHNICAL COMMITTEE Wednesday, September 8, 1976 - 6:30 PN Thursday, September 9, 1976 - 8:30 A2: ATTENDANCE: For Industry: G. Baise, Beveridge, Fairbanks & Diamond t F. C. Dehn, PPG Industries W. C. Holbrook, B. F. Goodrich J. R. Lawrence, SPI C. Loechelt, Ethyl Corp. W. W. Madden, Firestone J. P. Sandstedt, Tenneco R. N. Wheeler, Union Carbide For EPA: Jack Farmer Don Goodwin Susan Wyatt 1. The EPA Technical Committee met on the evening q- Septi review its position on R&D facilities with respect to EPA's E^o^g^ed ^WagdatdT on Vinyl Chloride. It was agreed that the position 6tated in tJfe^letleJybn Sri stationery (copy attached) should be submitted. However, reyai^lJm&nDers urged that the proposed change in the regulation be presented as an alurhrative to the language in the most current Draft Standard. 2. In meeting with Mr. Goodwin and his staff on September 9, the industry's position as presented in the SPI letter was presented with the recommendation SPI's suggested language be considered as an alternative to EPA's most recent version of the Standard. Mr. Goodwin explained that his work on the Standard is basically completed and that th would be difficulties to make any changes or delay its issuance as it now reads. He Indicated that he did understand the concepts of the problem but he would like to have more information on the specific facilities having such problems and the costs in volved in conforming to the Standard as it now reads. Mr. Goodwin indicated that if sufficient information can be supplied rapidly, he would consider introducing some language into the preamble of the Standard when it is published indicating some late information on R&D facilities is being reviewed that may require certain changes to be made in that area of the Standard. He emphasized that this is an unusual procedure and that he would need to have supporting facts THE SOCIETY OF THE PLASTICS INDUSTRY, INC. 355 Lexington Avenue New York, N.Y. 10017 573-9400 BFS OB9199 before he would propose changes In Che Standard. He further indicated that he was concerned about alternate interpretations of the Standard for R&D facilities as this would cause confusion with enforcement. 3. There were no other significant comments made by the industry with respect to the proposed Standard. Mr. Goodwin did indicate that his people will be working with the Enforcement Division of EPA as it prepares its guideline Document for use by EPA's field enforcement staff. 4. In a post-meeting discussion, the industry representatives agreed that John Lawrence send EPA a letter confirming our position on the September 7 letter being used as an alternative approach. It was further agreed that all members of the VCM/PVC Producers Group be contacted and encouraged to supply EPA with the following: . A description of the operating procedures that would be followed to verify compliance with the requirement that total combined emissions from all sources not exceed 0.05 lb of vinyl chloride per lb of vinyl chloride charged to the reactor. . Description of R&D facilities, identifying where they are located with respect to production equipment and the type of neighborhood surrounding the facility. . Information on the technical problems relating to compliance with the Standard as it now reads vs. the proposed alterna tive. . Information on i as it now reads ^-Standard 5. The meeting concluded at a] Respectfully submitted. John R. Lawrence Technical Director BFS O092OO The Society of the Plastics Industry, Inc. 355 Lexington Avenue New York, New York 10017 (212) 5739400 September 7, 1976 Mr. Don R. Goodwin Emission Standards & Engineering Division Environmental Protection Agency Research Triangle Park, North Carolina 27711 Dear Mr. Goodwin: After reviewing the proposed EPA Vinyl Chloride Standard, Mothers of SPI have raised an issue regarding the portion of the Propose&^SMiitfs^J relating to the Laboratory and Research and Development facilities. In SPI's initial comments to EPA on the-Sr^phsed 'Standard for Vinyl Chloride we proposed that polymerization rcaofrers=a. 500 gal, or less capacity be exempt from the standard. After vevie^t^gr^current and complete industry data, the SPI now agrees with the EPA that 50 is the appropriate cut-off point for exemption, based on examination of the data presented in Exhibits A and B; however, SPI respectfully requests that EPA reconsider its requirements for reactors between 50 and 1100 gallons capacity. The difficulties created in meeting the current proposal by EPA, in paragraph 61.64 go beyond the fact that costs far outweigh the benefits derived. It is true that larger reactors tend to be installed near production facilities for convenience of monomer supply; however, please be advised that several are at research facilities. Other research reactors are at a sufficient distance from the production equipment that their interconnection is not feasible. Long runs of vacuum or slurry lines are not practical, esp. cially in climates where subfreezing conditions are experienced. Line plugging, burning of resin, and excessive pressure drops will make these lines inoperative. There are also problems with sync rout/, at ion of remote operations and availability of equipment. In the short time we have focused on this issue, we have had confirmation from Air Products, Conoco, Firestone, Goodrich, Tenneco and Union Carbide that they will experience some or all of the problems raised above. Two of the major purposes for which pilot-scale equipment is used are development of improved products and processes, and the solution of plant production problems. In the first case, it is often impossible to obtain adequate scale-up data from a 50 gal. reactor. This is becoming more important as reactor sine increases in modern plants. In the second case, it is necessary that equipment be available Y Continued .... BBS 009201 Mr. Don R. Cood^ln 2- - Scptc.-mbcr 7, 1976 IthiumHate ly to resolve production problems, and that the polymerizer be as similar to production equipment as possible. Another problem arises when the research facilities are using -different comonomers from those in use at the production plant, which is a frequent occurrence. Common use of a single recovery/abatement facility is not possible under these circumstances. The spirit of the Proposed Standard calls for the use of the best available technology, to encourage innovations and to minimize potential losses by encouraging research and providing means for performing needed studies on the smallest practical scale. Any regulation that discourages the use of research equipment will limit innovation and improvement in the industry, and will lead to more developmental work being done in production equipment, where the potential for major releases is increased. We believe the present wording of the standard will- inhibit use of research facilities, not only because of the cost of compliance, but because of res trictions on the flexibility of operations. For example, in several installations the interconnection of research -end production equipment would take the operation of the research equipment out of the hands of trained engineers and put it under the Jurisdiction of production lnl-or because of the wording of union contracts. As another example, the rate and timing of the termination and recovery of unreacted monomer at the end of a batch can affect the properties of product, and to depend ^ iSVyon a product-oriented facility for this important servic- t realistic. We, therefore, request that 61.60(b) and (c) be^anjendea to read as follows: (b) Research and development equipm<(^oT 50 gal. or smaller capacity shall be exempt from this subnartjC Equipment larger than 50 gal. but no greater than 1100 gal, shi^iybe exempt, except that total combined emissions from all sources shdll be no more than 0.05 lb. vinyl chloride per lb. of vinyl chloride charged to the reactor. Each operator of such facilities shall submit a standard operating procedure to the agency for approval of its plan to meet this re quirement. "Tie attached data in Exhibit B show that eight companies would reduce their emissions substantially in complying with the SPI proposal, while company q is already in compli mice. The resulting total emissions would be about 68,000 lbs, per year, less than that emitted by reactors of 50 gal. or less, and less than 257. of current emissions. These 9 companies represent 457. of industry capacity, and include many of the major producers. Finally, we want to address the cost-benefit issue raised by the proposed Research and Development Regulation. The Agency has declared it does not want to require a technology when it will create costs which are grossly disproportionate to the benefits derived. SPI believes the proposed Research and Development Regulation creates a problem which to date El'A has sought to avoid--namely grossly disproportionate costs for the removal of small amounts of monomer. For example the cost of compliance with BFS 009202 tr -* " Mr. Ton R. Ooodwin 3- Soptf.i.Sor 7, 1976 the SPI proposal has been estimated at about $90,000 for one research facility in excess of 50 gal., while compliance with the EPA proposal will be about $''*00,000 per facility. The cost of the Sl'I proposal is equivalent to $.42 per lb. versus $7.19 per lb, of VC removed if the EPA level of 10 TPM is adopted. At least two companies have confirmed the magnitude of these estimates, based on our yet in complete survey. These are disproportionate costs for the removal of only 68,000 lb/yr of monomer of the entire country. ^ Based on the foregoing SPI contends that the WA VC Standard relating to laboratories and Research and Developu^njt facilities limits and restricts the flexibility of operation of these^a^lities while at the same time imposing disproportionate costs for th~"re'nibval of so little monomer. .. ^ We thank you for the opportunity to present these views. Very truly yours. ais* / John R. Lawrence Technical Director \ \ BFS 00 920