Document jy5Z9B0ZRXa52zrvjeReYj2g9

ENVIRONMENTAL PROTECTION ADMINISTRATION Reeulationa on Vinyl Chloride Emissions for Monomer and Resin Plants 1. Time Schedule March 8 1975 -Issue draft of proposed regulation, health effects, and environmental impact statement March 25 & 26, 1975 -Review and comment on draft before National Air Pollution Advisory Committee Late June July October 1975 1975 1975 -Publish regulation in Federal Register -Public Hearings on Regulation -Promulgate the Regulation 2. Basis The EPA Administrator is going to invoke Section 112 of the Clean-Air Act by declaring VC a hazardous pollutant which permits definition of procedures, equipm nt, etc. so long as the public health is endangered. Maximum period permitted for full compliance is two years. 3. Regulation for PVC Plants. a. Fugitive Emissions - Leaks, Relief Valves, Sampling, Loading and TTnlnadmg. Cleaning Strainers Control by equipment specification. Fixed point monitoring supplemented by portable monitoring. A formal program of leak detection must be mounted and records of such action kept. Canned pumps or pumps with double mechanical seals. Pipe line delumpers, ruptur discs before relief valves, revised sample methods, etc. b. Reactor Entry Emissions Permissible emission is 0. 001 lbs. /lb. of resin produced. ucc 025761 3. Regulation for PVC Plants (cont'd.) 2. c. Re.ac.tor Safety Valve Discharges None permitted through gas holder collection, auxiliary power, better instruments, etc. d. Plant System from Reactor to Dryer Blowdown, monomer recovery system, blend tanks, centrifuges, and the like. Vents limited to 10 ppm VC concentration via scrubbers, adsorbers, etc. e. Drver. Silos, and Packaging Operations. Permissible emissions limited to following formula: Resin to Dryer VCM cone. - Resin out VCM cone. = 400 ppm man f. Water Leaving Plant At Source. Maximum VCM emission 0. 0043 lbs. /100 lbs. resin produced. g. No exceptions will be made for any plant or process. 4. Monomer Plants Fugitive emissions controlled by equipment specification and formal leak detection program as per the resin plant. Alt other vents * mt^mnm permissible VCM concentration 10 ppm. UCO 025762 5. Costa for 150 MM Pounds/Year Suspension Resin Plant Capital Cost $1,638,000 Operating Cost/Year includes depreciation, maintenance, interest cost, etc. ($220,000) 3. 6. General for PVC Hants Yenta cleaned up by carbon adsorption, solvent absorption, or incineration. Reactor purges, safety valves, etc. Collect in a gas bolder as General Tire does. Dryer, etc. - Improved stripping of resin slurry. Resin Analysis - based on head space analysis - Perkin-Elmer BFG method. No averaging of resin types. Each product in 400 ppm limit. 7. Significance to UCC a. VCM unloading, storage, and tank-car maintenance - vent collection and scrubbing to 10 ppm. b. Solvent resins - probably good as planned except for monomer recovery vent which must be clean to 10 ppm. e. Dispersion Resins - UCC in better shape than most, but major investment is required. d. Suspension Resins - stripping and vent cleanup are investment problems. e. Non-Solvent Resins - stripping, vent cleanup, and emissions are investment problems. f. Latexes - present plants have no vent cleanup facilities. UCC 025763 A I 8. Actions Planned 4. a. B. F, Goodrich, Firestone, and UCC people will draft a white paper on the dispersion resin industry, b. EPA document will be reviewed and presentation via SPI will be made to NAPTAC on March 25, 1975, c. Ruckleahaus is considering ways to separate the plant and neighborhood cases of A. S. d. EPA costs on investment and operation are to be questioned. e. Air Products will discuss the water VCM limitation. RNWheelerJr/ra February 26, 1975 UCC 025764