Document k6ZEgMdy901OJ56Gzjvj9goGV

INTERORGANIZATION TO. ATTENTION FROM DATE SUBJECT ASHTABULA David Jenkins C. G. Lopez January 9, 1980 I noted in the latest BNA that your neighbor, Diamond Shamrock, received a five item willful citation with $50,000 in penalties for the following: 1. 1910.1017 (c) (1) failure to ensure that employees were not over-exposed to vinyl chloride. 2. 1910.1017 (g) (4) for failure to provide respirators appropriate for protection from exposure to vinyl chloride. 3. 1910.1017 (g) (6) (ii) for failure to ensure that a monitoring system provided adequate indications of the concentrations of V.C.M. They also got hit for lead exposure and improper floor guarding. Since these people are so close to you it might be advisable to call them and discuss the exact details of the citations and establish if we have similar conditions. cal FORM 1 BONO GENC 19194 BETTER Service Is Our Business' RECEIVED JAN i ''' 80 & W. Laundrie La- Aahtabula A. D. Jeffrey II. E. Jewett January 11, 1980 Diamond Shamrock Diamond Shamrock was fined $52,000 by OSHA over violations at thair Delaware City PVC facility. The sequence of events were as follows: 1. A female OSHA inspector of child bearing age stopped at Stauffer PVC plant for a brief inspection and was turned away. 2. She had a complaint over lead dust to investigate at Diamond, so she went there next. They would not let her in. She became upset and said she would get the paperwork (court order?) to get in and left. 3. OSHA District Director called Diamond. Diamond said if she'd sign a release of responsibility, they would let her in. OSHA refused. Finally Diamond agreed to let her in under conditions of constant monitoring and respiratory protection. 4. After they entered the plant, the inspection went on and off for nine (9) months. 5. Three (3) days before OSHA's deadline to cite, she end District Chief came to Diamond and laid the following citations on Cham three (3) serious citations and five (5) willful. (1 am not sure which of these are serious and which willful except the first.) a. Employees exposed to 4-1 ppm end/or 4-5 ppm for 15 minute#. Workers did wear respirators in ell cases except one. b. Areas monitoring system: (1) Alarm levels too high - sat at 10, 25, & 100 ppm. Should be 1, 5 ppm per OSHA. (Ours are 4-1 & 4-5) (1) Monitoring results not adequate to protect workers. (3) Monitor points not located adequately. (4) Alarm system did not prevent an employee from being exposed. 1 GENC 19195 c. o beard policy and noor control or testing respirator fit. iuo crjinii'.", on rns'lntors inadequate. . ,su: ;uot exposure. e. date on work platform not closed to prevent worker from falling. Repeated open after warned by 05HA inspector. f. breathing air system analysis and air processing (lack of carbon filter?) (We have one.) g. Tot labeling FVC waste containers per Standard. n. Policy of Engineering compliance and getting to lowest possible level was not emphasised and current. Diamond's policy of complying with Standard and not doing Engineering is a violation of Standard. (This one tends to confuse me) I think really the citation was because they did not have a working engineering plan to reduce levels in work areas. I conclude levels in work areas have been increasing at Diamond which is what caused this problem. Ours is decreasing. Our engineering plan needs to be updated. Interesting Sidelines: 1. Fingham told District to 'get tough again on VC1." 2. Diamond did get all willful violations except #1 above reduced to serious, and fine reduced to approximately $5,000. 3. Used plant records as proof of her findings. 4. Took word of workers on Company violations of Standard. 5. Obvious vendetta on her part to get Diamond because of their position. Any questions, please call. { ] , - t H. E. Jewett Plant :ianager TJJ/ikb cc: R. Vi. Laundrie Staff GENC 19196 Pollutl nC ntr I Microprocessor-based ambient air monitoring system provides rapid detection of VCM leaks FRANK L. CONRAD Technical Supervisor CertainTeed Corporation Pipe & Plastics Group Sulphur, Louisiana MARX ISAACS, Southwestern Editor New Solutions to Plant Problems Problem: At the Sulphur, Louisiana plant of the CertainTeed Corporation, the raw material is vinyl chloride monomer (VCM); the product, poly vinyl chloride (PVC). Emissions into the atmosphere must be eliminated in order to comply with federal air pollu tion control regulations and to avoid loss of product. Until September 1977, when a new system was installed, an infrared ana lyzer was used for monitoring the air leaving the VCM process. Inaccura cies were encountered due to drift and temperature sensitivity of the analyz er, and there were maintenance prob lems. An analysis required three min utes, so that if a VCM leak occurred, it was at least three minutes old before an operator could take the proper measures to correct the situa tion and stop the air pollution and loss of product. Solution: An ambient air monitor ing system was installed to replace the infrared analyzer. It consists of a sampling system, a process microcom puter (PMC) which controls the con tinuous operation of two chromato graphs, each with a flame ionization detector (FID). The detector signals are sent back to the microcomputer for processing. Communication is done through two typewriters with printout. One is in the ambient air sampling building, the other in the technical supervisor's office. Ambient air samples are taken at 30 points, with 15 pumped to each of the two 112 DECEMBER 1980 CHEMICAL PROCESSING GENC 19197 t Safety new literature Safety supply catalog featiires a wide variety of products to assist in meeting OSHA regulations Included are drench showers, goggles, face shields, protec tive clothing, hearing protection, burn stations, fire extinguishers and more All products m the 64-pg catalog are described and illustrated in full detail Safety supply cat -- Interex Corp r:'(? or" OCPP3 Te 30 C3ge Garments of Tyvek spunbonded olefin are fully described in 12-pg bulletin. Workers are protected in a variety of hazardous or dirty jobs involving such materials as asbestos, PCBs, pesticides and lead dust Barrier properties, liquid hold-out, chemical protection, tough ness and durability, breathability / com fort and cost performance are all addressed in the illustrated brochure. Tyvek bro -- Du Pont Co C.rcie 51S opposite rast page Plant identification products, including conduct and voltage markers, pipe marking products, aisle marking dots and tapes, visual barricading products, complete systems for numbering and lettering, sign-making components, inte rior and exterior graphics systems, vehi cle placards and safety signs are described in a 118-pg catalog Catalog S-4 -- W H Brady Co ",''f 51? ODDOvte `i p3ee Over 100 disposable garments, includ ing head gear, smocks, aprons, pants, shirts, coveralls, jumpsuits, shoe covers and other accessories, are discussed in catalog. Made of Tyvek, these garments are designed to meet most clean room and health hazard requirements and are strong enough to reuse many times. Disposable clothing cat -- Melco, Inc Circle 520 opposite last page Digital audible dosimeter with a range of 0-9999 mfi is described in a bulletin The instrument had LCD readout and presettable integrated alarms from 109999 mR and rate alarms from 100-9000 mR/hr All alarms are inside the device so that they are inaccessible to the user after being preset by the radiation safe ty personnel SuperDAD bul 1888 -- Dosimeter Corporation of America C.rcie 521 opposite sst page Protective footwear and clothing cata log analyzes each boot and protective suit by the way they perform at specific hazardous iob sites. Line has been organized so that customer can select products by materials, construction and price. Protective clothing cat -- Uniroyal, Inc. Circle 522 opposite last page For more information circle correspond ing numbers on deader Service Card opposite Pack cover THEREIS NO EQUAL Down through the years, customers have told us, time and again, there is no equal to our facilities for reactor, tank, column and pressure vessel fabrication. Customers tell us how clean and orderly our factories and offices are. They tell us about all the help they get from friendly, willing people--from highlyqualified engineering specialists, salesmen who follow right through to on-time shipment, production personnel who keep up to date on scheduling, inspection and quality control people who look after every minute detail Customers always note the pride of our craftsmen. Everything we do is precisely calculated to please our customers, because they are the most important part of our business. For full details, write for Bulletin BF-21 BRIGHTON Brighton Corporation Master metalsmiths to the process industries 11861 Mosteller Road. Cincinnati, Ohio 45241 Phone (513) 771-2300 Air sampling point on an overhead line analyzers. A 16th stream to each is used for calibration, done once each shift, or three times every 24 hours. Ninety-six analyses are made in 24 hours for each sampling point, each requiring 60 seconds, with continuous typewriter printouts showing VCM in parts per million and location and exact time of each sample. Gas chro matography is the method recognized by OSHA for monitoring levels of vinyl chloride and other hydrocar bons. The tolerance is a maximum of 10 ppm VCM from any control device. An alarm registers immediate ly on the printouts if VCM reaches 5 ppm at any sampling point, indicating a leak; the alarm continues to register until the VCM level is reduced. The PMC controls the timing of sample taking and holds analyses in memory until 12 01 AM each morn ing, then takes about 20 minutes to print out all readings and averages in a 24-hour report. Appropriate pro gramming can provide averages for any desired time periods, e.g., by the hour or shift. Data can be transferred to a minicomputer with greater stor age capacity. Results: The ambient air monitor ing system has functioned smoothly and there have been no maintenance problems to date. The alarm feature is considered one of the greatest advan tages over the former system of analy sis. VCM leaks, which occur infre quently, are rapidly detected and stopped, saving an estimated 100 manhours per month, minimizing product losses due to leaks, and com plying with federal control regulations for VCM content of air emissions. Information on the Areas Model 505 Analyier and Model 2000 Process Micro Computer is given in Bulletins 300-0179 and PMC-0578 from Foxboro Analytical, a division of The Foxboro Co., Areas Chromatography Center, 10707 Haddington St., Hous ton, TX 77043. Circle 524 opposite last page Continuous air analysis printout in supervisor 's office GENC 19199 DECEMBER 1980 CHEMICAL PROCESSING 113 Pollution Control products rapid and easy to run. Vlany use premeasured reagents and precalibrated meter scales producing quick results which allow prompt remedial action |HMDK portable laboratorv - Hach Chemical Co,. Box 389, Loveland, CO 80537 ) ' ' ^ P,?? .IDPOS Pt .3 it Pollution detection lab monitors 300 substances Hazardous materials detection kit is a complete, portable laboratory which provides a rapid means for determining the extent and severity of toxic substance contamination. The kit uses 15 general test methods to monitor over 300 hazardous materi als, Portable carrying case contains a spectrophotometer, pH meter, con ductivity meter and all required reagents and apparatus. Tests are Packaged scrubber system mounted on skid Complete "packaged" scrubber sys tem is pre-assembled and mounted on a skid for in-plant installation. System consists of a scrubber and separator vessel in addition to a liquid storage tank, recycling pump, piping, level controls, pressure blower, pressure cartridge filter, flue dampers and annunciator panel. All electrical and mechanical engineering is completed before shipping. The unit meets all OSHA and EPA compliance standards. Energy re quirements are minimized through the selection of high-efficiency fan and pump systems. System can treat 6000 acfm and lower gas flow rates with a variable throat control. Skid mounted units can also be designed with flow rates up to 70,000 cfm, (Packaged scrubber system -- Air Pollution Control Equipment Div,, C roll-Reynolds Co . Inc, 751 Central Ave , Westfield, \'J 07091 ) Circle 526 opposite last page 1U DECEMBER 1980 CHEMICAL PROCESSING ) rue 527 opposite 'ast page genc l, 9200 Section 61.66 61.65(b)(8) 61.67 61.67 61.69(b)(1) 61.70(a) 61.64(a)(3) 61.65(a) SIGNIFICANT DATES AND DEADLINES FOR EPA VINYL CHLORIDE STANDARD Ijtem Date Promulgation Date Effective Date October 21, 1976 Equivalent equipment and procedures November 20, 1976 Formal leak detection program December 5, 1976 Enforcement Date January 19, 1977 Request for Waivers January 19, 1977 but for real consideration December 5, 1976 Emission Tests (no waiver) January 19, 1977 Emission Tests (if waiver requested) January 19, 1979 Initial Report (no waiver) for existing sources and new sources with startup before effective date January 19, 1977 Initial Report (with waiver) as scheduled by Administrator Initial Report - startup after effective 90 days after startup date date (October 21, 1976) Semi-Annual Report First - January 19, 1977 Continuing - on March 15 and September 15 Emergency Manual Vent Valve Discharges 10 days after occurrence to Administrator Relief Valve Discharges 10 days after occurrence to Administrator GENC 19201 EXPANDED INDEX TO PARAPHRASED EPA VINYL CHLORIDE STANDARD Page Section Title 46564 61.60 Applicability (a)(1) ethylene dichloride (EDC) (a)(2) vinyl chloride (VC) (a)(3) polymers of vinyl chloride (PVC) Non-Applicability (b) R&D reactors up to 50 gallon capacity Partial Applicability (c) For R&D reactors between 50 gallons and 1100 gallons, only sections 61.64(a)(1), 61.64(b), 61.64(c) and 61.64(d) apply. 61.64(a)(1) - exhaust gases from such reactors cannot exceed 10 ppm of VC except that reactor opening loss Q&1.64(a) (2f) and relief valve discharge clause 61.65 (a)] are fully applicable. 61.64(b) - exhaust gases from strippers cannot exceed 10 ppm of VC except that the relief valve discharge clause 61.65(a) is fully applicable. 61.64(c) - exhaust gases from mixing, weighing and holding containers cannot exceed 10 ppm of VC except that the relief valve discharge clause 61.65 (a_2 is fully applicable. 46564 61.61 DEFIOTIONS (a) Ethylene dichloride plant (b) Vinyl Chloride plant (c) Polyvinyl chloride plant (d) Slip gauge (e) Type of resin (f) Grade of resin (g) Dispersion resin (h) Latex resin (i) Bulk rein (j) In-Process water waste (k) Waste water treatment process (l) In vinyl chloride service (m) Standard operating procedure (n) Run (o) Ethylene dichloride purification (p) Vinyl chloride purification (q) Reactor (r) Reactor opening loss (s) Stripper GENC 19202 Page 46565 Section 61.62 46565 61.63 46565 61.64 -2- Title EMISSION STANDARD FOR ETHYLENE DICHLORIDE PLANTS (a) Ethylene dichloride purification: exhaust gases cannot exceed 10 ppm of VC except that relief valve discharge section J3l.65(ay] is fully applicable. (b) Oxychlorination reactor: exhaust gases cannot exceed 0.2g VC/kg (200 ppm) of ethylene dichloride. Again, relief valve discharge clause (111. 65 (aj] is fully applicable. EMISSION STANDARD FOR VINYL CHLORIDE PLANTS (a) Vinyl chloride formation and purification: exhaust gases cannot exceed 10 ppm of VC. Again, relief valve discharge clause |61.65(a)|is fully applicable. EMISSION STANDARD FOR POLYVINYL CHLORIDE PLANTS (a)(1) Reactor: exhaust gases cannot exceed 10 ppm of VC except that reactor opening 61.64(a) (2^ and relief valve discharge |~51.65(aT1 clauses are fully applicable. (a)(2) Reactor opening loss: cannot exceed 0.02g VC/Kg PVC (20 ppm) (0.00002 lb. VC/lb PVC). For bulk type resin, same number applies to combined losses of PREPOL and POLY REACTORS. (a) (3) Manual vent valve discharge: No discharge to atmosphere permitted except In a bona fide emergency. Discharges must be reported in writing to Regional Administrator within 10 days showing: 1) source 2) nature 3) cause 4) date and time 5) amount of VC loss 6) method for calculating loss 7) prevention measures taken 8) remedial measures planned (b) Stripper: exhaust gases to atmosphere cannot exceed 10 ppm of VC except that relief valve discharge clause f3l-65(a}is fully applicable. (c) Mixing. weighing and holding containers in VC service: exhaust gases to atmosphere cannot exceed 10 ppm of VC except that relief valve discharge clause [~61.65(aTl is fully applicable, (d) Monomer recovery system: exhaust gases to atmosphere cannot exceed 10 ppm of VC except that relief valve discharge clause 1~&1.65(aTlis applicable. GENC 19203 46565 Section 61.64 46565 61.65 46566 61.65 -3 Title (e)(1) Sources following stripper(s): Strippers Used (e)(l)(i) for dispersion type resins, 2000 ppm (e)(1)(ii) for suspension, latex, bulk and solution type resins, 400 ppm Strippers Not Used (e)(2)(i) for dispersion type resins, 2000 ppm (e)(2)(ii) for suspension, latex, bulk and solution type resins, 400 ppm EMISSION STANDARD FOR EDC. VC AND PVC PLANTS (a) Relief valve discharge: permitted only in an emergency. Emergency discharge defined as discharge that could not have been prevented. Such discharges must be reported within 10 days to Regional Administrator (see 61.64(a)(3) above for details of report). FUGITIVE EMISSION SOURCES ' (b)(1) Loading and unloading lines: emissions of VC must be minimized by: (i) prior to breaking line open to atmosphere, VC content must be reduced to 0.0038 nr (0.13 ft^) at STP. (ii) VC must be removed to primary control device that exhausts less than 10 ppm of VC (or equivalent under 61.66). (b)(2) Slip Gauges: must be exhausted to primary control device that exhaust less than 10 ppm of VC (or equivalent under 61.66). (b)(3) Leakage from pump, compressor or agitator seals: (i) Rotating pumps in VC service: must use double mechanical seals, sealless pumps or equivalent under 61.66. Leaks must be directed into pump or into primary control device that emits less than 10 ppm of VC (or equivalent under 61.66). (ii) Reciprocating pumps in VC service: must use double outboard seals (or equivalent under 61.66). Leakage must be directed into pump or into primary control device that emits less than 10 ppm of VC (or equivalent under 61.66). (iii) Rotating compressors in VC service: must use double mechanical seals (or equivalent under 61.66). Leaks must be directed into compressor or to primary control device that emits less than 10 ppm of VC (or equivalent under 61.66). GENIC 19204 Page 46566 Section 61.65 -4- Title (iv) Reciprocating compressors in VC service: must use double outboard seals (or equivalent under 61.66). Leaks are to be directed into compressor or to primary control device that emits less than 10 ppm of VC (or equivalent under 61.66). (v) Agitators in VC service: must use double mechanical seals (or equivalent under 61,66). Leak must be directed into agitated vessel or into primary control device that emits less than 10 ppm of VC (or equivalent under 61.66). (b)(4) Leakage from relief valves in VC service: Must use rupture disk before valve or direct leaks into process line or direct leaks into primary control device recovery (or equivalent under 61.66), (b) (5) Manual venting of gases from vessels in VC service: Must be directed into primary control device that emits less than 10 ppm of VC (or equivalent under 61.66) except in bona fide emergency shown in 61.64(a)(3). Actions conducive to obviating emergency manual discharges inclui e: (b) (6) (b)(7) (b)(8) A) Up-to-date written operating instructions B) Proper operator training and retraining C) Proper maintenance of equipment D) Discharge to control devices E) Emergency electrical generators F) Emergency refrigeration capacity G) Stopping reactions Opening of equipment: Emissions must be minimized by: (i) reducing volume of VC to 2.0 percent or less or 0.0950 m^ (25 gallons), whichever is larger. (ii) removed VC must be directed to primary control device that emits less than 10 ppm of VC (or equivalent under 61.66), Samples: that were taken from equipment in VC service must be directed into closed process system. Leak detection and elimination: requires formal leak detection and elimination program (last date to comply is 12/5/76 unless waiver is requested in which case regional administrator will set date) for all equip ment in VC service. Such programs must include: (i) reliable and accurate system of monitoring for MAJOR leaks on a continuous sequential basis (can be 1R or GC measurements or equivalent). GENC 19205 < Page 46566 Section 61.65 46567 61.65 / 46567 61.65 -5- Title (ii) Reliable and accurate portable detectors (sensitivity of 10 ppm HC). (ill) Acceptable calibration and maintenance schedules. Daily span check required for monitorconcentration defined by definition chosen for leak in 61.65(b)(8)(VI). Calibration may be done with: A) Mixtures prepared from 99.9+% VC and a calibrated VC-Nj mixture traceable to NBS or to a gravimetrically calibrated VC permeation tube, or B) A calibrated VC-N? mixture traceable to NBS or to a gravimetrically calibrated permeation tube. (iv) Frequency and number of points and locations for monitoring are dependent on plant size and physical layout. (v) Plan for affirmative action is clear and convincing. (vi) An acceptable definition of leak. Give in terms of "over background level". (b)(9) In-Process Wastewater: (i) Streams containing over 10 ppm of VC must be stripped to less than 10 ppm of VC before being mixed with streams containing less than 10 ppm of VC, before being exposed to the atmosphere, before being discharged to a waste water treatment plant or before being discharged untreated as a wastewater. Above does apply to water used for gas displacement [(sections 61.65(b)(6) and 61.64(a)(2)j of equipment in VC service but does not apply to wash water used in vessels already opened to atmosphere. (ii) Any VC stripped from such wastewaters must be directed to primary control device that emits less than 10 ppm of VC (or equivalent under 61.66). (c) The requirements of: 61.65(b)(1) - Loading and Unloading lines 61.65(b)(2) - Slip gauges 61.65(b)(5) - Manual venting 61.65(b)(6) - Opening of equipment QENC 19206 61.65(b)(7) - Samples 61.65(b)(8) - Leak detection and elimination are to be incorporated into SOP that is available to EPA upon request. Title Additionally, SOP mast include provisions for measuring VC in equipment over 1250 gallons for which an emission limit is set in 61.65(b)(6) - Opening of Equipment prior to the actual opening. Measurement can be made by using: A) Method 106 B) Portable Detector C) Alternative or equivalent means Equivalent equipment and procedures: Request must be in writing directed to Regional Administrator. Last date to request is November 20, 1976 for existing sources. For new sources, requests must accompany the application for approval of construction or modification. Emission Tests Unless a waiver of tests has been granted: (a)(1) (a) (2) (b) (c) (d) (e) (f) (g) (g)(1) Emission tests must be made starting January 19, 1977 for existing sources or new sources started up before January 19, 1977. For a new source, tests must be run within 90 days of startup date, You must notify Regional Administrator 30 days before emission test in case he wants to send an observer. Emission tests must be run at maximum production rate at which equipment can reasonably be expected to operate in foreseeable near term (90 days) future. Emission tests consist of three (3) runs on a time weighted basis. Samples for emission tests must be analyzed within 24 hours. VC emissions must be determined within 30 days after emission test and be reported to Regional Administrator via registered letter posted no later than next business day. Emission test data must be retained for two years on plant site. Test methods 106 and 107 must be used unless equivalent or alternative method has been approved by Administrator. Reference method prevails if there is a dispute. Test Method 106 is used for the following: 61.62(a) - EDC purification 61.62(b) - Oxychlorination 61.63(c) - VC purification 61.64(a)(1) - Reactor releases 61.64(b) - Stripper releases 61.64(c) - Mixing, weighing, holding releases GENC 19207 Page 46567 Section 61.67 4656S 61.68 -7- (g)(2) (g)(3) (g)(4) (g)(5) 61.64(d) - Monomer recovery releases 61.64(a)(2) - Reactor opening loss 61.65(b)(1)(H) - Unloading line releases 61.65(b)(2) - Slip gauge releases 61.65(b)(5) - Agitator seal releases 61.65(b)(6)(H) - Relief valve releases 61.65(b)(9)(H) - Water stripper releases Test method 107 is to be used for the in-process wastewaters streams that have emission limits (see 61.65(b) (9)(i), Test method 107 is to be used for ail resin slurry samples where stripping technology is used for emission conpliance (see 61.64(e). (i) number of strippers and types and grades of resin to be sampled are to be determined by administrator at time of emission test. (ii) Slurry samples are to be taken after stripping operation is complete. (Hi) Production per stripper on a dry solids basis must be approved by Administrator (historical material balances will suffice). (iv) Duplicate samples are required only if Administrator asks for them. Where add-on devices or a combination of stripping plus add-on devices are used for control (i) Test method 106 is used for atmospheric emissions and (H) Test method 107 is used for in-process waste water streams covered by 61.64(e). Reactor opening loss will be determined as part of emission limit prescribed in 61.64(a)(2), EMISSION MONITORING (a) Continuous sequential monitoring is required for: 61.62(a) EDC purification 61.62(b) Oxychlorination reactor 61.63(a) VC formation and purification 61.64(a)(1) Reactor exhaust gases 61.64(b) Stripper exhaust streams 61.64(c) Mixing, weighing & holding exhaust streams 61.64(d) Recovery exhaust streams and all exhausts from primary and secondary control devices. (b) Continuous sequential monitors can be GC, IR, FID or an equivalent or alternative method. OENC 19206 Zaaa 46568 Section 61.68 46568 61.69 46568 46569 61.70 61.70 Title -8- (c) Dally Span Check is to be run with VC concentration of 10 ppm for tests in 61.68(a) (except for 61.62(b) - oxychlorination vent). For 61.62(b) oxychlorination vent, the span check should conform to a VC concentration based on emission limit set in 61.67 INITIAL REPORTS (a) Statement must be submitted in writing that following equipment and procedures are being implemented: 61.65(b)(1) 61.65(b)(2) 61.65(b)(3) 61.65(b)(4) 61.65(b)(5) 61.65(b)(6) 61.65(b)(7) 61.65(b)(8) Loading Lines Slip Gauges Compressed reactor seals & leakage from pumps Leakage from relief valves Manual venting Opening of equipment Samples Leak detection and elimination (b)(1) Due dates for initial report No waiver - January 19, 1977 With waiver - as scheduled by the Administrator. Applies to existing sources and new source with startup before effective date (October 21, 1976). (b)(2) For new sources (startup after October 21, 1976), initial report is due 90 days after startup date. (c) Statement must include: 1) List of equipment installed for compliance 2) Physical and functional characteristics of each piece of equipment 3) Methods in SOP for measuring and calculating emissions in 61.65 (b)(1)(i) - loading and unloading lines losses 61.65(b)(6)(i) * opening of equipment losses 4) Statement that such equipment and procedures are actually being used. SEMI-ANNUAL REPORTS DUE OATES - Semi-Annually GENC 19209 Page 46569 Section 61.70 46569 61.70 9- Title (b)(1) If no waiver is granted, for existing sources or new sources with startup dated before October 21, 1976 on January 19, 1977. If waiver is granted, first report date will be set by Administrator. (b)(2) For new source with startup date after October 21, 1976, the first semi-annual is due 180 days after such date. (c) Contents of Semi-Annual Reports (Reference analytical methods prevail when there is a difference between equivalent, alternative and reference methods). (c)(1) Report emissions that exceed standard for averaged one hour time in following areas: (c)(2) 61.62(a) - EDC purification 61.62(b) - Oxychlorination vent 61.63(a) - VC formation and purification 61.64(a)(1) - reactor releases 61.64(b) - stripper releases 61.64(c) - Mixing, weighing and holding tank releases 61.64(d) - recovery system releases and all other primary and secondary control devices Where stripping is used for control, submit VC content of PVC resins (slurries, latices, solutions, bulk). SAMPLE FREQUENCY (c)(2)(i) Batch stripping - each batch of each grade (c)(2)(ii) Continuous stripping - every 8 hours for each grade (c)(2)(iii) Quantity of Products - dry solids basis (c)(2)(iv) Duplicate Samples - only upon request of Administrator (c)(2)(v) Summary - by type for each 24 hour period and weighted by quantity of each grade (c)(2)(vi) Data developed in (c)(2)(v) must be retained for 2 years (c)(3) Semi-annual report must also show reactor opening losses RECORD KEEPING (2 Years) (a)(1) Leak monitoring results collected from continuous sequential monitoring system (a)(2) Leaks detected by portable analyser and action taken (a)(3) Daily operating record for each reactor GENC 19210 Page 46569 46571 Section -10- Title Test Method 106 Test Method 107 RWL/mls 11/5/76 R. W. Laundrie OENC 19211 Februar 15, 1980 kecewco fe6io\c'SO Area Director Occupational Safety & Health Ate. 12Uo . 9tb Street Cleveland, Ohio MtUb ^uundrte Dear Sira: A tacbed la Tbe General Tire & Bubber Co^enj'e report to U.8. Eft on an emergency relief and renting of vinyl chloride that occurred In our fadllt In Aabtabola, Ohio. There were no docunrated exposure* of employees to over tbe OBHA Standard for vinyl chloride. Several employees were required to wear respirators, and several operation* were euependad during this tine. Beepectfully Submitted, GB:aa attach. ce: A. D. Jeffrey lit Wi Inuadile H. X. Jewett 0. K. BrmfaMb Technical Superintendent QENC 19212