Document kaB33vvnj54jNR77wwedN0VY0
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Office df'^A-rr-OuaUty-Elanmng-and-Standards------- ~ Research Triangle Park, North Carolina 27711
5 1985
NOTICE OF DOCUMENT AVAILABILITY
On January 9, 1985, the Administrator of the U.S. Environmental Protection Agency (EPA) proposed revisions to the national emission standard for vinyl chloride under Section 112 of the Clean Air Act, as amended. The standard controls air emissions of vinyl chloride from facilities producing ethylene dichloride, vinyl chloride and polyvinyl chloride in the United States.
The proposed revisions represent administrative and clarifying revisions to the standard; no major revisions are proposed. The major technical analysis for the review of the standard is contained in "Vinyl Chloride - Relief Valve Standard." A copy of the proposed regulation revisions is enclosed. Details covering the public hearing and comment period for this proposed regulation are given in the Federal Register announcement.
Sincerely,
1 Enclosure
Robert L. Ajax Chief
Standards Development Branch
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Wednesday January 9, 1985
Part V
Environmental Protection Agency
40 CFR Part 61 National Emission Standards for Hazardous Air Pollutants; Vinyl Chi ride; Proposed Rule and Notice of Public Hearing
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ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 61 [AD-FRL-2707-4]
National Emission Standards for Hazardous Air Pollutants; Vinyl Chloride
agency: Envoronmental Protection Agency (EPA).
action: Proposed rule and notice of public hearing.
summary: The current emission standard for vinyl chloride (VC) was
promulgated under Section 112 of the Clean Air Act in 1978. A review of the
technological basis and administrative aspects of the standard has been
completed, and rha conclusions of the
review are presented in this notice The
conclusions are the basis for this action
which (1) proposes administrative and
clarifying revisions to the standard and
(2) announces decisions pertaining to
ether aspects of the current standard.
T!::. notice also withdraws proposed
revisions to the current standard which
w'r.ro
rj Fctlsrs! R6rtlcur
on f;:r*3 2. 197/ (42 FR 28154). if requested, a public hearing '.viil b>;
h.-tid to provide interested persons an
opportunity for oral presentations of
data, views, or arguments concerning
the proposed revisions to the current
standard.
dates: Comments. Comments must be
received on or before March 25,1985.
Public Hearing. If anyone contacts the
EPA requesting to speak at a public
hearing by January 301935. a public
hearing will be held on February 26,
19C3 beginning at 9:00 a.m. Persons
interested in attending the hearing
should call Ms. Shelby Joumigan at (919)
541-5573 to verify that a hearing will
occur. Request to Speak at Hearing. Persons
wishing to present oral testimony must
contact EPA by January 30.1385.
Incorporation by Referencs. The
incorporation by reference of certain
publications in these standards will be
approved by tha Director of the Federal
Register as of the date of the final rule.
addresses: Comments. Comments
should be submitted (in duplicate if
possible) to: Central Docket Section (A-
130), Attention Docket Number A-Bl-21.
U.S. Environmental Protection Agency.
401 M Street, S.W.. Washington, D.C.
20460.
Public Hearing. If anyone contacts the
EPA requesting to speak at a public
hearing by January 30,1985, the public
hearing will be held at EPA Auditorium.
corner of Highway 54 and Alexander Drive. Research Triangle Park, North Carolina. Persons interested in attending the hearing should call Ms. Shelby Joumigan at (919) 541-5578 to verify that a hearing will occur. Persons wishing to present oral testimony should notify Ms.
Shelby Joumigan, Standards Development Branch (MD-13), U.S. Enviromental Protection Agency. Research Triangle Park. North Carolina 27711, telephone number (919) 541-5378.
Background information Document The general findings of the review study are documented in ``Vinyl Chloride--A Review of National Emission Standards", EPA-450/3-82-003 (NTISP3 84-114354), available from the National Technical Information Service. 5285 Port Royal Road. Springfield. Virginia 22161. The major technical analysis for the review study is contained in a separate document which may be obtained from the U.S. EPA Library (MD-35), Research Triangle Park. North Carolina 27711. telephone number (919) 541-2777. Please refer to "Vinyl Chloride: Relief Valve Discharge Standard." EPA-130/3-35-C02, for the technical document.
l.edict. Docket .*o. *v--ill--21. containing supporting information used in developing the proposed standard, is available for public inspection and copying between 6:00 a.m. and 4:00 p.m.. Monday through Friday, at EPA's Central Docket Section. West Tower Lobby, Gallery 1, Waterside Mall, 401 M Street. SW,, Washington. D.C. 20460. A reasonable fee may be charged for copying.
FOR FUTHER INFORMATION CONTACT: Mr. Robert E. Rosensteel or Mr. Leslie B. Evans. (919) 341-3371. concerning technical aspects of the industry and control technologies, and Mr. Fred Dimmick or Mr. Gilbert H. Wood, (919) 541-5578. concerning regulatory decisions. The address for these contacts is Emission Standards and Engineering Division (MD-13). U.S. En vironmental Protection Agency. Research Triangle Park, North Carolina 27711,
SUPPLEMENTARY INFORMATION: *
Summary of Revisions to Currant Standard
Revisions. Several administrative changes are being proposed as a result of a review of the national emission standard for VC- No major revisions are being proposed to the standard- Aa with the current standard for VG the revisions are being established under Section 112 of the Clean Air Act The significant administrative revisions include: (1) Reformatting the emission
limit for relief valve discharges, (2) providing a compliance test procedure
and a specific emission limit for operators who perform stripping operations in reactors, and (3) specifyin requirements for leak detection and repair programs for certain equipment in VC service. Additional minor administrative changes to the standard are being proposed and are explained later in this premable.
Summary of Health, Environmental. Energy, and Economic impacts. Since no major revisions to the standard are being proposed, the impacts resulting from the current standard remain generally unchanged. In 1975. it was estimated that emissions of VC from plants producing ethylene dichloride (EDO), VC monomer and polyvinyl chloride (PVC) would be reduced from 36.000 Mg/yr to 4.910 Mg/yr under `.he current standard, representing an emission reduction of 91.000 Mg/yr of VC (or 95 cercent of VC emissions). Emissions of volatile organic compounds (VOC) and EDC are also reduced under the standard.
The estimated risks attributed to exposure to VC from EDC/VC snd PVC plants <r. operation prior to tha current standard were 3.5 cases per year for lit, -31 angiosarcoma and 11 cases per year for ail cancers. T'.e risks attributed to exposure to VC from sources under :he current standard have been estimated to be 0.28 cases per year for liver angiosarcoma and 0.55 cases per year for all cancers.
!n 1975. the estimated capital cost for existing plants to meet the VC standard was $198 million, of which $15 million was for EDC and VC monomer plants and S1R3 million was for PVC plants. The EPA estimated that the annualized cost (including capital amortization, etc.) to these plants to maintain the required emission levels would be $70 million per year.
Background
The VC standard was propossd on December 24.1975 (40 Fr 59532). and promulgated on October 21.1976 (41 Fr 48559). It is applicable to plants producing EDC .by the reaction of oxygen and hydrogen chloride with ethylene, plants producing VC by any process, and plants producting one or more polymers containing any fraction of VC. These plants are subject to different requirements at numerous VC emission points in the manufacturing process. These requirements include numerical emission limits, equipment specifications, and work practices.
The standard was designed to minimize the health risks associated
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with VC by requiring reasonable control measures. As stated in the preamble to the proposed standard (40 Ff 59532, December 24,1975), there is no known threshold level of effects for VC. Therefore, the only approach that would eliminate health risks associated with VC would ban its production and use. . This approach was not selected. Rather, an approach was selected to minimize the health risks associated with VC by use of reasonable control measure.
On November 19.1976. the .Environmental Defense Fund (EDF) petitioned the United States Court of Appeals for the District of Columbia Circuit to review the standard. On March 24.1977, the EDF and the EPA moved to dismiss the proceedings on the basis of a settlement agreement requiring the EPA to propose amendments which would require increased efficiency of existing control equipment, require more stringent control of new sources, and prohibit increases in emissions within the vicinity of an existing source due to new construction. The preamble to the proposed amendments was to state that the EPA's policy for regulating carcinogens under Section 112 of the Clean Air Act would include a general goal of eliminating emissions of carcinogens and that the EPA would initiate a review of the VC standard 3 years after the promulgation of the amendments.
On June 2.1977, the amendments were proposed 142 FR 28154). Many comments pertaining to policy, technological feasibility, and procedural aspects of the proposed amendments were received. Review of these comments indicated that additional technical data and cost information were required before the proposed amendments, or revisions of the proposed amendments. could*be promulgated.
Meanwhile, the EDF filed a petition with the EPA requesting the establishment of a comprehensive program for regulating airborne carcinogens under Section 112 of the Clean Air Act The aspects of the EDFs petition concerning the development of standards under Section 112 were similar to those proposed in the June Z 1977. amendments to the VC standard. Based on the similarity of the proposed amendments and the EDFs requested comprehensive program for regulating
airborne carcinogens, the EPA believed that it should not take final action on the proposed VC amendments until after it had acted on the EDFs petition-
On October 10.1979 (44 FR 58642). the EPA proposed "Policy and Procedures for Identifying, Assessing, and
Regulating Airborne Substances Posing
a Risk of Cancer." This proposal addressed several issues which were central to the proposed VC amendments. It also articulated the EPA's conclusion that Section 112 does not express an intent to eliminate totally all risks from emissions of airborne carcinogens. The EPA's selection of the level of control for a hazardous air pollutant emission standard would not be based on a policy that requires zero emissions of carcinogens. This policy is consistent with the basis for other recent actions under Section 112. For example, standards for benzene from coke ovens and leaks from equipment components in benzene service are not based on a zero emissions policy but rather on a reasonable level of control, which considers emissions and health risks.
The EPA believes it is not appropriate to leave the proposed amendments to the VC standard in effect or to promulgate amendments based on the proposed amendments. Therefore, the June 2.1977. proposal is withdrawn. As described in the following section of this notice, the EPA began a review study to obtain additional technical data and cost information and to determie whether other amendments to the standard are needed. New amendments developed as a result of the review study are proposed in this notice.
Review of VC Standard
Early in 1980 the EPA began a review of the VC standard. The primary purpose of the review was to investigate the adequacy ana appropriateness of the standard in light of policy decisions, health studies, control technology developments, and enforcement and compliance experience which have occurred since the standard was first promulgated. The review consisted of a screening study of: (1) Existing and new control technologies. (21 sources not regulated by the standard, and (3) enforcement and compliance experience since promulgation of the standard. Information and data evaluated during this study were obtained through literature searches, plant visits, and interviewa with industrial representatives and EPA regional personnel involved in enforcement and surveillance of the VC*emitting
industries. The information and data are presented in a document that may be
obtained as described in the admcssks section ofthis preamble. Decisions based on this review are summarized in the next two sections of this preamble.
As another aspect of the review of the VC standard, the EPA's Carcinogen
Assessment Group reviewed new health studies that have become available since the standard was promulgated. This review included a study of the estimated carcinogenic strength of VC (the VC unit risk number) and focused on whether this number should be changed to reflect new informaton. Since the current standard was promulgated, new occupational studies have confirmed qualitatively that liver and brain cancer incidence are asociated with population exposure to atmospheric VC. However, none of these new studies have sufficient exposure information to warrant a refinement of the quantitative cancer risk estimate.
Findings and Conclusions of the Review Study
The findings and conclusions of the VC review study are presented in the following subsections. The first subsection discusses the need and basis for the current standard. The second subsection addresses the level of control required by the current standard. The third subsection identifies source categories not covered by the current standard and evaluates the appropriateness of regulating these sources.
(1) Need and Basis for Current Standard
The current VC standard was established based on judgments concerning the costs and benefits of the standard to society. The standard is not designed to eliminate VC exposure risk entirely. Rather, it strikes a balance between public health protection and the cost of that protection. Data (evaluated before the current standard was established) strongly indicate that VC causes or contributes to the development of angiosarcoma, other cancers, and various noncarcinogenic disorders in people with occupational exposure and in animals with experimental exposure to VC. Although no dose-response data are available at the concentrations of VC found in the ambient air, the EPA concluded when the standard was established that any atmospheric concentration of VC poses some public heath risk. To eliminate the risk of VC exposure entirely, a complete prohibition of all VC emissions would be necessary. This would require the closure of the entire industry and result in serious, adverse economic impacts. Furthermore, the EPA concluded at the time the current standard was established that a complete prohibition of all VC emissions would not be desirable or necessary. The EPA
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concluded this in view of (1) the beneficial uses of VC products for which desirable substitutes are not readily
available; (2] the potential adverse health and environmental impacts associated with VC substitutes that have not been throughly studied: (3) the number of employees, particularly in fabrication industries, who would become at least temporarily unemployed; and (4) the availability of control technology that is capable of substantially reducing emissions of VC into the atmosphere.
Although all EDC, VC and PVC plants have now incorporated VC emission controls, the maintenance of a Federal standard for VC i3 still considered necessary. The VC standard contains requirements for the proper operation and maintenance of control devices and the proper implementation of work practices. These requirements reflect an appropriate balance between the need to minimize health risks and the avoidance of unreasonable economic and community impacts which would resi.lt from standards d!sigriid to reduce risks to zero. Relative to the initial control costs, the additional cost of "taintaining and implementing the federal VC standard is small. Nevertheless, if the Federal standard is discontinued, these small costs may be sufficient to provide the industry with art economic incentive for discontinuing the use of proper control measures. Thus, the continued maintenance of Federal standards for the control of VC is necessary to ensure a continuation of the current level of control. Additionally, the standard is important for the control of VC emissions from plants built in the future. The consequence of not maintaining a Federal standard would be to increase the carcinogenic risk to large segments of the population. (In 1975 when the standard was originally proposed, approximately 4.6 million people lived within a 5-mile radius of EDC. VC end PVC plants.) Accordingly, the EPA has concluded that the maintenance of the Federal standard for VC. or reasonable revision of the standard. Is appropriate.
(2) Review of Technology-Based level of Control
This subsection describes the status of the technology-based level of control for sources covered by the current standard. The present status of emissions from sources covered by the currant VC stindard is presented In Table 1.
Table 1. Status of Current Emission Lev els From Sources Covered by the vinyl Chloride neshap
Ertiitaoft owe*
SBmwS
EnMcnt (mg/yr)
UnemofeO* (prior to 1975
Controlled* (current
Emfeaions from * model 31&000 mfl/yr OC/VC feoftty
Wirfry
0 ppm-------
eoftvoL
OxyOHortn** 0.2 Q/*g DC
soft *flt
product
fufpH*---- ----- Wortfrc*
*ftd
qmpmr*
tender**.
&9fc*t VlfMam HonprWi.l^
01*
tfvCftfrry#
Oft*.
114 379
Not frutileW**
3.2 SO
2.1
Smjj-Bni from a .r.oO* 56.000 ng.y P'.'C
*r(marv
10 come ........
Wfttrd.
fieerjy OOC'>'<},
0 OvZ VO * 00 o
P'SCucL
jou-'ce*
*00 5CI>
after w*
stnppift*
____u WOfk pr*eac 1 and
aw i
Jt3i
t \
3SC
1 C*5
c.*
:-t
-7
-iA*.... Nonproven**
iSd 2.
ornr
Sajed ft W* P* r>B ani
OfrHiOped tar*
AU lua'ntfra ft bOura* tourc** poor to promw-^dttortof
me f979 vC standxrO.
* fioprmna otunatod
tarn COC/VC tno PVC
piano m--onq currant jnndara
* Data wrt not eonactod on ra*af vajva o*cn9* tam
C/VC punt* V<t to 1979.
fiataa on *** Pa emuont ettimostt for * typical
i tnrt mt*0ft aaametas 'o* OuUu iaian ano
tapareort p-arc* ara not praaantaP
10 pprrv Standard. Emission sources covered by this standard include EDC purification and VC monomer formation and purification equipment, monomer recovery systems and other equipment at PVC plants, and vents from fugitive emission capture systems. The standard is based primarily on the control of these emissions by incineration or other primary control devices and specifies an emission limit of 13 parts per million by volume (ppmv) of VC averaged over a 3hour period. The 10 ppmv standard applies to control device bypass streams.
One of the amendments proposed in 1977 would have required reduction of
the emission limit from 10 to 5 ppmv. The goal of the proposed 5 ppmv limit was to ensure that the standard continued to approach a "zero emission goal** by requiring owners and operators both to maximize the effectiveness of existing control systems and to design improved new control systems at the time of construction. The 3 ppmv limit was not based on data for control technology different from that analyzed
at the time of the promulgation of the 10 ppmv limit
Comments received on the proposed
1977 amendments stated that in order to
meet a limit of 5 ppmv. a control device
would have to be capable of control at a
level even lower than 5 ppmv to offset
emission fluctuations. Commenters also
stated that a change from 10 to 5 ppmv
would result in little reduction In mass
emissions of VC. Finaly, commenters
questioned the rationale of the "zero
emission goal" policy.
Because the proposed 5 ppmv
emission limit was not based on data
from a control technology different from
that analyzed for the current standard
and because 10 ppmv represents the
lowest level of control which has been
consistently achieved, the EPA
withdraws the proposed 5 ppmv limit
and affirms the original 10 ppmv limit. If
such a technology had been identified, it
could have been the basis of a revised
standard. However, during the review
study no more advanced technology was
identified, even chough additional data
on incinerators, carbon adsorbers, and
solvent eKsorri'tijn
systems on
existing plants were obtained. Although
these data indicate that ir.cineiators are
capable of reducing emissions below in
ppmv. 10 ppmv represents the lowest
level of control which has been
consistently achieved. Based on this
information, the EFA has concluded that
there is no improved or new control
technology that has been demonstrated to significantly and consistently reduce
emissions to a level below that required
by the current standard. Therefore, no
furtiter technological investigation of the
10 ppmv standard is planned.
Oxychlorination Vent Standard~0.2
%/kg EDC. The current oxychlorination
vent standard of 0.2 g of VC per kg of
EDC does not require an add-on control
device. Instead, the limit can be
achieved at most pisnts by controlling
operating conditions and at the
remaining plants through process
modifications. At the time the original
standard was written, incineration of
oxychlorination vent emissions was
investigated. Because of expected high
energy costs associated with
supplemental fuel requirements for
combustion, incineration was
determined not to be e reesoneble
method of control for this source.
The amendments proposed in 1977
specified a level of 5 ppm for the
oxychlorination vent The proposed
requirement was based on installation
of an oxygen feed system with an
incinerator or equipment control device.
The use of oxygen feed In the EDC oxychlorinaton process decresses the
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volume of inert substances in the vent stream and, consequently, the cost for supplemental fuel required fof incineration. Comments received on this proposed amendment focused primarily on the high expense and large energy requirements associated with the production of oxygen.
The review study identified no control technology for oxychlorination vents at EDC/VC plants that had not been considered during the development of the original standard. Additionally, the
EPA reevaluated the cost of retrofit incinerator controls and reached the same conclusion drawn in the development of the original standard. As before, the high cost associated with incinerating oxychlorination vents at
existing EDC/VC plants makes this level of control unreasonable. Thus, the current standard of 0.2 g/kg EDC is considered still to be the most reasonable level of control for existing oxychlorination vents. In addition, the review study concluded that significant new construction or modification of EDC/VC plants is not expected. At this i:me. only one new EDC/VC facility is reportedly planned. (Br Goodrich has plans to construct an EDC/VC facility in Convent. Louisiana.) Oxychlorination vents at new EDC/VC plants will be regulated by the proposed standards of performance for air oxidation processes (40 CFR Part 60 Subpart III) or by the BACT or LAER requirements of new source review regulations applicable in specific locations to a level comparable to that achievable through the use of incineration. Because ihs technologically achievable level of control is assured through the current requirements, the EPA concluded that investigation of additional control (i.e., incineration) was not required for oxychlorination vents.
Reactor Opening--0.02 g/kg PVC Product. The current VC standard restricts emissions during polymerization reactor openings. The standard was based on reactor purging and on a reduction in the frequency of reactor openings. An increased level of control was not proposed in the 1977 amendments. (The level of control provided by the current standard. 0.02 g/kg of PVC product, reduces VC emissions to about 1.30 Mg per year for a model PVC plant.) During the review of the standard, no technology was identified that would provide additional VC reductions beyond the level of the current standard. Therefore, the EPA is not investigating further the control of reactor openings.
Combined Sources After Resin Stripping. The sources of VC emissions covered under the current standard
include blend tanks, dryers, centrifuges, storage silos, bagging operations, and any sources following the stripper. Control of these emissions is based on either stripping the PVC resin to a specified (based on resin type) residual VC level (i.e., 400 ppm for suspension, bulk, solution, and latex resins; and 2,000 ppm for dispersion resins) or controlling the emissions from all sources following the stripper with a control device. The 1977 proposed amendments would have required "new resins" to be stripped to lower levels (i.e., 100 ppm for suspension, bulk, solution, and latex resins: and 500 ppm for dispersion resins). When the amendments were proposed, the EPA believed that some resins could meet the proposed limits: whereas, for other resins the manufacturer would have been required to develop improved stripping technology or not to produce the resin.
Industry comments stated that most dispersion, copolymer, and bulk resins would suffer degradation if more stringent emission limits were imposed. Additionally, the eommentsrs no'ed the inherent difficulties in defining a "new resin." Information submitted by
commenters indicated that minor adjustments to resin compositions are made routinely, and completely new resins are rarely, if ever, made. As a result of these comments, the EPA concluded that it is impossible in many cases to distinguish between new and existing resins and stiil have any resins covered by the proposed amendments. Further, the proposed amendments did not address what levels of control could be achieved by improved stripping technology. For these reasons, the EPA chose to evaluate whether higher levels of control are achievable for ail resins, or only for some special classes of resins.
The review study found that resin stripping technology has improved since the current standard was promulgated,
and that some processors can achieve lower resin residual VC levels than those required in the original standard. In certain cases, some resins can meet the more stringent levels specified in the previously proposed amendments. However, other processors manufacturing resins of differing grades and characteristics can only marginally comply with the original standard. Because of the wide variation in resin grades and characteristics, it cannot be concluded that, even though a particular
resin made by one company can meet a particular level, any other tesin or similar resins produced by another company could also meet that level Furthermore, in some cases these
processors meeting the more stringent limits proposed previously are stripping
these resins to this low level to offset emissions from those resins which are more difficult to strip. Without this ability to average the emissions and reductions among resins, these processors might not achieve the current standard. Exempting resin grades known to be difficult to strip is not feasible because these resins cannot readily be defined. For the foregoing reasons, the EPA has concluded that there is no demonstrated level of control
which could significantly and consistently reduce residual VC levels in resins to levels below that required by the current standard. Therefore, the
EPA is not investigating further the control of the combined sources after
stripping. Equipment Leaks. Because little was
known about leak detection and elimination programs for control of equipment leaks from components in VC service, specific requirements for these
programs were not included in the current standard. Instead, each plant
was required to institute and implement a formalized leak detection and elimination program incorporating both a fixed-point monitor and a portable monitor. Plant-specific programs were
subject to approval by the Administrator. Consequently, due to site-specific differences among plants, as well as variations in leak definitions and monitoring practices, differences in
control of equipment leaks among the plants have resulted. Since the standard
was promulgated, the EPA has obtained more information pertaining to the control of equipment leeks from components in VC service. With the information obtained form the development of other standards, an effective leak detection and repair program based on use of a portable monitor can now be specified for equipment covered by this program. The
specific leak detection and repair requirements are discussed in the Administrative Revisions section of this
preamble.
Relief Valve Discharge Standard. Sources of VC emissions covered by this standard include discharges from relief valves on pressure vessels, transfer lines, and other equipment in EDC/VC and PVC plants. Tne standard is based on emission control by a combination of equipment and process modifications, and operational procedures, found in plants during development of the standard. An exact combination of
modifications and operational procedures was not specified- Instead, a performance standard (i.e., an emission
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standard) was established because it was believed that different combinations could be equally effective in controlling relief valve discharges. The current format of the standard prohibits all relief valve discharges except emergency discharges. Emergency discharges are described as those which could not have been avoided by taking measures to prevent the discharge (i.e., those that are "nonpreventable"). Since the standard was promulgated, all plants have experienced some releases. Many of these releases are considered preventable by the EPA, Based on visits to plants with good compliance histories, the EPA concluded that a level of performance reflecting compliance with the current format of the standard through the combined effects of equipment, process modifications and operational procedures remains reasonable, during the review, no technological level of control was found that would provide for a more stringent standard. Therefore, the standard is still considered to reflect the appropriate level of control for these sources. However. as discussed in ihe Administrative Revisions section of the preamble, the EPA is proposing to revise the standard by setting limits for relief valve discharges in a different format.
Administrative Aspects of the Standard. Even though the EPA decided not to revise the level of control associated with the current VC standard, the EPA identified revisions to several administrative aspects of the standard. These revisions as well as those identified above, are discussed in the Administrative Revisions section of the preamble.
(3) Review of Sources Not Previously Covered
This subsection discusses the status of VC sources not covered by the current standard that were identified in the review study. For these sources, the
EPA assessed whether a Federal standard was warranted. The EPA's assessment of these sources was based primarily on a quantitative analysis of VC emissions from these sources combined with a qualitative analysis of risks associated with exposure to VC from these sources. The EPA considers these analyses to be adequate in place of a thorough quantitative risk assessment for purposes of determining
whether a Federal standard is warranted for these sources. Because these sources are already relatively well-controlled and the quantity of VC emission, and consequently, the risks associated with exposure to VC from these sources, are small In comparison
to sources covered by the VC standard, the EPA concluded that none of the additional sources identified in the review study warrant a Federal standard.
Miscellaneous Sources of VC Emissions. Miscellaneous sources are plants other than PVC and EDC/VC plants that use VC as a raw material or produce VC as an intermediate or by product. The EPA has identified four such plants, two of these plants produce 1.1.1-trichloroethane, one produces perchloroethylene and trichloroethylene
and the fourth plant produces pesticides. (An additional 1.1,1-trichloroethane unit was constructed at a fourth location but has reportedly never operated. There are no plans to operate in the furture.) Review of VC emission sources at the identified plants showed them to be well controlled. Emissions of VC from these plants are primarily from fugitive sources and range from less than 1 Mg/ yr to 14 Mg/yr per plant. In general, the
VC NE3HAP requirements for process vents and equipment in VC service are being met at the miscellaneous sources due to company poticy considerations and State and local regulatory requirements. In addition, many of the equipment components in VC service would be covered by standards of performance for new sources and standards for sources in nonattainment areas. Based on the investigation of
these sources, the EPA concluded that
they are already relatively wellcontrolled and do not contribute significantly to VC exposure. For these reasons, additional requirements for miscellaneous sources of VC are not being preposed at this time.
PVC Fabrication Plants. There are about 8,000 fabrication plants which take the resin produced by PVC plants and fashion it into intermediate or final products. Emissions from these plants are estimated to be about 0.0035 Mg/vr per plant In comparison to VC production plants (which typically emit
about 92 Mg/yr). PVC fabrication plants are small emitters of VC. If standards were developed for this category they would not result in reduced emissions because the best control for these plants
is to reduca the VC levels in the resins being processed by the fabricators. Resin stripping beyond the level that process economics would dictate is already being done as a result of the
EPA's current standard and OSHA's VC
standard, based on the EPA's assessment of these sources, the EPA concluded that they do not contribute significantly to VC exposure. Therefore, the EPA believes that the evaluation of controls for PVC fabrication plants is
unnecessary and that the current level of control resulting from the EPA's standard and OSHA's standard is stilly reasonable.
Landfills. Off-specification resins TM containing VC has been taken to landfills where the gaseous VC can be released. However, the current EPA standard intends that all resins, including off-specification resins, be stripped to reduce the VC emissions from sources downstream from the stripper. In order to clarify that stripping requirements also apply to the offspecification resins before removal of landfills, these requirements ere being restated to explicity address offspecification resins. The EPA believes that the level of control resulting from the stripping requirements is reasonable: thus. VC emission requirements for landfills are not being proposed today. However, the EPA recognises that VC may be emitted from hazardous waste landfills and is evaluating and may regulate under the Resource Conservation and Recovery Act (RCRA) volatile emissions (including VC I from > ,, ,, t*k wastuswwuii it mokG I*.,.- * facilities. The EPA also recognizes that VC has been detected in municipal landfills. Therefore, in addition to assessing VC emissions from hazardous waste disposal facilities, a (RCRA) Subtitle D TASK FORCE has been formed which will assess all environmental releases including ?ir emissions from Subtitle D facilities (a category which includes municipal landfills),
Administrative Revisions
As discussed in the Findings and Conclusions of the Review Study section of this preamble, the EPA identified several administrative revisions that are appropriate as a result of the review study. The rationale for the proposed administrative revisions is presented in this section of the preamble. These revisions include: (1) Reformatting the emission limit for relief valve discharges, (2) providing a compliance test procedure and a specific emission limit for operators who strip in the reactors. (3) specifying requirements for leak detection and repair program for equipment components in VC service, and (4) miscellaneous revisions.
Relief Valve Discharges
Background. The current format of the standard for relief valve discharges allows only "emergency" discharges (i.e., discharges that could not be avoided by taking preventive measures). The standard applies to all pressure relief devices on pressure vessels.
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transfer lines, and other equipment in EDC/VC and PVC plants. The control techniques considered as the basis of ,
the standard involve a combination of equipment modifications, process
modifications, and operational procedures. An exact combination of modifications and operational procedures was not specified in the
current standard; rather, a performance standard (i.e.. an emission standard] was established because different combinations of the modifications and procedures were expected to be equally effective in controlling relief valve discharges.
Based on 6 years of enforcement and compliance experience, the EPA has concluded that the relief discharge
standard has resulted in: (1] Significant reductions in the frequency and quantity
of VC discharges from relief valves. (2) significant use of agar.cy resources to evaluate individual discharges for preventability, and (3) uncertainty cn
the part of producers regarding whether they comply with the standard. Additionally, the EPA learned some cf VC and PVC believe that this part 0f the
current standaid applies only to discharges through safety relief valves and that discharges through other
pressure relief devices, such as rupture disks or manual or automatic vent valves, are not covered. This interpretation is not compatible with the intern behind the current standard. To
provide more efficient enforcement by decreasing the burden of individual preventability assessments on the EPA. and to provide a better understanding to plant operators of the goal of the standard, the EPA is proposing to reformat the standard for relief valve discharges and to define the emission points covered by this standard to include appropriately all pressure relief devices. As discussed more completely in the following sections, the EPA is proposing to change the format of the numerical limits in the standard to reflect the number of discharges that occur from those plants complying with the format of the current standard.
The EPA found in the review study that efforts by all EDC/VC and PVC ' producers to comply with the standard are reflected in their preformance (in
terms of size and frequency of discharges) since the standard went into effect. In general, a reduction in the
reported frequency and size of relief valve discharges by PVC producers has occurred since 1978. A further decrease in relief valve discharges by the PVC industry occurred between 1980 and 1981. Performance by the EDC/VC industry exhibited a less marked trend
of decreased discharges over the compliance period. Following an initial drop in relief valve discharges after the standard went Into effect the frequency and quantity of relief valve discharges by EDC/VC plants have decreased slightly or remained relatively constant.
General Basis for Numerical Limits.
In selecting the proposed numerical limits, EPA first evaluated in detail the recent performance (1981 to 1983) of five PVC plants and one EDC/VC plant These plants were chosen based on discussions with EPA Regional Office
personnel and industry and were intended to represent plants with good relief valve discharge records. In general, the EPA's evaluation of these plants indicates that each has adopted the combination of equipment, operational procedures and attitude
toward prevention of relief discharges intended by the current standard, and that their resulting performance is consistent with compliance with the current standard. The EPA's evaluation found that a few discharges may
continue to occur from some plants that comply with the standard. This observation is consistent with the expectation held by the EPA when the standard was written.
In order to revise the standard in terms of numerical limits representing
compliance with the current format of the standard, this evaluation separated
PVC and EDC/VC plants. For plants, relief valve discharge performance data were further separated by source (reactor vs. nonreactor) and by resin type The EPA then reviewed the performance cf 25 additional PVC plants and 12 additional EDC/VC plants. The EPA reviewed this large set of plants to ensure that the level of performance
demonstrated by the evaluated plants could be achieved by all PVC and EDC/ VC plants.
The numerical limits presented in the Findings section of this preamble are based on an evaluation of the number of
discharges representing the demonstrated performance level associated with compliance with the provisions of the existing standard.
Format for Numerical Limits. The
EPA visited the five PVC plants evaluated In detail. As expected, the EPA found differences in the
combinations of hardware and operational procedures associated with control of relief valve discharges of each of the plants. Furthermore, no exact relationship was found between the
effectiveness of specific hardware Items and operational procedures and prevention of discharges. In the EPA's
judgment the various combinations of
hardware and operational procedures implemented by each of the plants along with the attitudes adopted toward preventing relief valve discharges represent the types of control measures that the standard intended. In particular, the EPA concluded that the low frequency of discharges by the visited
plants was indicative of their degree of effort to prevent relief valve discharges. Consistent with the goal of this proposed revision, the EPA decided that an alternative numerical emission limit based on performance resulting under the current standard could be revised in a format that would be easier to understand by enforcement and industry
personnel.
The EPA investigated two basic ways of expressing relief valve discharge performance for PVC plants. One format is based on mass emissions, for example, the pounds of VC discharged per million pounds of PVC produced (lb VC/MM lb PVC). Based on a review of methods used by industry to determine the amount of VC discharged from relief valves, the EPA was unable to identify a sufficiently accurate method for measuring discharge quantities from relief valves. At present, producers are required only to estimate discharge quantities for reporting purposes.
Demonstration of compliance with a lb VC/MM lb PVC limit would require producers to measure the amount of VC discharged during an incident. Because a suitable measurement method ws3 not identified, the EPA decided not to 'redefine relief valve discharge performance by PVC plants in a lb VC/ MM lb PVC format.
Another format is based on the frequency (i.e., number per unit time) cf
discharge horn occurrences. No method for measuring the amount of VC discharged from relief valves is needed because only the occurrence of a release is required for this format. The occurrence of a discharge can be
determined by monitoring process parameters as well as inspecting relief valve performance reports. Thus, of the two basis ways of expressing relief valve performance that were considered, the EPA selected a format based on the frequency of discharges.
Bused on this decision, the EPA then considered how the format would be applied to PVC and EDC/VC plants. At
PVC plants, the frequency ofdischarges
from polymerization reactors and associated process equipment may be related to the fact that a batch process is used to produce most types of PVC For batch PVC production processes, the opportunity for discharges is related to the number of times a new
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polymerization batch is initiated. Expressing relief valve discharge performance for these plants with a discharge-per-batch format accounts for variations among plants in the number of batches produced. The EPA selected 100 polymerization batches as a convenient basis for expressing relief valve discharge performance by PVC plants with batch production processes in a discharge frequency format
Further, the EPA noted that the ability of batch PVC producers to limit the discharge frequency may be different for reactor and nonreactor discharges and that reactor discharges may vary by resin type at any plant Consequently, relief valve discharges by individual PVC plants (except for continuous solution process piants) were classified according to type of discharge (i.e., reactor vs. nonreactor) and the reactor discharges were separated by resin type. Nonreactor discharge sources at PVC plants include blowdown tanks, transfer lines, and storage vessels.' Because usage of this equipment is also related to some extent to the frequency of batch polymerization operations, the relief valve discharge performance bv
norreactcr sources in PVC plants wiih batch production processes was also examined on the basis of number of discharges/100 batches.
Unlike the batch process used to produce other PVC resin types, the solution PVC process is continuous. Thus relief valve discharge performance for the solution PVC process cannot be expressed on a frequency per batch basis. Instead, the relief valve discharge performance associated with the solution production process can only be
expressed in terms of the total number of discharges (reactor and nonreactor) per year.
Similarly, the EDC/VC production process is not a batch process, but is continuous. Thus, relief valve discharge performance by EDC/VC plants also cannot be expressed on a frequency per batch basis. Moreover, the EPA was unable to detect a direct relationship between discharge frequency and VC production at EDC/VC plants. Thus, the EPA decided to define releif valve
discharge performance for EDC/VC plants on the basis of a total number of annual discharges.
Findings. PVC Reactor Discharges.
Suspension resins account for the highest percentage of total PVC production. The remaining PVC production is in the form of bulk, dispersion and solution resins. (A small amount of latex resin is produced by a process closely related to the dispersion process.) Examination of relief valve discharge performance associated with
production of suspension and bulk resins indicates that reactor discharge frequency generally is either less than 0.035 discharges/lOO batches or is much greater. (Recent reactor discharge frequencies for suspension resin plants
with poorer performance levels ranged between 0.059 and 0.101 discharges/lOO batches.) Further examination of relief
valve discharge performance by suspension resin producers indicates that only one plant experienced more than 4 discharges per year during the period from 1981 to 1983. Performance by this plant also exceeded 0.035 discharges/100 batches.
The reactor discharge frequency associated with dispersion and latex production is typically zero. However, for a typical dispersion or latex resin process with a low production rate (i.e., number of polymerization batches per year], a single emergency reactor discharge in a given year would be equivalent to a discharge frequency of about 0.035 discharges/100 batches.
Nonreactor Discharges. Nonreactor discharge frequencies by PVC plants typically were either less than 0.035 discharges/100 batches or were much
greater. (Recent nonreactor discharge frequencies reflecting poorer performance than the 0.035 level ranged between 0.048 and 0.225 discharges/100 batches.) Furthermore, with the exception of two producers, no more than three discharges per year were reported from nonreactor sources in PVC plants during the period from 1981 to 1983.
Each of the five PVC plants that the EPA evaluated In detail was among those achieving 0.035 discharges/1Q0 batches or less in each of the reactor
discharge categories and 0.025 discharges/lOO batches or less in the nonreactor discharge category. The EPA examined individual discharge incidents for the PVC producers whose recent performance has exceeded 0.035 discharges/100 batches in one or more of the reactor discharge categories or who exceeded 0.025 discharges/lOO batches and 3 discharges per year from nonreactor sources. In every case, the EPA identified one or more discharges that were preventable. Elimination of these preventable discharges indicates that these producers should have achieved discharge frequencies comparable to the five PVC plants that the EPA evaluated in detail.
Solution PVC Process. Discharge frequency from both reactor and nonreactor sources by the single plant producing PVC by the solution process was zero during the period 1981 to 1983. Previously, this plant experienced as
many as two discharges in a 12-month
period. Recent performance suggests that preventable discharges have been eliminated at this plant. With the exception of a potential emergency discharge occurrence, future discharges at this plant are not anticipated.
EDC/VC Discharges. During the review study, the EPA evaluated performance by one EDC/VC plant in detail. This plant experienced about four discharges that could be considered emergencies. Recent (1981 to 1983) relief valve discharge performance data for other EDC/VC producers indicates an industry range of 0 to 7 discharges/yr. Information obtained from plants during the review indicated that, where applicable, similar types of equipment, process modifications and operational procedures used to control relief valve discharges from PVC plants also are used at EDC/VC pants. The EPA examined discharges by the EDC/VC producers who exceeded four
discharges in one or more years since 1981 and found that one or more of the discharges at each plant were preventable. Elimination of the preventable discharges would aliow each of there piants to reduce their annual discharge frequency to four or fewer.
Summary of Numerical Limits. Based on the study of current relief valve discharge performance by PVC and EDC/VC plants, the EPA is proposing that the following numerical limits for relief valve discharges be added to the standard. Each discharge causing an exceedence of any numerical limit presented below would be considered a vtslatler. without regard to whether any individual discharge was preventable.
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Compliance Provisions. The EPA recognizes that all plants may experience an unavoidable relief valve discharge incident at some time. Examination of relief valve discharge performance by PVC plants with low
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discharge frequencies indicated that plants with the lowest-polymerization batch frequencies typically experience about one discharge in a 12-month
period. The EPA concluded that for most
plants a 12-month reporting period (rolling every 6-months) was both
suitable and appropriate for determining compliance with the proposed numerical limits. For plants producing only a small amount of a particular resin [i.e., low number of polymerization batches), an apparent violation of the standard may result from a single discharge occurrence during a 12-month compliance period as described below.
For a PVC plant producing a single resin type to meet the numerical limit for reactor discharges (i.e., 0.035 discharges/100 botches), it must experience and average of no more than one discharge per 2.858 polymerization batches over the precediug'l2-month period. An average reactor discharge frequency exceeding one discharge per 2.S38 batches would be a violation of the standard. However, if the plant made less than 2,858 polymerization batches
over the 12-mcr.th compliance period, a single discharge occurrence would be an
apparent violation of the standard (i.e., the discharge frequency per 100 batches would exceed 0.035). Because insufficient batches were made, the
reported discharge frequency per 100 batches would net correctly reflect the
performance by that plant in comparison to other plants complying with the standard. In rectifying the undue compliance burden posed on plants with small numbers of batches by the
discharge/lOO batch format and the selected 12-month compliance period, the EPA is proposing to add additional provisions affecting the number of batches used to calculate the discharge frequency. For PVC plants producing less than 2,858 batches of a particular res;n. the minimum number of 2,353 batches will be used when determining
compliance with the numerical limits.
PVC plants producing more than one resin type must demonstrate compliance separately for reactor discharges occurring from different resin production processes. Only the relief valve discharges and polymerization batches specific to each resin type ere
considered for determining compliance. However, for determining compliance with the standard for nonreactor discharges, the total number of
polymerization batches (regardless of resin type] are counted.
To determine the number of polymerization batches produced for purposes of assessing compliance, the following guidelines apply. A
"polymerization batch" consists of each sequence of charging VC and other materials to the reactor, heating reactor, contents, polymerization of reactor contents, and removal (i.e., blowdown) of reactor contents. Any batch that is aborted following charging of VC to the reactor is nonetheless counted as a polymerization batch in assessing compliance. For PVC plants producing bulk resin, a single "polymerization
batch" includes both prepolymerization and postpolymerization reactor operations.
Discharge frequency can be recorded in two ways. Discharge frequency can be recorded on the basis of discharge events (involving discharges from one or more relief valves) or on individual relief valve discharges. In most cases, plants currently report discharges individually when they occur from relief valves on separate equipment. However, certain equipment such as polymerization reactors that are equipped with multiple relief valves may
experience discharges simultaneously from more than one relief valve. Most plants currently report such multiple discharges from a single piece of
equipment a3 a single discharge. Thus, the performance levels serving as the basis for the numerical limits represent individual discharges and not multiple discharge events except when they occur from a single piece of equipment. For determining compliance with the numerical limits, discharge frequency is to be recorded on the basis of individual discharges except when simultaneous discharges occur from relief valves on the same piece of equipment.
A relief valve discharge in considered to be any venting through a pressure relief device to prevent or relieve an overpressure condition from equipment .in VC service that results in emissions of VC directly or indirectly to the
atmosphere. In determining whether or not a relief valve discharge resuits in
emissions to the atmosphere, the controlling factor is the ultimate disposition of the gases. Venting to a manifold or header system that ultimately discharges to the atomsphere constitutes a relief valve discharge. If the manifold or header discharges gases through a control device meeting the 10 ppmv VC emission limit, the venting does not constitute a relief valve discharge.
For purposes of reporting compliance status with the limits, plants will be
required to calculate their discharge per batch frequencies with sufficient precision to demonstrate that performance is either equal to, below of in excess of the limits. Based on
operating history, relief valve discharge performance by certain plants is expected to be much better than the respective limits. For example, some new suspension resin PVC plants
produce about 5,000 batches during a 12-month compliance period. One and two discharges at one of these plants during a compliance period would result
in a discharge performance of 0.02 and 0.05 discharges per 100 batches, respectively. The second discharge during the compliance period would be a violation of the proposed 0-035 discharges per 100 batches Umit despite the fact that the first discharge would result in performance well below the limit. These types of plants were considered in selecting the proposed limits and reporting procedures for relief valve discharges. The result that plants of this type must perform well below the limits in the standard in order to be in compliance is consistent with the proposed limits, which were selected to represent an upper boundary on the
number of allowable discharges intended by the standard. The EPA
expects that plants using the best technology and procedures should be
able to perform better than the proposed
limits.
Reporting Requirements. The current standard for relief valve discharges requires producers to report discharges within 10 days of the incident. The EPA is proposing to eliminate the 10 day reporting requirements and to require reporting of all discharges on a quarterly basis. Although compliance is to be determined on a semiannual basis, quarterly reporting of discharges is appropriate because violations of the standard may occur well before the end of the 6-mor.th period. Quarterly reporting notifies enforcement personnel of potential violations and violations that have already occurred prior to the end of the compliance period so that corrective actions can take place sooner following the end of the compliance period. Information to be included in the semiannual report for individual relief valve discharges is to be reduced to include only the date, time, source, cause and estimated amount of each discharge occurrence. The semiannual report will also inlcude information on compliance status.
In addition, plants will now be required to maintain relief valve discharge records for 3 years, because of the potentially significant increase in the time period between a discharge occurrence and reporting of the discharge.
Effective Gate ofRevision. The current standard as written will remain
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in effect for relief valve discharges until the proposed revisions are promulgated. The proposed administrative revisions do not change the standard's original intent and are intended only to set limits to facilitate compliance and enforcement efforts. Thus, the current standard will continue to be enforced until the revisions are promulgated.
Stripping-in-Reactor Compliance Test Procedure
The test method for measuring reactor opening losses was developed for resin stripping operations that take place in vessels separate from the reactor. Some PVC plants, including all bulk resin manufacturers, however, do not use separate strippers to remove residual VC from the resin produced. Instead, these plants strip VC from the product resin in the reactor (postpolymerization reactor in the case of bulk resin producers). For plants with reactor resin stripping operations, the concentration of VC in the reactor vapor space, as measured in accordance with the current standard, exceeds the O.C2g/kg
ovi"-1 - t-------------T--'-- -- -'-a.-i". coti-'.or.traf.ons result form VC monomer c:h ring from the resin into the v.'.por sps:*3 during the period following completion of the stripping operation (normally occurring under a vacuum that must be broken before the reactor can be emptied) and before the reactor is completely emptied of PVC resin. According to the Federal Register notice of promulgation of the current VC standard (40 FR 46533. October 21.1S7&), any VC escaping from the resin after it has been stripped to acceptable levels is not intended to be counted as part of the reactor opening loss. However, the current standard did not include in the measurement method an acceptable method for determining what part of the VC in the vapor space has escaped from the resin after stripping is completed.
The current standard allows bulk resin producers to calculate reactor opening loss emissions from the postpolymerization reactor based on the number of reactor evacuations, the vacuum invloved end the volume of gee in the reactors. For nonbulk resin producers with reactor resin stripping operations, calculation of reactor opening loss emissions is more complicated dee to the presence of water vapor in the reactor vapor space. Currently, waivers of testing for producers with nonbulk resin stripping operations in the reactor have been granted on a case-by-case basis by the EPA Regions, typically with the provision that residual VC samples are anlayzed on each batch. A variety of
calculation methods are then used to establish the reactor opening loss.
Based on experience of the EPA Regional offices, a method for determining the reactor opening loss that accounts for stripping in the reactor has been developed for use by all nonbulk resin producers with reactor resin stripping operations and is included in the proposed revisions to the current VC standard. Limitations for resin residual and reactor opening loss are added together to give a total allowable VC content from these two sources. The measured resin residual VC and the calculated reactor opening loss would then be added together, and averaged over a 24-hour period according to resin type. If the 24-hour average meets the combined standard, the plant would be considered to be in compliance with both the stripping and. the reactor opening loss requirements.
LeoA Detection and Repair
Background. The current standard requires implementation of a formalized program for detection of leaks from ecuioment in VC service and elimination of these leaks. The formalized program includes a multipoint VC detector and'a portable volatile organic compound (VOC) analyzer. The fixed-point monitoring system continuously monitors VC concentrations in the work area around equipment in VC service and sounds an alarm when concentrations exceed a prescribed level. The portable monitor is used independently to screen individual equipment components for leaks. Rather than specifying the number of points to be monitored, the sensitivities of the multipoint detector, the VC concentration that indicates a leak, and the actions to be taken to repair leaks, the current standard requires each plant owner or operator to prepare a program plan containing these specifications and to submit the plan to the EPA for approval. Plant owners or operators are required to submit data on background concentrations of VC in different areas
of the plant to use in determining the VC concentration that should be designated as indicating a leak. Plans, therefore, were tailored by each plant and reviewed by the the EPA Regional
Offices. The EPA found in the review study
that differences in leak detection and elimination programs exist among PVC and EDC/VC production plants and miscellaneous sources and that sitespecific differences include variations in leak definitions and monitoring practices. The definition and monitoring practices, along with repair practices, are primary influences on the control
effectiveness of leak detection and repair programs. Some plants implemented rigorous programs and others implemented programs lacking specific procedures or requirements.
Accordingly, the effectiveness of leak detection and elimination programs varies among the plants.
Since the current standard was promulgated, the EPA has obtained more information pertaining to the control of emission from equipment leaks. Based on this information and the review of the leak detection and
elimination plans being implemented to control emissions of VC. the EPA decided to specify leak detection and repair requirements for certain equipment components in VC service. Although information obtained from development of other standards indicates that a routine leak detection
and repair program with a portable monitor can be an effective emission reduction technique without the requirement of a fixed point monitoring system. the EFA concluded that fixedprint cg systems already in piece have uses that justify their retention in the current standard. In particular, fixed-point monitors allow tor quick detection of certain large VC leaks that might otherwise go undetected until the next routine portable monitor screening. The EPA recognizes that existing fixed-point monitoring plans will need to be reviewed in light of the leak detection and repair requirements being specified at this time. The complexity of existing fixed-point monitoring plans, in terrr.3 of number and distribution of monitoring points, varies greatly among plants. Consequently, some plant owners or operators may want to alter the number of points that are monitored and the distribution of monitoring locations to better complement the specified portable monitoring requirements. Such changes to existing fixed-point monitoring plans will be allowed providing they do not alter the plant's ability to detect large VC leaks.
The proposed revisions are primarily intended to standardize control of VC emissions from equipment leaks. In doing this, the EPA is concerned that existing effective plans not be inappropriately changed. The proposed revisions include provisions that allow plants with existing effective plans to periodically demonstrate the effectiveness of their plans without additional requirements. Accordingly, the EPA requests comments from industry representatives concerning the specific effects of specifying leak
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detection and repair requirements on effective existing plans.
Leak Detection and Repair
Requirements. The EPA established leak detection and repair requirements [40 CFR Part 61 Subpart V) for certain equipment in volatije hazardous air pollutant (VHAP) service on June 6. 1964. These requirements were established in conjunction with the final standard for benzene equipment leaks. The requirements of Subpart V generally apply to pumps, compressors, pressure relief devices, sampling connection systems, open-ended valves or lines, valves, flanges and other connectors, and product accumulator vessels. These requirements reflect the level of control that the EPA considers reasonable for equipment covered by developing standards for VHAP. The EPA is therefore proposing to add VC to the list of substances covered by Subpart V.
Subpart V would substantively affect only valves and flanges in VC service within this industry. All other equipment in VC service are already required by the VC standard to comply with equipment and work practice standards consistent with those in Subpart V. For example, pumps and compressors meeting the dual mechanical seal requirements of the current VC standard will be in compliance with the Subpart V requirements. In addition, the sampling connection systems requirements of Subpart V are essentially the same as the current standard. The use of rupture discs for controlling leaks from pressure relief devices, as required by the VC standard, is consistent with the "no detectable emissions" requirement included in Subpart V, Requirements for controlling leaks from pressure relief devices are described in more detail later in this section. Thus. Subpart V will affect primarily valves and flanges in VC service by requiring a specific
monitoring schedule, leak definition and repair provisions.
Compliance with the provisions of Subpart V will be used to determine compliance with the portable monitor leak detection and elimination requirements in the current VC standard (40 CFR 6l.65(b)(8)(ii)J, and therefore, the current standard it being revised to reflect this change. However, process units within VC and PVC plants in which the percentage of leaking valves is equal to or less than 2.0 percent are considered by the EPA to be effectively controlling VC emissions from leaking valves. For these process units, the existing leak detection and elimination program will continue to be allowed while the percentage of leaking valves Is
2.0 percent or less. Any process unit in which the percentage of leaking valves is found to exceed 2.0 percent will be required to comply with the provisions of Subpait V,
The Subpart V requirements for valves are based on a leak detection and repair program that requires (1] monthly monitoring for valves in gas/ vapor and light liquid service, (2J an initial attempt at repairing these valves within 5 days after detection of a leak, (3] repair of leaking valves within 15 days after detection of the leak unless repair would require a process unit shutdown, and (4) repair of valves during the next process unit shutdown after repair is delayed until a process unit shutdown. Valves found not to leak for 2 successive months can be monitored quarterly until leaks are detected. Monitoring of equipment to detect leaks is conducted in accordance with Method 21 and a leak is defined as a measured organic concentration equal to or greater than 10.000 parts per million by volume (ppvm). For a complete description of the leak detection and repair requirements, see Subpart V (49 FR 23498, June 6,1934).
In addition. Subpart V contains standards for other types of equipment (c.g., flanges, and open ended valves or lines). Standards for flanges include monitoring with a portable instrument under prescribed procedures within 5 days of observing evidence of a potential leak by visual, audible or other means. Open-ended valves or lines are required to be cupped, blinded or fitted with a second valve. These provisions are not expected to significantly affect producers with these types of equipment in VC service. The equipment and procedures employed as normal practice by these producers or as a result of the current VC standard are expected generally to ensure compliance with Subpart V.
Pressure ReliefDevices. The EPA proposed and promulgated the work practices, equipment, design and operational standards in the current standard before explicit legal authority existed in Section 112. These requirements are found in } 61.65(b). In August of 1977, Congress amended Section 112 to allow the use of these requirements. Section 112 of the Clean Air Act requires that an emission standard (i.e a performance standard) be established for control of a hazardous air pollutant unless, in the judgment of the EPA, it is not feasible to prescribe or enforce such a standard. An emission standard allows for some flexibility in complying with the standard, since any control technique
that achieves that standard may be applied. Section 112(e)(2) defines the following conditions under which it is not feadible to prescribe or enforce an emission standard: (1) If the pollutants cannot be emitted through a conveyance designed and constructed to emit or capture the pollutant; or (2) if the application of measurement methodology is not practicable due to technological or economic limitations. Section 112(e)(1) allows that if an emission standard is not feasible to prescribe or endorce. then the EPA may istead promulgate a design, equipment, work practice, or operational standard, or combination thereof.
The EPA has reviewed the design, equipment, work practice and operational requirements contained in the current VC standard. The only sources covered by the current standard with one of the requirements for which a performance standard (i.e.. an emission standard) is feasible are pressure relief devices. As discussed below, the EPA is setting a "no detectable emissions" limit for these sources. For the other sources, the EPA is reinstating those requirements as set forth in the current standard.
The EPA selected the use of rupture disks as the basis for the current standard for pressure relief devices. When the integrity of ruptures disks is maintained, equipment leaks through the relief device are eliminated. Ruptur e disks normally maintain their integrity unless an overpressure occurs. After the occurrence of an overpressure, replacement of the rupture disk once again eliminates equipment leaks of VC through the pressure relief device.
For emission control techniques that eliminate equipment leaks, such as the use of rupture disks, a "no detectable emissions" limit is feasible. An instrument reading of less than 500 pans per million by volume (ppmv) above a background concentration based on Reference Method 21 can be used to indicate whether equipment leaks have been eliminated: that is, that the equipment has "no detectable emissions."
The "no detectable emission" limit would not apply to discharges through the pressure relief device during overpressure relief. (These releases are covered under $ 61.64(a) and 61.65(a).) The standard would specify, however, that the relief device be returned to a state of "no detectable emissions" within 5 days after such a discharge. The standard would further require an annual test to verify the "no detectable emissions" status of the pressure relief devices and a test after each over
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pressure relief. This administrative change implements the basis of this standard consistent with the requirements of Section 112(e).
Miscellaneous Revisions
Based on discussions with the EPA regional personnel regarding their experience in administering the current VC standard, the EPA is proposing several additional administrative revisions that would facilitate compliance and enforcement efforts associated with the current standard. These revisions represent minor changes to the standard. A brief description of these administrative revisions and the hesisjor making them follows.
De -ir.ition of Leek. xi'o:;s` C-os end ::ef Valve Discharge. Functional d:jtir:itions of "leak", "exhaust gas" and ' rf iief vaive discharge" are being added to 'he standard to clarify the f.t'o'icabtlity of the standard to each of faesr- tvpes of VC emissions. During their review of enforcement and compliance experience since the 'andiird 'aas premuigated. the EfA discovered several cases of confusion o'ho ir.tcrJed meaning of "leak", "c'-k-ust gas" =r.d "relief \aSve discln.rge." These three distinct e..U cories of VC emissions a^e berg defined in the revised standard to provide compliance and industry personnel with a clear understanding of, rich part of the standard jppiies :a any given discharge of VC emissions to ' the atomosphere. Drfinition of EDC and VC Pur;icci:on. In the past, some plains have misinterprented which equipment components are included in EDC purification and VC purification processes with the result that emissions from certain equipment intended to be covered by the standard may not have been controlled. The definitions of "EDC purification" and ``VC purification" are oetng revised to clarify that all
purification equipment following EDC and VC formation were subject to regulation under the current standard.
lOppmv Standard. Two clarifying revisions are being made to the 10 ppmv regulations to improve understanding of the applicability of this part of the standard. First although tha last method for determining compliance with the 20 ppmv standard specifies that the average results from three 1-hour sampling runs be used, this 3-hour averaging period is not specified in the 10 ppmv requirements. Specifying that emissions may not exceed 10 ppmv over a 3-hour averaging period clarifies that
instantaneous compliance with the 10 ppmv standard is not an intended requirement. Moreover, specification of
the 3-hour averaging period is intended to clarify that the 10 ppmv standard applies to VC emissions in all exhaust gas streams covered by the 10 ppmv requirements, including any control device bypass streams. Requirements for calculating the VC content in bypassed emissions for purposes of reporting VC emissions in excess of the 10 ppmv standard are being added to the regulation. The EPA may use these calculations along with continuous emission monitoring results as indications of noncompliance if they show clearly that emissions in excess of the 10 ppmv requirements occurred.
The second clarifying revision to the 10 ppmv standard involves the specification that the 10 ppmv requirements apply to each exhaust gas stream from the covered equipment. The purpose of this ravision is to clearly prohibit plants from using dilution with ether exhaust gas streams as a technique for meeting die 10 ppmv requirement. This revision is not intended to prohibit the common practice of combining two or more
iubafila lie ci COiIiiUOil header leading to a control device. According to the revised 10 ppmv requirements, combining an exhaust gas stream containing more than 10 ppmv VC with another exhaust gas stream containing less than 10 ppmv VC is allowed only when the combined stream is ducted to the control device.
Relief Vaive Definition. The current standard for relief valve discharges was intended to apply not only to safety reiief valves but to all types of pressure rr'iaf devices. A definition of "relief valve" is being proposed under the revised standard to clarify that the current relief vaive discharge standard also applied to rupture discs, manual vents and other pressure relief devices that vent to the atmosphere to protect process equipment from unsafe overpressure conditions. The definition of relief valve in the proposed standard is not intended to include pressure control valves used to control flow to an incinerator or other control device. However, the current relief valve discharge standard did cover emissions from pressure control valves. Also not included in the definition of relief valve are pressure control systems such as polymerization reaction shortstop systems or refrigerated water systems which act to reduce pressure by means other than venting.
Reactor Opening Loss Requirements for Bulk PVC Resin Producers. Bulk PVC resin production differs from production of other types of PVC resin in that the polymerization reaction is
carried out in two separate vessels. The reaction is initiated in the "prepolymerization" reactor and the reactor contents are then transferred to the "postpolymerization" reactor where the reaction is completed. Stripping of residual VC in bulk resin is performed following the postpolymerization step in the reactor vessel. The postpolymerization reactor generally is opened after every batch and must comply with the reactor opening loss limits specified in the standard. Because the prepolymerization reactor is opened less frequently and because determination of gross product (for reactor opening loss estimation) is difficult, the EPA has allowed plants to meet ,he equipment opening requirements for minimizing VC em.r.stona from polymerization reactor openings. The reactor opening loss requirements are being revised at this time to specifically exclude prepolyreerization reactors. Accordingly. VC emissions from ail opening of prepoiymerizztion reactors will be subject to the equipment opening : aquii'BiiLoitis. 11,1a lel.siuil intenuuo to clarify and improve the consistency of the ecuirentents of the revised sixnottd as they apply to bulk PVC resin producers in light of actual industry practice. No reduction in VC emission control stringency will result from the change in requirements for prepolymerization reactors.
Inprocess Wastewater Requirements for Gasholder Seals. Under the current standards, the VC content of inprocess wastewater must be reduced to less than 10 ppm exposure of the wastewater la the atmosphere. In the case of gasholder water seals, the VC content in the exposed water seal may exceed 10 ppm during normal operation of the gasholder. Experience since the standard was promulgated indicates
that compliance with the atmospheric exposers limit is not practicable for this particular inprocess wastewater source. Consequently, the definition ci inprocess wastewater is being revised to exclude the exposed water seal of gasholders. The tnprocess wastewater stripping requirements will continue to apply to wastewater after removal from the gasholder seal.
Elimination of 30-Day Limit on Equivalency Requests. The current standard specifies a 30-day limit for existing sources to submit requests for
use of equivalent methods. Because such a limit poses a restriction on initiative by industry to develop alternative, and potentially more effective, control measures, the 30-day limitation is being
eliminated.
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Other. In addition to the revisions described above, a review of the recordkeeping and reporting requirements of the current standard was performed to identify ways to ease recordkeeping and reporting burden on plants and to identify any additional recordkeeping and/or reporting needs. The EPA identified two areas where the reporting burden on plants could be reduced. The current reporting requirements for residual VC monomer specifications and reactor opening measurements require that results of all compliance tests be reported in semiannual reports. The EPA is proposing to allow plants to report only test results that show exceedences of the respective standards. If no exceedences occur, plants will be required to indicate that fact in the semiannual report. This type of exception reporting is currently allowed for demonstration of compliance with the 10 pprav standard for process vents. The second area is the requirement to report relief valve discharges within 10 days of their occurrence. The SPA is crcposing ta allow plants to report relief vr.ive discharge occurrences on a quarterly basis rather than within 10 drys of their occurrence. Furthermore,
the reporting requirements for relief valve discharges have been streamlined by dropping the need to report actions taken and'implemented preventive measures for each discharge. Information on the date, time, source, cause and estimated amount of individual relief valve discharge will be included with the semiannual reecrts along with information on compliance status.
Additional semiannual reporting requirements being added for FVC producers are the number of reactor openings and the design capacity number of polymerization batches for ouch resin type. This requirement will provide general information to facilitate review of industry-wide compliance status during past reporting periods.
Specific recordkeeping and reporting
requirements are included as part of the revisions to the leak detection and
repair requirements. The recordkeeping requirements include preparation of an initial log to record equipment component identification, physical tagging of equipment components which leak, and maintaining a record of equipment leaks and repair action. Included in the reporting requirements are the number of equipment leaks and the repair status of leaking components. Depending on the particular leak detection and repair program in place, these requirements may represent an
increase or decrease in the overall recordkeeping and reporting currently practiced by individual plants.
The EPA concluded that the current recordkeeping requirements, as specified in 40 CFTR 6L71, are still appropriate. However, the EPA is proposing to extend the current recordkeeping requirements for all reporting activities from 2 to 3 years.
The net impact of the revised recordkeeping and reporting requirements proposed by the EPA is estimated to be a decrease in a paperwork burden of about 2.B personyears.
It should be noted that all Comprehensive Environmental Response. Compensation, and Liability Act (CERCLA) Section 101(14) hazardous substances such as vinyl chloride are subject to reporting requirements under Section 103(a) of CERCLA. CERCLA requires that persons in charge of vessels or facilities from which hazardous substances have been released in quantities (RQs) immediately notify the National Response Center (NRC) of the release. The toii-free 24-hour telephone number of the NRC is 80CM24-SB02 and in Washington. D.C. metropolitan area it is (202) 425-2675. (See CERCLA Section 103 and 48 FR 23552. May 25.1983.)
Vinyl chloride was assigned a statutory 1 pound reportable quantity under Section 101(14) until adjusted by regulation, and is presently undergoing assessment for both chronic toxicity and carcinogenicity. Its RQ will be adjusted pending the outcome of these reviews by the Office of Emergency and Remedial Response. Federally permitted releases under CERCLA (See CERCLA Section 101(1) end 48 FR 23552) are not subject to CERLA notification requirements or liabilities. However, releases of hazardous substances that are not subject to a permit or control regulation must be reported.
Regulatory Flexibility Analysis
The Regulatory Flexibility Act of 1980 requires that adverse effects of all Federal regulations upon small businesses be identified. According to the current guidelines of the Small Business Administration (SBA), a small business that produces or processes VC is one that has 500 employees or less. Currently, none of the existing producers or processors that are affected by the standard are estimated to be small by this definition. Since none of the companies meets the SBA definition of small business, no regulatory flexibility analysis is required. Even if an analysis were required, the proposed administrative
revisions do not increase the cost of compliance with the standard.
Public Hearing
If requested, a public hearing will be held to discuss the proposed revisions to the VC standard in accordance with sections 112(b)(1)(B) and 307(d)(5) of the Clean Air Act Persons wishing to make oral presentations on the proposed revisions should contact the EPA at the address given in the adoresses section of this preamble. Oral presentations will be limited to 15 minutes each. Any member of the public may file a written statement before, during, or within 30 days after the hearing. Written statements should be addressed to the Central Docket Section address giver, in the addresses section of this preamble.
A verbatim transcript oi the hearing and written statements will be available for public inspection and copying during normal working hours a! the EPA's Central Docket Section in Washington. D.G. (see ADDRESSES section of this preamble).
Docket
The docket is an organized and complete fiie of all the information submitted to or otherwise considered b\ the EPA in the development of this proposed rulemaking. The principal purposes of the docket are: (1) To allow interested parties to identify and locate documents so that they can effectively participate in the rulemaking process, er.d (2) to serve as the record in case of jotiicir.l review (except for ir.itTugtmrv review materials (5 307(d|(7(AiJi.
Miscellaneous
In accordance with section 117 oi the Act, publication of this proposal was preceded by consultation with appropriate advisory committees, independent experts, and Federal departments and agencies. The Administrator will welcome commenr-i on all aspects of the proposed regulation, including health, and economic and technological issues.
The information collection requirements in this proposed rule have been submitted for approval to the Office of Management and Budget (CMB) under the Paperwork Reduction Act of 1980.44 U.S.C. 3501 et set;. Comments on these requirements should be submitted to the Office of Information and Regulatory Affairs of OMB. marked "Attention: Desk Officer for EPA". as well as to the EPA docket described above. The final rule will respond to any OMB or public comments on the information collection requirements.
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Under Executive Order 12291, the EPA must judge whether a regulation is "major" and therefore subject to the requirement of a Regulatory Impact Analysis. This regulation is not major because: (1} The national annualized compliance costs, including capital charges resulting from the standards total less than S100 million; (2] the standards do not cause a major increase in prices or production costs; and (3) the standards do not cause significant adverse effects on domestic competition, employment, investment, productivity, innovation or competition in foreign markets.
This regulation was submitted to the Office of Management and Budget for review as required by Executive Order 12291. Any comments from OMB to EPA and any EPA response to those comments are included in Docket Number A-61-21. The docket is available for public inspection at EPA's Central Docket Section, West Tower Lobby, Gallery 1, Waterside Mall, 401 M Street, SW,, Washington, D.C. 20460.
Pursuant to the provisions of 5 U.S.C. SO.'jb), I hereby certify that this rule, if promulgated, will not have a significant economic impact on a substantial number of small entries because no small entities are affected.
List of Subjects in 40 CFR Part 61
Air pollution control. Asbestos, Beryllium. Hazardous materials, Mercury, Vinyl chtoride.
Dated: Dated December 31, 1961.
Alvin L Atm,
Actin% Administrator.
PART 31--{AMENDED!
It is proposed to amend 40 CFR Part 61 as follows:
1. The proposed changes to 40 CFR Part 61 proposed at 42 FR 28154, June 2, 1977 are withdrawn.
2. By revising the definitions in existing 5 8l.ei(j), 11). (o) and (p) for "in process wastewater", "In vinyl chloride service", "ethylene dichloride purification" and "vinyl chloride purification" and by adding definitions for the terms "relief value", "leak", "exhaust gas", "relief valve discharge and "3-hour period" in new paragraphs (v). (w), (x). (y) and (z).
9 61.81 OeftniUon*.
*4 ** *
(j) "Inprocess wasterwater" 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. Gas-holder seal water is not inprocess wastewater until it is removed from the gasholder.
4*44#
(1) "In vinyl chloride service" means that a piece of equipment either contains or contacts a liquid that is at least 10 percent vinyl chloride by weight or a gas that is at least 10 percent by volume vinyl chloride as determined according to the provisions of 9 61.67(h). The provisions of $ 61.67(h) also specify how to determine that a piece of equipment is not in vinyl chloride service. This definition must be used in place of the definition of "VHAP service" in Subpart V of this part.
*m**
(o) "Ethylene dichloride purification" includes any part of the process of ethylene dichloride production which follows ethylene dichloride formation.
(p) "Vinyl chloride purification" includes any part of the process of vinyl chloride production which follows vinyl chloride formation. *****
(v) "Relief valve" means each pressure relief device including pressure relief valves, rupture disks, manual vents and other pressure relief systems used to protect process components from overpressure conditions. "Relief valve" does not include control valves used to control flow to an incinerator or o`ther air pollution control device.
(w) "Leak" means any of several events that indicate interruption of confinement of vinyl chloride within process equipment Leaks include events regulated under Subpart V of this part such as: (1) An instrument reading of 10,000 ppm or greater; (2) indications of liquid dripping; (3) a sensor detection of failure of a seal system, failure of a barrier fluid system, or both: and (4) detectable emissions as indicated by an instrument reading of greater than 500 ppm above background. Leaks also include events regulated under } 81.68(b)(8)(i) of detection of ambient concentrations in excess of background concentration. Emissions of vinyl chloride not regulated under 9 81.61 (a)
and (b): 9 61.63(a): 3 61.64 (a), (b). (c),
(d), (e) and (f): and 9 61.65 (a) and (b)(1), (b)(2). (b)(3). (b)(4), (b)(5), (b)(6). (b)(7) and (b)(9) shall be considered a leak. A relief valve discharge is not a leak.
(x) "Exhaust gas" means any offgas discharged directly or ultimately to the atmosphere that waa initially contained in or was in direct contact with the equipment for which 10 ppm emission
limits are prescribed in 9 61.62 (a) and (b) : 9 61.63(a): 9 61.84 (a)(1), (a)(2), (b). -
(c) and (d): 9 61.65 (b)(l](ii), (b)(2).
(b)(6)(h) and (b)(9J(ii). A leak as defin^^B in paragraph (w) of this section is not exhaust gas.
(y) "Relief valve discharge" means any nonleak discharge through a relief valve.
(z) "3-hour period" means any three consecutive 1-hour periods (each hour commencing on the hour).
3. By changing " all exhaust gases" to "each exhaust gas stream" and making other minor clarifying revisions in 5 61.62(a), 9 61.63(a), and 9 61.64 (a)(1), (b), (c) and (d) as follows:
9 Si.$2 Emission standard tat ethylene dichloride plants.
(a) Ethylene dichloride purification: The concentration of vinyl chloride in each exhaust gas stream from any equipment used in ethylene dichloride purification is not to exceed 10 ppm (average for 3-hour period or as determined in accordance with 9 61.67(g)(1)), except as provided in j dl.ouiaj. This requirement does not preclude combining of exhaust gas streams provided the combined steam is 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 9 81.66. This requirement does not apply to equipment that has been opened, is out of operation, and met the requirement in 9 61,e5(b)(6)(i) before being opened.
*****
9 61.83 Emission standard for vinyl chloride plants.
An owner or operator of a vinyl chloride plant shall comply with the requirements of this section and 9 61.65
(a) Vinyl chloride formation and purification: The concentration of vinyl chloride in each exhaust gas stream from any equipment used in vinyl chloride formation and/or purification is not to exceed 10 ppm (average for 3-hour period or as determined in accordance with 9 61.67(g)(1)), except as provided in 61.65(a). This requirement does not preclude combining of exhaust gas streams provided the combined steam is 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 9 61.86, iliis requirement does not apply to equipment that has been opened, is out of operation, and
met the requirement in 9 61.65(b](6)(i)
before being opened. ***
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$61.64 Emission standard for polyvinyl eWorld* plants.
An owner or operator of a polyvinyl chloride plant shall comply with the requirements of this section and $ 61.65.
(a} Reactor. The following requirements apply to reactors:
(1)Tne concentration of vinyl chloride in each exhaust gas stream from each reactor is not to exceed 10 ppm (average for 3-hour period or as determined in accordance with $ 61.67(g)(1)), except as provided in paragraph (a)(2) of this section and $ 61.65(a). *****
(b) Stripper. The concentration of vinyl chloride in each exhaust gas stream from each stripper is not to exceed 10 ppm (average for 3-hour period or as determined in accordance with 61.67(g)(1)), except as provided in $ 61.65(a). This requirement does not apply to equipment that has been opened, is out of operation, and met the requirement in J- ei.65(b)(6)(i) before being opened.
(c) Mixing, weighing, and holding containers. The concentration of vinvl chloride in each exhaust gas stream 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 (average for 3-hour period or as determined in accordance with $ 61.67(g)(1)), except as provided in 5 '31.55(a). This requirement does not apply to equipment that has been opened, is out of operation, and met the requirement in 61.63(b)(6)(i) before being opened.
(a) Monomer recovery system. The concentration of vinyl chloride in each exahust gas stream from each monomer recovery system is not to exceed 10 ppm (average tor 3-nour period or as determined in accordance with ? G1.6r(g)(i!), except as provided in 51.65(a). This requirement does not apply to equipment that has been opened, is out of operation, and met the requirement in $ 61.65(b)(6)(i) before being opened. t
4. By revising existing paragraphs $ 61.64(a)(2) and by removing (a)(3) aa follows;
$ 61.64 Emission standard for polyvinyl chloride plants.
An owner or operator of a polyvinyl chloride plant shall comply with the requirements of this section and S 61.65.
(a) Reactor. The following requirements apply to reactors:
(2) The reactor opening loss from each reactor is not to exceed 0.02 g vinyl chloride/kg (0.00002 lb vinyl chioride/lb) of poly vinyl chloride product except as provided in paragraphs (f)(1) and (f)(2) of this section, with the product determined on a dry solids basis. This requirement does not apply to prepolymerization reactors in the bulk process. This requirement does apply to postpolymerization reactors in the bulk process, where the product means the gross product of prepolymerization and postpolymerization.
*t * t
5. By revising paragraph (e) introductory text and adding paragraph (e)(3) to $ 61.64 as follows:
$ 61.64 Emission standard for polyvinyl ch>oride plants.
4 t* * t
(e) Sources following the stripperfs). The following requirements apply to emissions of vinyl chloride to the atmosphere from the combination pf all sources following the stripper(s) [or the reactor(s) is the plant has no stripper(s)] hi die plant process flow inciuding but not limited to. centrifuges, concentrators, blend tanks, filters, dryers, conveyor air discharges, baggers, storage containers, and inprocess wastewater, except as provided in paragraph (I) of this section: *****
(3) The provisions of this paragraph apply at ail times including when of'specification or other types of resins are made.
6. By adding paragraph ff) to $ 61.64 as follows:
$ 61.64 Emission standard for polyvinyl chloride plants *
(f) Reactor used as stripper. When a nonbulk resin reactor is used as a stripper this paragraph may be applied in lieu of $ 61.64 (a)(2) and (e)(1):
(1) The weighted average emissions of vinyl chloride from reactor opening loss end all sources following the reactor used as a stripper from all grades of polyvinyl chloride resin stripped in the reactor on each calendar day may not exceed:
(i) 202 g/kg (0.00202 lb/lb) of polyvinyl chloride product for dispersion polyvinyl chloride resins, excluding latex resins, with the product determined on a dry solids basis.
(ii) 0.42 g/kg (0.00042 lb/lb) of polyvinyl chloride product for all other polyvinyl chloride resins, including latex resins, with the product determined on a dry solids basis.
7. By revising paragraph (a) to $ 61.65 as follows;
$ 61.65 Emission standard for ethylene dlchlorids, vinyl chloride and polyvinyl chloride plants
An owner or operator of an ethylene dichloride, vinyl chloride, and/or polyvinyl chloride plant shall comply with the requirements of this section.
(a) Relief valve discharges. (1) Polyvinyl chloride plants (suspension, dispersion, latex, and bulk processes).
(1) Reactor. The number of discharges to the atmosphere from relief valves on polyvinyl chloride reactors in vinyl chloride service is not to exceed the following limits except as provided in paragraph (a)(l)(iii) of this section. For all reactors producing suspension resins within a PVC plant, the number of relief valve discharges is not to exceed 0.035 discharges per 100 polymerization batches nor 4 discharges per year. For all reactors producing dispersion and latex resins within a PVC plant, the number of relief vaive discharges is not to exceed 0.0S5 discharges per ICO polymerization batches. For all reuciors including prepolymerization and postpoiymerization reactors, producing bulk resir.s within a PVC pisnt the number of relief valve discharges is not to exceed 0.035 discharges per 100 polymerization batches.
(ii) The number of discharges to tue atmosphere from relief valves on equipment (excluding polyvinyl chloride reactors) in vinyl chloride service is not to exceed C.025 discharges per ISO polymerization batches nor 3 discharges per year except as provided in paragarph (a)(l)(iii) of this section.
(iii) The limits specified in paragraphs (a)(l)(i) and (a)(l)(ii) of this section may be exceeded when only one relief valve discharge to the atmosphere occurs during the 12-mon:h period preceding the dose of the 6-month reporting period.
(2) Polyvinyl chloride plants (solution and other continuous PVC production processes). The number of discharges to the etmosphere from relief valves on all equipment in vinyl chloride service is not to exceed 1 discharge per year.
(3) Ethylene dichloride and vinyl chloride plqnts. The number of discharges to the atmosphere from relief valves on equipment in vinyl chloride service is not to exceed 4 discharges per year.
(4) Each relief valve discharge that contributes to a relief valve discharge frequency in excess of any limit prescribed in paragarphs (a)(1), (a)(2) and (a)(3) of this paragraph constitutes
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an individual violation of the respective limit.
(5) For every relief valve discharge to the atmosphere, the owner or operator shall record the identity of the source, the date and time of the discharge, the cause of the discharge, the approximate total vinyl chloride loss during the discharge, and the method used for determining the vinyl chloride loss. This information shall be submitted in writing to the Administrator as part of the reporting requirements of paragraph . 5 61.70. This information shall be retained and made available for inspection by the Administrator for a minimum of 3 years.
8. By revising paragraphs (b)(3), (b)(8)(i). (b)(8)(:ii). (b](8i(lv) and (b)(3)(vi) to 5 81.65 as follows:
61.65 Emission standard for ethylene dichlorida, vinyl cnicrids and polyvinyl chloride plants.
An owner or operator of an ethylene dionioride. vinyl chloride, and/or polyvinyl chloride plant shall comply with the requirements of this section.
fI .lF - F '
(bj Fugitive emission sources
!'! ' * `
(21 ' * * !>! 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 minimized by installing sealless pumps. pump3 with double mechanical seals or equivalent as provided in 5 61.66. 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 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 $ 61.63. (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 } 61.88. If double outboard seals are used, vinyl chloride emissions from the seats are to be minimized by 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 $ 61.88. (iii) Rotating compressor. Vinyl chloride emissions from seals on all
rotating compressors in vinyl chloride service are to be minimized by installing compressors with double mechanical seals, or equivalent as provided in S 61.66. 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 $ 61.66.
(iv) Reciprocating compressors. Vinyl chloride emissions from seals on all reciprocating compressors in vinyl chloride service are to be minimized by installing double outboard seals, or equivalent as provided in 3 61.63. If double outboard 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 61.66
(v) Agitator. Vinyl chloride emissions from seals on all agitators in vinyl chlorida service are to be minimized by installing agitators with double mechanical seals, or equivalent as provided in 5 61.83. If double mechanical seals are used, vinyl chloride emissions from lire seals are to be minimized by maintaining the pressure between the two seals so that any leak that occurs is into the agitated vessel; 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 3 61.66. . *
(8) Leak detection and elimination.
(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. ***
(iii) It provides for an acceptable calibration and maintenance schedule for the vinyl chloride monitoring system 1 and portable hydrocarbon detector. Fo|^^ the vinyl chloride monitoring system, aV^B daily span check is to be conducted witli
a concentration of vinyl chloride equal to the concentration defined as a leak according to paragraph (b)(8)(vi) of this section. The calibration is to be done with either
(A) A calibration gas mixture prepared from the gases specified in sections 5.2.1 and 5.2.2 of Test Method 106 and in accordance with section 7.1 of test Method 108, or
(B) A calibration gas cylinder standard containing the appropriate concentration of vinyl chloride. The gas composition of the calibration gas cylinder standard is to have been certified by the manufacturer. The manufacturer must have recommended a maximum shelf life for each cylinder so that the concentration does not change greater than 5 percent from the certified value. The date of ga3 cylinder preparation, certified vinyl chlorida concentration and recommenced maximum shelf life must have been affixed to the cylinder before shipment from the manufacturer to the buys*. If a gas chromatograph is used as the vinyl chloride monitoring system, these gas mixtures may be directly used to prepare a chromatograph calibration curve as described in section 7.3 of Tes^^ Method 1C6. The requirements in section 5.2.3.1 and 5.2.3.2 of Test Method 106 for certification of cylinder standards and for establishment and verification of calibration standards are to be followed.
(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 chlorida service and the size and physical layout cf the plant. * * '*
(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 chlorida 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 in the plant are reduced.
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9. By revising paragraph (b)(4) to S 61.65 as follows:
$ 61.65 Emission standard for ethylene dichloride, vinyl chloride and polyvinyl chloride plants ** * *
(b) Fugitive emission, sources.
* * 4
(4) Leaks from relief valves. Vinyl chloride emissions due to leaks from each relief valve on equipment in vinyl chloride service shall comply with 5 81.242-4 of Subpart V of this part 4 t
10. By revising paragraph (b)(7) of 5 61.65 as follows:
? 61.65 Emission standard for ethylene dichloride, vinyl chloride and polyvinyl chloride plants. *****
(b) Fugitive emission sources.
* *
(7) Samples. Unused portions of samples containing at least 10 percent* by weight vinyl chloride are to be returned to the process or destroyed in a control device from which the concentration of vinyl chloride in the exhaust gas does not exceed 10 ppm. Sampling techniques are to be such that sample containers in vinyl chloride are purged into a closed process system.
11. By revising paragraphs (b)(8) introductory text, (b)(8)[ii), and (b)(8](v) to 61.65 as follows:
$61.65 Emission standard lor ethylene dichloride, vinyl chloride and polyvinyl chloride plants.
*
(b) Fugitive emission sources.
4**4
(8) Leak detection and elimination. Vinyl chloride emissions due to leaks from equipment in vinyl chloride service are to be minimized by instituting and implementing s lead detection and repair program consistent with the provisions of Subpart V of this part The program is to be implemented within 90 days of the effective date of these regulations, unless a waiver of compliance is granted under { 61.11. Approval of a program will be granted by the Administrator provided he finds:
(i) * * (ii) It includes a reliable and accurate portable hydrocarbon detector to be used consistent with the provisions of Subpart V of this part An owner or operator is exempt from $ 61.242-l{d). IS 61.242-7 (a), (b) and (c), $ 61.248 and $461,247 of Subpart V of this part for any process unit in which the percentage of leaking valves is demonstrated to be equal to or less than 2.0 percent, as
determined in accordance with the following:
(A) A performance test as specified in paragraph (b)(8)(ii)(C) of this section shall be conducted initially within 90 days of the effective date of these regulations, anrpilly and at times requested by the Administrator.
(B) For each performance test, a minimum of 200 or 90 percent of the total valves in VOC service (as defined in I 60.481 of Subpart W of Part 60) within the process unit shall be randomly selected and monitored within 1 week by the methods specified in $ 61.245(d) of Subpart V of this part. If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. The leak percentage shall be determined by dividing the number of valves in VOC service for which leaks are detected by the number of tested valves in VOC sendee.
(C) If a leak is detected, it shall be repaired in accordance with $ 61.242-7 (d) and (e) of Subpart V of this part.
(D) The results of the performance test shall be submitted in writing to the Administrator in the first semiannual report following the performance test as part of the reporting requirements of $ 61.70.
(E) Any process unit in which the percentage of leaking valves is found to be greater than 2.0 percent must comply with all provisions of Subpart V of this part within 90 days. *+
(v) It contains a plan of action to be taken when a leak is detected consistent with Sufcpart V of this part.
1Z. By revising $ 61.66 as follows:
$ 61.66 Equivalent equipment and procaduraa.
Upon written application from an owner or operator, the Administrator 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 subpart
13. By revising paragraph (Q of $ 61.67 as follows:
{61.67 Emission taste.
**t *
(f) The owner or operator shall retain at the plant and make available, upon request for Inspection by the Administrator, for a minimum of 3 years, records of emission test results and other data needed to determine emissions.
14. By revising paragraphs (g)(3) introductory text, (g)(3)(i), and (g)(3)(iii) of $ 61.67 as follows:
$ 61.67 Emission tests.
* ** *
(g) * * * (3) When a stripping operation is used to attain the emission limits in $ 61.64 (e) and (f), emissions are to be determined using Test Method 107 as follows: (i) The number of strippers (or reactors using as strippers) and samples and the types and grades of resin to be sampled are to be determined by the Administrator for each individual plant at the time of the test based on the plant's operation.
(ii) * * * (iii) The corresponding quantity of material processed by each stripper (or reactor used as a stripper) is to be determined on a dry solids basis and by a method submitted to and approved by the Administrator. *****
13. By revising paragraph (g)(5) introductory text and adding paragraph (g)(6) to 61.67 as follows:
$61.67 Emission tests. **
(S) * * * (5) The reactor opening loss for which an emission limit is prescribed in $ 61.64(a)(2) is to be determined. The number of reactors for which the determination is tc be specified by the Administrator for each individual plant at the time of the determination based on the plant's operation, *****
(6) For a reactor that is used as a stripper, the emissions of vinyl chloride from reactor opening loss and all sources following the reactor used as a stripper for which an emission limit is prescribed in $ 61.64(f) are to be determined. The number of reactors for which the determination is to be made is to be specified by the Administrator for each individual plant at the time of the determination based on the plant's operation.
[i] For each batch stripped in the reactor, the following measurements are to be made:
(A) The concentration (ppm) of vinyl chloride in resin after stripping, measured according to paragraph (g)(3) of this section:
(B) The reactor vacuum (mm Hg) at end of strip from plant instrument: and
(C) The reactor temperature (*C) at end of strip from plant instrument.
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fii) For each batch stripped in the reactor, the following information is to be determined:
(A) The vapor pressure (mm Hg) of water in the reactor at end of strip from the following table:
---------------------1
Rmetor vipot
tyr# CQ
WsO *lpOf
3U
(pm
Mg)
ftactor vipor tomodra-
ijfd CQ
HtO
r pra-
(ran Hg)
vapor td/npw tur* l'Q
H*0
vipor
***SUI
(mm
Hg)
*Q 55.3 41 58.3 42 51.5 43 64.8 44 68.3 45 71.9
4* 75.6
47 79,6
83.7
49 38 3
50 92 5
Si 97 2
52 102.1 53 TC72
54 Wli
55 1180
1238
57 1296
58 138.1 JV U25
50 U9.4
61 156.4 62 *63.8 53 17V4 64 172.3 65 157.5 65 194.1 67 20S.0 M 214.2
69 223 7
70 233.7
71 2-3.3
72 254.6
73 2*5.7 74 277 2
75 239.7
76 30i 4
77 314 1
78 327 3
79 341 0
60 355.1
41 343 7
52 344.9 63 4.90.0 64 416.6 65 433.6
66 450.9 67 468.7 88 487,1 69 SC6.1 40 52$ 9
41 540.0
92 567 3
93 588.8
910,9
ss 633.3
96 557 6 97 642.1
33 707 3
.10 733.2
___TOO
700.0
!Bj The partial pressure [v.m Hg) of v:nvi chloride in reactor nt er.d of strip from `.he following equation:
Rl>VA7fiO-RV-VPW Vv'Ser'v
r?VCpartial pressure of vinyl cnSonde. >n mm Hg
"Ol atmospheric pressure at 0`C. in mm Hg RV - absolute value of reactor vacuum, in
mm Hg VP'.V - vapor pressure of water, in mm Hg
(C) The reactor vapor space volume (m3) at end of strip from the following aquation:
sw
where: RVSV-reactor vapor space volume, in m* RC--reactor capecity. in a* WV--volume of water In reactor from recipe,
in m3 PVCW--dry weight of polyvinyl chloride in
reactor from recipe, in kg 833 -typical density of polyvinyl chloride, in
kg/m3
(iii) For each batch stripped in the reactor, the combined reactor opening loss and emissions from all sources following the reactor used as a stripper is to be determined using the following equation:
(FPVC)(RVSV)(i.Q02) C(PPMVC)(10-J) +
(PVCW)(273+RT)
where:
C--g vinyl chloride/kg polyvinyl chloride product
PPMVC=concentration of vinyl chloride in resin after stripping, in pom
IQ-' --conversion factor for ppm PPVC--partial pressure of vinyl chloride
determined according to paragraph (sK9)(ii)(S] of this section, in mm Hg RVSV-reactor vapor space volume determined according to paragraph (8](6)(>i)(C) of this section, in m3 1.002--ideal gas constant in g--`K/taia Hg-- m* for vinyl chloride PVCW--dry weight of polyvinyl chloride in reactor from recipe, in kg 273--conversion factor for `C to "K RT = reactor temperature, in 'C
15. By adding paragraph (h) to 3 61.37 as follows: t4 f *
(h)(1) Each piece of equipment witlria a process unit that can reasonably contain equipment in vinyl chloride sar/icft is presumed to be in vinyl chloride service unless an owner or operator demonstrates that the piece of equipment is not in vinyl chloride service. For a piece of equipment to be considered not in vir.yi chloride service, it must be determined that the percent vinyl chloride content can be reasonably expected not to exceed 10 percent by weight for liquid streams and 10 percent by volume for gas streams. For purposes of determining the percent vinyl chloride content of the process fluid that is contained in or contacts equipment, procedures that conform to the methods described in ASTM Method D-2237 (incorporated by reference as specified in $ 81.13) shall be used.
(2X1) An owner or operator may use engineering Judgment rather than the procedures in paragraph (h](l) of this section to demonstrate that the percent vinyl chloride content does not exceed 10 percent by weight for liquid streams and 10 percent by volume for gas streams, provided that the engineering judgment demonstrates that the vinyl chloride content clearly does not exceed 10 percent When an owner or operator and the Administrator do not agree on whether a piece of equipment is not in vinyl chloride service, however, the procedures in paragraph (h)(1) of this section shall be used to resolve the disagreement
(ii) If an owner or operatordetermines that a piece of equipment is in vinyl chloride service, the determination can
be revised only after following the procedures in paragraph (h)(1) of this section.
(3) Samples used in determining the percent vinyl chloride content shall be representative of the process fluid that is contained in or contacts the equipment
17. By adding paragraphs (d), (e) and (f) to S 01.68 as follows:
5 S1.68 Emission monitoring. ***
(d) When exhaust gas(es), having emission limits that are subject to the requirement of paragraph (a) of this section, are emitted to the atmosphere around the control system and required vinyl chlonds monitoring svstsm. the vinyl chloride content of the emission shall be calculated (in units of each applicable emission limit) by best practical engineering judgment based on the discharge duration and kr.o-.vn VC concentrations in the affected equipment as determined in accordance with $ 31.67(h) or other acceptable method.
(e) For each 3-hour period, the vinyl chloride content of emissions subject to the requirements of paragraphs (a) and (d) of this section shall be averaged (weighted according to the proportion of time that emissions were continuously monitored and that emissions bypassed the continuous monitor) for purposes of reporting excess emissions under i 81.70(c)(1).
(f) For each vinyl chloride emission to the atmosphere determined in accordance with paragraph (e) of this section to be in excess of the applicable emission limits, the owner or operator shall record the identity of the source(s), the date, time, and duration of the excess emission, the cause of the emission, the approximate total vinyl chloride.loss during the excess emission, and the method used for determining the vinyl chloride loss. This information shall be retained and made available for inspection by the Administrator as required by $ 81.71(a).
18. By changing the title from "Semiannual report" to "Reporting*' and by revising paragraph (a) of { 81.70 as follows:
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61.70 Reporting.
(a)(1) The owner or operator of any source to which this subpart applies shall submit to the Administrator on September 15 and March 15 of each year a report in writing containing the information required in paragraphs, (c). (d) and (e) of this section and on December 15 and June 15 of each year a report in writing containing the information required in paragraph (e) of this section, except as provided in paragraph (a)(2).
(2) In the case of an existing source that submits semiannual reports on an approved fixed schedule other than September 15 and March 15, the approved semiannual reporting schedule shall be used to report the information required in paragraphs (c). (d) and (e) of this section. In addition, the information required in paragraph (e) of this section will be reported exactly 3 months following the semiannual reporting dates.
(3) The first report is to be submitted following the first full 3 month reporting period after the initial report is submitted.
IS. By revising paragraph (cjfl) of 61.70 as follows:
'51,70 Roporimg.
(lj The owner or operator shall include in the report a record of the vinyl chloride content of emissions for each 3*hour period during which average
emissions are in excess of the emission limits in 5 61.62 (a) or (fa). $ 61.63(a). cr ? 61.64 (a)(1), (b). (c), or (d). or during
which average emissions are in excess of the emission limits specified for any control system to which reectcr emissions are required to be ducted in 61.64(a)(2) or to which fugitive emissions are required to be ducted in 61.65 (b](i)(ii).-(b)(2), (b)(5). (b)(6)(ii). cr lb)(9)(ii). If emissions in excess of the emission limits are not detected, the report shall contain a statement that no
excess emissions have been detected. The emissions are to be determined in accordance with 5 61.68(e).
20. By revising paragraph (c)(2) introductory text, removing paragraphs (c)(2)(iv), revising paragraph (c)(2)(iii) and revising (c)(2)(v) and (c)(2)(vi)
introductory text to j 61.70 as follows:
61,70 Reporting. **
e
(c) * * *
(2) In polyvinyl chloride plants for which a stripping operation is used to attain the emission level prescribed in 61.64(e), the owner or operator shall include in the report a record of the
vinyl chloride content in the polyvinyl chloride resin.
W* * '
(ii) * * *
(iii) The vinyl chloride content in each sample is to be determined by Test Method 107 as prescribed in 61.67(g)(3).
(iv) (Reserved) (v) The report to the Administrator by the owner or operator is to include a record of any 24-hour average resin
vinyl chloride concentration, as determined in this paragraph, in excess of the limits prescribed in } 61.64(e). The vinyl chloride content found in each sample required by paragraphs (c)(2)(i) and (c)(2)(ii) of this section shall be 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:
H pQiMai+P))tU<h+ . . .
where:
= 24-hour average concentration of type. 7) resin in ppm (dry weight basis).
QTotal production of type 7) resin over the 24-hour period, in kg.
TiType of resin: 1.2. , . m where m Is total number of resin types produced during the 24-hotir period.
A/=Concentration of vinyl chloride in one san:p!c of grade C, resin, in ppm,
7*--Production of grade Ci resin represented by the sample, in kg.
G4=Grade of resin: e.g.. C,, Cj. and G,. n*Total number of grades of resin produced
during the 24-hour period.
If no 24-hour average resin vinyl chloride concentrations in excess of the iimits prescribed in 61.64(e) are measured, the report shall state that no excess resin vinyl chloride concentrations were measured.
(vi) The owner or operator shall retain at the source and make available for inspection by the Administrator for a minimum of 3 years records of all data needed to famish the information required by paragraph (c)(2)(v) of this section. The records are to contain the following information:
(A) * * . -
.(B) * * *
** *
21. By revising paragraph (c)(3) of 61.70 as follows:
61.70 Reporting. * +
(C) * * *
(3) The owner or operator shall include in the report a record of any emissions from each reactor opening in excees of the emission limits prescribed in 61.64(a)(2). Emissions are to be determined in accordance with} 81.67(g)(5), except that emissions for each reactor are to be determined. If . emissions in excess of the emission limits are not detected, the report shall
include a statement that excess emissions have not been detected. *****
22. By adding paragraph (c)(4) to 61.70 as follows:
61.70 Reporting ***
tr\ * * *
*
(4) In polyvinyl chloride plants for which stripping in the reactor is used to attain the emission level prescribed in $ 61.64(f), the owner or operator shall include in the report a record of the vinyl chloride emissions from resetor opening loss and all sources following the reactor used as a stripper.
(i) 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 operation, and identified by resin type 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 identified by resin type and grade and the date and time the batch is completed.
(ii) The vinyl chloride content in rach sample is to be determined by Test Method 107 as prescribed in I 61.67(g)(3).
(iii) The combined emission from reactor opening loss and all sources following the reactor used as a stripper are to be determined for each batch stripped in a reactor according to the procedure prescribed in ) 61.67(g)(6).
(iv) The report to the Administrator by the owner or operator is to include a record of any 24-hour average combined 'reactor opening loss and emissions from all sources following the reactor used as a stripper as determined in this paragraph, in excess of the limits prescribed in } 61.64(f), The combined reactor opening loss and emissions from
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all sources following the reactor used as a stripper associated with each batch are to be averaged separately for each type of resin, over each calendar day and weighted according to the quantity
of each grade of resin stripped in reactors that calendar day as follows:
For each type of resin (suspension, dispersion, latex, bulk, other], the following calculation is to be performed:
n
A
Z 1*1
PrGi CrGi
"hS * W * \ \
Q
Where:
A-24-hour average combined reactor opening loss and emissions From all sources following the reactor used aa a stripper, in g vinyl chloride/kg product (diy weight basis!.
Q--Total production of resin in batches for wh:c'n stepping i3 completed during the 24-hour period, in kg,
C -Average combined reactor opening loss and emissions from all sources following the reactor used as a 3tnpper of ail batches of grade G, resin for which stripping 13 completed during the 24-hour perod in g vinyl chlnride/kg product (dry weigh! basis] (datermir.sd according to procedure prescribed ir. i 62.3rfgtfn);,
P --Production of grade G, resin in the batches nr which C is determined, in kg.
C,-Grade of resin: e.g.. Gi. Gi. and Cj. n--Total number of grades of resin in batches
for which stripping is completed during the 24-hour period.
If no 24-hour average combined reactor opening loss and emissions from all sources following the reactor used a stripper in excess of the limits prescribed in 01-64(0 are determined, the report shall state that no excess vinyl chloride emissions were determined.
23. By adding paragraphs (d], (e) and (0 to 5 81.20 as follows:
61.70 Seporting.
* **
*
(d) The owner or operator shall
include in the report a record of relief valve discharges as prescribed in 61.95(a)(4). and the owner or operator shall report exceedences of the relief valve discharge frequency limits prescribed in 81.69(a) to be determined as follows:
(1) For polyvinyl chloride plants producing dispersion, latex or bulk resins, the relief valve discharge frequency from polyviniy chloride reactors is to be determined using the following equation. Separate calculations are to be made for each resin type (t) as defined:
N
Where F,-- relief valve discharge frequency per 100
polymerization batches from ail reactors producing resmg type t N -- total number of relief valve discharges durtng the 12-month period preceding the dose of the 3-month reporting period from all reactors producing resin type t V = total number of polymerization batches of resin type t during the '.2-mor.th period preceding `he close of :he S-mor.th reporting perod divided by ICO t = rosm type: dispersion (indudmg l-iiex) or bulk resin type
(2) For polyvinyl chloride plants producing suspension resins, the relief valve discharge frequency from polyvinyl chloride reactors is to be determined in two ways using the following equations:
N - --, and F,i N
*
where F,, -- relief valve discharge frequency per 100
polymerization batches from ail reactors producing suspension resin Ftl -- relief valve discharge frequency per 12month period from ail reactors producing suspension resin N--total number of relief valve discharges during the 12-month period preceding the dose of the 6-month reporting period from all reactors producing suspension resin Y--total number of polymerization batches of suspension resin during the 12-month period preceding the dose of the 6-month reporting period divided by 100
(3) For polyvinyl chloride plants producing suspension, dispersion, latex, or bulk resins, the relief valve discharge frequency from all other equipment (excluding polyvinyl chloride reactors) is to be determined in two ways using the following equations:
N F, -- ~: and Fi - N
Y
where
Fa--relief valve discharge frequency per 100 polymerization batches from all equipment (excluding reactors)
Ft - relief valve discharge frequency per 12month period from all equipment (excluding reactors)
N--total number of relief valve discharges during the 12-month period preceding the dose of the 8-month reporting period from ail equipment (excluding reactors)
Y --total number of polymerization batches of all resin types combined divided by ICO
(4) For polyvinyl chloride plants using the solution process or any other continuous production process, the relief valve discharge frequency is the summation of each relief valve discharge from all equipment types during the 12-month period preceding the dose of the 6-rr.onth reporting period.
(5) For ethylene dichioride/vinyl chloride plants, the relief valve discharge frequency is the summation of each relief valve discharge from 3-1 equipment types during the 12-month period preceding the dose of the 6month reporting period.
(6) A polymerization batch consists of each sequence of charging VC and other materials to the reactor, heating reactor contents, polymerization of reactor contents, and removal of reactor contents including any incomplete sequence that is aborted after charging VC to the reactor. For bulk resin production plants, a single "polymerization batch" includes both prepolymerization and postpolymerization reactor ooerutions.
(e) The owner or operator shall include in the report the number of relief valve discharges to the atmosphere during the 3-month period preceding the report from each of the following sources: suspension resin production reactors: dispersion and latex resin production reactors: bulk resin production reactors: all nonreactor equipment in PVC plants; all equipment used in solution process and other continuous process PVC plants; and all equipment in EDC/VC plants: any other source.
(0 The owner or operator shall include in the report the number of reactor openings and the design capacity of the number of polymerization batches for each type of . resin in each plant during the 9-month period preceding the report. The design capacity of tha number of polymerization batches may be defined
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initially and remain unchanged unless significant changes to thedesign capacity occur.
24. By revising paragraph (a) introductory text of 5 61.71 as follows:
61.71 Recordkeeping,
(a) The owner or operator of any source to which this subpcrt applies shall retain the following information at the source and make it available for inspection by the Administrator for a minimum of 3 years:
*t
25. By adding the words ``vinyl chloride" to the definition of the term "volatile hazardous air pollutants" in S PI.241 cf Suhpart V as follows:
61.241 Definitions.
'Vc'aule hazardous air pollutant" or "VHAP" means a substance regulated under this part for which a standard for "'luipmert leaks of the substance has been proposed and promulgated. Benzene is a VHAP. Vinvl chlorine is a I'KAP.
112 Cicsn Air Act of iSTfi)
jt It Doc. S3-509 Fiifcd 1-3-S5: 8:45 ami
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