Document kar5bnLyg4Jnr9X7Me61yMXgJ

EPA-450/2-75-009 STANDARD SUPPORT AND JKKNTAL IMPACT STATEMENT: EMISSION STANDARD VINYL CHLORIDE Emission Standards and Engineering Division U. s. EiJVIRQ.,;;t.;iTAL PROTECTION AGENCY Office cf Air and '.Jaste Management Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 2/711 October 1975 COLORITE 008336 This report has bacn reviewed by the Emission Standards and Engineering Division, Office of Air Quality Planning and Standards, Office of Air and 'haste Man a cereal, environmental Protection Agency, and approved for publi cation. Ren lion of company or product names does not constitute endorsement by EPA. Copies are available free of charge to federal employees, current contractors and grantees, and non-profit organizations--as supplies permit-from the Air Pollution Technical Information Center, Environmental Protection Agency, Research Triangle Park, h'orth Carolina 27711 ; or may he obtained, for a fee, from the Rational icchnical Information Service, 5285 Port Royal Road, Springfield, Virginia 22161. Publication Mo. EPA-450/2-75-009 ii COLORITE 008337 PREFACE A. Pl'i/'CSF OF THIS DOCUMENT This report summarizes the information obtained during the development of a national emission standard for vinyl chloride under the authority of section 112 of the Clean Air Act. It is being distributed in connection with formal proposal of the standard in the FEDERAL REGISTER. Its purpose is to explain the background, basis, and environmental and economic impacts of the proposal in greater detail than could be included in the FEDERAL REGISTER and to facilitate analysis of the proposal by interested persons, including those who may not be familiar with i: any of the technical aspects of ethylene dichloride-vinyl chloride and polyvinyl chloride plants. Contained in this document is information on the industrial sources of vinyl chloride, control technology which can be applied to these sources, the proposed standard and the rationale for its selection, alternative approaches for regulating vinyl chloride, environmental and economic impacts of the proposed standard and alternative control levels, and other Federal or State regulations which apply to vinyl chloride or to plants which emit vinyl chloride. Information on the health effects of vinyl chloride is contained in a second document prepared by EPA, which is entitled the Scientific and Technical Assessment Report on Vj_ny_]_ Chioride and. Polyvinyl Chloride. Copies of both documents may be obtained front Mr, Don R. Goodwin, (KD-13), Director, Emission Standards and Engineering Division, United States Environmental Protection Agency, Research Triangle Park, North Carolina 27711 1(919) 688-8146]. Requests for additional information or for copies of reports (ether than published literature) cited in the background documents, and cements on the i ii COLORITE 008338 proposed standard should be forwarded to the same address. B. AUTHOR]TV FOR THE STANDARD National omission standards for hazardous air pollutants are promulgated in accordance with section 112 of the Clean Air Act (42 U.S.C. 1857c-7), as amended in 1970. "Hazardous air pollutant" is defined in the Act as "an air pollutant to which no ambient air quality standard is applicable and which in the judgment of the Administrator may cause, or contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness." Emission standards established under the authority of section 112 are to be set at a level which in the Administrator's judgment "provides an ample margin of safety to protect the public health from such hazardous air pollutants." To set a standard under section 112 of the Act, a pollutant must be listed in the FEDERAL REGISTER as a hazardous air pollutant. Within 180 days of listing, the Administrator must propose a national emission standard which, in his judgment, adequately protects public health. Within 30 days of proposal of the standard, the Administrator must give notice of a public hearing. The Administrator can withdraw a pollutant from the hazardous list only if he finds, on the basis of information presented at the public hearing, that the pollutant clearly is not hazardous. Otherwise the Administrator must promulgate a standard -within 180 days of the proposal. The Act does not require that the Ad wo Istrutor consider available control technology or economic b ;ww. i:i w- ' i1 > 1 i s1 tq ! i w- iwvol of ire s t wrrd . COLORITE 008339 Howovm, tFA must, fro::i time to -;me, issue information on control techno loov. C. COhSIH! RATION OF LNVIRONMrrjTAL IMPACTS Section 10?(2)(c) of the National Environmental Policy Act (NEPA) of 1969 (PI-91-190) requires federal agencies to prepare detailed environmental impact statements on proposals for legislation and other major federal actions significantly affecting the quality of the human environment. The objective of NfPA is to build into the decisionmaking process of Federal agencies a careful consideration of all environmental aspects of proposed actions. The Inergy Supply and Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically exempted proposed actions under the Clean Air Act from NEPA requirements. According to section 7(c)(1), "No action taken under the Clean Air Act shall be deemed a major federal action significantly affecting the quality of the human environment within the meaning of the National Environmental Policy Act of 1969." EPA has concluded, however, that the preparation of environmental impact statements could have beneficial effects on certain regulatory actions. Consequently, while not legally required to do so as a result of section 102(2)(c) of NEPA, EPA will prepare environmental impact statements for various regulatory actions, including proposed actions under section 112 of the Clean Air Act. This voluntary preparation of environmental impact statements, however, in no way legally subjects EPA to NEPA requirements. v COLORITE 008340 To ir > 1 enent this f PA policy decision, therefore, a separate section is included in this document which is devoted solely to an analysis of the potential environmental impacts associated with the proposed standard and alternative levels of control. Goth adverse and beneficial impacts associated with the proposed standard and alternatives in such areas as air and water pollution, increased solid waste disposal and increased energy consumption are identified and discussed. Generally, standards proposed under section 112 will most likely have beneficial impacts on ambient air quality and potential adverse impacts in other areas. D. CONSIDERATION' OF INFLATIONARY IMPACTS Executive Order 11821 (39 FR 41501, November 29, 1974) requires all Executive agencies to issue inflation impact statements when enacting major regulations or rules and when submitting proposals for major legislation. In accordance with the executive order, a separate chapter is included in this document which describes in detail the economic impact of the proposed standard for vinyl chloride and alternative levels of control. The economic analysis includes to the extent possible the impact of other regulations on the industries which would be affected by the proposed standard. Figures are given for both the capital and annual operating costs to the industries of installing and implementing the necessary control equipment to meet the proposed standard and other regulations. The potential plant closures and price increases in consumer goods which would occur as a result of {hose costs to the industries are also cs time, tvO. COLORITE 008341 Draft Standard Support and Environmental Impact Statement Vinyl Chloride Emissions from Ethylene DichlorideVinyl Chloride and Polyvinyl Chloride Plants Type of Action: Administrative ,0 A A Prepared by . ____________________________________ Director, Emission Standards and Engineering Division Environmental Protection Agency Research Triangle Park, N. C. 27711 /ofe`-//'7S (Date) _ Approved by Mac _______ Assistant: Administrator Office of Air and Waste Management Environmental Protection Agency 401 M Street, S. W. Washington, D. C. 20460 WPV2J.J97S (Date) Draft Statement Submitted to Council on Environmental Quality on (Date) Additional copies may be obtained or reviewed at: Emission Standards and Engineering Division Office of Air Quality Planning and Standards Environmental Protection Agency' Research Triangle Park, N. C. 27711 Public Information Reference Uni t Environmental Protection Agency Room 2922 (ERA Library) 401 M Street, S. W. Washington, D. C. 20460VI VI 1 COLOR!TE 008342 TABLE OF CONTENTS Page List of Tables ................................................................................................... xvii List of Maps and Figures ................................................................................ xxiv Chapter 1. Summary ......................................................................................... 1.1 The Proposed Standard ..................................................................... 1.2 Environmental Impact ....................................................................... 1.2.1 Alternatives to the Proposed Action ................................ 1.2.2 Summary of the Environmental Impacts of the Proposed Standard .................................................... 1-1 1-1 1-8 1-8 1-23 1.2.3 Relationship Between Local Short-Term Uses of Han's Environment and the Maintenance and Enhancement of Long-Term Productivity ........................................................ 1-31 1.2.4 Irreversible and Irretrievable Commitments of Resources Which Would Be Involved if the Proposed Action Should Be Implemented ................................................. ]_3i 1.3 Economic Impact .................................................................................. 1-32 Chapter 2. Rationale for Regulating Vinyl Chloride ................................ 2.1 History ................................................................................................ 2-1 2.2 Alternative Control Strategies Considered .................................. 2-2 2.2.1 No Action or Delayed Standards ........................................... 2-2 2,2.1.1 Summary of Health Findings ....................................... 2-2 viii COLORITE 008343 P.2.1.2 Extent of Public Exposure to Vinyl Chloride ....................................................................... 2.2.1.3 Other Regulations and Their Effect on Vinyl Chloride Emissions ......................................... 2.2.1.4 Conclusions ................................................................. 2.2.2 Action Under Section 115 - Abatement Conferences ........ 2.2.3 Action Under Section 303 - Emergency Powers ................. 2.2.4 Standards Under Section 109 - National Ambient Air Quality Standards (fJAAQS) .................................................. 2.2.5 Standards Under Section 111 - Standards of Performance for New Stationary Sources (SPNSS) .................................. 2.2.6 Standards Under Section 112 - National Emission Standards for Hazardous Air Pollutants (NESfiAP) ......... 2.2.6.1 Vinyl Chloride as a Hazardous Pollutant ............. 2.3 Setting an Emission Limit .............................................................. 2.3.1 The Alternative of Prohibiting Vinyl Chloride Emissions ................................................................................ 2.3.2 1 Me Alternative of Best Available Control Technology- 2.4 Selection of Source Categories ...................................... .............. 2.4.1 Ethylene Dichloride - Vinyl Chloride Plants ................. 2.4.2 Polyvinyl Chloride Plants .................................................. 2.4.3 Polyvinyl Chloride Fabricating Plants ............................ 2.4.4 Miscellaneous Sources of Viny1 Chloride ...................... 2.5 Conclusions ......... References .................................................................................................. Chapter 3. The Ethylene Dichloride - Vinyl Chloride and Polyvinyl Chloride Industries ................................................ 3.1 General ........................................................................... ................... Page 2-4 2-5 2-7 2-7 2-8 2-9 2-11 2-14 2-15 2-18 2-19 2-25 2-27 2-27 2-27 2-27 2-29 2-31 2-33 3-1 3-1 ix COLORITE 008344 3.2 Description of the Process ........................................................... 3.2.1 Ethylene Dichloride - VinylChloride Production ............ 3.2.1.1 Acetylene - Hydrogen ChlorideProcess ................... 3.2.1.2 Ethylene Dichloride Process ................................... 3.2.2 Polyvinyl ChlorideProduction ............................................. 3.2.2.1 Suspension Polymerization ....................................... 3.2.2.2Dispersion (Emulsion) Polymerization ....................... 3.2.2.3 Bulk Polymerization .................................................. 3.2.2.4 Solvent Polymerization ............................................. 3.2.3 Summary ......... References .................................................................................................. Chapter 4. Control Technology .................................................. 4.1 Adsorption ............. ........................................................................... 4.1.1 Carbon Adsorption ................................................................. 4.1.2 Resin Adsorption .................................................................. References ........................................................................................... 4.2 Incineration ..................................................................................... Pago 3-3 3-3 3-3 3-5 3-10 3-11 3-19 3-19 3-22 3_24 3-26 4-1 4-3 4-3 4-7 4-9 4-10 References ......... 4.3 Solvent Absorption .......................................................................... 4-15 4_16 References ............. 4.4 Refrigeration .................................................................................... 4-20 4_21 References ............................................................................................ 4.5 Control of Fugitive Emissions ...................................................... References ........................................................................................... 4-23 4-24 4-29 O COLORITE 008345 4.6 Relief Vi? Ivs Ui seh a roe References ................................................................................ 4.7 Gasholder and Purge Water System ....................................... References ................................................................................ 4.8 Improved Stripping ............................................................... Page 4-30 4-31 4-32 4-37 4-38 References ............................................................................... 4-45 I 4.9 Reactor Opening Loss Controls ........................................... 4-46 References .............................................................................. 4-49 4.10 Emissions and Centro! Techniques for Inpromss Wastewater ............................................................................ 4-50 References .............................................................................. 4-53 4.11 Particulate Control ........................................................... 4-54 4.11.1 Centrifugal Separators Applied in the Polyvinyl Chloride Industry .................................................... 4-55 4.11.2 Fabric Tilters Applied to the Polyvinyl Chloride Industry .................................................... 4-56 4.12 Data Demonstrating Capability of Selected Control Techniques ............................................................. 4-57 4.12.1 Stripping ................................................................... 4-57 4.12.2 Carbon Adsorption .................................................... 4-61 4.12.3 Incineration ............................................................. 4-68 4.12.4 Solvent Absorption .................................................. 4-70 4.12.5 Purge Water System .................................................. 4-71 4.12.6 Process Equipment Purge ......................................... 4-72 xi J COLORITE 008346 Page 4.12.7 Oxycblorination Process Priissions ................................... 4-72 4.12.8 Bulk Plant Purge ................................................................... 4-72 References ............................................................................................. 4-73 4.13 Control Techniques Summary ........................................................... 4-74 Chapter 5. Alternative Control Levels ........................................................... 5-1 5.1 Ethylene Bichloride - Vinyl Chloride Plants .............................. 5-4 5.2 Polyvinyl Chloride Plants ............................................................... 5-6 Chapter 6. Environmental Impacts of the Alternative Control Levels .............................................................................. 6-1 6.1 Secondary Environmental Impacts of Individual Control Systems .................................................................................. 6-2 6.2 Primary and Secondary Environmental Impacts at Model Plants ........................................................................................ 6-8 6.2.1 Primary EnvironmentalImpacts ............................................... 6-8 6.2.2 Secondary EnvironmentalImpacts ............................................ 6-25 6.2.2.1 Air Impact .................................................................... 6-26 6.2.2.2 Water Impact ................................... ............................ 6-40 6.2.2.3 Solid Waste ............. .................................................... 6-51 6.2.2.4 Noise and Radiation .................................................... 6-52 6.2.2.5 Energy Considerations ................................................ 6-52 References .................................................................................................... 6-61 Chapter 7. Economic Impact Analysis ........................................................... 7-1 7.1 Industry Economic Profile ............................................................... 7-1 7.1.1 Ethylene Dichloride ............................................................... 7-1 7.1.2 Vinyl Chloride ........................................................................ 7-1 X.11 t O COLOR!TE 008347 7.1.4 Vertical Mitegration and IndustryConcentration ............ 7.1.5 Polymerization of Polyvinyl Chloride Rosins by Process ................................................................. 7.1.6 Polyvinyl Chloride Consumption byEnd Use ....................... /. 1.7 Polyvinyl Chloride Substitutes ......................................... 7.1.8 Industry Employment ............................................................. 7.1.9 Increases in Industry Capacity ......................................... 7.1.10 Product Price Histories .................................................... 7.2 Cost Analysis of Alternative Emission Control Systems ................................................................................ 7.2.1 Introduction .......................................................................... 7.2.2 Cost of Alternative Control Measures .............................. 7.2.2.1 Ethylene Dichloride - Vinyl Chloride Model Plant ................................................................. 1.2.2.2 Suspension Polyvinyl Chloride Model Plant .......... 7.2.2.3 Dispersion Polyvinyl Chloride Model Plant .......... 7.2.2.4 Bulk Polyvinyl Chloride Model Plant ...................... 7.2.3 Cost-Effectiveness of Vinyl Chloride Controls ............. 7.3 Economic Impact Analysis of Alternative Control Systems ............................................................................................... 7.3.1 Introduction .......................................................................... 7.3.2 Discussion .............................................................................. 7.3.3 Ethylene Dichloride - Vinyl Chloride Plants - Existing Plant Economic Impact Analysis ......................................... 7.3.3.1 Existing Ethylene Dichloride Plants ...................... 7-2 7-3 7-3 7-4 7-5 7-5 7-6 7-8 7-8 7-10 7-10 7-12 7-15 7-16 7-17 7-18 7-18 7-19 7-22 1-22 xi i i COLORITE 008348 7.3,3.2 Exist.inq Vinyl Chloride Plants .................... 7.3.4 ethylene Dichloride - Vinyl Chloride Plants - New Plant Economic Impact Analysis ......................................... 7.3.5 Polyvinyl chloride Plants - Existing Plant Economic Impact Analysis .................................................... 7.3.5.1 Introduction ................................................................ 7.3.5.2 Control Scenario #1 ................................................... 7.3.5.3 Control Scenario f2 ................................................... 7.3.5.4 Control Scenario #3 ................................................... 7.3.5.5 Control Scenario ^4 ................................................... 7.3.6 Polyvinyl Chloride Plants - New Plant Economic Impact Analysis .................................................... 7.3.6.1 Introduction. ................................................................ 7.3.6.2 Net/ Suspension ProcessPlants ................................... 7.3.6.3 New Dispersion ProcessPlants ................................... 7.3.6.4 New Bulk Process Plants ............................................ 7.3.7 Summary .................................................................................... 7.3.7.1 Ethylene Dichloride - Vinyl Chloride Plants .......................................................... 7.3.7.2 Polyvinyl Chloride Plants ........................................ References ................................................................................................... Chapter 8. Rationale for the Proposed Standard ..................................... 8.1 Selection of Emission Sources to be Covered by the Proposed Standard ..................................................................... 8.2 Rationale for the Emission Limits ............................................... 8.2.1 Oxychlorinatinn Reactor at Ethylene Dicbloride Vinyl Chloride Plants .......................................................... Pane 7-28 7-35 7-38 7-38 7-38 7-42 7-43 7-45 7-47 7-47 7-47 7-50 7-53 7-54 7-54 7-57 7-65 8-1 8-1 8-3 8-5 O COLORITE 008349 8.2.2 Source's Followin'] the Stripper in Dispersion Resin Manufacture at Polyvinyl Chloride5 Plante ...................... 8.2.3 Other stack EmissionSources ............................................... 8.2.4 Fugitive EmissionSources ..................................................... 8.3 Selection of the Format of the Proposed Standard ................... 8.4 Methods for Determining Compliance With the Proposed Standard ............................................................................ 8.4.1 Emission Tests ...................................................................... 8.4.2 Reporting ................................................................................ 8.4.3 Recordkeepinq ........................................................................ 8.4.4 Other Methods for DeterminingCompliance ......................... 8.5 Evaluation of Need to Set Standards for Polyvinyl Chloride Particulate ....................................................................... 8.5.1 Polyvinyl Chloride Particulate as a Source of Vinyl Chloride Emissions .................................................... 8.5.2 Need to Set a Standard forPolyvinyl Chloride Particulate ............................................................ References ................ .......................................................................... Chapter 9. Other Regulatory Requirements Developed or Being Developed for Vinyl Chloride and Their Relationship to the Proposed Standard Tor Vinyl Chloride ............................ 9.1 Occupational Safety and Health Administration ........................ 9.1.1 The Emergency Temporary Standard ..................................... 9.1.2 The Proposed Permanent Standard ....................................... 9.1.3 The Promulgated PermanentStandard .................................. 9.1.4 Amendments and Corrections to the October 4 , 1 974 Regulation ................................................ 9.1.5 Relationship of the Proposed EPA Standard and tlve OSHA Regulation ............................................................ Page 3-9 8-14 8-22 8-32 8-40 8-40 8-41 8-45 8-45 8-46 8-46 8-49 8-51 9-1 9-1 9-1 9-1 9-2 9-3 9-4 xv COLORITE 008350 9.2 Environmental Protection Aqentv .................................................. 9.2.1 Water Regulations ................................................................. 9.2.2 Pesticide Regulation ........................................................... 9.3 Department of Transportation ........................................................ 9.4 Department of Health, Education, and Welfare .......................... 9.4.1 Food Packages ........................................................................ 9.4.2 Aerosol Products ................................................................... 9.5 Consumer Product Safety Commission ............................................. 9.6 State Regulations ............................................................................ Appendix A. Evoluation of the Proposed Standard ................................... Appendix B. Index to Environmental Impact Considerations ................... Appendix C. Emission Source Test Data ...................................................... Appendix D. Emission Monitoring and Compliance Testing Techniques and Costs ............................................................... Abstract and Technical Report Data............................................................... Paqe 9-6 9-6 9-7 9-7 9-8 9-8 9-9 9-9 9-10 A-l B-l C-l D-l E-l O ! > vi O COLORITE 008351 LIST C!r TABLES Paq_e 1-1 Emission Standard for Ethylene Dichloride - Vinyl Chloride Plants ............................................................................................ 1-9 1--2 Emission Standard for Polyvinyl Chloride Plants .......................... 1-11 1-3 Matrix of Environmental and Economic Impacts of Alternatives for Ramil ating Vinyl Chloride Emissions from Ethylene Dichloride - Vinyl Chloride Plants ................................... 1-16 1-4 Matrix of Environmental and Economic Impacts of Alternatives for Regulating Vinyl Chloride Emissions from Polyvinyl Chloride Plants .......................................................................................... 1-17 2-1 Estimated Vinyl ChlorideEmissions in the U. S.- 1974 ..................... 2-28 3-1 Producing Comoanies, PlantLocations, andCapacities Ethylene Dichloride .................................................................................. 3-28 3-2 Producing Companies, Plant Locations, and Capacities Vinyl Chloride ............................................................................................ 3-30 3-3 Producing Companies, Plant Locations, and Capacities PVC Resins ................................................................................................... 3-32 3-4 PVC Producers by Process ........................................................................ 3-35 3_g Vinyl Chloride Emissions for Ethylene Dichloride-Vinyl Chloride Production ................................................................................................... 3-37 3-6 Vinyl Chloride Emissions forSuspensionPolyvinyl Chloride Process ........................................................................................ 3-38 , 3-7 Vinyl Chloride Emissions for Dispersion Polyvinyl Chloride Process ......................................................................................... 3-39 3-8 Vinyl Chloride Emissions for Bulk Polyvinyl Chloride Polymerization ............................................................................................. 3-40 3-9 Vinyl Chloride Emissions for Solvent Polyvinyl Chloride 1 Polymerization ............................................................................................. 3-41 y xvi i COLORITE 008352 Pane 3-10 Su'Tiary Fugitive Emisslons ......................................................... 3- 11 Vinyl Chloride Monomer Content in Streams Discharninq to Sewer ......................................................................... 4- 1 Source Description for Typical Polyvinyl Chloride Plant ..................................................................................... 4-2 Source Description for Typical Ethylene Dichloridc-Vinyl Chloride Plant ..................................................................................... 4-3 Control Techniques Applicable to Polyvinyl Chloride Plants .................................................................................... 4-4 Control Techniques Applicable to Ethylene Dichloride-Vinyl Chloride Plants ................................................................................... 4-5 April 1975 Status of Dispersion Resin Stripping with Projection of Future Capabilities ......................................... 4-6 April 1975 Status of Suspension Resin Stripping ......................... 4-7 Adsorption of Recovered Vinyl Chloride Monomer on Activated Carbon ............................................................................ 4-8 Kilograms Per Year of VCM Emitted during Equipment Purge for Typical 316 MM kg/yr (700 MM Ib/yr) EDC-VCM Plant 4-9 Kilograms Per Year of VCM Emitted Durinq Equipment Purge from Typical 68 MM kg/yr (150 MM Ib/yr) PVC Plant .......... 4-10 Oxychlorination Process Vent Description ...................................... 4-11 Polyvinyl Chloride Particulate Emission Factors .......................... 6-1 Secondary Environmental Impacts of Individual Control Systems .................................................................................... 6-2 Vinyl Chloride Mass Emission Reduction .......................................... 6-3 Reductions in Vinyl Chloride Ambient Concentrations Estimated by Diffusion Modeling - 5-Minute Maxima ................... 6-4 Reductions in Vinyl Chloride Ambient Concentrations Estimated by Diffusion Modeling - ?4-Hour Average Maxima ........ 3-4? 3-44 4-77 4-79 4-80 4-83 4-84 4-85 4-86 4-87 4-88 4-89 4-90 6-3 6-9 6-13 6-14 xvi i i COLORITE 008353 Pacje 6-5 Reductions in Vire/1 rhlonde A: .bient Concentrations Estimated by Diffusion Model inn - Annual Average Maxima ........... 6-15 6-6 Vinyl Chloride Ambient Concentrations - Cluster of Four Ethylene Dichloride - Vinyl Chloride and Polyvinyl Chloride Plants - 5-Minute, 24-Hour and Annual Average Maxima Unregulated and Regulated ................................................................... 6-18 6-/ Emission Factors for Hydrogen Chloride Resulting From Incineration of Emission Points in Ethylene Dichloride Vinyl Chloride (EDC-VCM) and Polyvinyl Chloride (PVC) Plants .. 6-29 6-8 Hydrogen Chloride Mass Emissions from Model Ethylene Dichloride - Vinyl Chloride Plants Using Incineration to Attain the Alternative Control Levels ............................................. 6-30 6-9 Hydrogen Chloride Mass Emissions from Model Polyvinyl Chloride Plants Using Incineration to Control a Maximum Number of Emission Points ................................................................... 6-31 6-10 Hydrogen Chloride Ambient Concentrations Prom Incineration of Vinyl Chloride Emissions at Ethylene Dichloride - Vinyl Chloride Plants - Estimated by Diffusion Modeling ....................... 6-34 6-11 Hydrogen Chloride Ambient Concentrations From Incineration of Vinyl Chloride Emissions at Polyvinyl Chloride Plants Estimated by Diffusion Modeling ........................................................ 6-35 6-12 Increased Water Consumption by Model Ethylene Dichloride Vinyl Chloride Plants Using an Incinerator-Scrubber to Attain the Alternative Control Levels ............................................. 6-41 6-13 Increased Water Consumption by Model Polyvinyl Chloride Plants Usinq Various Control Systems to Attain the Proposed Standard/ Alternative II (Dispersion Plants) .................................................. 6-42 6-14 Quantities of Vinyl Chloride Released Into the Plant Inprocess Wastewater by Control Systems Which Can Be Used to Meet the Proposed Standard/Alteniative II (Dispersion Plants) ................. 6-44 6-15 Information on Water Effluent Frcm Incinerator-Scrubber Systems At Model Ethylene Dichloride - Vinyl Chloride Plants Attaining the Alternative Control Levels ......... ............................ 6-47 J xi x COLORITE 008354 6-16 Information on Water Effluent from Incinerator-Scrubber Systems at Model Polyvinyl Chloride Plants Control lint] a Maximum. Humber of Emission Points With Incineration ............... 6-17 Increased Energy Consumption - Ethylene Dichloride - Vinyl Chloride Plant [318 MM kg 7CM/YR (700 MM lb VCM/YR)] Attaining the Alternative Control Levels ................................... 6-18 Increased Energy Consumption - Dispersion Polyvinyl Chloride Plant [14 MM kg/yr (30 MM lb/yr)] ................................ 6-19 Increased Energy Consumption - Suspension Polyvinyl Chloride Plant [68 MM kg/yr (150 MM lb/yr)] Meeting the Proposed Standard .............................................................................. 6-20 Increased Enemy Consumption - Bulk Polyvinyl Chloride Plant [45 MM kg/yr (100 MM lb/yr)] Meeting the Proposed Standard .. 6-48 6-53 6-54 6-56 6-57 6- 21 Comparison of Energy Consumption by Model Plants With and Without Controls ......................................................................... 7- 1 Vertical Integration in the EDC/VCM/PVC Industry ..................... 7-2 1974 PVC Consumption by End-Use Category .................................... 7-3 Possible PVC Substitutes .................................................................. 7-4 Announced PVC Capacity Expansions and Closures ......................... 7-5 Prices of Ethylene Dichloride, Vinyl Chloride, and Polyvinyl Chloride ............................................................................ 7-6 Summary of Algorithms Used For Computing Model Plant Costs and Credits .............................................................................. 7-7 Control Costs for Model Balanced EDC-VCM Plant ......................... 7-8 Control Costs For Model PVC Suspension Plants ........................... 7-9 Control Costs for Model PVC Dispersion Plants ........................... 7-10 Control Costs For Model PVC Bulk Plant; ...................................... 7-11 Summary of Fugitive Emission Control Costs For Balanced Ethylene Dichloride - Vinyl Chloride Model Plant ..................... 6-58 7-66 7-68 7-69 7-71 7-72 7-73 7-78 7-79 7-81 7-83 7-84 xx COLORITE 008355 7-12 Sui'Tury of fuoifive Emission Cunlrol Costs for Suspension Polyvinyl Chloride locio 1 Plant ........................................................... 7-86 7-13 Summary uf Fugitive Emission Control Costs for Dispersion Polvirr/I Chloride Model Plant ............................................................. 7-88 7-14 Summary of Punitive Emission Control Costs For Bulk Polyvinyl Chloride Model Plant ............................................................................... 7-90 7-15 Cost-Effectiveness of Alternative Vinyl Chloride Control Methods ................................................................................................... 7-92 7-1C EPA Water Effluent Reciulations - Compliance Costs for EDC, PCM, and PVC Plants to Meet the 1933 (Best Available Technology) Recrui reman ts ................................................................... 7-94 7-17 Existing FDC Plants - Capital Summary, Alterna'.ive I or Alternative II ................................................................................ 7-95 7-18 Existinq EDC Plants - Annualized Cost Summary, Alternative I or Alternative II ...................................................... 7-96 7-19 Existing EDC Plant Profitability Calculations and Assumptions (Before Control) ............................................................ 7-97 7-20 Existing EDC Plants - Profitability Summary, Alternative I or Alternative II ................................................................................ 7-98 7-21 Existinn EDC Plants - Capital Summary, Alternative III.............. 7-99 7-22 Existing EDC Plants - Annualized Cost Summary, Alternative III ................................................................................... 7-100 7-23 Existinn EDC Plants - Profitability Summary, Alternative III ................................................................................... 7-101 7-24 Existing VCM Plants - Capital Summary, Alternative I ................ 7-102 7-25 Existing VCM Plants - Annualized Cost Summary, Alternative I ........................................................................................ 7-103 7-26 Existing VCM Plants - Profitability Summary, Alternative I .................................. 7-104 7-27 Existing VCM Plants - Genital `'ummary, Alternative II ............... 7-105 xxi COLORITE 008356 Page 7-28 Existing VCM Plants - Annualized Cost Sumnarv, Alternative II ...................................................................................... 7-29 Existing VC; 1 Plants - Profitability Summary, Alternative II ..................................................................................... 7-30 Existing VCM Plants - Capital Summary, Alternative III .................................................................................... 7-31 Existing VCM Plants - Annualized Cost Summary, Alternative III .................................................................................... 7-32 Existing VCM Plants - Profitability Sunmary, Alternative III ............................. 7-33 Financial Impact of Alternative- Control Levels on New EDC-VCM Plants .............................................................................. 7-34 Existing PVC Plants - Capital Summary, Control Scenario #1 ............................................................................. 7-35 Existing PVC Plants - Annualized Cost Summary, Control Scenario #1 ................................................ ,.................. . 7-36 Existing PVC Plants - Profitabi1ity Summary, Control Scenario =1 ........................................................................... 7-37 Existing PVC Plants - Capital Summary, Control Scenario#2 .............................................................................. 7-38 Existing PVC Plants - Annualized Cost Summary, Control Scenarioe2 .............................................................................. 7-39 Existing PVC Plants - Profitability Summary, Control Scenarios'2 ....................................................................... 7-40 Existing PVC Plants - Capital Summary, Control Scenario-3 .............................................................................. 7-41 Existing PVC Plants - Annualized Cost Summary, Control Scenario-3 .............................................................................. 7-42 Existing PVC Plants - Profitability Summary, Control Scenario-3 .............................................................................. 7-106 7-107 7-103 7-109 7-110 7-111 7-112 7-114 7-116 7-118 7-120 7-122 7-124 7-126 7-128 xx ii COLORITE 008357 7-43 Existing PVC Plants - Capital Summary, Control Scenario -M ............................................................................ 7-44 Existing PVC Plants - Annualized Cost Summary, Control Scenario -4 ............................................................................ 7-45 Existing PVC Plants - Profitability Summary, Control Scenario #4 ............................................................................ 7-46 Financial Impact of Various Control Systems at Hew Suspension Process PVC Plants .......................................................... 7-47 Financial Impact of Various Control Systems at New Dispersion Process PVC Plants .............................................................................. 7-48 Effect of Economies of Scale on New Dispersion Process PVC Plants ...................... ..................................................................... 7- 49 Financial Impact of Various Control Systems at New Bulk Process PVC Plants .............................................................................. 8- 1 Alternative Control Levels for a Typical [318 Million Kiloqrams (700 Million Pounds) a Year] Ethylene Dichloride Vinyl Chloride Plant .......................................................................... 8-2 Alternative Control Levels for a Typical 14 Million Kilograms (30 Million Pounds) a Year PVC Dispersion Plant .... Pane 7-130 7-132 7-134 7-136 7-138 7-139 7-140 8-6 8-11 xxii i J COLORITE 008358 LIST OF MAPS AND FIGURES Figure 3-1 Acetylene Process For Vinyl ChlorideProduction Figure 3-2 Vinyl Chloride by the Balanced Process Figure 3-3 Dichloroethane Cracking Process for Vinyl Chloride Production Figure 3-4 The Oxychlorination Process Figure 3-5 Polyvinyl Chloride Plant - Suspension Process Figure 3-6 Polyvinyl Chloride Plant - Dispersion Process Figure 3-7 Polyvinyl Chloride Plant - Bulk Process Figure 3-8 Polyvinyl Chloride Plant - Solvent Process Map 3-1 Ethylene Dichloride Plant Locations Map 3-2 VCM Plant Locations Map 3-3 PVC Plant Locations Figure 4-1 Countercurrent Stripping Column Figure 4-2 American Chemical Incinerator Test Figure 6-1 Map of Four Plant Cluster - Case A Figure 6-2 Map of Four Plant Cluster - Case B Page 3-4 3-6 3-7 3-8 3-12 3-20 3-21 3-23 3-29 3-31 3-34 ^-69 6-19 6-19 xx i v COLORITE 008359 1. SUMMARY 1.1 The Proposed Standard A national emission standard for vinyl chloride emissions from ethylene dichloride-vinyl chloride and polyvinyl chloride plants is being proposed under the authority of section 112 of the Clean Air Act. Section 112 is intended for the regulation of hazardous air pollutants. "Hazardous air pollutant" is defined in section 112 as "an air pollutant to which no ambient air quality standard is applicable and which in the judgment of the Administrator may cause, or contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness." Vinyl chloride has been implicated as the causal agent of angiosarcoma (a rare form of liver cancer), other cancers, and serious noncarcinogenic disorders in people with occupational exposure and in animals with experimental exposure to vinyl chloride. Reasonable extrapolations from these findings cause concern that vinyl chloride may cause or contribute to the same or similar disorders at present ambient air levels. Therefore, vinyl chloride meets the specifications of a "hazardous air pollutant" as defined in the Clean Air Act. Section 112 requires that emission standards be established at a level which provides an ample margin of safety to protect public health. As applied to threshold pollutants, this requires that emission standards be established below the threshold level of effects. This cannot be done for vinyl chloride because no dose-response data are 1-1 J COLORITE 008360 available for the concentrations of vinyl chloride found in the ambient air. Moreover, for carcirogens there nay be no atmospheric concen tration -which poses absolutely no public health risk. Therefore, the purpose of the proposed standard is to minimize vinyl chloride emissions from ethylene dichioride-vinyl chloride and polyvinyl chloride plants to the level attainable with best available control technology. This would have the effect of furthering the protection of public health by minimizing the health risks to the people living in the vicinity of these plants and to any additional people who are exposed as a result of new construction. The stationary source categories of vinyl chloride emissions include 41 polyvinyl chloride plants which are responsible for approximately 85 percent of the total nationwide emissions, 17 ethylene dichloride-vinyl chloride plants which are responsible for approximately 11 percent of the total emissions and approximately 8000 fabricating plants and several miscellaneous sources which are responsible for the remaining emissions. The proposed standard is applicable to only ethylene dichloride-vinyl chloride and polyvinyl chloride plants which are the largest sources of emissions. (It should be noted that throughout this document the term "ethylene dichloride-vinyl chloride plants" is used. This is because ethylene dichloride and vinyl chloride are typically produced at the same plant location. However, this is not necessarily the case. The proposed standard applies to plants which produce ethylene dichloride or vinyl chloride as well as to plants which produce both). Standards for the fabricating plants are 1-? COLORITE 008361 not being proposed at this time because available ambient monitoring data indicate that vinyl chloride concentrations in the vicinity of these plants are negligible. Also, vinyl chloride emissions from these plants will be minimized indirectly as polyvinyl chloride plants reduce the residual vinyl chloride in the raw materials going to the fabri cating plants in response to the proposed standard and OSHA's standard for vinyl chloride which was promulgated October 4, 1974. A decision on whether standards for the miscellaneous sources will be proposed will be made after on-going studies on them are completed. The proposed standard for ethylene dichloride- ,'inyl chloride and polyvinyl chloride plants would impact primarily on southeastern Texas, southern Louisiana, and the Northeastern States, where most of the plants are located. Fourteen of the 17 ethylene dichloride-vinyl chloride plants are located in southeastern Texas and southern Louisiana. Other States in which ethylene dichloride-vinyl chloride or polyvinyl chloride plants are located include Kentucky, California, Illinois, Massachusetts, Mississippi, Oklahoma, Delaware, Maryland, Pennsylvania, Ohio, New Jersey, New York, West Virginia, Georgia, and Michigan. There is also an ethylene dichloride-vinyl chloride plant in Puerto Rico. Additional States may be affected by the proposed standard as new plants are constructed. The proposed standard is a national emission standard which will be enforced by the Federal EPA and by States which request and are delegated the authority to enforce the standard. In order to minimize vinyl chloride emissions to the atmosphere, the proposed standard covers all known point and fugitive emission 1-3 COLORITE 008362 sources in both ethylene dichloride-vinyl chloride and polyvinyl chloride plants. The point sources in ethylene dichloride-vinyl chloride plants include ethylene dichloride purification, vinyl chloride formation and purification, and the oxychlorination reactor. The point sources in polyvinyl chloride plants include reactors; strippers; mixing, weighing and holding containers; monomer recovery systems; slurry blend tanks; centrifuges; concentrators; dryers; baggers; and storage silos. Fugitive emission sources in both kinds of plants include loading (or unloading) vinyl chloride from storage vessels into transfer equipment, slip gauges, leakage from equipment (including pump, compressor, and agitator seals and relief valves), opening of equipment for cleaning and maintenance, manual venting of gases to reduce pressure in equipment, obtaining samples of vinyl chloride product, and inprocess wastewater. Relief discharges from equipment in both ethylene dichloride-vinyl chloride and polyvinyl chloride plants cause short-term peak emissions. The proposed standard would reduce emissions from a typical ethylene dichloride-vinyl chloride plant by approximately 94 percent and from a typical polyvinyl chloride plant by approximately 95 percent. (These emission reductions are based on emission levels which were reported to exist in the spring of 1974. The reductions in fugitive emissions as a result of the proposed standard cannot be quantified, but are included in these percentages based on best judgment.) The 1-4 COLOR!TE 008363 emission limitations included in the proposed standard for ethylene dichloride-vinyl chloride and polyvinyl chloride plants are summarized in the following paragraphs. Ethylene Dichioride-Vinyl Chloride Plants The proposed standard would apply to any plant where ethylene dichloride is produced by reaction of oxygen and hydrogen chloride with ethylene. It would also apply to any plant where vinyl chloride is made by one or more processes including, but not limited to, the addition of hydrogen chloride to acetylene and delydrochlorination of ethylene dichloride. Ethylene dichloride and vinyl chloride are typically produced at the same plant location, although this is not necessarily the case. The individual emission points in ethylene dichloride-vinyl chloride plants would be regulated as follows: 1. Emissions from equipment used in the purification process for ethylene dichloride and in the formation and purification processes for vinyl chloride would be reduced to 10 ppm by volume. This can be accomplished by add-on control devices, such as an incinerator 2. Emissions from the oxychlorination reactor would be reduced to 0.02 kg/100-kg ethylene dichloride product from the oxychlorination process. This can be accomplished by controlling process parameters or by add-on control devices, such as an incinerator. 3. Preventable relief valve discharges would not be permitted 1-5 V COLORITE 008364 4. Fugitive emissions would be minimized primarily by equipment and procedural specifications requiring enclosure of the emission sources and capture of the emissions. For example, before opening equipment to the atmosphere, vinyl chloride contained in the equipment would have to be removed and transferred to a recovery system or a control device. Leakage from pump seals would be prevented by installing pumps with no seals or with double mechanical seals. A formal program would be instituted and implemented for leak detection and elimination. Vinyl chloride emissions from the more highly concentrated inprocess wastewater streams would be reduced by removing the vinyl chloride from the water before the water is exposed to the atmosphere; the vinyl chloride removed would be collected and ducted to a recovery system or control device. Polyvinyl Chloride Plants The proposed standard would apply to any plant which polymerizes vinyl chloride. Production of homopolymers, copolymers, terpolymers, or other polymers containing any fraction of polymerized vinyl chloride would be covered. The standard would be applicable to all manufacturing processes, including suspension, dispersion, emulsion, Ktex, bulk, and any other processes developed in the future. The individual emission points in polyvinyl chloride plants would be regulated as follows: 1. Emissions from major process equipment preceding and including the stripping operation in the flow of materials through the plant (e.g. reactors, strippers, and monomer recovery systems) would 1-6 COLORITE 008365 be reduced to 10 ppm by volume. This can be accomplished by add-on control devices, such as carbon adsorption. 2. Emissions from major process equipment following the stripping operation in the flow of materials through the plant (e.g. slurry blend tanks, centrifuges, dryers and storage silos) would be reduced by removing the residual vinyl chloride from the polyvinyl chloride resin during the stripping operation before the polyvinyl chloride resin is processed in equipment following the stripper. Dispersion resins would contain no more than 2000 ppm residual vinyl chloride as they completed ..he stripping operation and all other resins would contain no more than 400 ppm residual vinyl chloride. Add-on control devices, such as incinerators, could also be employed to attain comparable emission levels. 3. Emissions from opening of .reactors would be reduced to 0.001 kg/100 kg of reactor product. Except for postpolymerization reactors in the manufacture of bulk resins, one way in which this can be accomplished is by using water to displace the vinyl chloride in the reactor to a recovery system before opening the reactor and reducing the number of reactor openings by solvent cleaning. For postpolymerization reactors in the manufacture of bulk resins, the proposed standard could be attained by evacuating the reactor several times and breaking the vacuum with nitrogen. The number of evacuations would depend on the volume of gas in the reactor and the vacuum involved. 4. Preventable relief discharges would not be permitted. For example, relief discharges from reactors can be prevented by 1-7 COLORITE 008366 several measures, including injectinq chemicals to stop the polymerization reaction, instrumentation of the reactor to detect upset condition, or venting the contents of the reactor to a gasholder and ultimately to a monomer recovery system. 5. As in ethylene dichloride-vinyl chloride plants, fugitive emissions would be minimized primarily by equipment and procedural specifications requiring enclosure of the emission sources and capture of the emissions. A formal program would be instituted and implemented for leak detection and elimination. Vinyl chloride emissions from the more highly concentrated inprocess wastewater streams would be reduced by removing the vinyl chloride from the water before the water is exposed to the atmosphere; the vinyl chloride removed would be collected and ducted to a recovery system or control device. A more detailed summary of the proposed emission limits and testing, reporting, and recordkeeping requirements for ethylene dichloride-vinyl chloride and polyvinyl chloride plants can be found in Tables 1-1 and 1-2, respectively. 1.2 Environmental Impact 1.2.1 Alternatives to the Proposed Action Several different sets of alternatives were considered in developing the proposed standard for vinyl chloride. These different sets of alternatives are listed as follows; A. Alternative regulatory strategies The first step in evaluating the vinyl chloride problem was to dercmint: who! her standards for a t i; ospiieri t ..'missions of vinyl Ml COLORITE 008367 1) TABLE 1-1 EMISSION STANDARD FOP ETHYLENE DtCHLORIDE-VTNYL CHLORIDE PLANTS Peguired testing, _ reportiogL_and reco rdk ee pirg _5rjur:e___ ,, ('} EEC Puri f: cat i on Emission lt'iit 10 pom Possible method of control \ nclnerator Initial report (within 90 days of promulgation - Routine tests Semi-annual .. .report Other report iflg Emission Test ustng Test Method 106 A record of any emissions ir excess of the standard as measured by a multipoint vinyl chloride detector Pecordieemnq A record nf emissions as Measured by a nul ti po l r.t vinyl chloride detector (?) Vr Cj" < Pficotaatt'ioonn and 10 ppm Incinerator Emission, Test using Test Method 106 A record of any enn ss ions in excess of the standard as measured by a multipoint u'-yl chloride detector A record of emissions as measured by a mu111 solrt ;lny1 chirr'de detector n - (3) '* ilcnnatinr o8t* Rc ? c ` o r 0.02 kg/100 kg ethylene dichioride prodjet fro-'i the oxyohlorination process Control process variables Emission Test using Test Method 106 A record of any emissions in excess of the standard as measured by a isnjl 11 point vinyl chloride detector A r^r.erd of ci'ssions as measured by a mult1 on in t *iry1 chio1*1 He di1 lector HI (Jj Cl`?ii'>f Va*ve Discharges 0 Preventive Measures a ,J i thin 10 days of any discharge a o co U) m oo _ . ..VTurce.......................; :11.ve Elusion Sources {a) i j ,l i nn \ ines (11 SI ip gauges Emission .. (a) 4,4 1. U at STPa (b) 10 ppm 10 ppm 1 gal) vinyl chloride !0 Pi 0 cn | ir teals {d) "' ' l e f valve 111 j I. a n e (e} v-:raz\ vending (r1 L_ening ecuip'-vf! t (; J <l J 53') ' 1 L:, gal) <i-.> i c-.'ro 1 1U igsl) (oj . 1 -- flask ih, l-;1- detection Minimize leakage Minimize leakage la) 0 {b) TO ppm1 (a) no 1, 1 5 jail at STP (b) 10 ppm f (a) Reduce,VC to J)t at STP (b) 10 ppm1 "0 Fixed ronitort portable monitor, standard operasing procedure TABLE 1-1 (continued) EMISSION STANDARD FOR ETHYLENE 01 CHLORIDE-VI NYL CHLORIDE PLANTS Required testing, reporting, and recordkeeping Possible method of control Initial report (wfthin 90 davs of oromirl nat. on Routine tests Sem -annual report Other report inq Recordkneoino ------ -------------------------------- (a) Displacement vacuum (b) Incineration Incineration Standard fioeraiirg Prccmj ure Standard r perat l ng Procedure Sealess pumps, double mech. seals Rupture disks (a) Gasholder (b) Incineration Reduce pressure, [a^vacuum . (b)Incineration (a) Displace, vacuum (b) Incineration 1 Purge back to process Formal program for Teak detection and repair Statement that have installed and are tuplemeriting neressary equipment* ard ah emission test for the control device to which fugitive emissions are required to be ducted>'jsing test method 106, Standard Operating ProcrvJure Standard Operating Procedure Within 45 days.submit program for approval A record of reasurerrents; a record of tea* detect ion and re o ai r. (i) nprocess 'rfaste al 10 ppm b) TO ppm (a) Stripper , Lb) Incineration -.'-.''s to the control device to which captured fugitive emissions are retired to be ducted. Etoisslon TestMethod 107 COLOR!TE 008369 oo L ') Sou rce f 1) PrecisL'luiorer,t rr'i',r to and inclucmg stripper n dctcir,,,s tri peer', IV r n . rpre v-'-ry r y *tr m n-:, weigh* ' q ' no A 1 r.q c `lj * trs) CJ Pt-actcr Opening I :ss rVTPtlu' va'-e 2's cha r'.'-s r\~l ' 1 c'Sw'ijfi cgesr e C*r - { O ijfry t an tdry r, storv't ccsi s s :1 -. v. "r, e t:.) [miss 1 on 1 i -ti 11 10 ppm 0.001 kg/ 1 CO V g product ~D--------------- TABLE 1-2 EMISSITN STANDARD FOR POLYVINYL CHLORIDE PLANTS Requi rod testing, reporting, and recordkeeping Possible method of control Adsorption Initial report (within 00 ch/s of p ronu I go 11 nn Emission Te$tUsinq Test Method 106 Pout me tests Sei m-annual report A record of any emissions in excess of the standard as measured by i mul 11 pon t vi nyl chloride detector Other reporting Re :o rdk co'iir.rj A record of emi s sions as iieasered bjr i mil 11 poip t vnyl cMoride detector Water Purge Preventlve Measures Erfssion Test Using Test Method 106 or Portable Hydrocarbon Outector Emiss'on Test using Test Method 106 or Portable hydrocarbon Dotnctor - L'tnin 10 days of any discharge - Aa i i y oeorat1 nq record on rrjetems , inclurJ'nj pressures, temperatures. {a 1 Dispersion Pesins (1) Strip to 2^00 ppm (averaged on a ch^ly basis and weighted accord'rq tr the production of COC!' Cj'M'JrjJ;Or (2) n.2 k-j/100 kg product (b) Other Resins (1) Strip to AGO opn (averaged on a dui) rasis, averaged separately for each res*" type, and we ted according to the production of each grades); or (?) 0.04 kg/ICO kq product (a) Dispersion Resins (1) Improved Stripol ng (?) Add-On Controls (b) Other Resins p<ng{1) Improved Stno- (2} Add-On Controls If improved strip If improved strip ping is not used as ping is used; meas- the method of con uremnts of the trol ; simultaneous vmyl chloride in emission tests for ' i*' resin as the a!1 sources, using '.sin leaves the Test Method 106 s' ripper. lf for stacks and Test batch strioping is Method 117 for used, ore sample .per batch, [ f continuous strip- J* inp'oved strip pi nn is used, one ping i' used, sample per shift. measurements of the Test Vet hod 107 vinyl chloride in the resin as the umseeadsuforermefsntes, rr sir, 1 paves the sir{pper. Information i>sed to develop the $eni -annual report COLOR!TG 008370 TABLE 1-2 (continued) EMISSION STANDARD FOR POLWINVL CHLORIDE PLANTS TrT'F'J-;i't1 yL i. "i ssTort' Er if OS a' Unloading T irn$ I1 b i Slip g i u gp s Emission __ 1 init (a) 4.4 T (1 at STP (b) 10 ppm 10 ppm I gal) vinvl chloride ft' pjmp, cororessor md aH tntor seals (o ! "!fl>l1eanfe valve 11.11 1 a 1 ."j.nti nLf Minimize leakage Minimize leakage n fb) 10 ppm3 f f) 0 ."C-r i ng eqj l p- ! \ s^.dO i vUEIridl) (a) 110 1 (25 gal) at STP (b) 10 ppm ' fii1 (1>2550,5i1a01) 1 (q) Ernie flask l,B i ak dc-t ect ion 10 bom(b)(a) Reduce,VC to Z% at STP =0 Fixed monitor, portable monitor* standard op* erating orocedure Required testing, reporting, and recordkeeping Initial report Routine tests Other Possible (within DO days Semi-annual reporting net hod of control________of promul gat ion_________ report ___________________________ Recordkeeping (a) Displacement* vacuum (b) Adsorptfon3 Adsorpti on Sealess pumps* double nech. seals Rupture disks (a) Gasholder (b) Adsorption (a) rate prTure> (b) Adsorption (a) Displace, vacuum (b> Adsorption^ Purge back to process FoTiial program for leak detection and repai r Statement that have installed and are Imnlementing neces sary equipments and an emiision test for the control device to which fugi Live emissions are required to be ducted * using test method 106. Standard Operating Procedure Standard (.pcrating Procedure Stai dard Operating Procedure Standard Operating ps-,W|/- m^fjH'Q Within 45 days *subnit program for approval A record of measurements; a record cf leak detect ion and rep r. ^process Wastewnc"' (ai 10 pp11 (b) f0 ppm1 (a) Stripper , (b) Adsorption 1 c--f."-s to tbe control device to which captured fugitive emissions re t i ured to be ducted. Emission TestMethod 107 COLORITE 008371 o chloride are needed, and if so, which section of the Clean Air Act should be used to regulate the emissions. Therefore, the following alternatives were considered: 1. No proposal of standards. 2. Delay proposalof standards until more data are available. 3. Section 115 of the Clean Air Act (Abatement Conferences). 4. Section 303 of the Clean Air Act (Emergency Powers). 5. Section 109 of the Clean Air Act(National Ambient Air Quality Standards for Vinyl Chloride). 6. Section 109 of the Clean Air Act (National Ambient Air Quality Standards for Non-Methane Hydrocarbons). 7. Section 111 of the Clean Air Act (Standards of Performance for New Sources). 8. Section 112 of the Clean Air Act (National Emission Standards for Hazardous Air Pollutants). After a thorough evaluation of the above alternatives, EPA concluded that a standard is needed for vinyl chloride now and that it should be developed under the authority of section 112 of the Act. Since a standard for vinyl chloride could not be based on a threshold level of effects, consideration was given to the following alternative regulatory strategies under section 112. 1. Prohibit all emissions from the manufacture and processing of vinyl chloride. 2. Minimize emissions by setting a standard which would require emission reduction to the lowest level achievable by use of best available control technology. COLORITE 008372 A decision also had to be made regarding which source categories of vinyl chloride emissions should be regulated. The source categories considered include: 1. Ethylene dichloride-vinyl chloride plants 2. Polyvinyl chloride plants 3. Polyvinyl chloride fabricating plants 4. Miscellaneous sources The alternative regulatory strategy selected is to propose a standard based on the application of best available control technology. The source categories selected for regulation at this time are ethylene dichloride-vinyl chloride and polyvinyl chloride plants. The rationale for selecting this regulatory strategy and a discussion of the alternative strategies considered are contained in Chapter 2. B. Alternative control levels Once EPA decided that the standard for vinyl chloride would be based on the application of best available control technology, a second set of alternatives was examined. This second set of alternatives concerned the level of control which should be required. In Chapter 4 are discussed the alternative control systems which are available for application to the vinyl chloride industries. In Chapter 5 are outlined alternative levels of control which can be achieved with the control systems described in Chapter 4, These alternative control levels include: 1, The proposed standard 2. A more stringent standard 1-14 COLORITE 008373 3. A less stringent standard The environmental impacts of these alternative control levels are discussed in Chapter 6 and the economic and socioeconomic impacts of these alternatives are discussed in Chapter 7. Other alternatives were considered, such as for the units of the proposed standard and the methods for determining compliance with the proposed standard. These alternatives are discussed in Chapter 8. The matrices in Tables 1-3 and 1-4 summarize the environmental, health, economic, and social impacts of the proposed standard and alternative control levels. Some of the alternative regulatory strategies, such as setting no standards and prohibiting all emissions, are also presented in the matrix. Although health impacts are not specifically listed, they can be assumed to be directly related to the primary air impacts. The +'s and -'s in the squares indicate whether the impacts are positive or negative and the numbers beside the +`s and -'s represent a subjective estimate of the degree of the positive or negative impact on a scale of 1 to 5. The point-of-reference is the current situation, with no standard in effect. The impacts for the proposed standard and alternative actions for ethylene dichloride-vinyl chloride plants are summarized in Table 1-3. Basically, the alternative control levels for ethylene dichloride-vinyl chloride plants differ only in the level of control required for one of several emission points in a typical plant (the oxychlorination reactor). The oxychlorination reactor was selected to present alternatives for because it is a relatively small emission source in the average plant and relatively large quantities of energy would be 1-13 COLORITE 008374 Table 3 ! Acminis- j Primary j trative j Air | Action j Impact it \ Less 1 Seri ngfjnT:! iSt-.r.-ard 1 ! 1i +3.5 ^ooosoi * j Star lard ti Matrix of Environmental and Economic Impacts of Alternatives for Repulating Vinyl Chloride Emissions from Ethylene Dichloride-Vinyl Chloride Plants Secondary Solid Ai r Water Waste Imoact Imoact Imoact Energy Impact Noise Impact Social or Economic Inflation Impact Impact -1 0 -1 0 -1 -1 -3 -1 ' 0 -1 0 -1 -1 KEY + Beneficial IniDact 7 Adverse'Impact 0 FJo Impact 1 Negligible Imoact 2 Small Impact 3 Moderate Impact 4 Large Imoact 5 Extremely Large Impact j s. t;r';onrecenr;! !Standard l i; 1 .. 1 Prohibiteng > Emissions j j +4.5 i relayed _ ( s t -- rr a f o > 1 + '< ' Standard -2 j s | > : j i i i j / -3 u , J -2 0 -1 0 -4 .0 0 0 -1 00 0 -2 -2 0 -5 -2.5 0 -1 00 -1 0 o o COLORITE 008375 Oo Table 1-4 Matrix of Environmental and Economic Impacts of Alternatives for Requlatir.q Vinyl Chloride Emissions from Polyvinyl Chloride Plants J -- Acini n i s trative Ai r Action Impact Secondary Ai r Impact Solid Water Waste Energy Impact Impact . Impact Less Serinqent Standard +2 0 -1 -1 -1 f I Proposed Standard +4 0 -1 -1 -2 i] i i Mere Stringent + 4.5 0 0 0 0 i Standard Noise Impact 0 0 0 Economic Inflation Impact Impact -2 -2 -3 -2 -4.5 -2.5 KEY* 1 + Beneficial Impact 7 Adverse Impact 0 No Impact 1 Negligible Impact 2 Small Impact 3 Moderate Impact 4 Large Impact 5 Extremely Large Impact !I jProhibitMng [Emissions _____ i i Relayed It Standard +5 +3 0000 0 -1 -1 -2 0 -5 -2.5 0 -3 -2 No Standard -2 0 0 0 0 00 0 COLORITE 008376 necessitated if the emissions from it were required to be controlled with incineration, the most effective current method of control which could be applied to it. The alternative labeled in the matrix as "a more stringent standard" would require a level of control equivalent to incineration of the emissions from the oxychlorination reactor. The alternative labeled as "a less stringent standard" represents no control of the emissions from the oxychlorination reactor. The proposed standard represents a level of control in-between, which can be attained by control of process variables. The less stringent standard would result in only a 90 percent emission reduction from the entire plant, compared with a 94 percent emission reduction with the proposed standard and a 97 percent emission reduction with the more stringent standard. The greater reduction in vinyl chloride emissions achievable with the more stringent standard would also result in greater secondary impacts. Incineration of the emissions from the oxychlorination reactor and control of emissions from the incinerator with a scrubber would result in more water consumption, greater emissions of hydrogen chloride to the air and water, and minute amounts of additional vinyl chloride released into the inprocess wastewater. One of the more significant secondary impacts of the more stringent standard would be the increase in energy consumption required for combustion. The more stringent standard would result in a 7 percent increase in energy consumption at an average plant. The proposed standard would require less than a 1 percent increase. The neqative economic and social (inflation) impacts assigned to rhe more stringent standard are slightly higher than those assigned to the proposed and 1-18 COLORITE 008377 less stringent standards, because the increased cost of the control equipment to achieve the more stringent standard would add somewhat to the increased price of polyvinyl chloride products to the consumer. The secondary impacts of the proposed standard and the less stringent standard are essentially the same, because they do not require combustion of emissions from the oxychlorination reactor at a typical plant. There is one plant which may have to use incineration for the oxychlorination reactor to attain the level of the proposed standard. This plant would then incur the impacts indicated for the more stringent standard. The alternative control levels for polyvinyl chloride plants also differ only in the degree of control required for one of several emission points, i.e., emissions from sources following the stripper. The alternatives apply to the manufacture of only one type of polyvinyl chloride resin (dispersion resin), which constitutes 13 percent of the total polyvinyl chloride production. This emission point in the manu facture of dispersion resin was selected as the one to present altern atives for because it can be controlled in two ways: (1) installation of control devices such as incinerators or (2) stripping the vinyl chloride from the polyvinyl chloride resin before the resin is processed. Under proper conditions, stripping can achieve the same degree of emission reduction as add-on control devices and is much less energy consuming. For several reasons explained in more detail in Chapters 4, 5, and 8, the technology for stripping has not been developed to the same extent for dispersion resins as for other resins. There are three alternative control levels for polyvinyl chloride dispersion plants. The less stringent standard represents essentially no 1-19 COLORXTE 008378 control of the sources following the stripper. The proposed standard represents a level of control which is judged to be generally available within the maximum time allowed for compliance under section 112 of the Act. This level of control has been achieved by one plant for all resin grades and two plants for some resin grades. It can be achieved by all plants with the more energy-consuming add-on control technology. The more stringent standard represents the degree of stripping which is required for other polyvinyl chloride resins. In regard to primary impact, the less stringent standard would achieve only a 52 percent reduction in emissions compared with a 95 percent emission reduction with the proposed standard and a 97 percent emission reduction with the more stringent standard. There are no significant secondary environmental impacts indicated for the three levels of control, A small economic impact is indicated for the less stringent standard and a moderate economic impact is indicated for the proposed standard. A large economic impact is indicated for the more stringent standard because EPA judged that if that degree of control were imposed, the majority of the dispersion resin manufacturers would close, at least temporarily until technology could be developed to achieve that degree of control. For this mason, no environmental or energy impacts are .indicated for the more stringent standard. The inflation impacts or the price increases in consumer products due to the less stringent standard and the proposed standard are both indicated as small. A small to moderate impact is indicated for the alternative of prohibiting emissions because, in general, substitutes for polyvinyl chloride rosins would he more expensive 1-20 COLORITE 008379 than the resins. Since the more stringent standard would be expected to also close down dispersion resin manufacture, at least temporarily, the same inflation impact is indicated for the more stringent standard as for prohibiting emissions. There would be more significant secondary environmental, energy, and economic impacts than indicated in the matrix if a plant elected to meet the proposed standard with add-on control devices rather than improved stripping. Since these two types of control under proper conditions achieve the same level of control, they represent alternatives for the industry, rather than for EPA to choose between. Therefore, the impacts from using add-on controls are not indicated in the matrix. For the alternative regulatory strategy "no standard," for both ethylene dichloride-vinyl chloride and polyvinyl chloride plants, the only impact listed is a negative primary air impact. Even though unregulated plants do have an impact on other environmental media, the secondary impacts listed in the matrices represent only those effects on the environment caused by implementing controls. The primary air impact of "no standard" is negative because not only would this alternative result in a continuance of present ambient air concentrations of vinyl chloride and their associated health risks, but it would result in an increase in ambient air concentrations of vinyl chloride in some locations due to growth in the industries. As discussed in Chapter 7, the annual growth rate in the industries was approximately 10 percent between 1969 and 1974. Future qrowth in the industries is expected to continue at approximately this same rate, although it is possible that the rate 1-21 COLORITE 008380 will decrease somewhat. Growth in production would obviously result in higher ambient air concentrations of vinyl chloride and more increased health risk with no standard in effect than with the proposed standard in effect, both in communities in the vicinity of expanding plants and in presently unaffected communities where new plants will be constructed. The secondary environmental impacts for the alternative regulatory strategy "delayed standard" for both the ethylene dichloride-vinyl chloride and polyvinyl chloride plants are the same as for the "proposed standard," except that they would obviously be delayed in time. The primary impact of the delayed standard would be the same as the proposed standard once it went into effect. However, the primary impact is not rated as highly for "delayed standard" as for the "proposed standard," because the primary impact represents health impact, and the "delayed standard" would allow for a longer period of continued exposure to current ambient concentrations of vinyl chloride and the associated risk of adverse health effects. The secondary economic impact of a delayed standard might be less than that of the proposed standard, although this is not indicated in the matrix, because this would give the affected industries more time for research and development of more cost-effective control equipment. The alternative regulatory strategy of prohibiting all emissions of vinyl chloride could not be attained with available control technology and would in effect ban vinyl chloride and polyvinyl chloride production. Since no control devices would be used, there would be no secondary environmental impacts. The primary impact of banning vinyl chloride 1 nO I - L <- O o COLORITE 008381 and polyvinyl chloride production has been assigned a positive high number since this alternative would virtually eliminate ambient air concentrations of vinyl chloride. The social and economic impacts of "prohibiting all emissions" have been assigned high negative numbers, however, because as described in Chapter 2, banning production of vinyl chloride and polyvinyl chloride would have not only a negative impact on firms producing vinyl chloride and polyvinyl chloride, but also a large impact on unemployment rates due to the dependence of approximately 8,000 fabricating plants on polyvinyl chloride production. There would also be a negative impact on users of polyvinyl chloride products due to the lack of readily available desirable substitutes and the probable higher costs of these substitutes. It is conceivable that substitutes that would be used for vinyl chloride or polyvinyl chloride would have adverse health or environmental impacts. Due to the wide variety of available substitutes and the lack of knowledge about all possible substitutes, this subject has not been thoroughly studied and therefore is not included in the matrix. 1.2.2 Summary of the Environmental Impacts of the Proposed Standard The purpose of this section is to summarize the beneficial and potential adverse environmental impacts of the proposed standard. The significance of each potential adverse impact is evaluated, and any steps which have been or will be taken to minimize or eliminate the potential adverse environmental impacts are discussed. Those impacts which cannot be avoided are identified. 1,2.2.1 Beneficial Environmental Impacts The beneficial, or primary, environmental impacts of the Kj proposed standard would be teductions in vinyl chloride emissions 1-23 COLORITE 008382 and consequently, correspondin'] reductions in amblon air conconLrations of vinyl chloride and risks to health in the vicinit of these sources. Although the proposed standard would not eliminate a 1 vinyl chloride emissions, it would further the protection of public health by minimizing emissions. For a typical average-sized ethylene die loride-vinyl chloride plant, the proposed standard would reduce h urly vinyl chloride emissions from 176 kg to 10 kg. This is approximate y a 94 percent reduction. For a typical average-sized polyvinyl ch oride plant, the hourly vinyl chloride emissions would be reduced fro 330 kg to 16 kg, or by approximately 95 percent. Percentage numbers or both source categories are based on an estimated 90 percent redu tion in fugitive emissions. 1.2.2.2 Potential Adverse Environmental Impact and Steps Which Can Be Taken to Minimize Them There are several potential adverse, or seconda -y, environmental impacts of the proposed standard. These include inc -eased atmospheric emissions of hydrogen chloride, lowered pH of inproc ss wastewater due to hydrogen chloride, increased water consumptio small increases in the quantity of vinyl chloride released into inprocess wastewater, increased solid waste disposal due to ca -bon used for adsorption and increased energy consumption. As dis :ussed in detail in Chapter 6, the types and degree of the secondary mpacts resulting from the proposed standard would vary frorr plant to plant depending on the type of control selected to meet th: standard. As discussed in the following paragraphs, methods are a/ailable for minimizing all of the potential adverse impacts so 1 -at most of 1-2' COLORITE 008383 o them would be insignificant. Increased Atmospheric Emissions of Hydrogen Chloride Atmospheric emissions of hydrogen chloride are expected to be a potential problem only at ethylene dichloride-vinyl chloride plants. This is primarily because incineration, the source of hydrogen chloride emissions, is more likely to be selected as a control method to meet the proposed standard at ethylene dichloride-vinyl chloride plants than at polyvinyl chloride plants. Polyvinyl chloride plants are expected to meet the proposed standard with control measures other than incineration. Hydrogen chloride emissions to the atmosphere can be minimized by utilizing a scrubber after the incinerator. Due to corrosion problems which would be caused by uncontrolled hydrogen chloride emissions both on plant property and in the community, ethylene dichloride-vinyl chloride plants are not expected to use incineration to control vinyl chloride emissions without using scrubbers to control the hydrogen chloride emissions. However, there is no assurance that scrubbers would be used since there are no EPA regulations requiring the plants to use them. If a typical, average-sized ethylene dichloride-vinyl chloride plant did use an incinerator to meet the proposed standard and did not control the hydrogen chloride emissions, diffusion model results indicate that the maximum 24-hour average ambient concentrations would be approximately equivalent to the American Conference of Governmental Industrial Hygienists (ACGIH) 8-hour average ceiling level for occupational exposure (7000 vg/nT ; and would exceed all the existing foreign 1-25 COLORITE 008384 standards and mo National Academy of Sciences (NAS) recommended guidelines identified in Chapter C for public exposure to hydrogen chloride. [It should be noted that F.PA has no standard or guideline limit for public exposure to ambient concentrations of hydrogen chloride, and thus no "yardstick" with which these diffusion model estimates can be compared. The NAS guidelines and foreign standards are the only "yardsticks" available; they have limited value because they have varying averaging times that do not necessarily correspond with the averaging times used for the diffusion modeling.] However, as already stated, it is expected that a plant would control the hydrogen chloride emissions. A large typical ethylene dichloride-vinyl chloride plant using a 98 percent efficient scrubber to control the hydrogen chloride emissions from the incinerator would emit 10.2 kg/hr (22.6 Ib/hr) hydrogen chloride. Diffusion model results indicate that the maximum 24-hour average concentrations of hydrogen chloride in the vicinity of this large plant would be 430 ig/m^ or about 6 percent of the ACGIH's 8-hour average ceiling level for occupational exposure and below the NAS guidelines and West Germany's standard. The diffusion model results would exceed the Russian and Czechoslovakian standards, which are substantially lower than the other guidelines and standards. The Russian standard is based on concentrations which might cause reflexive reaction of the sensory organs. In addition, ethylene dichiorido-vinyl chloride plants typically already emit hydrogen chloride *tv; pioci'ss .vuii. ml. When the l.vdrogon chloride tmissiru: fro; brnh th .-m eyuip ci re! the incm ? Woe- COLORITE 008385 _r j; )f;' .,yst. -m a, e considered together in computing maximum ambient concentrations, the projected maximum 24-hour average ambient concentration at the large plant would be in the same range or somewhat higher than the existing foreign standards and the NAS recommended guidelines for public exposure. However, it should be noted that the emissions from the incinerator-scrubber would represent only about 25 percent of the total emissions from the two sources. In other words, the projected maximum ambient hydrogen chloride concentrations in the vicinity of the plants would already be relatively high due to emissions from the process equipment, and the incinerator-scrubber would increase these levels. Lowered pf[ of Inprocess Wastewater Due to Hydrogen Chloride Hydrogen chloride absorbed in an incinerator-scrubber control system would cause the water leaving the scrubber to have a low pH. At ethylene dichloride-vinyl chloride plants, where incinerator-scrubber systems are most likely to be used to meet the proposed standard, the pH could be less than 1. This acidic effluent could cause the total plant effluent to have a low pH since the scrubber effluent would be a sizeable portion of the total effluent stream. In order to meet the EPA effluent guidelines, the pH of the total plant effluent would have to be adjusted to 6.0 - 9.0 by recovering the hydrogen chloride to be used as a raw material by the plant or by adding caustic either to the scrubber water or to the effluent leaving the scrubber. Therefore, no additional steps to minimize the impact of this pollutant are needed. Increased Water Consumption Ethylene dichloride-vinyl chloride plants using incineratorscrubbers to meet the proposed standard would increase their water consumption by less than 1 percent. Polyvinyl chloride plants 1-27 COLORITE 008386 meeting the proposed standard with improved stripping for the sources following the stripper, a water purge system to control emissions from reactor opening, carbon adsorption for the monomer recovery system,and steam stripping for the inprocess wastewater, would increase their water consumption by 6 to 38 percent, depending on the manufacturing process. EPA's Office of Water and Hazardous Materials is currently investigating whether these increases in water consumption to meet the proposed standard for atmospheric emissions of vinyl chloride would require a change in EPA's Effluent Guidelines and Standards for ethylene dichloridevinyl chloride and polyvinyl chloride plants (39 FR 12506 and 39 FR 14678). After the investigation is completed, appropriate changes will be made in the guidelines and standards as needed. Increases in the Ouantity of Vinyl Chloride in Inprocess Wastewater Incinerator-scrubbers used at ethylene dichloride-vinyl chloride plants to meet the proposed standard would increase the quantities of vinyl chloride released into the wastewater by less than 0.1 percent. The increase in vinyl chloride released into wastewater at polyvinyl chloride plants meeting the proposed standard could be more significant if the plants used steam for improved stripping, steam to desorb vinyl chloride from a carbon adsorption unit, o<" a water purge system to remove vinyl chloride from reactors before opening them to the atmosphere. However, any increases in vinyl chloride released into the wastewater from these sources at polyvinyl chloride plants are expected to be minimized by the proposed standard, which would require that vinyl chloride emissions to the atmosphere from the more highly concentrated inprocess waste-water streams be controlled by removing the vinyl chloride fro:" the wastewater. Therefore, no addi COLORITE 008387 tional steps need to be taken to minimize this potential adverse impact. Increased Solid Waste Disposal Due to Carbon Used for Adsorption Although carbon used in adsorption is continuously desorbed and recycled, it is expected that it may have to be replaced every 1 to 3 years. Since there has been very limited experience with carbon adsorption in the ethylene dichloride-vinyl chloride or polyvinyl chloride industries, it is not known for certain at this time what the carbon bed-life would be or whether the damaged carbon could be regenerated. If polymerization occurred on the carbon, it could be regenerated by oxidizing the polymer. If the structural characteristics which make carbon desirable, however, were damaged, it could not be regenerated. In meeting the proposed standard, the most likely emission point to be controlled by carbon adsorption is the monomer recovery system in polyvinyl chloride plants. For an average sized plant an adsorption unit used for this purpose would require 3450 kg of carbon (7,600 lb of carbon). If this were thrown away every year, it would represent 3 percent of the total solid waste generated by an average-sized plant. This appears to be an insignificant impact. In addition to the problem of bulk, however, there may be problems in disposal of the carbon associated with residual vinyl chloride or other materials collected on the carbon. The significance of any such problems is not known at this time. The carbon could also be burned in a boiler as a low sulfur fuel, but may cause air pollution problems associated with conversion of chlorinated hydrocarbons to hydrogen chloride. Increased Energy Consumption Typical ethylene dichloride-vinyl chloride plants using incineration to meet the proposed standard would require less than a 1 percent 1-29 COLORITE 008388 increase in energy consumption. This is because only the emissions from the ethylene dichloride purification and vinyl chloride formation and purification processes would be required to be incinerated, and little if any supplemental fuel would be required for their combustion. Polyvinyl chloride plants using incineration to meet the proposed standard would increase their energy consumption very significantly ("typical" suspension plants, 223 percent; "typical" dispersion plants, 836 percent; and "typical" bulk plants, 166 percent) primarily due to the supplemental fuel which would be required for control technology to reduce emissions from dryers, storage, and transfer operations. Improved stripping would require a much smaller percent increase in energy consumption ("typical" suspension plants, 15 percent; "typical" dispersion plants, 81 percent; and "typical" bulk plants, 50 percent). Summary Based on the above discussion, the potential secondary or adverse environmental impacts of the proposed standard are either insignificant or will be minimized without additional action, except for two. First, .EPA may find it necessary, as a result of current investi gations, to make some changes in the water effluent guidelines and standards, particularly for polyvinyl chloride plants. Second, hydrogen 1_ f COLOR!TE 008389 chloride is already emitted by process equipment at ethylene dichloridevinyl chloride plants and by other petrochemical plants in the complexes where ethylene dichloride-vinyl chloride plants are typically located. An incinerator used to attain the proposed standard at an ethylene dichloride-vinyl chloride plant could increase its hydrogen chloride emissions by several fold. Typically, however, due to the corrosion problems which would otherwise occur both on plant property and in the community, plants use scrubbers to control already existing hydrogen chloride emissions. Hydrogen chloride emissions resulting from control of vinyl chloride emissions are expected to also be controlled for the same reason. If even a moderately efficient scrubber (98 percent control) were used to control the hydrogen chloride emissions resulting from incineration of vinyl chloride emissions, the increase in hydrogen chloride emissions from a typical ethylene dichloride-vinyl chloride plant due to the proposed standard would be reduced to 35 percent. However, since diffusion model results indicate that under "worst-case" meteorological conditions, the hydrogen chloride emissions from the process equipment and the incinerator combined would cause maximum ambient concentrations of hydrogen chloride in the vicinity of ethylene dichloride-vinyl chloride plants to be in the sane range or somewhat higher than existing foreign standards and National Academy of Sciences (NAS) guidelines for public exposure, TPA plans to further evaluate the need to control hydrogen chloride emissions. NAS is currently preparing a report on the health effects of hydrogen chloride for EPA. A 1-31 COLORITE 008390 final draft of that report is scheduled for completion by the end of 1 375. At that ti...e, EPA will assess the hydrogen chloride problem. 1.2.3 Relationship Between Local Short-Term Uses of Man's Environment and the Maintenance and Enhancement of LongTerm Productivity By taking steps now to establish standards based on best available control technology to minimize vinyl chloride emissions, EPA will be able to minimize exposure and prevent severe illnesses and deaths which may have occurred in future years as a result of prolonged community exposure to vinyl chloride. Therefore, the proposed standard may curtail industrial expansion on a short-term basis, as a result of funds being diverted from support of industrial expansion to support of installation of process changes and control systems to attain the standard; but it will enhance the long-term productivity of man and his environment. 1.2.4 Irreversible and Irretrievable Commitments of Resources Which Would Be Involved if the Proposed Action Should Be Implemented Irreversible and irretrievable resources which would be committed to reduce ambient concentrations of vinyl chloride include energy and the materials to construct incinerators, boilers, monitoring equipment, carbon adsorption units, etc. If incineration v/ere used to meet the standard, additional energy and materials would be needed for operation of an absorption unit to abate hydrogen chloride emissions. 1-32 COLORITE 008391 1,3 Economic Impact In accordance with Executive Order 11821 and 0M8 circular A-107, EPA has carefully evaluated the economic and inflationary impacts of the proposed standard. This economic analysis is contained in Chapter 7, and includes the costs of control systems which can be used to attain the proposed standard and alternative control levels, and the impact of these costs on the vinyl chloride industries and the public consumer. The total estimated capital cost for existing plants to meet the proposed standard is $198 million, of which $15 million is for ethylene dichloride-vinyl chloride plants and $183 million is for polyvinyl chloride plants. The total annualized costs for attainment of the proposed standard are estimated to be $70 million, of which $12 million is for ethylene dichloride-vinyl chloride plants and $58 million is for polyvinyl chloride plants. Also, included in the economic analysis were the costs of the OSHA standard which the plants are subject to and the EPA water effluent guideline limitations which the plants will be subject to in 1983 (best available control technology economically achievable). The total capital cost for existing plants to meet the EPA water effluent guideline limitations is $83 million, of which $35 million is for ethylene dichloride-vinyl chloride plants and $48 million is for polyvinyl chloride plants. The total annualized cost to meet the effluent guideline limitations is $17 million, of which S7 million is for ethylene dichloride-vinyl chloride plants and 1-33 COLORITE 008392 SI0 million is ror polyvinyl chloride plants. lino costs to the industry ot meeting the OSHA standard cannot be quantified at this time, but they are expected to overlap to some degree with the costs to meet the fugitive emission regulations in the proposed standard. The capital cost to meet the fugitive emission regulations is $37 million and the annualized cost is $25 million. The proposed standard would not deter construction of new ethylene dichloride-vinyl chloride plants or new polyvinyl chloride suspension or bulk plants. For polyvinyl chloride dispersion plants (which constitute 13 percent of the industry production), the proposed standard would significantly deter the construction of new plants that have capacities of less than 45 million kg/yr (100 million lb/yr) but would not deter construction of plants larger than 45 million kg/yr. Total costs for attainment of the proposed standard and the effluent guideline limitations are estimated to result in the closing of no ethylene dichloride-vinyl chloride plants and four small polyvinyl chloride plants. These four plants are estimated to employ 30 people and account for approximately 0.5 percent of existing industry capacity. It is estimated that the four plant closures resulting from imposition of the proposed standard would have occurred if only the costs of fugitive emission controls were incurred. It is estimated tiiat the price of polyvinyl chloride resins would rise by approximately 7.3 pvt'cent in order to maintain precontrol profitability and ilv; to i ..mover tnv total annualized Control co.. is i ..a'.iii y. bv b > d ' m, 1 COLORITE 008393 dichloride-vinyl chloride plants and polyvinyl chloride plants This increase is estimated to translate into a maximum consumer price increase in goods fabricated from polyvinyl chloride resins of approximately 3.5 percent. Recovery of effluent annualized costs plus maintenance of precontrol profitability is estimated to add approximately 2 percent to polyvinyl chloride resin prices and result in an additional maximum consumer price increase of 1 percent. 1-35 \J COLORITE 008394 2. RATIONALE FOR REGULATING VINYL CHLORIDE 2.1 History In January 1974, the B. F. Goodrich Chemical Company reported to the National Institute of Occupational Safety and Health (MIOSH) that several of its employees had died from angiosarcoma of the liver (a rare form of cancer) and that those deaths may have been related to occupational exposure to vinyl chloride gas. This report resulted in growing concern over the potential health effects of vinyl chloride and spurred efforts by various government agencies to take steps to obtain data needed to assess in more detail the impact of vinyl chloride on human health and to reduce vinyl chloride exposure both to the worker and to the general population. EPA established a Task Force on vinyl chloride in February 1974, to identify the environmental problems resulting from the manufacture and use of vinyl chloride and polyvinyl chloride. While air, water, and solid waste disposal are all possible routes for entry of vinyl chloride into the environment in the vicinity of manufacturing facilities, the Task Force concluded that, based upon current information, the air route poses the most significant environmental problem to the population located there.^ Potential sources of exposure to the general population due to the use (as opposed to the manufacture) of vinyl chloride include aerosol containers, plastics used for containing or wrapping food products, and drinking water. On April 26, 1974, EPA published in the FEDERAL REGISTER an emergency suspension order for specific indoor aerosol pesticides 2-1 COLORITE 008395 containing vinyl chloride. In May 1974, EPA initiated a study to determine whether Tederal regulation of atmospheric emissions of vinyl chloride from manufacturing facilities is needed and, if so, which of the regulatory alternatives under the Clean Air Act would be most appropriate. For the purpose of the study, data were gathered on health effects, air quality concentrations, control techniques, and costs. 2.2 Alternative Control Strategies Considered The Administrator of EPA considered several approaches to dealing with air emissions of vinyl chloride. The main alternatives were taking no action, delaying action until more data on health effects at lower concentrations of vinyl chloride are available, taking action under section 115 or 303 of the Clean Air Act, or setting standards under section 109, 111, or 112 of the Clean Air Act. 2.2.1 No Action or Delayed Standards Factors considered in determining whether Federal regulatory action is needed for vinyl chloride emissions and, if so, whether it is needed at this time, included the health effects of vinyl chloride, the extent of public exposure to vinyl chloride, and the degree to which other regulations are reducing vinyl chloride emissions. 2.2.1.1 Summary of Health Findings 2 Vinyl chloride has been shown to cause cancer in both sexes of three species of rodents by the inhalation route, the primary route by which humans who live in the vicinity of plants manufacturing 2-2 o COLORITE 008396 or processing vinyl chloride are exposed. Angiosarcoma of the liver has been observed in rats, hamsters, and mice exposed to vinyl chloride. In two of these species, rats and mice, liver angiosarcoma has been produced at exposure levels as low as 50 parts per million (ppm), which is the lowest level for which studies have been completed thus far. In one experiment, exposure levels as low as 50 ppm for four hours per day, five days per week for a 12 month period produced nephroblastomas and liver angiosarcoma after 135 weeks. In a second experiment, angiosarcoma in mice has been produced by exposures as low as 50 ppm for a 26 week duration. Furthermore, these animal studies showed a multiple cancer risk from vinyl chloride, i.e., tumors in organs other than the liver such as the brain, lungs, kidneys, and mammary glands. As of June 1975, the National Cancer Institute had confirmed 27 cases of liver angiosarcoma among workers with a history of exposure to vinyl chloride, 15 in the United States and 12 in Europe and Canada. Additionally 11 cases had been reported and not yet confirmed. Most, but not all, of these confirmed cases have been among workers involved directly in polyvinyl chloride production. Cases of liver angiosarcoma have been reported in one U. S. and three European workers exposed to vinyl chloride, but not directly involved in polyvinyl chloride production. These cases suggest that exposure to vinyl chloride at lower levels than usually encountered in polyvinyl chloride production plants is capable of causing liver angiosarcoma. To date, angiosarcoma of the liver has been considered an extremely rare disease among the general population. In a survey 2-3 COLOR!TE 008397 by the American Cancer Society, only one case of liver angiosarcoma was recorder! per 72,000 deaths. Compared with this record, the data indicating the frequency of liver angiosarcoma among workers exposed to vinyl chloride show that the relative risk to these workers of developing this disease is approximately 3,000 times greater than that to the general population. Such a relative risk represents a statistically significant difference ( p <0.001) in the frequency of liver angiosarcoma among those exposed to high levels of vinyl chloride compared with those in the general population. Occupational exposure studies have strongly implicated vinyl chloride as a human chemical carcinogen which causes tumors in many different sites, only one of which is angiosarcoma of the liver. Other manifestations in humans include acroosteolysis and liver dysfunction. Similar toxicology studies have verified the occurrence of tumors in other body organs such as the brain and lungs. Bioassay studies have shown the potential of vinyl chloride to be a chemical mutagen and teratogen. (More details on these animal and occupational studies may be found in the Scientific Technical Report on Vinyl Chloride and Polyvinyl Chloride .) 2.2.1.2 Extent of Public Exposure to Vinyl Chloride Generally, the population exposed to vinyl chloride emissions is composed of those people living within the vicinity of the approximately 17 ethylene dichloride-vinyl chloride plants, 41 polyvinyl chloride plants, 8000 fabricating plants, and 8 identified miscellaneous sources. COLOR!TE 008398 Results from a preliminary ambient monitoring program conducted by ERA in the spring of 1974 indicate that people living in the immediate vicinity of ethylene dichloride-vinyl chloride and polyvinyl chloride plants are generally exposed to average daily concentrations of less than 1 ppm with some 24-hour average excursions of 1 to 3 ppm and with 3 occasional peak exposures of as high as 33 ppm . Results from a more extensive ambient monitoring program conducted by EPA from November 1974 to June 1975 are not discussed in detail here because they are still being analyzed. The results are generally in the same range as reported here for the preliminary ambient monitoring program except there are no concentrations as high as 33 ppm. If ethylene dichloride-vinyl chloride and polyvinyl chloride industries are not regulated, community exposure to vinyl chloride may increase as the industries expand. The growth rate in consumption of vinyl chloride and polyvinyl chloride between 1969 and 1974 averaged approximately 10 percent per year. Future growth in consumption is expected to continue at approximately this same rate, although it is possible that the rate will decrease somewhat. Assuming that the growth rate in capacity would be the same as for consumption, at a 10 percent growth rate, current capacity would double in approximately 7 years. 2.2.1.3 Other Regulations and Their Effect on Vinyl Chloride Emiss At least some reduction of vinyl chloride emissions may be expected as the result of the standard promulgated by the Occupational Safety and Health Administration (OSHA) on October 4, 1974, and some State regulations for new construction and for hydrocarbon emissions. These regulations are described in Chapter 9. 2-5 COLORITE 008399 In response to the OSHA regulation which became effective April 1, 1975, the ethylene dichloride-vinyl chloride and polyvinyl chloride industries have adopted some measures which not only reduce employee exposure, but also reduce emissions to the atmosphere. However, other methods of reducing employee exposure to vinyl chloride, such as respiratory protection, ventilation of the workplace, opening sides of buildings, and installing tall stacks do not reduce the emissions to the atmosphere. Although the OSHA standard requires all employers to institute feasible controls to the fullest extent possible and to continue to improve and apply engineering controls until full compliance is achieved, it does not establish any deadlines for compliance through engineering controls. Written plans demonstrating how plants will achieve this goal must be drawn up and made available, upon request, to representatives of OSHA and NIOSH; however, for submittal of formal plans, there is also no deadline. For these reasons, it is difficult at this time to evaluate the degree to which the OSHA regulation will reduce vinyl chloride emissions to the atmosphere. It is assumed, however, that the plants will respond to the OSHA regulation with a combination of ventilation techniques, emission reduction, and respiratory protection and that this response will not be uniform. As the result of some State regulations for new sources and for hydrocarbon emissions, seme newly obstructed ..olwinyl c h 1 o i .it? t''!'.nts and the : 1 o,c ! a*' i nr ' i 'n rr > .v s- o ethyl., nc ' ! oil 1 Ol'l do - V ! i'! 1 1 <, f , 'cno , 'r i 1. COLOR!TE 008400 The State regulations, however, do not necessarily cover all emission ooints, nor do they require the same degree of emission reduction as the oroposed standard. Additionally, the State regulations are not expected to be uniform in the degree of control they require. 2.2.1.4 Conclusions Based on the analysis summarized above, EPA concluded that vinyl chloride is a carcinogen, that ambient concentrations of the gas pose a public health risk, and that the alternative of taking no action to regulate it is unacceptable. The alternative of delaying the standard setting would allow acquisition of additional information, but it is likely that gaps in the relevant information would still remain. Due to the expected long latency period between initial exposure to vinyl chloride and occurrence of disease, it will be many years before useful epidemiological data will be available on the effects of lowered occupational exposure resulting from the OSHA regulation. Therefore, EPA has further concluded that ambient concentrations of vinyl chloride should not be allowed to persist until all information gaps are filled. If EPA were to wait until all needed data were available to establish precise dose-response relationships, a standard could be long delayed, and the public might be exposed to substantial and irreversible harm in the interim. Moreover, the risks to the public could increase as the industry expands. 2.2.2 Action under Section 115 - Abatement Conferences Section 115 of the Act gives EPA the authority to call abatement conferences in cases where an air pollutant endangers the health or welfare of persons. Such conferences may be requested by a 2-7 COLOR!TE 008401 SMu- or o i:v `.e'en the go 11 utan c oriyinates within their i or o*ri ct i on or when the- rroh!'-1 originates ^ 1 sc .'here hut p-sr^ o problem within their area. ETA ray initiate conferences if +ne pollutant problem exceeds State boundary lines. An abatement conference covers many subjects, including information on occurrence of the air pollutant, adequacy of abatement actions, and the amount of delay that may be encountered in abating the pollution. For vinyl chloride, abatement conferences would have to be initiated by at least 16 States and Puerto Rico where all of the ethylene dichloride-vinyl chloride and polyvinyl chloride plants are located. Generally, EPA would not be able to call abatement conferences since vinyl chloride problems are localized and not interstate, but EPA could encourage the States to call such conferences. Once appropriate abatement actions were determined during the conferences, the States involved would have to initiate such actions. If abatement actions were not initiated, EPA would have six months to hold hearings and request that abatement action be taken within a reasonable time not to exceed six months. If the States or industry failed to act, EPA would have to file suit in the appropriate U. S. District Court to enforce the abatement action. In general, this procedure is unwieldy, requires a significant amount of manpower, and based on past experience, may not bring about the required abatement measures. Abatement conferences, `oerefore, are not considered an effective approach to coniro11irq vinyl rm'oride. 2,2.3 Action 'ir !.'r feet wi 1 V - '"Or nev P '.vcs O COLORITE 008402 contributing to air pollution that presents an "immiment and substantial endangerment to the health of persons.1' The Administrator may seek to stop pollutant emissions or take other action as may be necessary. This mechanism has been used or.ce by EPA. In 1971, court injunctions were obtained against plants in Birmingham, Alabama during an air pollution episode to reduce concentrations of particulate matter below dangerous levels. EPA has concluded that in the case of vinyl chloride where permanent regulatory control of a continuing problem is possible, that control is preferable to Section 303. Additkoally, using Section 303 could be cumbersome since injunctions may have to be obtained in each U. S. District Court that has a source of vinyl chloride within its jurisdiction. 2.2.4 Standards under Section 109--National Ambient Air Quality Standards (NAAQS) The purpose of air quality standards is to control air pollutants which have an adverse effect on public health and welfare and which are present in the ambient air due to numerous or diverse stationary or mobile sources. Primary standards are set at levels requisite to protect the public health, allowing an adequate margin of safety. Secondary standards are set at levels requisite to protect the public welfare from any known or anticipated adverse effects. Section 109 is usually used to control a pollutant whose presence in the ambient air is ubiquitous. Vinyl chloride is emitted from ethylene dichloride-vinyl chloride plants, polyvinyl chloride plants, polyvinyl chloride fabricating plants, and a few miscellaneous sources. 2-9 COLORITE 008403 ^V'Ctobl e com, ex Li'd i i oils of vinyl chloride have not yet boon found in the ambient air except in the vicinity of these sources. Establishing a national ambient air quality standard (NAAQS) for vinyl chloride would set into motion preparation of State implementation plans (SIP) for each of the 247 air quality control regions (AQCR's) to demonstrate attainment and maintenance of the standard. This is a complex process and is not generally considered the optimum regulatory approach for situations involving a limited number of source categories. The time required to implement the NAAOS/SIP process is estimated to be 6 months for setting a standard plus 13 months to develop and approve the SIP's. Compliance with the standards must be within 3 to 5 years after the SIP's are approved. EPA concluded that Section 109 is not the most suitable alternative for controlling vinyl chloride because vinyl chloride is a localized problem and because the NAAQS/SIP process is time-consuming and complex, and requires considerable State and Federal resources. Furthermore, Section 109 does not provide the expedited means of control which Congress meant to be used for a hazardous air pollutant. 2.2.4.1 Section 109--Existing National Ambient Air Ouality Standard for Nonmethane Hydrocarbons There exists a NAAQS for nonmethane hydrocarbons which possibly could be used as an indirect regulatory mechanism for controlling vinyl chloride. However, the hydrocarbon standard is clearly intended as a guide to achieving the NAAQS for photochemical oxidants. 40 CFR 51.14(c)(4) provides that the degree of total hydrocarbon emission 2-10 COLORITE 008404 reduction necessary for attainment and maintenance of the NAAQS for photochemical oxidants will also be adequate for the attainment of the NAAQS for hydrocarbons. States now have approved control strategies for hydrocarbon/oxidants and are progressing toward fulfilling the require ments of their respective strategies. To change the SIP's, EPA would have to present findings that the plans are inadequate and would have to require resubmittal of the plans. This would reopen a full review of the hydrocarbon/oxidant control strategies, including the transportation control plans. Hydrocarbon/oxidant strategies have focused on area-wide hydrocarbon emissions and it would be difficult to justify singling out vinyl chloride sources for control. Vinyl chloride is less photochemically reactive than many other petrochemicals and does not contribute signi ficantly to total urban hydrocarbon emissions. Moreover, the hydrocarbon standard regulates only the 6-9 a.m. concentrations of nonmethane hydrocarbons. During the remaining 21 hours of the day, control of vinyl chloride emissions could not be required under existing SIP's. Since the NAAQS is for hydrocarbons in general, there is no way to require States to regulate vinyl chloride in particular. For the above reasons, control of vinyl chloride under the existing NAAQS for hydrocarbons would not be appropriate or effective. 2.2.5 Standards under Section 111--Standards of Performance for New Stationary Sources (SPNSS) Standards of performance for new stationary sources apply to categories of sources that emit pollutants which may cause or contribute 2-11 COLOR!TE 008405 to the endanger,nonL of public health or welfare. flew sources are controlled under Section 111(b) and existing sources, under Section 111(d). [Section 111(b) standards can be established for pollutants already regulated under the authority of sections 109 or 112, whereas section 111(d) standards cannot.] Such standards reflect the use of the best system of emission reduction (considering cost) which has been adequately demonstrated for the affected source. The level of control set by EPA need not be related directly to the adverse effects of the air pollutant. The standard setting process begins by listing in the FEDERAL REGISTER categories of sources for which the Agency intends to set standards of performance. Within 120 days after listing, standards for these sources must be proposed and public comments solicited. Within the next 90 days the Administrator must consider the public comments and promulgate the standards. Any new source which commences construction after the proposal of the standard must comply. To control existing sources emitting health-related pollutants under Section 111(d), the Agency proposes and promulgates emission guidelines that describe the degree of emission control achievable with best demonstrated control systems, considering costs. Also, proposed and promulgated is the time within which EPA believes that compliance with such emission guidelines can be achieved. Within 9 months after promulgation of the emission guidelines, the individual States must submit a plan for implementing emission standards for existing sources of the pollutant (in this case, vinyl chloride). After the plans are received, EPA 'ins 4 mirths to nr^rov' or d i r,,:r'",'e thr plans and, if COLOR!TE 008406 a State plan is unacceptable, two months more to promulgate EPA regulations. To be utoroved, State plans must contain emission standards at least as stringent as the EPA emission guideline. However, in cases where existing sources would incur severe economic hardship or would risk closure if forced to comply with the emission guidelines, less stringent State standards could be approved. Furthermore, a State could issue a variance allowing the source to continue operations without full compliance with a standard. As noted above, the use of section 111 would require the use of best demonstrated control technology, taking c^-t into account. The best available systems for controlling vinyl chloride emissions have been used within existing ethylene dichloride-vinyl chloride and polyvinyl chloride plants. Since those control systems appear to be economically feasible, emission standards reflecting the use of best available control technology would be required under section 111 and would achieve considerable emission reduction at both ethylene dichloridevinyl chloride and polyvinyl chloride plants. However, consideration of costs could result in lower levels of emission reduction being required at some individual existing plants. After very close examination, EPA concluded that section 111 is not the best mechanism for controlling vinyl chloride. Specifically, the length of time required under section 111(d), the possibility of differing levels of control from State to State, State-granted variances that may be based only on cost considerations, and standard development as a State rather than a Federal process were all features that made section 111 unacceptable for vinyl chloride. 2-13 COLOR!TE 008407 Standards under Section 11 ?--National Emission S-.otidariis for fiazardous Air Pollutants (NLSHAP) Section IIP was incorporated in tne Clean Air Act to control pollutants which, in the Administrator's judgment, may cause, or contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness. Emission standards should be set at levels that provide an ample margin of safety to protect the public health from the atmospheric emissions of the pollutant. Emission standards under section 112 apply to all new and existing sources of the pollutant. To set a standard under section 112, EPA must list vinyl chloride as a hazardous pollutant in the FEDERAL REGISTER. Within 180 days of the listing, the Administrator must propose a national emission standard which, in his judgment, adequately protects public health. Within 30 days, the Administrator must give notice of a public hearing to be held to examine his judgment that the pollutant is hazardous. Allowance must also be made for comments on the proposed standard from the public and scientific and industrial communities. The Administrator can withdraw a pollutant from the hazardous list only if he finds, on the basis of information presented at the public hearing, that the pollutant clearly is not hazardous. Otherwise, the Administrator must promulgate a standard within 180 days of the proposal. Section 112 does not require that in setting a standard the Administrator consider available control technology or economic impact. However, ERA must, from time to time, issue information on control technology. 2-H COLORITE 008408 """ 2.2.6.1 Vinyl Chloride as a Hazardous Pollutant In deciding whether section 112 would be an appropriate regulatory strategy for vinyl chloride, it had to be determined whether vinyl chloride meets the specifications of a hazardous air pollutant as defined in the Act. "Hazardous air pollutant" is defined in section 112 as "an air pollutant ... which in the judgment of the Administrator may cause, or contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness." Vinyl chloride appears to be such a hazardous air pollutant. As noted earlier in this chapter (section 2.2.1.1), data taken from animal experiments and occupational exposure studies have strongly indicated that vinyl chloride causes or contributes to angiosarcoma, other cancers, and noncarcinogenic disorders in people with occupational exposure and in animals with experimental exposure to vinyl chloride. Reasonable extrapolations from these findings cause concern that present ambient levels of vinyl chloride may cause or contribute to the same or similar disorders. Data obtained in the spring of 1974 from plants that produce or process vinyl chloride indicate that approximately 100 million kg of vinyl chloride are emitted to the atmosphere annually. The majority of these emissions are from ethylene dichloride-vinyl chloride and polyvinyl chloride plants. Approximately 4.6 million people live within a five mile radius of where these plants are 4 located. There are no dose-response data, and thus no absolute proof of adverse effects, at the concentrations of vinyl chloride found in the ambient air. However, for carcinogens there may be no atmospheric concentration which poses absolutely no public health risk. Also, 2-15 COLORITE 008409 data from studies of occupational exposure indicate that there is a latency period as long as 20 years between initial exposure to vinyl chloride and occurrence of disease. This latency period could possibly be longer for low levels of exposure. Production of polyvinyl chloride did not begin to operate on a large scale until relatively recently. Only about 10 of the approximately 40 polyvinyl chloride plants are 20 years old or older, and the oldest one is 40 years old. These considerations led to the conclusion that EPA should take action now to reduce exposure levels to vinyl chloride before retrospective evidence of risk is allowed to show itself. By taking steps now to reduce emissions, EPA will be able to reduce substantially the risk that severe illness and death will occur in the future as a result of present and prolonged community exposure to vinyl chloride. EPA's conclusions are supported by The Evaluation of Environmental Carcinogens which was completed on April 22, 1970, by the Ad Hoc Committee on the Evaluation of Low Levels of Environmental Chemical Carcinogens. The Ad Hoc Committee was formed in response to a request by the Deputy Assistant Secretary for Health and Scientific Affairs of the Department of Health, Education, and Welfare (HEW). The Committee was to review the problems relating to the evaluation of low levels of environmental chemical carcinogens, to consider the scientific bases on which such evaluations can be made, and to advise the Department of HEW on the implications of such evaluations. The report to HEW includes the 4 following conclusions and recommendations: 2-16 COLORITE 008410 (1) "Any substance which is shown conclusively to cause tumors in animals should be considered carcinogenic and therefore a potential cancer hazard for man." (2) "Because the latent period in human carcinogenesis is so long, epidemiologic evidence develops only over periods of 15 to 20 years. Timely decisions to exclude materials from uses involving exposure to man, therefore, must be based solely on adequately conducted animal bioassays. Retrospective human evidence of risk must not be allowed to show itself before controlling action is taken. Chemicals should be subjected to scientific scrutiny rather than gi'en individual rights; they must be ccnsidered potentially guilty unless and until proven innocent." (3) "No chemical substance should be assumed safe for human consumption without proper negative lifetime biological assays of adequate size. The minimum requirements for carcinogenesis bioassays should provide for adequate number of animals of at least two species and both sexes with adequate controls, subjected for their lifetime to the administration of a suitable dose range, including the highest tolerated dose, of the test material by rates of administration that include those by which man is exposed." (4) "No level of exposure to a chemical carcinogen should be considered toxicologically insignificant for man. For carcinogenic agents a safe level for man cannot be established by application of our present knowledge. The concept of 'socially acceptable risk' represents a more realistic notion." COLORITE 008411 Several court derisions also support rr'A's decision. In t'nvi ronmonl'jl L^frnso Fund_, I_n_c^ v. Luvj\rojwqntsJ_ Projection. Anrncy, 510 F.2d 1292 (D. C. Cir. 1975), which questioned the protection of the manufacture and sale of aldrin and dieldrin, Judge Lever.thal recognized (1) consideration of the long latency period in cancer, (2) the finding that the concept of threshold level has no practical significance for carcinogens, and (3) the extrapolation to humans from animal test data, as valid grounds for EPA's decision-making. See also Environmental Defense Fund, Inc, v. Ruckelshaus, 142 U. S. App. D. C. 74, 439 F. 2d 584 (1971) on animal test data. Furthermore, in the preamble to the October 1974 OSHA regulation for vinyl chloride, The Evaluation of Environmental Carcinogens was cited as partial support for the level of the standard. This regulation was upheld by the U. S. Court of Appeals for the Second Circuit in the case of Society of the Plastics Industry v. Occupational Safety and Hea1th Administration, 509 F. 2d 1309 (1975), cert, den, sub nom. Firestone Plastics Co. v. U_. S. Department of Labor, 43 U. S. L. W. 3623 (1975). In its decision, the Court of Appeals stated that much of OSHA's evidence for the regulation was based on animal exposure to vinyl chloride, with only indirect human evidence, but that ...nevertheless, it remains the duty of OSHA to protect the working man, and to act even in circumstances where existing methodology or research is deficient. The panel also stated that the evidence on vinyl chloride's dangers was "quite sufficient" to merit OSHA's regulations. 2.3 Setting an Emission Limit A coneur'-ent issue be Fore f f' A urns '..hat level of emission control could or '-hsulj he requir.-d e r mr;-; (1 '< S.i'iun ills o,'1',; s COLORITE 008412 o r\ J..iiriijti ,:tcc :.hall set an emission standard "at th: level vlinh in sis jud-yent provides an an,pie margin of safety to prelect the public health from such hazardous air pollutants." 1 he problem presented was how this provision should be interpreted when dealing with an apparent non-threshold pollutant that is hazardous at some level. The Item "non-threshold pollutant" refers to a substance which creates a risk of adverse health effects at all ambient levels (other than zero). An "apparent non-threshold pollutant" is, quite simply, a substance which, on the basis of available information, appears to be a non threshold pollutant. An apparent non-threshold pollutant may be known to be "hazardous" within the definition of section 112 at some levels, and create a risk to public health at all levels. Vinyl chloride is such a pollutant. It clearly causes angiosarcoma, other cancers, and noncarcinogenic disorders in animals which have been experimentally exposed to vinyl chloride and in people with occupational exposure. However, an emission standard for vinyl chloride cannot be established below a threshold level of effects because, as noted above, no doseresponse data are available for the concentrations of vinyl chloride found in the ambient air. Further, it is EPA's position that for a carcinogen it should be assumed, in the absence of strong evidence to the contrary, that there is no ambient concentration that poses absolutely no public health risk. The issue is how far the level of such pollutants should be reduced to provide "an ample margin of safety." 2.3.1 The Alternative of Prohibiting Vinyl Chloride Emissions EPA considered that sectionll2 might be interpreted to require a 2-19 COLORITE 008413 complete prohibi Mon of emissions of -ny apparent non - threshol d pollutant, hie zero {Mission 1 Mii tation would be Ihe onlv emission standard which id offer oh'oluto safety from ambient, exposure. Establishing zero f-c.ission limits would in effect ban domes tic vinyl chloride and polyvinyl chloride production because ethylene dichloride-vinyl chloride and polyvinyl chloride plants could not comply with zero emission limits using currently feasible control technology, 2.3.1.1 Direct Impact. The direct impact of banning vinyl chloride and polyvinyl chloride production would be on the producing companies and their employees and in the regions in which these companies are located. Twenty-eight companies would be directly impacted. Howeve--, the lack of detailed financial information for privately-held companies and of profit data about vinyl chloride and polyvinyl chloride output for publicly-held companies make an assessment of probable company failure difficult. For 27 companies, however, EPA approximated dependency on vinyl chloride and polyvinyl chloride production by comparing estimated vinyl chloride and polyvinyl chloride sales to total sales. In doing this, EPA recognized that the estimated percentage of vinyl chloride and polyvinyl chloride sales is not necessarily the same as the estimated percentage of profits. Based on sales information, three of the 27 companies are judged to be highly dependent upon vinyl chloride and polyvinyl chloride production. The three companies are all polyvinyl chloride fabricators as well as producers. Uith a ban on VM'yl chloride and polyvinyl chloride 'reduction, dll three would orubabiy fail. lrjr file . re fit.- 'M- wi, -,Me-- M..; m are un,,/a : 1 ..! M . COLORITE 008414  i ; i; M ( ' .'! it ;"i" x i bl e. irr; c ' 'tt'; cr r i x i col av'. therefore, huri e/; , r,j :i :>>. ,.e;j! : have effects on ompl')/;.ont. Direct ci.plo" i^tacts on a pc-t plant basis are imt. known, but estimates of total crplopment are available. According to these estimates, there are rwoxinately 94D people employed in vinyl chloride production and 9' ') people in polyvinyl chloride production. Thus, over 6500 people would los their jobs as a result of prohibiting vinyl chloride emissions. Although many skills used in vinyl chloride and polyvinyl chloride production are readily transferable to other industries, the extent that this transfer would occur is not known. At any rate, transfer would not be immediate. For ethylene dichloride-vinyl chloride plants, immediate regional impacts of a ban would be felt primarily in the areas of southeastern Texas and southern Louisiana where 14 of the 17 plants are located. In certain instances, vinyl chloride output goes to other regions as well. For polyvinyl chloride plants, the immediate impacts would be more dispersed geographically. Although some polyvinyl chloride plants are located in the southeastern Texas-southern Louisiana area, most are located in Delaware, New Jersey, New York, and Massachusetts. In all of these areas, multiplier impacts in terms of decreased output, unemployment, and lowered income could be expected. 2.3.1.2 Indirect Impacts The indirect impacts of prohibiting emissions (and thereby banning vinyl chloride and polyvinyl chloride production) would be felt 2-21 COLORITE 008415 primarily Ly rv.v material suppliers (ethylene dicalorida producers) and by product output receivers (polyvinyl chloride fabricators). There are 11 firms producing ethylene dichloride at 17 plants. About SO percent of their ethylene dichloride output goes to vinyl chloride and polyvinyl chloride plants. With one exception (Vulcan Materials), all companies also produce either vinyl chloride or polyvinyl chloride or both. Because much ethylene dichloride output appears captive, the impact of lost ethylene dichloride revenues has probably been counted in terms of lost vinyl chloride and polyvinyl chloride sales. Vulcan Materials would not be expected to fail in the event of a ban, because it does not rely heavily on ethylene dichloride sales. The Chemical Economics Handbook estimates the number of polyvinyl chloride fabricating plants to be 8,000.^ It is not known how many of the 8,000 are independent or how many are affiliated with larger com panies. The economic viability of the fabricator has not been analyzed. However, the more dependent these companies are upon vinyl chloride and polyvinyl chloride input, the more likely is the possibility of failure. There are no estimates of domestic ethylene dichloride employment and, therefore, no determination of potential impact. For polyvinyl chloride fabrication, total direct and indirect employment loss with no transfer of jobs or raw material substitutes is estimated by Arthur D. Little, Inc. to be 1.7 to 2.2 million jobs."7 This estimate includes not only persons employed by fabricating plants, but also persons employed in utilization of the fabricated products, such as auto and construction workers. The estimate amounts to over 1 percent of the 19/2 labor force. COLORITE 008416 !!( arly all ethylene dirhloride production occurs in southeastern rs Tovris . no southern l.ouisiana. Since most vinyl chloride production ocujrs here and soi.ie polyvinyl chloride production occurs here as well, this area could conceivably be hard hit. This is especially true if the affected resources could not be transferred to other uses in the area. Although no location maps for fabricating plants have been developed, the number of, and the wide variety of outputs from, polyvinyl chloride fabricators suggests no geographic concentration. If there are any clusters of plants, they are probably in metropolitan areas. 2.3.1.3 Substitutes for Polyvinyl Chloride According to one estimate, substitutes for polyvinyl chloride exist for approximately 85 percent (by weight) of present polyvinyl chloride uses.^ It is believed that prices of substitutes would generally be higher than polyvinyl chloride prices and would result in h-'gher consumer prices for finished goods. Industry representatives have indicated that, although known substitutes exist for most polyvinyl chloride uses, they do not feel that substitutes exist in sufficient quantities to fill immediately the void which would be created by banning vinyl chloride and polyvinyl chloride production. In effect, they say that there would not be sufficient substitutes for polyvinyl chloride products for approx imately two years.^ Even if substitutes for polyvinyl chloride were readily available, they would not necessarily have some of the desirable characteristics of polyvinyl chloride. For example, one of the desirable properties of polyvinyl chloride fabricated products is nonflammability; most of the proposed substitutes do not have this property and would require 2-23 COLOR!TE 008417 additional processing to achieve it. Furthermore, the potentially adverse health and environmental impacts from substitutes have not been thoroughly studied, and, therefore, it is not known whether they would pose an even greater environmental hazard than vinyl chloride. As an alternative to substitution, there exists the possibility of importing polyvinyl chloride resins for final fabrication by U. S. industry. Although the l). S. has imported very little polyvinyl chloride in the past [18 million kilograms (4 million pounds) in 1972], imports in 1973 increased significantly to 28.8 million kilograms (64 million pounds).^ Excess foreign polyvinyl chloride capacity remained. At the end of 1973, excess polyvinyl cnloride resin capacity outside the United States was about 1237.5 million kilograms per year. But there is no assurance that raw materials would be available so that foreign producers could operate at 100 percent capacity in the future. Nor would there be any assurance that U. S. polyvinyl chloride resin users would receive the additional supplies. 2.3.1.4 Conclusions Complete prohibition of all vinyl chloride emissions would require closure of vinyl chloride and polyvinyl chloride production because there is no technology to achieve a zero emission limitation and development of such technology is not foreseen. Banning production of vinyl chloride and polyvinyl chloride would have a negative impact on the .producing companies, especially on the three or four companies which according to EPA's evaluation are highly dependent on sales of 2-24 COLORITE 008418 vii.y 1 chloride and polyvinyl 'hlonV.- and micjht therefore be expected to foil 'f vinyl chloride and polyvinyl chloride production were banned. Tnere would be an even greater impact on unemployment at the approxi mately it,000 fabrication plants which depend at least partially on polyvinyl chloride as a raw material. This impact would persist i.nlass and until these plants could adapt their equipment to manufacturing substitutes. With regard to the consumer, there are substitutes for about 85 percent by weight of the uses of polyvinyl chloride, but these substitutes would generally not be available for at least two years, would generally be more expensive than polyvinyl chloride products, and would not necessarily have some of the desirable characteristics, such as nonflammability, of polyvinyl chloride. In view of (1) the beneficial uses of vinyl chloride products for which desirable substitutes are not readily available, (2) the potential adverse health and environmental impacts from substitutes which have not been thoroughly studied, (3) the number of employees (particularly in fabrication industries) who would become at least temporarily unemployed, and (4) the availability of control technology which is capable of substantially reducing emissions of vinyl chloride into the atmosphere, EPA concluded that setting zero emission limits would be neither desirable nor necessary. 2.3.2 The Alternative of Best Available Control Technology An alternative interpretation of section 112 is that it authorizes setting emission standards that require emission reduction to the lowest level achievable by use of the best available control technology in cases involving apparent non-threshold pollutants, where complete 2-25 COLORITE 008419 emission prohibition would result in widespread industry closure and EPA has determined that the cost of such closure would be grossly disproportionate to the benefits of removing the risk that would remain after imposition of the best available control technology. EPA recognizes that consideration of technology in standard setting is not explicitly provided for under section 112. Congress never discussed the particular problem associated with apparent non threshold pollutants. The Administrator, however, believes that Congress did not intend to impose the costs associated with complete emission prohibition in every case involving such a pollutant. The best available control technology approach will produce the most stringent regulation of hazardous air pollutants short of requiring a complete prohibition in all cases. This interpretation of section 112 has been adopted for vinyl chloride. This approach was used in the case of asbestos, but has never been judicially tested. The purpose of the proposed standard is thus to minimize risk to public health by establishing an emission standard which will reduce emissions to the level attainable with best available control systems. An emis sion standard based on best available control technology will result in different total emission levels and different ambient air concentrations at different plants due to variations in plant sizes and configurations. However, it will further the protection of public health by minimizing the health risks to the people living in the vicinity of these plants and to any additional people who are exposed as a result of new construction. 2-26 COLORITE 008420 2.4 Selection of Source Categories There are four source categories of vinyl chloride emissions: ethylene dichloride-vinyl chloride plants, polyvinyl chloride plants, polyvinyl chloride fabricating plants, and miscellaneous sources. In developing the proposed standard, EPA evaluated or is evaluating 9 all four sources. 2.4.1 Ethylene Dichloride-Vinyl Chloride Plants According to EPA estimates, 17 ethylene dichloride-vinyl chloride plants were responsible for about 11 million kg (24.2 million pounds) of vinyl chloride emissions in 1974. This constituted 11 percent of total emissions from all sources. (See Table 2-1.) These plants are second to polyvinyl chloride plants as being the largest source category of emissions. 2.4.2 Polyvinyl Chloride Plants There are about 41 existing polyvinyl chloride plants which are responsible for approximately 85 percent of the total nationwide emissions of vinyl chloride. In 1974, these emissions were 85 million kg (187 million pounds). (See Table 2-1.) Information on the source categories of vinyl chloride covered by the proposed standard, including polyvinyl chloride plants, is presented in more detail in the remainder of this document. 2.4.3 Polyvinyl Chloride Fabricating Plants There are about 8,000 polyvinyl chloride fabricating plants emitting (in 1974) approximately 0.6 million kq/yr (1.3 million Ib/yr) of vinyl chloride. (See Table 2-1.) A monitoring program conducted by EPA at five fabricating plants indicated that ambient concentrations 2-27 COLORITE 008421 Table 2-1 Estimated Vinyl Chloride Emissions in the U. S.-1974 Source Estimated Vinyl Chloride Emissions - 1974 Number of Plants _ (1,000 Kg/yr) ___ ______ Percent of Total Estimated Emissions ___ 1974 Ethylene DichlorideVinyl Chloride Plants 17 11,000 11 Polyvinyl Chloride Plants 41 85,000 85 Polyvinyl Chloride Fabricating Plants Miscellaneous Sources ^8,000 8 600 v3,000 1 3 Total 99,600 100 2-28 O COLORITE 008422 around the perimeter of these plants are almost negligible. At three of the plants, no vinyl chloride was detected, and, where it was found, the highest concentration was 6 parts per billion (ppb). According to an Arthur D. Little report,10 the major emphasis in 1974 on limiting vinyl chloride emissions at fabricating plants vias concentrated on reduction of vinyl chloride monomer content in plant air in order to minimize risk to plant workers. Manufacturers believed that the most practical way to limit emissions both inside and outside the plant was to reduce the monomer content in the incoming resin. As far as can be determined, all vinyl chloride emissions from the fabricating plants are due to residual vinyl chloride in the raw materials coming from the polyvinyl chloride plants. Consequently, vinyl chloride emissions from fabricating plants will be minimized indirectly as polyvinyl chloride plants, in response to the proposed standard, reduce vinyl chloride in these raw materials from as high as 1000 ppm to less than 10 ppm. For the foregoing reasons, EPA has concluded that no standard for fabricating plants is necessary at the present time. 2.4.4 Miscellaneous Sources of Vinyl Chloride For purposes of EPA action, sources of vinyl chloride emissions, other than ethylene dichloride-vinyl chloride plants, polyvinyl chloride plants, and polyvinyl chloride fabricating plants, are classified as miscellaneous sources. Of a number of miscellaneous sources of vinyl chloride emissions, two major categories have been identified. The first category includes those plants that use vinyl chloride as a chemical intermediate for the production of 1,1,1Trichloroethane (1,1,1-TCE) and 1,1,2-Trichloroethane (1,1,2-TCE) 2-29 COLORITE 008423 and for the production of other special chemicals, e.g. certain pesticides, including endrin. The percent of total emissions of vinyl chloride attributable to those plants is not known. Some emission controls have been reported by 1,1,1-TCE and 1,1,2-TCE production plants integrated with ethylene dichloride-vinyl chloride plants. The extent and effectiveness of these controls, however, is unknown at the present time. Of the two plants manufacturing special chemicals, one already vents gases to a thermal oxidizer; information on the emission controls of the other is not yet available. The second category of miscellaneous sources includes those plants that produce vinyl chloride as a by-product. Known to be in this category are three plants manufacturing ethylene amines from ethylene dichloride and one plant manufacturing ethylene imine from ethylene dichloride. An ADL study,^ however, notes the possibility that some industrial processes involving by-product vinyl chloride emissions have not been identified. Total emissions from the sources in this category are not known. Information on the use of emission controls was unavailable for two of the plants. Of the other two, one reported the burning of vinyl chloride in a flare tower as well as the current construction of an incineration facility with a scrubber. The remaining plant reported current construction for incineration as an interim control and plans for a solvent adsorption system as the permanent control. The reduction in vinyl chloride emissions that will be achieved by these controls is unknown. 2-30 COLORITE 008424 According to the EPA data, niscellaneous sources of vinyl chloride emissions accounted for about 3 percent of the total estimated 1974 enissions from all sources. (See Table 2-1.) EPA is continuing its research on vinyl chloride emissions from miscellaneous sources, although the proposed standard does not include these sources, there is a possibility that EPA will conclude that regulations for them should be proposed at a later date. 2.5 Conclusions Based on the findings of health studies (section 2.2.1.1), EPA has concluded that vinyi chloride, a carcinogen, i; a hazardous pollutant and that, as such, it must be regulated now. A careful study of regulatory options (section 2.2) indicated that section 112 of the Clean Air Act-National Emission Standards for hazardous Air Pollutants (NESHAP)-- is the most effective mechanism for regulating vinyl chloride. EPA determined that the use of best available control technology is the proper interpretation of section 112 for regulating an apparent non-threshold pollutant, such as vinyl chloride, where complete emission prohibition would result in widespread industry closure and where the Administrator has determined that the cost of such closure would be grossly disproportionate to the benefits to be achieved by completely prohibiting emissions. Based on data available on emission levels, process equipment, control technology, and costs of control technology, EPA concluded that the proposed standard should cover ethylene dichloride-vinyl chloride and polyvinyl chloride plants. As noted above, future action by EPA to control vinyl chloride emissions from miscellaneous sources may be found necessary. 2-31 COLOR!TE 008425 The proposed standard for polyvinyl chloride plants covers any plant where vinyl chloride alone or in combination with other materials is polymerized into polyvinyl chloride. Thus, the proposed standard includes plants which produce homopolymers in which vinyl chloride is the only polymerized constituent and/or copolymers, terpolymers, or any other polymers in which other raw materials in addition to vinyl chloride are polymerized. EPA considered exempting from the proposed standard plants (six of the approximately 41 existing plants) which produce a polymer in which vinyl chloride is less than 50 percent of the raw material polymerized. EPA decided not to exempt these plants from the proposed standard because the total vinyl chloride emissions from a plant are more a function of the total quantity of vinyl chloride processed in the plant than the percent vinyl chloride contained in the resin. Furthermore, available data indicate that the processing equipment in these six plants is the same as in the plants producing resins with higher percentages of vinyl chloride, so that the same control technology can be applied and separate standards are not required. Ethylene dichloride and vinyl chloride are typically produced at one plant. However, the proposed standard covers plants that produce one and not the other as well as plants that produce both. The definition of ethylene dichloride plants contained in the proposed standard limits the applicability of the proposed standard to the production of ethylene dichloride by oxychlorination of ethylene. Available data indicate that there are no vinyl chloride emissions from direct chlorination of ethylene. 2-32 COLORITE 008426 References 1. n re 1 '" i n ary A ss e_s_s me n_t_o_f _t h_e__E_rw_i ronmontal Problems Associated wiTn" Vinyl Chloride and RcVvvl n.y 1~ ChTo'ri de, Report 'on the Activities and' Finc!ing~s"of ~tne VinyT Ch 1 oridg Task Force, compiled by the Office ? ToxTcTiTbstan'c'esr Environtr-ental' Protection Agency, Washington, D. C., September 1974. 2. Sc^ntvric_and_J[echni_ca] Assessment Report on Vinyl Chloride and FoTyVlTyyTChioride, compiled by Office of Research and Development, Envfronmental Protection Agency, Washington, D. C., June 1975. 3. Preliminary Assessment of the Environmental Problems Associated with vTnyl~Chloride and Polyvinyl Chloride, ibid., p. 2. 4. Population Residing Near Plants Producing Vinyl Chloride, Prepared by the" Environmental Health Hazards Project--American Public Health Association for the Office of Toxic Substances--!!. S. Environmental Protection Agency, Washington, D. C., August 1^5. 5. Evaluation of Environmental Carcinogens. Report by Ad Hoc Committee on the Evaluation of Low Levels of Environmental Chemical Carcinogens to the Surgeon General, USPHS, HEW, Washington, D. C., April 22, 1974, pp. 1,8. 6. "Polyvinyl Chloride Resins," Chemical Economics Handbook, Stanford Research Institute, September 1973. 7. Cited from "Economic Impact of a Shutdown of the Polyvinyl Chloride Industry," a study done for the Society of the Plastics Industry, Inc. by Arthur D. Little, Inc., May 1974. 8. Calculated from Modern Plastics, January 1974. 9. Two studies by Arthur D. Little, Inc. (see footnotes 10 and 11) are currently being conducted for the U. S. Environmental Protection Agency. 10. Vinyl Chloride Monomer Emissions from the Polyvinyl Chloride Processing Industries, Draft Report to U. S, Environmental Protection Agency by Arthur D. little, Inc., May 1975. 11. Industrial Sources, Proccss, and Quantities of Vinyl Chloride Emissions in the U. S. Other Than Those Connected With The Manufacture of Vinyl Chloride or Polyvinyl Chloride, Draft Final Report to U. "S. Environmental Protection Agency"by Arthur D. Little, Inc., July 1975. 2-33 COLORITE 008427 3. THE ETHYLENE DICHLORIDE-VINYL CHLORIDE AND POLYVINYL CHLORIDE INDUSTRIES 3.1 GENERAL This chapter will discuss the production of vinyl chloride monomer and the associated industries, ethylene dichloride and polyvinyl chloride production. Ethylene dichloride is an important segment of the vinyl chloride monomer industry in that, in 1974, 92 percent of vinyl chloride monomer production capacity was based on the pyrolysis of etnylene dichloride. The other 8 percent was based on the addition of hydrogen chloride to acetylene. The 1974 production amounted to 2.6 billion kilograms of vinyl chloride. In 1975 polyvinyl chloride resins were produced by 23 companies at 41 plants by one or more of four processes--suspension, emulsion, bulk, and solution. Tables 3-1, 3-2, and 3-3 list the producing companies and indicate the locations and the capacities of the three industries discussed. Associated maps 3-1, 3-2, and 3-3 show the location of each of the plants. Table 3-4 shows the producers of each type of polyvinyl chloride resin. The near term (i.e. next 2 to 3 years) outlook for the vinyl chloride and polyvinyl chloride industry is uncertain. There has been a dramatic turnaround in the vital statistics of the total thermoplastic/thermoset sector of the plastics industry of which polyvinyl chloride is a part. In 1973 resin sales increased 12 percent over the 1972 level; production was up 10 percent. Future demand and capacity assumptions at that time yielded forecasts of improved operating rates and higher profits. However, 3-1 COLORITE 008428 at the end of 1974 , Society of Plastics Industry data revealed total resin production up 4 percent but sales were up only 1.7 percent. Such data are not consistent with projections of improved operating rates and higher profits. It is difficult to make an assessment of the near term vinyl chloride outlook with data specific to a much broader industry class. Chapter 7, Economic Impact, contains an in-depth look at the industry structure and projects the impact of various market influences on the industry. 3-2 COLOR!TE 008429 3.2 DESCRIPTION OF THE PROCESS The nurpose of this section is to Drovide a nrocess description and to identifv each source of emission in different tvnes of oolvvinvl chloride, vinyl chloride, and ethylene dichloride plants. The emission sources are described in terms of stream volumes and composition, In addition, a discussion of the cause of emission is presented. 3.2.1 Ethylene Dichloride-Vinyl Chloride Production Vinyl chloride is oroduced in the United States by two methods, which are distinguished by the starting materials. The first, accounting for 8 percent of the total vinyl chloride capacity is the acetylrse-hydrogen chloride method. The second method, accounting for 92 percent of the total, is the ethylene dichloride (dichloroethane) process. For a discussion of the chemical and physical properties of vinyl chloride, see Scientific and Technical Assessment Report of Vinyl Chloride and Polyvinyl Chloride, a document prepared by FPA's Office of Research and Development. 3.2.1.1 Acetylene-Hydrogen Chloride Process - Only two plants in the United States use this method of producing vinyl chloride which consists of the addition of hydrogen chloride to acetylene in a reactor. The acetylene path to vinyl chloride can be described as follows: CH i CH + HC3 CH2 - CHC1 The reaction is catalyzed in a large reactor by mercuric chloride on an activated carbon base at 85-141C (185-285F). Figure 3-1 shows a simplified flow diagram for the acetylene process. Vinyl chloride is produced in the reactor and purified in subsequent columns.^ The purification is accomplished by scrubbing with water or solvent to remove unreacted hydrogen chloride and acetylene. The vinyl chloride is transferred to storage and the material scrubbed from the process is incinerated or otherwise treated. As of August 1, 1975, neither of these plants were operating. 3-3 COLORITE 008430 Figure 3-] ACETYLENE PROCESS for VINYL CHLORIDE PRODUCTION & HCl VCM TO WASTE OR INCINERATOR _C2 CHLOROCARBONS TOV.'ER ( OPTIONAL) oo COLORITE 008431 j.2,1.2 Ethylene Dichloride Process The principal process currently used to produce vinyl chloride is dehydrochlorination (removal of hydrogen chloride) of dry ethylene dichloride. The ethylene dichloride path can be described as follows: CH2C1CH2C1 + CH2 = CHC1 + HC1 Typically, vinyl chloride producers will return the hydrogen chloride by-product of this process back to a system which makes more ethylene dichloride. This process is called the oxychlorination process and with vinyl chloride production via ethylene dichloride "cracking", the two are known as the balanced process (see figures 3-2 and 3-4). All nlants differ in their exact configurations but the process can be described generally as follows: Ethylene is directly chlorinated with chlorine in a catalytic reactor to produce ethylene dichloride. The material is transferred to a finishing column after being cooled by water and brine condensers. Noncondensable gases are separated in the finishing column and vented to the atmosphere after being scrubbed with water or aromatic solvent to recover ethylene dichloride and remove hydrogen chloride. The organic liquid product from the reactor is purified in a finishing column to produce pure ethylene dichloride. Impurities, including other chlorinated hydrocarbons, are sent to disposal.^ No emissions of vinyl chloride have been reported from the direct chlorination process. The ethylene dichloride is transferred to a cracking furnace operating at approximately 510C (950F), where vinyl chloride is produced. The furnace is packed with a catalyst such as pumice, or charcoal. The yield to vinyl 3-5 COLORITE 008432 Figure -J-2 FUGITIVE EMISSION (T) OXY VENT LIGHT ENDS VENT ' FINISHING COLUMN VENT 'PRODUCT VCM <J s COLORITE 008433 VINYL CHLORIDE BY THE BALANCED PROCESS O C dichloroethane ! Figure 3-3 blCHLOROETHANE CRACKING PROCESS FOR VINYL CHLORIDE PRODUCTION-7 TO STACK A LIGHT HYDROCARBONS HC1 ETC. VCM PRODUCT VCM STORAGE TRlCHLOROETHAfJE 5 I) EOC STORAGE V -5S- PERCHLOROETHYLENE COLOR!TE 008434 VAPORIZER PYROLYSIS FURNACE A QUENCH TOWER HCI TOWER LT. ENDS TOWER (OPTIONAL 1 ---------- VCM TOWER HEAVIES TO ------- WASTE OR INCINERATOR C2 CHLOROCARBONS TOWER (OPTIONAL) Figure The Oxychlorinati on Process--^ COLORITE 008435 Oo chloride is 94 to 97 percent. The hot effluent gases are quenched and partially condensed by direct contact with cold ethylene dichloride in a quench tower (see figure 3-3). The separation of hydrogen chloride and product Durification are Generally accomplished in additional operations described below. Each producer has minor modifications in this process, but typically the following would be included. Hydrogen chloride is recovered and recycled to an oxychlorination plant which chlorinates ethylene with the chlorine in the hydroqen chloride. Because of the entrainment of some vinyl chloride in the hydrogen chloride recycle process, and the generation of vinyl chloride in the process, some vinyl chloride emissions occur from the oxychlorination reactor. The ethylene dichloride produced from the oxychlorination Drocess is transferred to finishing columns for purification as described above in the direct chlorination step. As there is still some vinyl chloride in the system, some emissions of vinyl chloride occur from the ethylene dichloride finishing columns. The purified ethylene dichloride is used to producemore vinyl chloride in the cracking plant. Vinyl chloride is purified in finishing columns which vent some vinyl / chloride. The product is transferred to a product storage facility (usually large spheres) before shipment by nioeline or tank car. The ethylene dichloride and vinyl chloride finishing column vents are sometimes referred to in this document as the purification processes. Typically, the total vinyl chloride emissions from these vents are 0.29 kg/100 kg (lb VCM/100 lb VCM) produced. The oxychlorination vent has reported vinyl chloride emissions of 0.0364 kg/'lQQ kg (lb VCM/100 lb VCM) produced.^ 3-9 COLORITE 008436 t tiiyVdiVj di oninr>do - vinyl culcrida plants also have fugitive emissions >;,iich induce pump and valve emissions, transfer losses, inprocess wastewater losses, loading operation losses, and sample flask losses. There are special nroblems involved with using a riaterial balance to determine the fugitive loss of vinyl chloride from a vinyl chloride plant. The percentage fugitive loss from a vinyl chloride olant is smaller than the percentage fugitive loss from a polyvinyl chloride plant. For this reason it is necessary to measure all streams more carefully to determine the exact amount of fugitive emission. However, there are several qas streams into and out of these plants which are not measured as accurately as the liquid and solid streams into and out of a polyvinyl chloride nlant. These streams include the gaseous chlorine and ethylene feedstocks. For this reason material balance values for fugitive emissions from vinyl chloride plants are less -accurate than material balances values for fugitive emissions from polyvinyl chloride plants. The total fugitive emissions reported in table 3-10 were estimated by Q individual vinyl chloride operating companies in June of 1974.' These estimates are based on material balance or emission values (found in the literature) for various sources. 3.2.2 Polyvinyl Chloride Proauction Polyvinyl chloride is produced by four types of processes in the United States. Three of these are batch processes: suspension polymerization, which accounts for 78 percent of 1973 plant capacity; dispersion or emulsion polymerization accounting for 13 percent; and bulk (mass) polymerization vihich accounts for C percent. The solution or solvent ro 1 vwerization process is a continuous p: o.tsr, used tv on-_- - anv and accounts, for 3 percent of United States f'o 1 v. :nyT .s'; loriJe caoaedv. o O COLORITE 008437 3.2.2.1 Suspension Polymerization Figure 3-5 presents a simplifies flow diagram for the suspension V process. This is bv far the most common process used to manufacture oolyvinvl chloride resins (78 percent of the total U. S. capacity). The nrocess involves the mixinn of a weighed amount of vinvl chloride in a metered amount of water, catalyst and suspending agents. The ingredients are mixed in a clean, alass or stainless steel lined, reactor. A steam jet or vacuum pump is used to remove some of the air filling the reactor. The amount of air left depends on the absolute pressure after evacuation. The reactor is jacketed to provide steam heat or water cooling as necessary to control the reaction which takes place. The catalyst initiates the reaction and the suspending agent is used to keep vinyl chloride droplets small and dispersed. Agitation is supplied to the "slurrv" beino formed in the reactor bv an aqitator located in the bottom of. the vessel. The polymerization reaction continues in the slurry dronlets to 85 to 90 percent completion which requires approximately six hours. The 10 to 15 percent unreacted vinyl chloride is present in the vapor space of the reactor, is dissolved in the water, or is dissolved (or trapped in) the polyvinyl granule itself. The reactors are generally 11,340 to 22,680 liters (3000 to 6000 gallon) kettles and the typical plant may have from 12 to 18 reactors. Reactors built within the last three years in new plants are generally much larger (56,660 to 103,200 liters or 15,000 to 35,000 gallons) and fewer in number (4 to 8) than the older existing reactors. Some of the unreacted vinyl chloride in the reactor is removed from the batch by vacuum and transferred to a monomer recovery system consisting of compressors and condensers. The vinvl chloride is recovered to a holdina tank for recycling. Noncondensable oases ( such as the reactor air described above) accumulate in the recovery system and must be vented. The ventinq 3-11 COLORITE 008438 Hgure ! h POLYVINYL CHLORIDE PLANT SUSPENSION PROCESS-^' oo COLORITE 008439 may be manual or automatic and periodic or continuous deoendina on the sv^te1 d-sim and pressure, '-'ith the vent"no of these nases, some vinvl chloride h released. This is referred to as Source Area D in ficure 3-5 (Suspension Flow Diagram) and in table 3-6 (Sunmarv of Emissions), Eacli reactor is eouinned with a "manhole", which is a hatch allowinq entry into the vessel. The entry is necessary to clean the scale that is left on the walls of the reactors after the slurry batch has been transferred (usually pumped to another holding tank). The scale must be removed to insure the ouality of the resin subseouently produced will be maintained. The removal is done by hi ah pressure water SDray, bv personnel who enter the vessel and chip the scale away, or bv a combination of these two methods. When the hatch is opened the monomer which has not been removed bv the vacuum recovery system and which is still in the gas phase is released by purging the reactor with steam or air. This is referred to as the "Reactor Opening Loss" and is Source Area B in table 3-6 and figure 3-5. The cleaning of the reactors typically takes place every two to six batches (one to three days) for about three hours. The completion of this cleaning and the closing of the reactor marks the completion of the reactor cycle. The polymerization of vinyl chloride usually takes place at a pressure of about 5.1 to 6.8 atmospheres and the polyvinyl chloride reactors are protected from overpressure and catastrophic rupture by safety valves or a combination of rupture discs and safety valves. Because of eauipment failure, power failure, or operator error, run-away reactions .occasionally occur in the reactors. These excursions are generally stopped by releasing the pressure and venting to stacks by either automatic pressure relief valves or manual venting. The reason for the ventinq is to protect the vessel from overpressure. This vent contains a large amount and a high 3-13 COLORITE 008440 con _e!ilrutio;i of vinyl rhlorido (tvr i<~al 1 v 22.'r' to nr o f,0 lasts 5 to Ir : inLitr-;. .`mrty-six "lent; >'enort r itsicn Jactrrs of n.04-0.4Q kq/lOOkg (lb/100 lbs) of PVC produced from this source.1 Source Area B in fioure 3-5 and table 3-6 describes this emission. From the reactor, the batch can be transferred into a second vessel for further processing. In several plants, the slurry leaving the reactor is outrned to a stripoer. A stripper is a kettle similar to the reactor in which vinyl chloride is "stripped" from the slurry by applying heat and/or vacuum to the reactor contents for a period of time. Some plants perform this step in the reactor, but most producers do not wish to "tie uo" the reactors with the time consuming process (1-4 hours) since it can reduce the production rate. Heat is applied by steam jacketing or by direct introduction of steam into the slurry. The vent gases from the stripper are transferred to the monomer recovery system as described above. In some plants, the stripper is opened to the atmosphere following the vacuum step of stripping in order to vent the vessel and transfer the batch to a tank where the various batches can be blended (the slurry blend tank). This results in some vinyl chloride emissions. In other plants the vinyl chloride which was stripped from the polymer is released to the atmosphere. Seventeen plants reported vinyl chloride emissions associated with the stripping operation varied between zero and 0.5 kg/100 kg (lbs/100 lbs) of PVC produced.2 Source Area C describes this emission point on figure 3-5 and table 3-6. When stripping is complete, the batch is transferred to the slurry blend tanks where various batches are blended together to form a more uniform product. These large tanks (which typically hold three to four batches) are generally open to too atmosphere. As the slurry is mixed, residual o'cnomer in the slurry is rr-1 eased. This sis:ion (Scarce Ai an C) varies ,.idci v from O o COLORITE 008441 plant to plant depending on the effectiveness of stripping. Thirty plants reported losses of between 0.01 and 0.7 kg/100 kg (lbs/100 lbs) of PVC 3 produced (see table 3-5 and figure 3-5.) From the blend tank the slurry is usually pumped to a centrifuge where as much water as possible is removed (source Area F). Emissions of vinyl chloride can take place from the centrifuge casing. The water is generally transferred to a treatment area before being disposed of or recycled (see section 4-10 of chapter 4). Vinyl chloride emissions occur from this water and water from other sources within the plant., e.g., reactor cleaning, floor cleaning, etc. It is reported that the concentration of vinyl chloride '-'onomer from typical suspension polyvinyl chloride plant water streams before treatment ranges from less than 1 ppm to nearly 2000 ppm."*"' Tne wet polyvinyl chloride cake from the centrifuge is dropped to a hot air dryer, usually a rotary dryer, where the remaining water is removed. In the dryer most of the vinyl chloride remaining in the resin is released. This vinyl chloride is exhausted from the dryer baghouses or cyclones and is represented by Source Area 6 in table 3-5 and figure 3-5. The dried, solid, polyvinyl chloride particles (resin) are collected by bag collectors or cyclones. From this point the resin is transferred to storage or bagging areas (Source Area 6). The residual vinyl chloride monomer in the resin is released in all sources downstream of the stripping operation. These sources are the slurry blend tanks, centrifuges, dryers, and the bulk polyvinyl chloride resin storage areas. The sum of the emissions from all these sources is due entirely to the vinyl chloride content of the polyvinyl chloride resin leaving the strippers. The dryers, storage bins and silos, bulkloading operations, bagging machines and resin transfer operations are all potential sources of particulate polyvinyl chloride emissions. When the product resin is transferred by air to any of the 3-15 COLORITE 008442 shove areas, its separation from ' ho currier sir si.re.am, e. rt<_: a source of particulate emis i ns. Finally, there are emissions which are unaccounted for in all crhtr source estimates. These losses are called fugitive emissions and are the most difficult to quantify. Fugitive emissions as discussed here include emissions from (1) the loading, unloading, sampling and storage of vinyl chloride, (Source Area A) (2) pumps, compressor, and agitator seals, (3) pipe and equipment flanges and manhole cover seals, (4) the opening of equipment for inspection and maintenance, (5) leaking pressure relief valves, (6) sampling for laboratory analysis, (7) vinyl chloride dissolved in process water exposed to the atmosphere, and (8) manual venting of equipment. The data presently available do not permit an estimate to be made of the magnitude of the vinyl chloride emission attributable to most of these categories individually. Emissions from source area 4 are estimated and presented in Tables 4-8 and 4-9 . Emissions from source area 7 are detailed in table 3-11. The fugitive emission factor reported in table 3-11 was determined by averaging individual operating company data from June of 1974.^ The specific emission factors given in tables 4-8 and 4-9 were derived from data given to EPA in telephone conversations. Table 3-11 was given to EPA in a plant visit. An instantaneous value for the magnitude of the fugitive emissions at any one time is virtually impossible to determine. Average values over a period of time can most accurately be determined by conducting material balances. In a polyvinyl chloride plant, if the amount of vinyl chloride in the product is deducted from the amount of vinyl cnloride fed, the difference will be the total gas and solid loss from the system. Seme amc.wit of this total loss can be measured accurate!''/. Piste polvvinyl cs hjr idc- solid can be collected and weighed and the vinyl l'iici He in hie yn, streams to the a,-,'osphci'c and the waste COLORITE 008443 uacer streams can be measured. If the known (or accountable) loss is deducted ^rcm tiie total loss, the difference is the fugitive (or unaccountable) loss. While it is possible that appreciable amounts of the losses reported here represent solid losses, solid loss is more easily detected and measured than vinyl chloride loss. Most polyvinyl chloride producers assume that the unaccounted for loss in polyvinyl chloride plants consists primarily of vinyl chloride vapor emitted tc the atmosphere. The use of material balance to determine fugitive losses has several dis advantages. The accuracy of the loss determination depends on the accuracy of the measurements made. If the vinyl chloride raw material and the polyvinyl chloride product are weighed with an accuracy of +_ 1/2 percent then the calculated fugitive loss may be as much as 1 percent high or 1 percent low (the loss would be 1 percent higher than actual if the raw material measurement were 1/2 percent higher than actual and the product measurement were 1/2 percent lower than actual). An accuracy of 1/2 percent is about the best that can be expected using existing measurement techniques. Over a period of time high and low readings tend to balance each other, and the accuracy of loss determination increases as the time period over which the balance is made and as the number of readings increases. It is therefore difficult to make accurate balances over short periods. As an example, if an operational upset in a polyvinyl chloride plant causes an instantaneous emission of two thousand pounds of vinyl chloride it would not be possible to determine the time of the emission or the amount of the emission using this method. There is also an accounting problem associated with using material balances to determine loss. All waste polyvinyl chloride must be collected and weighed accurately and the vinyl chloride and polyvinyl chloride in all vents from the plant must be determined. sj 3-17 COLORITE 008444 T!'e t r. * 1 fugitive ooiscf.r,: 'V ported in table;;-].. >-o batcriincJ 5 ay individuci po i /vinyl cnloride operating companies in Jana ot lv74. Because these emissions were determined using different procedures they are not all exactly comparable. In many cases the material balances were based on engineering estimates because the necessary plant data had not been collected. In those plants where the major emission sources had been identified and measured, the reported unaccountable loss would be less than in those plants where these sources had not been measured. Some plants that had not measured the amount of scrap polyvinyl chloride produced estimated the amount. Not all polyvinyl chloride plants weigh all vinyl chloride cars into and out of the plant. Some plants receive vinyl chloride by pipe line and the amount received is calculated by tank level or integrated flow measurements. Other polyvinyl chloride plants weigh all vinyl chloride received but operate several processes from one vinyl chloride storage area. Although the total amount of vinyl chloride used can be determined accurately the amount used by each process can only be estimated. This limitation is important in plants which produce two types of resin (dispersion and suspension, for instance). The storage area may be common to the tv/o plants and accurate data on the monomer received by each plant is difficult to obtain. The production of polyvinyl chloride conolymers, which are polymers derived from two monomers such as vinyl chloride and vinvl acetate, differs from polyvinyl chloride homopolymer production in two respects. At least one producer by-passes the recovery system in vinyl acetate-vinyl chloride copolymer production because the vinyl acetate can form acetic acid in the system and caime corrosion problems. Otner producers recycle both back to the process. One producer indicates that stripping is more difficult, in copolymer production. COLORITE 008445 ^ ^ 3.2.7.3 z ; r L i cn n0] vi. - A sitin'] ifiec flow rii anrar: for a "vrvjcal disoersion vmerization olent is "resented in figure 3-6, This process is basical ! y verv sirilar to the suspension process in that the batch reactor processes liouid vinyl chloride dispersed in a water svstem. The difference is that more soap is added tc the slurry to stabilize the monomer drool ets and form agqlomerates. Emulsion resins can be polvmerized at lov/er temperatures and faster than suspension resins. The equipment used to produce emulsion resins is almost identical to suspension resin equipment. Emulsion resins are more sensitive to heat and shear stresses than susDension resins and the resin particle if subjected to heat and shear may be changed in ways that make it unsuitable for use. The main eauipment difference between the two resins is the tyoe dryer used. Since the particle sizes obtained by dispersion polymerization are much smaller than those obtained by susoensiori, spray dryers, which ensure the maintenance of the small particle size, are aenerallv used. These dryers have much higher air volumes than the rotary, flash and fluidized bed dryers used for suspension resin production. Latex resins are produced by the disoersion process. The production of these resins is similar to dispersion resins except that more soaD is added to the recipe and the product is sold without drying. Emissions from the sources within the dispersion nlant are outlined in table 3-7 which lists all sources within the Diant and characterizes emissions on a ka/100 kg (lb VCM/100 lb) PVC produced basis. 3.2.2.3 Bulk Polymerization - A bulk process flow sheet is shown in figure 3-7. The process consists of making "seed" polyvinyl chlotide from liquid vinyl chloride in a reactor sirilar to that described in the suspension process. Conversion of vinyl 3-19 COLORITE 008446 c Figure 3-7 FLOW SHEET FOR POLY VINYL CHLORIDE BULK PROCESS^7 ch 1 orif-'G ic. cclyvinyl chloride is only 7 to 12 percent. The suspension of rolyyiv/i l i, I u r , d c in vinvl chloride liquid is then transferred to a larger reactor, horizontal as oooosed to the vertical susoension resin reactors, along with more liquid vinvl chloride and more initiator. The agitator is much more rugged and the agitation is harsher. The polymerization is carried out to 85-90 percent comoletion with steam/water jacketing controlli the temDerature. As with suspension resins, the remaining monomer is removed by vacuum to be returned to storaae via the recovery system. As there is no water or water vaDor involved, however, it is possible to use very low temperature condensers in the recovery system (-35C or -31F as onposed to 7C or 44.6F in suspension and dispersion recovery). The second reactor,- called a post polymerization or pooo reactor, must be cleaned after every batch. The first reactor, called a prepolymerization or orepo vessel, does not require cleaning as frequently. Since there is no water in this nrocess, there are no drver or inprocess wastewater emissions of vinyl chloride. However emissions equivalent to emissions from the dryer in suspension and dispersion processes take place in all operations "downstream" of the podo reactors including pneumatic transfer, screeners, and bulk storage. Emissions are described in table 3-8. 3.2.2.4 Solvent Polymerization - Only one comoany manufactures polyvinyl chloride bv the solvent process in this country. Most resins produced bv this process are copolymers of polyvinyl chloride (75-90 percent) and polyvinyl acetate (10-25 percent). The basic process as shown in figure 3-8 consists of a mixture of the solvent, most generally n-buta.ne, and the comonomers, vinyl chloride and vinyl acetate. COLORITE 008448 Figure 3-8 9 A t A 1. VCM , TOR AG A POLYVINYL CHLORIDE QB SOLVENT PROCESS 4/ --SJ- SOLVENT 1 .MAKE-UP, A REACTOR MIXED SOLVENT & MONO MERj CO MONOMERv INITIATORS I 6 A GRINDER tI h .A. oo RECEIVING t* % () f CONT\_ ^FILTER/ L_ FLASH EVAPORATOR SCREEN SCREEN ----,| TI 0\J G\J IR% IINI | D\ / ER OR SCRA Hi M STORAGE STORAGE O o SILO SILO oo VO - - V BAGGING a SHIPPING ? BAGGING a SHIPPING being charge^ continuously to a reactor alone with the appropriate amount of ^ initiator. Slurry is continuous"! v drawn off and the oolvvinvl chloride filtered from the slurry. The filter cake is dried by flash evaporation and the recovered monomers and solvent returned to the system. The polyvinyl chloride resin is remarkably pure as no emulsifier or suspending agents are reouired. The cost is higher than other processes and so is limited to those products that justify a higher cost. Because the process is continuous, emissions from the reactor area are relatively low. There are indications that the resin is easily stripped of vinyl chloride and thus downstream emissions are kept low also. Emissions are described in table 3-9. 3.2.3 Summary This section has described the emissions from nine (9) major vinyl chloride sources within polyvinyl chloride plants. The magnitude of the emissions are dependent upon the size and age of the plant and the tvoe of resin which is produced. These nine sources are as follows: a) Fugitive emissions. The fugitive emissions can be broken down into seven major areas discussed in the text. b) Reactor opening loss c) Stripper losses d) Monomer recovery system e) Slurry blend tanks f) Centrifuges a) Dryers h) Bagging 3nd bulk resin storage areas i) Safetv relief valve discharges from reactors -i - ' O COLORITE 008450 Tables 3-6 through 3-9 have summarized the pen's? iuns from the f.,ur n.ahj, tvoC'S of resin nrocesses. Those figures were derived by averaging emission factors aiven bv individual nolvvinvl chloride rrooucers in resnonse to a May 30, 1974, reauest for information made by the Office of Air Duality Planning and Standards under authority of Section 114 of the Clean Air Act. Also, the four major sources within vinyl chloride plants were discussed. These sources are: a) Fugitive emissions b) Ethylene dichloride purification c) Vinyl chloride purification d) Oxychlorination vents The emissions from these sources are summarized in table 3-9 of this chapter. Not included in this study are the emissions from polyvinyl chloride compounders and fabricators, which account for less than one half of one percent of the national vinyl chloride emissions. Reference 10 gives a complete description of these two industries and their emissions. Also not included are miscellaneous sources such as aerosols, pesticides, other processes which use vinyl chloride as a chemical intermediate, processes which produce vinyl chloride as a by-product, and transfer operation of vinyl chloride outside of ethylene dichloride - vinyl chloride or polyvinyl chloride pi ants. 3-23 COLOR!TE 008451 References for Description of the Process 1. Thirty-six plants reported this emission (generally known as the reactor safety valve release) riurina sonnn, 1974 in response to a request for information under section 114 of the 1970 Clean Air Act. See Ref. 4. 2. Seventeen plants reported this emission which is termed the "stripoer loss" durina soring, 1974 in response to a renuest for information under section 114 of the 1970 Clean Air Act. See Ref. 4. 3. All reporting suspension, dispersion, and solution producers reported this emission (thirty-nine plants in total) during spring, 1974 in response to a request for information under section 114 of the 1970 Clean Air Act. See Ref. 4. The emission point is usually called the slurry blend tank loss. 4. Complied from "In-depth Study of Polyvinyl Chloride Production", draft document prepared for the Environmental Protection Agency bv Houdrv Division of Air Products and Chemicals, December 6, 1974. 5. All producers reported this emission known as fugitive or unaccounted losses during soring, 1974 in response to a request for information under section 114 of the 1970 Clean Air Act. 6. "In-depth Study of Vinyl Chloride Production," draft document prepared for the Environmental Protection Agency by Houdrv Division of Air Products and Chemicals, December 1974. 7. "Engineering and Cost Study of Air Pollution Control for the Petrochemical Industry Volume 3: Ethylene Dichloride Manufacture by Oxychlorination," prepared for the Environmental Protection Agency by Houdry Division of Air Products and Chemicals, November 1974. 8. Reference 6. 9. Reference 6. 3-?r. COLORITE 008452 "Vinyl Chloride Munc!"-.. r Ln.i ,s1 o" Industries," prepared for the Li. From the Polyvinyl Chloride Processing environmental Protection Agency by A. D. Little, Inc., May, 1975. 11. Farmer, Jack R. end Goodwin, Don R., Trip Note, "Goodrich, Henry, Illinois Plant Inspection," April 8, 1975. 12. Telephone conversation with Mr. Jim Mullins, Senior Engineer, Shell Oil Company, April 8, 1975. 13. Telephone conversation with Mr. John Barr, Technical Manager, Air Products and Chemicals, April 9, 1975. 14. McGraw Hill Publish Company, Modern Plastic Pvcenber, 1974, p. 18. I vJ t 3-27 COLORITE 008453 'i i Table 3-1 Produc injj Companies, Plant Lorat ions . nno Cancel tics - Ethylene Pi chloride Producim Company Allied Chemical Co. B. F. Goodrich Co. Continental Oil Co. Diamond Shamrock Corp. Plant Location Baton Rouge, Louisiana Calvert City, Kentucky Lake Charles, Louisiana Deer Park, Texas December, 1974 Capacity (Millions of Kiloqrams/Year) 295 455 455 120 Dow Chemical Co. Freeport, Texas Oyster Creek, Texas Plaquemine, Louisiana 590 500 525 Ethyl Corp. Baton Rouge, Louisiana Houston, Texas 250 120 Pittsburgh Plate Glass Co. Guayanilla, Puerto Rico Lake Charles, Louisiana 380 455 Shell Oil Co. Deer Park, Texas Norco, La. 545 530 Stauffer Chemical Co. Long Beach, California 135 Union Carbide Corp. Taft, Louisiana Texas City, Texas 70 70 Vulcan Geismar, Louisiana 110 TOTAL ~3oB SOURCE: Chemical Economics Handbook, Stanford Research Institute, Menlo Park, California, February, 1S75, pp. 648.5052Q-648.50531 . 3-1 COLORITE 008454 MAP 3-1 ETHYLENE DICHLORIDE PLANT LOCATION -- 3 COLORITE 008455 * H3 Table 3-2 Producire Companies , Plant Locations, and Capacities - Yirr'l Chloride Producing Company Plant Location June, 1S74 Capacity (Millions of Ki lograms/Year) Allied Chemical Corp. Geismar, Louisiana 155 B. F. Goodrich Co. Calvert City, Kentucky 455 Continental Oil Co. Westlake, Louisiana 330 Dow Chemical Co. Freeport, Texas Oyster Creek, Texas Plaquemine, Louisiana 80 320 155 Ethyl Corp. Baton Rouge, Louisiana Houston, Texas 120 70 Monochem, Inc.* Geismar, Louisiana 135 Pittsburah Plate Glass Co. Guayanilla, Puerto Rico Lake Charles, Louisiana 225 135 Shell Oil Co. Deer Park, Texas Norco, Louisiana 410 320 Stauffer Chemical Co. Long Beach, California 75 Tenneco, Inc.* Houston, Texas 115 TOTAL 3,100 SOURCES: Phone conversation with Chemical Marketing Reporter, June, 1974, and non-confidential data supplied by industry under Section 114 of the Clean Air Act. *Vinyl chloride is produced at these plants by the addition of hydrogen chloride to acetylene. COLORITE 008456 c riAP 3-2 VCM PLANT LOCATIONS -- A ' TF\\T Table 3-3 Producine Coinponies, Plant Locations, and Capacities - PVCRysins Producing Comoany Plant Location May, 1975 Capacity (Millions of Lilograms/Year) Air Products, Inc. Calvert City, Kentucky Pensacola, Florida 60 35 B, F. Goodrich Co. Avon Lake, Ohio Henry, Illinois Long Beach, California Louisville, Kentucky Pedricktown, New Jersey 120 100 50 65 65 Borden, Inc. Illiopolis, Illinois Leominster, Massachusetts 65 80 Continental Oil Co. Aberdeen, Mississippi Oklahoma City, Oklahoma 120 100 Diamond Shamrock Corp. Delaware City, Delaware Deer Park, Texas 45 125 Dow Chemical Co. Midland, Michigan 45 Ethyl Corp. Firestone Tire Co. General Tire CoJ Baton Rouge, Louisiana Perryville, Maryland Pottstown, Pennsylvania Ashtabula, Ohio 80 105 75 55 Georgia-Pacific Corp. Goodyear Tire Co. Plaquemine, Louisiana Niagara Falls, New York Plaquemine, Louisiana 100 45 50 Great American Chemi cal Corp. Jennat Corporation^ iteysor-tentury Corp. 2 Monsanto Co. Fitchburg, Massachusetts Torrance, California Tucker, Georgia Somerset, New Jersey Saugus, California Sprinqfield, MassachuseLts 30 2 3 2 15 30 COLOR!TE 008458 Table 3-3 (Con't) Producing Companies, Plant Locations, and Capacities - PVC Resins Producing Company Plant Location May, 1975 Capacity (Millions of Kiloqrams/Year) Occidental Petroleum Corp. Burlington, flew Jersey Hicksville, New York 75 7 Pantasote Co. Passaic, New Jersey , Point Pleasant, W. Va. 25 45 Robintech, Inc. 3 Shintech, Inc. Painesvilie, Ohio Freeport, Texas 115 100 Stauffer Chemical Co. Delaware City, Delaware Long Beach, California 80 70 Tenneco Chemicals, Inc. ' Burlinaton, New Jersey Flemington, New Jersey Pasadena, Texas 75 30 no Union Carbide Corp. South Charleston, W. Va. Texas City, Texas 25 135 Uni royal, Inc. Painesville, Ohio 50 TOTAL 2,609 NOTES: Pantasote's Point Pleasant, West Virginia plant is 50" owned by ?General Tire Company ^Due to close in 1975 JJoint venture of Robintech and Shin-etsu Chemical Co. of Tokyo ^Wholly owned subsidiary of Union Carbide Corporation SOURCES: 1) Chemical Marketing Reporter, May 20, 1974. 2) Mo~dern~Plastics, January, 1975, p. 58. 3) Non-confTdenti"a~l data supplied by industry under Section 114 of the Clean Air Act. 3-33 COLORITE 008459 MAP -3 tTT'r- Table 3-4 /"V PVC Producers by Prcce' 5 SUSP EMUL BULK SOLN Air Products B. F. Goodrich Borden Yes No No No Yes Yes Yes No Yes No No No Continental Oil Diamond Shamrock Yes No No No Yes Yes No No Dow Chemical Ethyl Corporation Firestone General Tire Georgia-Pacific Goodyear Great American Chemical Keysor-Century Monsanto Occidental Petroleum Pantasote Co. Robintech Inc. Shintech Stauffer Chemical Co. Tenneco Chemicals Inc. No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No No No No No Yes No No No No Yes Yes No No r11-sc No No No No No No No Yes No No No No No No No Yes No No No No No No No No No No No 3-35 COLORITE 008461 Union Carbide Uniroyal Inc. Table 3-4 (Con't) PVC Producers by Process SUSP EMUL Yes Yes Yes Yes BULK Yes No SOLN Yes No NOTE: N.A. = not available SOURCE: Non confidential data supplied by industry under Section 114 of the Clean Air Act. 3-3C COLORITE 008462 Table 3-5 VINYL CHLORIDE EMISSIONS Ff.R ETHYLENTTflCHLORIDE-VTilYL CT/RIDE Source Fugitive EDC Finishing Column VCM Finishing Column Oxychlorination Process Process Water TOTAL VCM Emissions kg/100 kg (lb VCM/100 lb) VCM .1215 .05 .24 .0364 .0007 .4479 J-J7 COLOR!TE 008463 Table 3-5 VINYL CHLORI_DE_EMISS_Ip;JS_ FOR_SUSPENSION POLYVINYL CHLORIDE PROCESS _____ Source______________ Fugitive Emissions Reactor Opening Loss Stripper Loss Monomer Recovery Vent Slurry Blend Tank Centrifuge Vent Dryer Exhaust Silo Storage Bagger Area Bulk Loading Operations Reactor Safety Valve Vents Process Water TOTAL Stream 1.D. on Simplified Flow Diagram 4-1 B C D E F G G G G B VCM Emissions kg/100 kg (lb VCM/100 lb) PVC 1.50 0.14 0.32 0.48 0.42 0.13 0.70 ' 0.20 .025 3.92 /' P---. 3-33 COLORITE 008464 VINYL_CMLORiDC EMISSIONS FOR DISPERSION POLYVINYL CHLORIDE PROCESS Source Fugitive Emissions Reactor Openinq Loss Stripper Loss Monomer Recovery Vent Slurry Blend Tank Dryer Exhaust Silo Storage Bagger Area Bulk Loading Operations Reactor Safety Valve Vents Process Water TOTAL Stream I.D. Qn Simplified Flow Diagram 4-2 B C D E G G G G B VCM Emissions kg/100 kg (lb VCM/100 lb) PVC 1.13 0.15 1.23 0.50 0.34 2.41 0.22 .025 6.01 3-39 COLORITE 008465 Table 3-8 VINYL CHLORIDE EMISSIONS FOR BULK POLYVINYL CHLORIDE POLYMERIZATION __ _______ Source________ _____ Fugitive Emissions Reactor Opening Loss Monomer Recovery Vent Reactor Safety Valve Vents Silo Storage Bagger Area Bulk Loading Operations Process Water TOTAL Stream I.D. on Simplified VCM Emissions kg/100 kg Flow Diagram 4-3________ (lb VCM/100 lb) PVC 0.43 B 0.08 D 1 .50 B 0.10 G G 0.23 G .011 2f:-4Q_ 3-40 COLORITE 008466 Table 3-9 VINYL CHLORIDE EMISSIONS FOR SOLVENT POLYVINYlT CHLORIDE POLYMERIZATION Source Fugitive Emissions Reactor Openinn Loss Stripper Loss Monomer Recovery Vent Dryer Exhaust Silo Storage Bagger Area Bulk Loading Operations Reactor Safety Valve Vents Process Water TOTAL Stream I.D. on Simplified Flow Diaqram 4-4 B C D G G G G B VCM Emissions kg/100 kg (lb VCM/100 lb) PVC 0.03 0.50 \ 0.05 0.31 0.83 0.06 Q,002 1 .78 H 3-41 COLORITE 008467 Table 3-U orSUMMER/ FUGITIV E_EMISSIORS ]~ Company PI ant Process A A'l Suspension B B-l Suspension B-2 Suspension C C-l Suspension C-2 Suspension C-3 Suspension C-4 Suspension C-5 Suspension D D-l Suspension E E-l Suspension F F-l Suspension F-2 Suspension G G-l Suspension G-2 Suspension H H-l Suspension Copolymer Suspension Resin Avg. I 1-1 Copolyper Dispersion Honiopolymer Dispersion J J-l Di spersion K K-l Dispersion K-2 Dispersion K-3 Dispersion K-4 Dispersion Dispersion Resin A;g. o ____ J VCM Emissions--' kg,/100 kg 1 (lb VCM/100 lb) PVC Produced 0.88 / 1.82--^ 1 2.68-/ j 1.54-^ j i 5.50-/ 1 , i. 22y { N 1.72^ J 0.54 1.01 0.63 0.59 0.7 1 .27 1.52 1 .05 1.16 1 .02 0.03 2.60 0.008 2.2 1 .15 CO^ 1 COLORITE 008468 Table 3-1j(cent.) SUMMARY OF FUGITIVE EMIS3I0MS j| lompary * 0r 1i u- h jl- I r L ; l-i Latex Process i VCM Emissions kq/100 Fg (lb VCM/100 lb) PVC Produced 0.22 V : M-i i Latex 1 M-2 Latex Latex Resin Average 1.9 2.9 1.67 N N-l Bulk 0.47 0 0-1 Bulk 0.82 P P-1 Bulk 0.25 Bulk Resin Average 0.50 Q Q-l Solution 0.025 Solution Resin Average R R-l Vinyl Chloride by Ethylene Dichloride S S-l Vinyl Chloride by Ethylene Dichloride Path EDC Path Average 0.025 0.00381/ 0.01521/ 0.0095!/ T T-l Vinyl Chloride by Acetylene Path 0.151 Acetylene Path Average 0.151 ^All data compiled by Houdry Division of Air Products and Chemicals and Environmental Protection Agency from responses to section 114 requests. -^These companies estimated a SO" vinyl chloride monomer - 50% polyvinyl chloride particulate breakdown of fugitive emissions at their plants. In the judgment of the Environmental Protection Agency, that breakdown is not realistic. The particulate is considered as a small part of fugitive emissions. In order to be consistent with other submittals5 the particulate portion of the reported loss was assumed to be vinyl chloride. -3A/ ll figures given here were calculated by a material balance. Plants which used other methods of fugitive emission estimates (i.e.. observation, emission factors) were not included in this table. 4/ --' The.1,'1 figures do not include loading and unloading operation losses, 1,'i ih inclus'on of these losses the Punitive emission factor is C.G5 kg/100 kq (lb VC 7100 lb) VCM. 3-43 COLORITE 008469 Table 3-11 Vinyl Chloride Monomer Content in Streams Discharging to Sewer Sou rce No. of Source No. Sources description Average Flow FI ow Range Flow1 Type Average Cone. VCM Cone. Range No. of Samples Total VCM Taken Lost per day 1 1 100 Seal Water 2.0 gpm 1.0 -+ Inter- 794 ppm - (Primarily Sus 10 gpm mi ttent pension) 1 19 3 400 Seal Water 3.5 gpm 3.0 -> Inter 660 opm " 1 27.7 (Primarily Dis 10 gpm mittent persion) J 36 HRC Water Suspension Dispersion 300 Gal/chg. 2000 Gal/ chg. 250 -* 500 gpc 1 500 - 2500 gpc Inter- mi ttent Intermi ttent 1 .32 ppm .64 ppm .14 + 6.9 .56 - .71 9 2 .2 lb. .15 lb. 4 3 Vacuum Jet Water 25 gpm 15 -* Continuous .45 ppm 45 gpm - i .13 lb. 5 2 Recycle Tanks 200 gal./ shift Intermi ttent 1880 ppm 1672 + 2137 3 9.4 lb. - 1 Roof Stack Water 100 Gal./ Day - .06 - 1 liegl igible 1 1 Concentrator 130 gpm (Dispersion) Continuous Based on 1000 ppm Reduction and 15 gpm feed 199 lb. r^ 1 Fluid Bed Dryer 65 gpm (Suspension) 30 * 70 gpm Continuous ,11 ppm - 1 .09 lb. COLORITE 008470 O 4. CONTROL TECHNOLOGY This chapter addresses the control techniques that can be applied and the emission reductions that can be achieved for each of the sources of vinyl chloride emissions identified in chapter 3. The control techniques that can be applied to .-educe vinyl chloride emissions fall into ihe following general categories: 1. Add-on type control systems such as sorbers, refrigeration systems or incinerators which reduce emissions from captive or point sources. 2. The reduction of emissions from pumps, compressors, and valves through the installation of effective seals on rotating or reciprocating shafts or by enclosing the equipment. 3. The reduction of emissions from pumps, valves, flanges, vessels, transfer operations, piping and other processing equipment during maintenance and inspection by adopting appropriate operating and maintenance procedures. 4. Reducing emissions by altering the manufacturing process such as adding improved stripping capacity to reduce the emissions from the slurry blend tanks, centrifuges, dryers, and storage silos by reducing the vinyl chloride content of the polyvinyl chloride resin. The control techniques described under items 1-3 above are generally applicable to both polyvinyl and ethylene dichloride-vinyl chloride plants an i 4-1 COLORITE 008471 will oe discussed as sucn below. In addition the principle of each control technique is described, specific emission points in the polyvinyl chloride and etnylene di cn Ion Uc--vinyl cnloride plants wnere the control technique is or is not applicable are pointed out, and factors such as high gas volumes and high temper atures that may limit the applicability or effectiveness of the control technique are addressed. Emphasis is placed on identifying the emission level the control device can achieve by incorporating good engineering design and operating practice. Process changes and other control techniques that are specific to an individual process are discussed in separate sections that describe the individual process. Not discussed in this chapter are those control methods which the EPA considered to be, at best, too underdeveloped to be considered candidates for best available control technology. The relatively new laboratory studies on ozonization and oxyphotolysis, for example, are omitted. (Both methods are used to oxidize vinyl chloride monomer into less toxic substances). Undemonstrated methods such as polyvinyl chloride dryer air recycle and silo stripping and adsorption were also not discussed in detail. Included in this chapter are those data which were accumulated during the course of EPA's investigation which show the capability of specific control devices or techniques to remove vinyl chloride from process streams. These data are included in section 4.11. 4-2 COLORITE 008472 1 /--I'. ,r , i;.'it !':t- :.-oponv of a surface to re-jin molecules of a fluid which has centre tiie surface is known as adsorption. This phenomenon permits cases, liquids, or solids, even at small concentrations, to be selectively removed ar.c captured from gaseous streams with specific materials knov.'n as adsorbents. The material adsorbed is called the adsorbateJ The,ethylene dichloride-vinyl chloride and polyvinyl chloride manufacturers and the vendors of adsorption resins and activated carbon have recently been experimenting with two adsorbents (activated carbon and polymeric or resin adsorbents) for the removal of vinyl chloride from certain process streams in bot'' oelyvinyl chloride and ethylene dichloride-vinyl chloride plants. A discussion of the advantages and problems associated with the application of these two adsorbents follows. 4.1.1 Carbon Adsorption Activated carbon is used to remove organic compounds from gaseous streams because, unlike other adsorbents, such as chemisorbents and silica gel which have an affinity for a highly reactive functional group in the adsorbate molecule or for moisture, carbon preferentially adsorbs organic materials. This fact gives carbon an advantage over other adsorbents in streams containing water and in streams in which all the adsorbed organics can be recycled to the process. Carbon adsorption systems presently in commercial and industrial use are oriented toward 'air purification" and "solvent recovery." In either application, the gas stream is passed through a granular activated carbon bed. The organic (adsorbate) gas or vapor is retained by the carbon and the purified stream pisses through. When the carbon bed has reached its capacity to retain vapor (saturation), the gas mixture flow is stopped or diverted to a system cona i ni ng fresh carbon while the collected organic vapors .m; removed (<J 'soi bed) f< cm l!':- spent carbon or the carbon bed is ' - ' COLORITE 008473 For many industrial applications, it is economically expedient to desorb, and thus regenerate, the saturated carbon for further use. The absorbate is generally removed by heating the carbon. This regeneration is accomplished by passing a hot gas through the carbon bed. Saturated steam is the usual source of heat and is sufficient to strip most types of organic vapors. The steam'and desorbed organic compound(s) are then condensed by cooling. The water and organic material can be separated by decanta tion or distillation. After the adsorbate is stripped, the carbon is not only hot, but saturated with water, (if steam is used or the pollutant stream contains water). Coding and drying are usually done by blowing pollutantfree ambient air or inert gases, such as hot nitrogen, through the carbon bed. Adsorption has been used in applications where profitable solvent recovery is possible, i.e. where the value of the recovered solvent will pay the cost to install and operate the adsorption system. Generally speaking, activated carbon systems are not economical when large volumes of gases that contain low concentrations of organic compounds have to be treated. The larger the gas volume, the larger the carbon bed that is required. This not only increases the investment cost but the increased quantity of steam or heat that is required to regenerate the carbon bed increases operating costs. Similarly, for a given gas volume, the quantity of removed solvent will vary in direct proportion to the concentration of the organic material in the gas stream being treated. The interest has been, in the past, on solvent vapor concentrations well above 700 ppm as this level represents the profit-loss breakeven concentration for many organics. 2 However, it is theoretically possible 4-4 COLOR!TE 008474 to apply the principles of carbon adsorption to lower stream concent At least one printing company has useo carbon adsorption systems on st concentration averages as low as 400-1000 ppm for the collection of tola 3 from rotogravure and flexograpnic presses. Another company collects ethanol in concentrations ranging from 200-505 ppm at 2040 cubic meters per minute (72,000 acfm) with an outlet concentration of 8-10 ppm.^ While carbon adsorption has not been applied on high volume sources [with volumes up to (72,000 acfm) 2040 cubic meters/min] in the vinyl chloride industries, primarily because of economics, at least one polyvinyl chloride manufacturer is currently operating a carbon adsorption unit on relatively high concentration streams.^0 The industry has ques.ioned the applicability of carbon adsorption in the control of vinyl chloride monomer because of the possibility of polymerization on the bed which would plug the bed and necessitate its replacement. The company's pilot study indicated that this did not take place after 28 cycles of saturation, desorption and drying. One vendor of activated carbon stated that their own studies did not show any evidence of polymerization on the carbon bed after 15 cycles. The polyvinyl chloride manufacturer mentioned above has since operated the carbon adsorption unit on full plant scale for over 7000 cycles^0 with an outlet concentration of less than 10 ppm vinyl chloride monomer. The unit is used to collect vinyl chloride from a monomer recovery system vent and a slurry blend tank vent. These two streams have relatively high concentrations of vinyl chloride (on the order of 100,000300,000 ppm), low stream volumes (less than 1.7 cubic meters/minute or 60 scfm total), and low temperature (approximately 10C or 50F).5 The cost of applying carbon adsorption to control emissions from the dryers and bulk storage silos in polyvinyl chloride plants will depend on the COLORITE 008475 bed life. Bed life is particularly important for these applications due to the large quantities of carbon that are required and some development work will bo required to quantify this parameter. The available data do not conclusively establish the bed life of carbon for all streams. Based on data from one design company and the above mentioned manufacturer's data, an outlet concentration lower than 10 ppm could be expected for most streams. 8 ' 10 In ethylene dichloride-vinyl chloride plants, carbon adsorption could be readily applied to the small gas volumes associated with the vinyl chloride and ethylene dichloride distillation columns. Some development work would be required to determine the costs that would be associated with treating the oxychlorination vent. A number of different organics would be captured by the system and, with the possible exception of the vinyl chloride distillation column, recycling of these organics would not be practical. Therefore, it would be necessary to dispose of the captured vinyl chloride by incineration or other means. The optimum source for application of carbon adsorption given the present state of the art is high concentration, low volume, low temperature streams (generally, adsorption is more efficient at lower temperatures) such as polyvinyl chloride plant monomer recovery systems, closed polyvinyl chloride slurry blend tanks containing nitrogen or other inerts in the vapor space, and vinyl chloride storage areas. Table 4-3 shows emission reductions possible for various sources in both ethylene dichloride-vinyl chloride and polyvinyl chloride plants with application of carbon adsorption. One design company lias examined tile limitations of carbon adsorption as applied to streams such as polyvinyl chloride dryer exhausts, which have large volumes of air with lew concentrations of vinyl chloride. The company suggests that the concentration of vinyl chloride in the stream can be 4-6 COLORITE 008476 iiica ;ed i y necycline the exhaust dir through the dryer.^ The method is not dciioustratod as of this date. In order to give an idea of the size of the adsorption unit required for a typical application of carbon adsorption the following description is offend. The parameters which determine the required size of an efficient caiuon adsorption unit are varied. Effluent concentrations, stream volume, particulate matter and water, corrosion problems, and temperature are all variables which make nearly every application unique. In addition to stream characteristic variations, there are at least three different types of adsorber designs, each with its own special design requirements. For the (60 scfm) application described above on the polyvinyl chloride plant monomer recovery system and slurry blend tank, the unit consists of 2-four foot inside diameter vertical beds with a packed height of 10 feet. Activated carbon 5 is a coked bituminous coal. The adsorption unit itself is skid mounted. Section 4.12 - Data Demonstrating Capability of Selected Control Techniques discusses and evaluates this carbon adsorption unit. The section also includes data from one vendor of activated carbon which would be of benefit in evaluating adsorption systeiisused to control vinyl chloride monomer emissions. 4.1.2 Resin Adsorption The mechanism of adsorption on a resin or polymeric adsorbent is the same as on activated carbon except that the resin has a higher affinity for the specific organic material being removed. This special affinity gives resin adsorbents an advantage over carbon on streams containing a multitude of organic materials. Resin adsorption has historically been attractive because of the resin's resistance to oxidation on the bed. Carbon beds lack this resistance due to carbon's flammability. This is an important safety consideration in 4-7 COLOR!TE 008477 streams containing oxygen. Producers of resin adsorbents claim that the 9 capacity of resin to retain organics is higher than carbon, but resins give up the materials more readily than carbon on desorption. This would indicate that resin adsorption units could be constructed with smaller bed sizes. A producer of polymeric adsorbents claims that other advantages of the resins are that they have greater resistance to water adsorption (the adsorpti of water can "blind" the bed), and arc mechanically stronger than carbon. Dusting (a pulverized condition of the carbon) does not occur as readily on these resin materials.^ Programs for development of a resin adsorbent for vinyl chloride have just recently been undertaken. Data to define the effectiveness or costs of the polymeric adsorbents to treat streams containing vinyl chloride are presently not available. COLORITE 008478 References for Adsorption 1. Air Pollution Engi risen no Manual, Danielson, J. A. (ED,). U. S, Environ mental Protection Agency, OAQPS, Research Triangle Park, N. C., ERA Publication No. AP-40. 1973. 987 p. 2. Package Sorption Device System Study, MSA Research Corporation for Off-ice of Research and Monitoring, U. S. Environmental Protection Agency, Washington, D. C., EPA Publication No. R2-73-202. April 1973. 3. Harvin, Richard L., "A Modern Design Solvent Recovery Plant," Technical Report for the 70th National Meeting of the American Institute of Chemical Engineers, September 1971. 4. Conversation with Mr. William R. Meyer, Environmental Project Manager, Vulcan-Cincinnati, Inc., February 19, 1975. 5. Letter with attachments from W. P. Anderson, Tenneco Chemical Company, --_ to Don R. Goodwin, EPA, October 18, 1974. 6. Letter with attachments from William D. Faulkner, Calgon Corporation, to Stanley T. Cuffe, EPA, October 18, 1974. 7. Letter with attachments from William D. Lovett, Calgon Corporation to Stanley T. Cuffe, EPA, December 19, 1974. 8. Letter with attachments from R. W. Alexis, Chemical Design, Inc., to Don R. Goodwin, EPA, December 6, 1974. 9. Letter from James S. Clovis, Rohm and Haas Company, to Leslie Evans, EPA, November 20, 1974. 10. Letter with attachments from W. P. Anderson, Tenneco Chemical Company, to Leslie B. Evans, EPA, May 13, 1975. 11. Conversation with Marvin Hurwitz, Steven Rock, Chester Fox, and John Thompson, Rohm & Haas Company, July 13, 1975. o 4-9 COLOR!TE 008479 4.2 INCINERATION Vinyl chloride can be combusted 'with oxygen to form hydrogen chloride, carbon dioxide and water. CH2 = CHC1 + 2 1/2 02 - 2 C02 + H20 + HC1 Because there is sufficient hydrogen in the vinyl chloride molecule to combine with the chlorine to form hydrogen chloride little free chlorine should be formed. The efficiency of the oxidation of vinyl chloride depends primarily on the temperature obtained and the residence time in the combustion device. In general chlorine does inhibit the oxidation reaction and even in low concentrations may cause higher temperatures and longer residence times to be needed for complete destruction of pollutants."' Little data is available on the temperature or residence time required to destroy vinyl chloride and therefore some additional testing might be required prior to the design of a combustion device to aandle such wastes. The information available, however, indicates that the vinyl chloride content of a gas stream can be reduced to less than 10 ppm by incineration in a steam boiler.^ Tables 4.3 and 4.4 show how effectively incineration could reduce the emissions from various sources in ethylene dichloride-vinyl chloride and polyvinyl chloride plants. Vinyl chloride can be combusted in a flare, a direct-flame afterburner, a catalytic afterburner, or a boiler, and combustion is generally applicable to all sources in ethylene dicnloriue-vinyl chloride and polyvinyl chloride plants. The choice of device will depend on the heat value of the stream, the amount of gas to be combusted and whether or not any steam produced could be used in the plant. A flare can and is being used to combust small vinyl chloride streams 2 or intermittent emissions such as would occur during a plant upset. Flares are already in existence in many petrochemical complexes and most q .-io COLORITE 008480 vinyl chloride plants are located in or near these complexes. However, the ase of a flare to oxidize vinyl chloride has several disadvantages. The hydrogen chloride produced by the oxidation of vinyl chloride in the flare cannot be controlled and therefore the flare may not be acceptable as a long term solution. In addition there are large dilute gas streams present in both ethylene dicnloride-vinyl chloride and polyvinyl chloride plants that cannot support combustion. Therefore natural gas or other fuel must be added to achieve combustion and all the heat produced is wasted. Due to the presence of the open flame, flares must be installed away from the plant or they require a considerable area in the plant for safe install.- fion. A direct-flame afterburner'(or vapor incinerator) can be used to combust offgas streams from ethylene dichloride-vinyl chloride and polyvinyl chloride plants. These afterburners consist of a refractory lined chamber fitted with one or more natural gas burners at the inlet end. The efficiency of this type of afterburner is determined by its temperature. One source estimates that a tempera- 3 ture of 981C (1800F) would be required. Another source estimates that a tenperature of 981 C (1800F) and residence time of two seconds would be necessary for essentially complete combustion.^ Unlike flares, afterburners can be designed to recover the heat present in the combustion gases. This is important when large volumes of dilute gases that will not support combustion (such as the dryer exit gas in a polyvinyl chloride plant) are burned with the supplemental fuel required to_ achieve combustion. Heat exchange can be used to reduce the amount of fuel required or the exit gas from the incinerator can be used to generate steam in a boiler. The combustion gas exiting from the heat exchanger or boiler can then be scrubbed with water or caustic solution to remove the hydrogen chloride to form dilute hydrochloric acid or a sodium chloride o 4-11 COLORITE 008481 solution. For each kilogram of vinyl chloride combusted 0.58 kilograms of hydrogen chloride are produced or 0.93 kilograms of sodium chloride if sodium hydroxide is used for neutralization. The disadvantage of using directflame afterburners fitted with hydrogen chloride scrubbers for the control of vinyl chloride emissions in ethylene dichloride-vinyl chloride and polyvinyl chloride plants is that the large gas streams such as the dryer and storage silo exhaust in the polyvinyl chloride plants will not support combustion and large amounts of natural gas or other.fuel will be required. In many instances control of the oxychlorination process in the ethylene dichloride-vinyl chloride plant will also require supplemental fuel. In addition they are expensive to build because of the corrosion problem caused by the hydrogen chloride in the burner and in the scrubber. Direct-flame afterburners of the type described which burn chlorinated hydrocarbons are presently in operation in at least seven locations in the United States. Some of these burners combust a gas stream, some combust a liquid stream of chlorinated hydrocarbons and some combust a combination of 35 the two. ' None of these installations, however, combust gas streams as large as the effluent from the oxychlorination process or the polyvinyl chloride dryer exit gas stream; and none of these installations recover heat by steam generation. Vinyl chloride may be combusted in a catalytic afterburner. The catalyst changes the rate of oxidation and permits the reaction to occur at a somewhat lower temperature than in a direct-flarne afterburner. The primary advantage of catalytic afterburners is that less fuel would be required to combust dilute (low Btu) gas. The primary disadvantage is the higher cost of the afterburner. One catalytic afterburner of the type described is presently in 3 operation in the United States. A production size unit is being constructed for one oxychlorination process. g plant for months. A pilot unit has been operating on the same 4-12 COLORITE 008482 The fireboxes of steam boilers can be used to incinerate gaseous streams containing vinyl chloride. It should be possible for plants operating steam boilers near vinyl chloride sources to use large dilute streams, such as the dryer exit stream, as combustion air in the boiler. Such an approach would not significantly change the plants fuel requirements. This technique could be used with existing boilers or in new plants. There are several disadvantages. There is a potential corrosion problem in the firebox because of the hydrogen chloride produced, and careful design is required. It has been found that the effluent stream is especially corrosive at temperatures either above 316C (60CF), or below the hydrogen chloride dew point. In order to maintain steam coils within the non-corrosive temperature range 19 atmosphere saturated steam is generated in the boiler and effluent gases are exhausted at 288C (550F). Adequate instrumentation is required to see that the tube wall temperatures do not exceed 316C (600F) or go below 204C (400F). It is also necessary to purge chlorinated compounds'from the system prior to furnace shutdown. 3 v There are presently two steam boilers in the United States being used to incinerate gaseous vinyl chloride streams. One of these has been tested by the Environmental Protection Agency and a summary of the test is presented in section 4.12. In this installation a concentrated hydrocarbon stream containing 1 to 18 percent vinyl chloride is used with supplemental natural gas and combustion air to generate about 3400 kg (7500 pounds) an hour of 18 atmosphere steam. The boiler is a fire tube Dixon marine type which has been modified to burn chlorinated hydrocarbons. (The exact nature of the modification is confidential). The exit of the boiler is scrubbed in a t packed column with a waste water stream from the plant that has a pH of 11. During the test the exit from the boiler contained an average of 4 ppm vinyl 4-13 COLOR!TE 008483 chloride for a removal efficiency of 99 percent.^ Although a previous boiler lasted for only five years, the present boiler has been in operation for three years and the service factor has been 98 per percent. The second steam boiler in the United States burning chlorinated waste material has had some corrosion problems which now seem to be corrected.^ A B. F. Goodrich licensee in Rotterdam, Holland, uses a thermal incinerator and a carbon steel boiler for heat recovery on a mixed stream that includes the emissions from the oxychlorination process from their balanced 300,000 metric tons per year ethylene dichloride-vinyl chloride plant. Although no details are available on the boiler service factor the unit has been in operation without difficulty for more than two and one-half years. The boiler flue gas is not scrubbed to remove hydrogen chloride.^ Although several boilers burning chlorinated hydrocarbons have been in operation for several years the long term reliability of this type of boiler has not been completely demonstrated. In some cases operators may choose to have two boilers with one on standby for use if the first is shut down. 4-14 COLORITE 008484 References for Incineration 1. AftCM'bjjrnj?21 Sys_^ei_"_Stu_dy_, ERA Contract EHSD 71-3. 2. Letter with attachments from R. E. Van Ingen, Shell Chemical Company to Don R. Goodwin, ERA, July 5, 1974. 3. Engineer!nq and Cost Study of Air Pollution Control for the Petrochemical Industry Volume 3: Ethylene Dichloride Manufacture by Oxychlorination, ERA 4501 3-73-006-c, November 1974. 4. Shell Chemical Representatives Conversation with LPA. Durham. N.C., April, 1975. 5. Chemical Week Magazine, April 19, 1972, p. 37. 6. Vinyl Chloride Testing Conducted at the American Chemical Company, Carson, California, ERA Contract 68-02-1400, Task No. 8, Scott Environmental Technology, Inc., EMB Project Report Number 75-VCL-2 7. Willard Bixby (B. F. Goodrich) conversation with Leslie B. Evans, February 14, 1975. 8. Diamond Shamrock representatives conversation with EPA, Durham, N.C. April 14, 1975. J 4-15 COLORITE 008485 4.3 SOLVENT ABSORPTION Absorption is the process whereby one or more soluble components of a gas mixture are dissolved into a relatively nonvclative liquid solvent. From an air pollution standpoint, absorption is useful as a method of reducing or eliminating the discharge of air comtaminants to the atmosphere, while possibly yielding profits to the user. The design of gas absorption equipment is intended to provide maximum contact between the gas and liquid solvent to insure interphase diffusion between the materials. There are other factors which influence the absorption rate, such as solubility of the gas in the particular solvent and the degree of chemical reaction, but these factors are characteristic of the constituents involved and are more or less independent of the equipment used. While such parameters as system temperature and pressure do affect the efficiency of the devices, the primary design parameter of absorption devices is the solvent surface exposure.^ There are a number of ways to accomplish contact between the gas and liquid. Packed towers, spray towers or spray chambers, and venturi scrubbers are devices which dispense liquid solvent into the gas stream. Tray towers and vessels with sparging equipment are examples of equipment that use gas dispersion. Packed towers are filled with a packing material having a large surface-to-volume ratio; the packing is wetted by the absorbent to provide a large surface area of liquid for continuous contacting of gas. Spray towers disperse the liquid solvent in the form of a spray and pass the gas through the spray. Venturi scrubbers contact the gas and the absorbent in the throat of a venturi nozzle. Tray towers, or bubble plate columns, induce contact by means of a number of plates or trays arranged so that the gas is 4-16 COLOR!TE 008486 dispersed through a layer of solvent on each plate. The number of plates required depends upon the difficulty of the mass transfer operation and the degree of separation desired. The copmon absorbents for organic vapors are water, mineral oil, nonvolatile hydrocarbon oils, and aqueous solutions (e.g. sodium carbonate or sodium hydroxide). 2 While it is possible to use any of a number of 3 aliphatic, aromatic or chlorinated solvents in the scrubbers, the types of solvents which are currently used to control vinyl chloride emissions include ethylene dichloride, 4 acetone, 5 and the petroleum based hydrocarbon "Carnea Oil". 6 Trichloroethane has been used in the past. 3 The main considerations in choosing a solvent include: a. A high solubility for vinyl chloride and a low solubility for air and water. b. Low volatility to minimize losses during handling. c. The solvent should be non-toxic, non-corrosive and non-flammable and should not constitute an explosion hazard. d. A low cost solvent is necessary for economic reasons. e. The solvent should either be easy to dispose of or be regenerate.^ After the gas has been scrubbed with a solvent in the absorber unit, the vinyl chloride is recovered from the enriched solvent by applying heat and vacuum. The vinyl chloride gas is then transferred to a monomer recovery syst.em. 6 At least three polyvinyl chloride producers currently use solvent absorbers in their plants. This equipment was put on emission points some years ago for economic reasons. 4 ' 5 ' 6 Other units scheduled for installation in the near future are being installed because of the low costs of this particular control tecnnique for specific source control. Current application 4-17 COLORITE 008487 of absorption is restricted to the monomer recovery system vent and storage area noncondensable gas vents in polyvinyl chloride plants. Two companies are planning to install units on storage area, distillation column, and loading operation noncondensable gas vents in ethyTene dichloride-vinyl chloride Diants.^ All of tnese streams are :iiqii concentration, low volume sources. Another source in the polyvinyl chloride plant, in addition to the two areas mentioned above, which could be controlled by absorption is the slurry blend tank. The application of absorption in the vinyl chloride industry is currently limited to the control of transfer and storage areas. Table 4-3 gives a summary of sources, stream descriptions and expected reductions with application of solvent absorption. It is possible to design an absorber for any of the sources listed above for very high efficiencies on the order of 99+ percent. A packed tower, was installed in 1950 to recover vinyl chloride from the vent gases of a process stream off the synthesizing of vinyl chloride from acetylene and hydrogen chloride. The system was later adapted to serve solely as a vent gas scrubber following a condensing system. The solvent used is ethylene dichloride at a 152 liters (40 gallons) per minute circulation rate through the absorber. The inert volume through the scrubber is 3.54 cubic meters per minute (125 scfm). The unit operates with an efficiency of 99+ percent for an exit vinyl chloride concentration of 15 ppm and exit emission of 9.1 grams/hr (0.02 lb/hr). 4 Section 4.12 Data Demonstrating Capability of Selected Control Techniques, includes a discussion of this absorber and evaluates its effectiveness in reducing emissions. The factors which limit the use of absorption include concentration, volume, and temperature of the pollutant stream. To a great extent, each 4-18 COLORITE 008488 of those limits can be overcome by engineering design (i.e., increasing the number of contact trays and cooling the gas streams before entry into tr;e aDSorber). Practically, however, the recovery efficiency of control decreases with decreasing concentration and volume and increasing temperature. For this reason, certain streams within polyvinyl chloride and ethylene dichloride-vinyl chloride plants are better controlled with other methods. These streams include polyvinyl chloride dryers and ethylene dichloridevinyl chloride oxychlorination vents. 4-19 COLORITE 008489 References for Solvent Absorption 1. Air Pollution Engineering Manual, Danielson, J. A. (Ed), U. S. Environ mental Protection Agency, OAQPS, Research Triangle Park, N. C., EPA Publication No. AP-40, 1973, 987 pp. 2. Control Techniques for Hydrocarbon and Organic Solvent Emissions from Stationary Sources, USD HEW-PHS-NAPCA, Washington, D. C., National Air Pollution Control Administration Publication No. AP-68. 1970. 3. Kleeberg, Charles F., EPA, Meeting Report, B. F. Goodrich Chemical Company, Cleveland, Ohio, September 26, 1974. 4. Letter with attachments from W. C. Holbrook, B. F. Goodrich Chemical Company, to Don R. Goodwin, EPA, November 15, 1974. 5. Letter with attachments from M. E. Eisenhour, Union Carbide Corporation to Don R. Goodwin, EPA, June 21, 1974. 6. Letter with attachments from C. J. Kleinert, Firestone Plastics Company to Don R. Goodwin, EPA, November 8, 1974. 7. "Vinyl Chloride Removal from Polyvinyl Chloride", Report to EPA, Office of Air Quality Planning and Standards, C. D. Callihan and E. McLaughlin 8. Letter with attachments from W. M, Reiter,Allied Chemical Corporation, to Don R. Goodwin, EPA, June 27, 1974. 9. Letter with attachments from Mr. A. T.Raetzsch, PPGIndustries, to Don R. Goodwin, EPA, June 21, 1974. 4-20 COLORITE 008490 4.4 REFRIGERATION Refrigeration systems are not the most effective means of reducing vinyl chloride emissions but they can be used in conjunction with other control equipment such as carbon adsorbers and solvent absorbers to reduce ttie load on these systems by condensing the bulk of the vinyl chloride and water,thus reducing the gas volume that has to be treated. The cooler gas temperature also improves the performance of both these devices. Many organic compounds, because of their relatively high boiling points, can be removed from gas streams by simple condensation. Surface condensers which reduce temperatures through cooling are generally used in the vinyl chloride industry. In these devices, vinyl chloride vapor condenses on the outside surfaces of tubes through which the cooling medium, usually water, flows. The condensed vapor film drains to storage or disposal. Other coolants used in the industry include Freon--( propane, and propylene. The effectiveness of refrigeration systems to reduce vinyl chloride emissions increases with decreasing temperature and increasing pressure. Reduction of vinyl chloride emissions by refrigeration is limited by the sharply increased costs associated with cooling and compressing the gas and by freezing if water is present in the gas. Usual design pressure and temperature are 4.4 atmospheres and 7C (45F). A condenser operating at such conditions would emit a stream containing 50 percent vinyl chloride. Lowering the temperature to -26C (-15F) and raising the pressure to 5.8 atmospheres would decrease the vinyl chloride content in the exit stream to 10 volume percent.^ The amount of inerts which have to be released from a particular system is the primary controlling factor of vinyl chloride emissions. Because the --^Dupont Trademark 4-21 COLORITE 008491 ratio of vinyl chloride to inerts is constant for a set of condenser conditions, the vinyl chloride emission is dependent on the amount of inerts in the system. A vent condenser would emit a stream of 50 percent vinyl chloride if it operated at 4.4 atmospheres and 7C (450F). The 50 percent vinyl chloride content is constant for that condenser. By reducing the volume of inerts the volume of vinyl chloride emitted is reduced. The quantity of inerts in the recovery system is a limiting factor to the effectiveness of control by refrigeration. Currently, refrigeration is extensively used in monomer recovery systems in polyvinyl chloride plants. At least 25 plants report using such systems; most were installed for economic reasons.^ One producer claims that vinyl acetate is not desirable in condenser systems because of the material's conversion to acetic acid. The corrosive nature of the acid prompts the producer to "by-pass" the recovery system when copolymers of vinyl acetate 2 and vinyl chloride are being vented. Both ethylene dichloride-vinyl chloride and polyvinyl chloride producers 34 report the use of refrigerated vent condensers on monomer transfer operations. ' It is also possible to apply refrigeration to ethylene dichloride and vinyl chloride distillation columns in ethylene dichloride-vinyl chloride plants. In summary, refrigeration is not the most effective means of controlling emissions but can be used in conjunction with carbon adsorption and solvent 5 absorption to reduce the capital and operating costs of these devices. For streams In polyvinyl chloride and ethylene dichloride-vinyl chloride plants, well designed refrigeration units can reduce the polyvinyl chloride concentration in the gas stream from 500,000 to 100,000 ppm. These figures are based on equilibrium data for vinyl chloride in a vent streamJ 4-22 COLORITE 008492 References for Refrigeration 1. "Ecsi 1 ibriu.Ti Concentration of Vinyl Chloride m Vent Gas," submitted by E. F. Goodrich Chemical Company. 2. K!cetera, Charles F., ERA, Trip Report, "Polyvinyl Chloride Production at Firestone Plastics Company in Pottstown, Pennsylvania," September 23, 1974 . 3. Letter with attachments from C. J. Kleinert, Firestone Plastics Company, to Don R. Goodwin, ERA, November 8, 1974. 4. Letter with attachments from R. H. Gerlach, Conoco Chemicals, to Don R. Goodwin, ERA, June 7, 1974. 5. Letter with attachments from W. P. Anderson, Tenneco Chemical Company, to Don R. Goodwin, ERA, October 18, 1974. 6. "In-depth Study of Polyvinyl Chloride Production," draft document prepared for the Environmental Protection Agency by Houdry Division of Air Products and Chemicals, December 6, 1974. 4-23 COLORITE 008493 4.5 CONTROL OF FUGITIVE EMISSIONS Fugitive emissions as described here include emissions that occur from pressure relief valves, pumps, compressors and agitator seals, from loading and unloading monomer, valve stems, flanges and sampling for laboratory analysis. In an average polyvinyl chloride plant there may be as many as 600 points at which there is a significant possibility of leakage. As previously explained in chapter 3, these fugitive or unaccountable losses represent the most significant source of emissions in polyvinyl chloride plants. The techniques that are discussed below to reduce fugitive emissions can be applied to both ethylene dichloride-vinyl chloride and polyvinyl chloride plants. Rapid detection of a leak so that it can be quickly repaired is an important facet of reducing fugitive emissions. Large vinyl chloride leaks can be visually detec :ed by the frosting which occurs at the discharge because of the cooling effect of gas expansion or by the odor of vinyl chloride. Small leaks can be detected quickly by several methods. A fixed multipoint gas chromatograph, analyzer and recorder can be used to periodically sample the vinyl chloride content of the ambient plant air at as many as 100 i points within a plant. The recorder can be fitted with an alarm to alert the operator of high vinyl chloride levels. When a high level is detected in a specific section of the plant the exact location of the leak can be determined by the use of a portable flame ionization type hydrocarbon sensing device (or sniffer). Although this instrument may respond to hydrocarbons other than vinyl chloride, it is adequate for this job. After the leak has been found it can be promptly repaired. 4-24 COLORITE 008494 A second method of detecting swell leaks (whicn can be used in conjunction with the metnod outlined above) is to check each possible leak point with a portable detector on a regular basis. Each Dotential leak point would be assigned a number and the vinyl chloride (or hydrocarbon} level at that point recorded on a routine basis. After a period of time U will be possible to tell from the recorded levels which pieces of equipment are leak prone. went, as appropriate. 2 ' 3 These may require special maintenance or replace- A third method of leak prevention that can be used is to hydrostatically test piping, flanges, vessels, manholes, and other process equipment after construction, maintenance or inspection.^ All thr^o of the methods above are now in use in some polyvinyl chloride and ethylene dichloride-vinyl chloride plants. Certain equipment in ethylene dichloride-vinyl chloride and polyvinyl chloride plants can be modified or changed to prevent vinyl chloride loss. Single mechanical seals are presently used on most vinyl chloride pumps today. The seal faces on single seal pumps are lubricated by a slight outward flow of vinyl chloride between the stationary and rotary faces. This flow can be eliminated by using a double seal pump in which an environmentally acceptable fluid such as ethylene dichloride is maintained, at a pressure greater than exists in the pump, between the two seals. Any leakage at the vinyl chloride face is into the pump, not out of the pump. The loss from mechanical rotary seals can also be eliminated by using completely enclosed or "canned" pumps. There are no seals in these pumps and tne pumped fluid circulates through the motor itself and lubricates the motor and cump bearings. Pumps with magnet to magnet drive and no seals may be even more suitable. Pumps with reciprocating shafts can be equipped with double outboard seals with ti.i chamber between the two seals vented and controlled. Every flanged oip'> joint is a potential leak source and welded connections COLORITE 008495 can be used when possible. In the past, companies have avoided welded pipe because it is more difficult to disassemble for cleaning or maintenance. This factor is of concern to ethylene dichloride-vinyl chloride and polyvinyl chloride producers as polymerization can occur in piping during upset conditions. When a process stream or vessel containing vinyl chloride is sampled for analysis the sample flask can be purged back to the process stream rather than to the atmosphere. The sample connections are placed so that the vinyl chloride flows from the process into one end of the sample flask and from the other end of the sample flask back into the process at a second point which is at a lower pressure. Each end of the sample flask is attached to the sample point with quick-connect couplings. The flask valves and the process valves are opened to purge a fresh sample from the process stream through tne flask and back to the process stream. Once the flask is purged and filled, the process valves and the flask valves are closed. The short sections of pipe between the flask and process valves can then be purged with inert gas to a monomer recovery system or to a control device. When vinyl chloride is loaded or unloaded into or from railroad tank cars (or barges) the usual method consists of connecting a hose to the top and one to the bottom of the car. The bottom hose is used to transfer the liquid vinyl chloride, the other hose equalizes the pressure between the vapor space in the tank car and the storage tank. When any part of the loading line (hoses, valves, coupling) is disconnected the material left in that part may be lost to the atmosphere. This source of emissions can be controlled by purging with nitrogen to an incinerator, boiler, or other control device or by using the compressor system to evacuate the line. An additional loss may occur during car filling. Most vinyl chloride producers measure the level in vinyl chloride cars with a "slip qauge." A vertical tube open at both ends is fitted thorough a packing gland in the tank car top and is "slipped" down into the car until the emission from 4-26 COLORITE 008496 the top ervj of the tube changes from gas to liquid. The position of the bottom cf tee tube at this point indicates the liquid level. At least one vinyl chloride producer has reduced the emissions from this source by collecting tiie emissions from the top end of the "slip gauge" and recovering the vinyl chloride in a recovery system. 3 When this method is used a sonic detector3 or magnetic dev.ic5e can be used to tell when liquid is flowing from the tube. All pressure vessels in ethylene dichloride-vinyl chloride and polyvinyl chloride plants must be equipped with safety discharge valves which are designed to relieve the pressure from the vessel in case of an operating upset. Because of their design characteristics these valves are more apt to leak than gate or plug valves. Also, if the valve is unseated by over pressure, it may not reseat properly and a large leak may result. These leaks are difficult to detect because the valve discharge is usually elevated and not readily accessible for detection with a portable sniffer. This emission can be prevented by installing a rupture disk between the vessel and the safety valve with a pressure gauge between the valve and rupture disk. Any pressure buildup between the disk and the valve will indicate rupture disk failure which can then be replaced. Rupture disks used for this purpose are designed to burst at a fixed pressure. If the disk does leak the pressure gauge will indicate this and the disk can be changed before the safety valve unseats. If the rupture disk is blown out by high pressure the safety valve will reseat after the pressure has returned to a safe level and prevent the entire loss (to atmosphere) of the vessel contents."^ Vinyl chloride emissions resulting from excessive pressure can be controlled by connecting the relief valve discharge to a flare or other control device. 4-27 COLORITE 008497 This technique is being applied to large relief valves on very large polymeri zation reactors of a new polyvinyl chloride plant.^ In most suspension polyvinyl chloride plants the slurry from the reactor is screened to remove lumps. In some older plants this screening is done in an open box. If the slurry has not been well stripped there will be considerable emissions from this device (just as there are from the slurry blend tanks). Other plants use inline screens which must be disassembled for cleaning. Modern plants use an inline "delumper" which breaks up the lumps with a propeller type device. These devices do not require frequent maintenance and can be retrofitted into existing plants. Vinyl chloride may also be lost to the air when process equipment is vented so that the equipment may be removed for maintenance or entered for inspection. It has been the practice in some plants to "valve off" or "block off" the equipment and then simply vent t:>e vinyl chloride that is contained in the enuipment between the closed or blocked valves to the atmosphere. At least one plant now has complete recovery systems which cover all major pieces of equipment. 4 Before the equipment is opened it is attached to a monomer recovery system, perhaps with a flexible coupling, and the vinyl chloride is blown out of or purged from the equipment. For larger equipment water or steam can be used to displace all the vinyl cnloride present to the monomer recovery system. It is difficult to estimate the emission reduction that typical polyvinyl chloride plants will be able to achieve using the methods described in this section. It is expected that fugitive emissions could be reduced by 90 percent. 4-23 COLORITE 008498 rs 'able 3-10 shows the individual fugitive emissions reported in response to the ERA section 114 reouest of '''ay 30, 1974. References for Fugitive Emission Controls 1. Kleeberg, Charles F., ERA, Trip Report, "Tenneco, Burlington, N.J., -- Plant Inspection," September 23, 1974, p. 3. 2. Letter with attachments from F. F, Hoy, Plant Manager, Firestone Plastics Company, Perryville, Maryland, to Don R. Goodwin, EPA, June 7, 1974. 3. Letter from R. E. Van Ingen, Manager, Manufacturing Environmental Conservation Department, Shell Oil Company, to Don R. Goodwin, EPA, December 6, 1974. 4. Letter with attachments from J, R. Mudd, Plant Manager, General Tire and Rubber Company, Ashtabula, Ohio, to Don R. Goodwin, EPA, June 17, 1974. 5. Letter from K. H. Oelfke, Jr., Manager, EDC and Derivatives, Dow Chemical, U.S.A., to Don R. Goodwin, EPA, June 12, 1974. 6. Letter with attachments from J. R. Mudd, Plant Manager, General Tire & Rubber Company, Ashtabula, Ohio, to Interested Persons, August 13, 1974. 7. Letter with attachments from W. P. Anderson Tenneco Chemical Company, , to Leslie B. Evans, EPA, May 13, 1975. 4-29 COLORITE 008499 4.6 RELIEF VALVE DISCHARGE The polymerization oT polyvinyl chloride usually takes place in batch reactors at a pressure of about 6.1-'^'^atmospheres. The polyvinyl chloride reactors are protected from overpressure and catastrophic rupture by safety valves or a combination of rupture discs and safety valves. Occasionally vinyl chloride will be vented through the reactor safety valves because of operator error, power failure or equipment failure. Safety discharges tend to occur more often in older plants which is probably due to the larger number of smaller reactors and the less sophisticated instrumentation found in the older plants. Information submitted to EPA indicates the number of reactor discharges per plant varies between one and twenty per year. Several plants reported less than one discharge per year. The amount of discharge is usually not measured accurately but typically 2260 kg (5,000 pounds) of vinyl chloride might be vented in five to ten minutes.^ Potential problems can be quickly detected by instrumenting each reactor with temperature or pressure alarms to alert the operator to upset conditions. Once alerted the operator can use the following procedures to eliminate pressure relief valve discharges. A gasholder can be installed that is designed to hold all the vinyl chloride contained in an entire reactor batch, then the batch can be vented to the gasholder either automatically or manually. When an emergency power outage occurs there is a danger of multiple reactor discharges and the gasholder may not be large enough to accept all the vinyl chloride vented. In such cases a chemical solution which inhibits the polymerization reaction (referred to in the industry as shortstop) can be injected into the reactor to stop the reaction and prevent 4-30 COLORITE 008500 pressure build-up. The inhibitor solution system can be built m so that it can be operated iustantaneously, either automatically or manually. Reactor emissions during pov/er outages can be prevented by equipping each reactor with a hydraulic system to enable the operator to manually inject the shortstop material. In addition, an emergency electrical generator can be used to keep essential equipment in operation until power is restored and will permit the plant to be shut down in a safe and orderly manner. A combination of proper instrumentation to detect upset conditions, gasnolder, and automatic inhibitor solution systc... can eliminate vinyl cnloride lost from this source in existing plants. Discharges similar to the reactor safety valve loss can occur elsewhere in ethylene dichloride-vinyl chloride and polyvinyl chloride plants. Pressure vessels in general are equipped with such safety features. Some of the control techniques described above can be used on all pressure vessels. References for Safety Valve Discharge 1. Preliminary Report with attachments, from M. E. Eisenhour, Union Carbide Corporation, Texas City, Texas, to U.S. EPA, June 7, 1974. vm.V` 4-31 COLORITE 008501 4.7 GASHOLDER AND PURGE WATER SYSTEM A gasholder and reactor purge water system can be used together to significantly reduce emissions from suspension and dispersion nolyvinvl chloride plants. Bulk polyvinyl chloride plants operate with dry, water free, reactors; and if water were introduced into these reactors it would be necessary to install elaborate drying equipment. For this reason other control systems are more appropriate for these plants. Bulk plants can reduce reactor entry purge emissions by reducing reactor openings, bv using a better vacuum to remove more of the vinyl chloride before the ourge or by using add-on control equipment on the purge exit. Solution polyvinyl chloride plants are continuous and do not use batch reactors so the reactor ourge would not be applicable. However, both bulk and solution plants could use gasholders to reduce both fugitive and safety valve discharge emissions. A gasholder and reactor purge water system will reduce emissions from reactor openings, from reactor safety valve discharges, from the vinyl chloride recovery system, and from fugitive emission sources. Although each of the devices might be used separately they are more effective and efficient in combination and they will be discussed that wav here. To understand the operation of these systems it is necessary to understand a "typical" reactor operating cycle usinq a separate stripper equipped with refrigeration (13C or ?F gas exit) in the monomer recovery system, water cleaning, and an occasional tank entry for manual cleaning. See section 4.8 for a discussion of stripping, section 4.4' for a discussion of the refrigerated vent used on a typical nlant, and section 4.9 for a discussion of water cleaning. 4-32 COLORITE 008502 The cvcle starts with a clean enoty reactor which is full of air. Tie s"Ount of water that is reouired for the no!vrr.erization reaction is added to the reactor and a steam jet or vacuum oumn is used to remove seme of the air. The amount of air left depends on the absolute pressure after evacuation. The vinyl chloride and other chemicals are then added to the reactor and the reaction takes place for about six hours. At the completion of the reaction step the batch is discharged to a second vessel called a dump tank or stripper. In the strioper the unreacted qaseous vinvl chloride is removed by heat and vacuum and compressed and cooled to a liquid in the vinyl chloride recovery system. The air which was initially left in the reactor before the vinyi chloride addition step (plus any air present in the stripper when the batch is dropped) cannot be condensed and must be vented from the system through the vent condenser to prevent system overpressure. The refrigerated vent condenser removes some of the vinyl chloride from the air stream before it is vented but the ratio of air to vinyl chloride is determined by temperature and pressure at the exit of the condenser. A typical chilled water vent condenser operatinq at 13C (45F) exit gas temperature and 4.4 atmospheres will emit a gas stream containing 50 volume percent air. (See 4.4 Refrigeration.) The vinyl chloride emissions are therefore directly related to the total gas volume that must be vented from the system in order to prevent the excessive pressure that results from inert gas accumulation. The air that is present in the reactor after cleaning ends up in the monomer recovery system and therefore increases the volume of gas that must be vented from the system. After the batch is discharged from the reactor to the stripper the reactor remains full of vinyl chloride gas. In a typical plant some of this 4-33 COLORITE 008503 vinyl chloride is recovered by a compressor which discharges to the vinvl chloride recovery system. The amount of vinyl chloride aas left in the reactor depends on the absolute pressure after evacuation. Typical nractice is to reduce the pressure to 127 millimeters (5 inches) of mercurv absolute which will leave aoproximatelv 10 ka (22 rounds) of vinyl chloride in a 18,900 liters (5000 gallon) reactor. A vent valve is opened, the vacuum relieved, and the vinyl chloride remaininn in the reactor is discharaed to the atmosphere by steam jet or blower. The auanti'tv of vinyl chloride remaining in the reactor after evacuation is therefore normally discharaed or purged to the atmosphere. This emission is called the reactor opening loss and the average emissions from this source, 0.46 kg VCM/100 kg (lb VCM/100 lb) PVC produced, is shown in table for suspension plants. The manhole is Q opened and the reactor washed with water. If it is necessary to enter the reactor for cleaning, additional air purging mav be conducted to remove any remaining traces of vinyl chloride. The reactor manhole is closed and the reaction cycle is complete. Solution plants use a continuous nrocess and do not have an eouivalent emission. A gasholder and purge water system controls emissions from the typical plant cycle described ahove by reducing the reactor opening loss / because all the vinyl chloride left in the reactor after the batch is discharged is displaced (or purged) to the qasholder. In addition, the emission from the vent condenser is reduced because there is less air left in the system before the reactor is charged. This air, as described above, increases the volume of gas that must be vented from the monomer recovery system. These points are discussed below. When a qasholder and purge water system is used to control emissions from the reactor, the cycle starts with a clean empty reactor which is 4-34 COLORITE 008504 full of air. The air is displaced to the atmosphere by filling the rea completely full of water. The water is then used to pressurize the reac and all flanges are checked for leaks. The reactor manhole flanae is a frenuent source of leaks in most plants and this source of fugitive emissions is also eliminated when this technique is used. *' Vinyl chloride vaoor is now used to disolace the water from the reactor and no air is permitted to enter. The bottom reactor valve is closed, the rest of the vinyl chloride, the water, and the other chemicals are charged and the reaction takes olace. After the reaction is complete the batch is discharged to a strioper. As previously explained, because there was no air left in the reactor before the reaction began the monomer recovery system emissions will be reduced since there will be less air to be vented through the vent condenser. The average vent condenser loss reported by all susoension plants wa-s 0.48 kg/100 kg (lb VCM/100 lb) PVC produced. (See chapter 3, table 3-5). The one plant using a gasholder and purqe water system reports a loss from this source of 0.02 kg VCM/100 kq (lb VCM/100 lb) PVC produced.^ The reactor which contains (mostly) vinyl chloride vanor after the batch has been discharged is now completely filled with hot water to disolace or purge all of the residual vinvT chloride vanors from the reactor to the gasholder. This reduces the reactor purge emission which occurs at this place in the cycle. The one plant using a gasholder and purge water system reports a loss from this source of 0.16 kg (0.35 pounds) of vinyl 2 chloride per reactor opening for a 15.,100 liter (4000 gallon) reactor. This is equivalent to 0.2 kn (0.44 rounds) of vinyl chloride for a 18,900 liter (5000 gallon) reactor. The reactor manhole is opened as the water is drained from the reactor. J 4-35 COLOR!TE 008505 Air is pulled into the reactor so the small amount of vinyl chloride remainina is not emitted to the room. The reactor is then cleaned as rcouired. If reactor entry is required the small amount of vinvl chloride remainino in the reactor is vented to atmosohere with a flexible ventilation hose that is dropped into the reactor through the open manhole. The gasholder also helps to Drevent reactor safety valve discharges which sometimes occur because of onerator error or equipment malfunction. When the operator sees that the polymerization reaction is proceeding too fast and the pressure is above normal he can manually vent the reactor to the gasholder. The gasholder can be sized to hold all the vinyl chloride present in one complete batch. A more complete description of this system is given in Section 4.6, Safety Valve Discharges. The gasholder also acts as a surqe tank between the plant and the vinyl chloride recovery system. The gasholder can accept and hold a short term hiah volume surge of vinyl chloride which v/ould normally overload the recovery system. The gasholder also is used to prevent fugitive emissions from other 2 sources in the plant. The relief valves from compressors can be yented to the holder as can rupture disks and relief valves for certain pressure vessels other than the reactors. The gasholder can also be used to vent tanks, pumos, lines, weigh scales, condensers, knockout pots, etc., before they are opened for maintenance or during equipment inspection. This use is covered in Section 4.5, Fugitive Emissions. There are disadvantages to the gasholder nurqe water system. The cycle time per batch must be increased to allow time for the reactor water purges. A aasholder sized to hold the charge from a tvnical 18,900 liter (5000 gallon) reactor will have a capacity of 2630 cubic meters (n3,0nQ cubic feet) which will require a relatively larue olot of land. 4-36 COLORITE 008506 References for Gasholder and Put go Water System ]. Letter with attachments from J. P. Mudd, Plant manager. General Tire and Rubber Company, Ashtabula, Ohio, to Don R. Goodwin, EPA, June 17, 1974. 2. Letter with attachments from J. R. Mudd, Plant Manager, General Tire $ Rubber Company, Ashtabula, Ohio, to Don R. Goodwin, EPA, October 29, 1974. 4-37 COLORITE 008507 4.8 IMPROVED STRIPPING Slurry Stripping After the completion of polymerization in a typical suspension, dispersion, or bulk process, approximately 10 to 15 percent of the original vinyl chloride monomer charge remains unreactedJ This vinyl chloride is present in the vapor space in the top of the reactor, is dissolved in the water (in suspension and dispersion processes) or is dissolved (or trapped in) the polyvinyl chloride granule itself. In the past, some part of this vinyl chloride has usually been recovered and recycled to the process, but the amount recovered was based on economic considerations alone. At the end of the polymerization step most of the gaseous vinyl chloride present in the vapor space can be removed simply by venting the reactor to a recovery system. The vinyl chloride remaining in the water or in the polyvinyl chloride granules can be recovered by a process known as stripping. In this step heat and vacuum are used to drive off the volatile vinyl chloride from the reactor contents. The vinyl chloride that is driven off is then sent to the monomer recovery system where it is condensed to liquid by a combination of pressure and cooling and returned to vinyl chloride storage for reuse. Most of the residual vinyl chloride trapped in the polyvinyl chloride particle is emitted to the air as the granules move through the process from the reactor to the slurry blend tank, centrifuge, dryer, and storage. Although technology exists to control the emissions from these individual points, and this technology is discussed in other sections of this chapter, an alternate method of control would be the reduction of the residual vinyl chloride content in the resin through optimization of the stripper operation. This will reduce substantially the emissions from the slurry blend tank, the centrifuge, the dryer and the bulk storage silos. The effectiveness of 4-38 COLORITE 008508 stripping depends on the type of resin and the design of the stripping system. Resin stripping also enables the polyvinyl chloride producer to recover and recycle some of the vinyl chloride that would otherwise be emitted to the atmosphere. The amount of vinyl chloride remaining in the polyvinyl chloride particles after the stripping operation depends primarily on the particle size and porosity, the temperature and vacuum used, and the retention time in the stripper. If the particles formed in the reactor are small and porous and a higher temperature is used for stripping the reduction in the residual monomer of the resin will be greater. The equipment that is presently used for stripping is shown in the flow diagram figure 3-1. In this diagram the stripper is shown as a separate vessel, which is the usual case, although in some plants the stripping step is carried out in the reactor under vacuum. In either case the vacuum is generally applied with a reciprocating or water seal compressor which also compresses the "stripped" vinyl chloride to a liquid in a series of after coolers and condensers in the monomer recovery system. The liquid vinyl chloride is returned to the system and reused. As previously explained, most of the vinyl chloride that is retained in the resin after leaving the reactor or stripper will eventually be emitted to the atmosphere from the slurry blend tank, the centrifuge, dryer, or storage silos. However the specific quantity of vinyl chloride that will be emitted from each one of these processing steps will vary with the retention time and temperature maintained in the slurry blend tank, dryer, and storage silo and with the particular type of resin. These factors vary considerably from plant to plant and within a given plant. As a result it is more practical to consider the total emissions from these sources rather than 4-39 COLORITE 008509 the individual emissions from each source. There is considerable variation in the efficiency of stripping at the various plants within the industry. In fact a few plants do not recover any of the vinyl chloride remaining at the end of the polymerization step and others only recover that part that can be recovered without the use of vacuum (as of May 1, 1975). Host companies now have development work under way to improve the efficiency of their stripping operations. Increasing the temperature, reducing the pressure (increasing vacuum) and increasing the duration of the stripping operation (residence time) favor removal of the vinyl chloride from the resin. Increasing the temperature is the most effective technique for reducing the vinyl chloride content of the resin. This method uses steam which may be applied to the outside jacket of the polymerization kettle or introduced directly into the bottom of the stripper. The disadvantage of this method is that some resins are sensitive to heat and there may be product degradation. Increasing the time of the stripping step is also effective in reducing the vinyl chloride content. This also requires additional steam and there may be a loss of production if additional stripper capacity is not provided to make up for the time lost during stripping. Typically an "improved" stripping operation would take place at 77C (170F) at 392-458 millimeters (15-18 inches) of mercury vacuum absolute for 10 to 20 minutes.**' Some manufacturers are also investigating the possibility of changing the resin recipe and/or reaction conditions to produce a resin whose properties are more amenable to monomer removal by stripping. When this method is used it may be necessary to test the modified resin in the compounding and fabricating equipment to make sure that no significant changes have occurred in the resin which makes it unsuitable for use. Whatever method of reducing the monomer content of the resin is used, it is 4-40 COLORITE 008510 likely tout procedures for each resin grade will have to be develop? separately. Sone polyvinyl chloride producers are phasing out grades or resin that a^e very difficult to strip well. Information presently available indicates that copolymer suspension resins and dispersion resins are more difficult to strip than other resin tynes.4'^'^'5,10 Copolymer suspension resins are apt to be more difficult to strip because these resins form granules which are less porous which make it more difficult for the vinyl chloride to escape from the particle. Dispersion resins are difficult to strip because the heat required for the stripping step in some way destroys the soap film separating the resin particles causina the particles to coagulate. Dispersion resins have commercial value because of their small particle size. Coagulation destroys this property. The figures for "Uncontrolled Emissions" in table 4-3 show the average emissions from suspension plants reported in reply to the EPA section 114 request of May 30, 1974. The uncontrolled average emissions from all four types of polyvinyl chloride processes are shown in tables 3-6, 3-7, 3-S and 3-9. For the most part these data represent economic recovery levels rather than optimum pollution control levels. The result of improved stripping on the residual vinyl chloride content of the four types of polyvinyl chloride resins is presented in section 4.11. Although additional development work will be reauired to perfect improved stripping, the data obtained so far indicate that all types of resins can be stripped to 400 ppm or lower except dispersion resins. The data indicate that 2000 ppm represents the current lower limit of the technology for dispersion resins. The figures for "Achievable Emission Levels" in table 4-3 show the effect of this improved stripping on the emissions from an average suspension plant. If' 4-41 COLORITE 008511 improved stripping is not oossible the operators have the options of installing either carbon adsorbers or incinerators on the slurry blend tanks, centrifuge, dryer, and storage silos. See chapter 4, sections 4.1 and 4.2. Commercial stripping in the United States is presently done batchwise from the stripper kettle or from the reactor itself. Other stripping methods are under development which may increase the efficiency of the stripping or decrease the cost of the stripping step.^ One of the most promising methods would be the use of countercurrent multistage column stripping. A diagram of this process is given in figure 4-1. The rate of vinyl chloride stripping is proportional to the difference between the amount of vinyl chloride in the resin and the amount of vinyl chloride in the water surrounding the resin particle. The primary advantage of multistage contacting is that this driving force is maximized because the resin leaving the column is contacted with water which contains no vinyl chloride. In batch stripping the resin is surrounded by water that is partly saturated with vinyl chloride during most of the stripping step. If improved stripping is used to control emissions from the slurry blend tank, centrifuge, dryer, and storage silo (rather than individual control devices on each source) then the vinyl chloride content of the final product resin should be less. This is an advantage to compounders and fabricators because it reduces the amount of vinyl chloride which can be released during processing. If the average stripped suspension resin has a vinyl chloride content of 400 ppm out of the stripper and 50 ppm out of the dryer then the maximum emission factor possible during storage, compounding and fabrication is 0.005 kg VCM/100 kg (lb VCM/100 lb) PVC. 4-42 COLORITE 008512 COLOR!TE 008513 Figure 4-1. COUNTER CURRENT STRIPPING COLUMN In summary, improved stripping is a preferred method of emission control because it makes the use of other more expensive methods of control unnecessary; it recovers vinyl chloride for reuse; and it reduces the residual monomer content of the finished resin product. 4-44 COLORITE 008514 References for Improved Stripoing j. Foster 0, Snell, Inc., Economic Impact Studies of the effects of Proposed GSHA Standards for Vinyl Chloride, September 27, 1974, Exhibit A-7, p. 2. 2. Letter from J. R, Mudd, Plant Manager, General Tire and Rubber Comoany, Ashtabula, Ohio, to Don R. Goodwin, ERA, October 29, 1974. 3. Letter from W. C. Holbrook, Manager, Environmental Control Engineering, B. F. Goodrich Chemical Company, to Don R. Goodwin, EPA, November 15, 1974. 4. Reference 3, p. 4 and 6. 5. Reference 2, p. 2. 6. Letter from W. P. Anderson, Director, Environmental Sciences, Tenneco ------Chemical Company, to Don R. Goodwin, EPA, October 18, 1974. 7. Reference 3, pp. 16 and 17. 8. C. D. Callihan and E. McLaughlin, Vinyl Chloride Removal from Polyvinyl Chloride, Louisiana State University, Baton Rouge, Louisiana, February 1975. 9. See tables 4-4 and 4-5. 10. Society of the Plastics Industry, "Comments on the Draft Document - "Standard Support - Environmental Impact Statement," presented at the NAPCTAC meeting, Washington, D.C., March 25, 1975. 4-45 COLORITE 008515 4.9 Tb\CTOR jPLi.Il.G LuSS CONTROLS Eocn tine a reactor is opened for maintenance, cleaning, or inspection soi.ie vinyl chloride escapes to the atmosphere. Traditionally in polyvinyl chloride plants it has been necessary to open reactors after the completion of every reaction to clean the kettle walls of polyvinyl chloride build-up accumulated during the course of polymerization. Each reactor, or polykettle, has a hatch which is opened and entered by a worker who scrapes and washes the reactor walls with a cleaning agent. This cleaning takes place after the polyvinyl chloride slurry has been transferred to another part of the process and after most of the vinyl chloride monomer has been removed by vacuum or by displacing it to the monomer recovery system by filling the reactor with water. The vacuum, does not remove all of the monomer left in the reactor and in the polyvinyl chloride resin on the reactor walls. A blower and flexible ventilation hose are usually used to clear the reactor of this monomer after the reactor is opened. The amount of monomer emitted is dependent on the size of the reactors, the effectiveness of the vacuum, the type of resin produced, and the incidental effectiveness of other control techniques such as water purge systems or improved stripping in the polykettles themselves (see sections 4.7 and 4.8) to remove the monomer. Bulk plants can reduce emissions from this source by a more effective vacuum system relieved by an inert gas, such as nitrogen. With each successive vacuum/purge release, more vinyl chloride is removed. It is possible to reduce the number of reactor openings and in turn reduce the monomer that escapes. High pressure water sprays could be inserted through a gland in the reactor to clean the kettle walls. This method could allow the reactors to stay closed for four to eight batches. 4-46 COLORITE 0085X6 ;,'ew plants are using a combination of recipe reformulation and reactor cesiyn to minimize scale formation. In this case, the cleaning agent is part of the reaction ingredients. New plants are claiming 80-SQ batches between openings and there are plans by one plant to decrease the frequency to one opening per 200 batches.^ At least one plant is experimenting with circulating an organic solvent through the reactors to dissolve any solids which remain in the reactor after the batch is completed, A heated solvent such as tetrahydrofuran or ethylene dichloride is pumped into the reactor and agitated for some period of time until the solid scale is broken up '5nd dissolved. The mixture is then distilled to separate the solvent, vinyl cnloride and polyvinyl chloride. The solids are reclaimed or discarded, the monomer is recovered and the solvent is recycled. The frequency of opening the reactors is 2 reduced to one opening per 40-60 batches with this system. There is some economic incentive to installing solvent cleaning systems in order to reduce the personnel requirements for reactor cleaning. Recent Occupational Safety and Health Administration's (OSHA) regulations concerning the safety of personnel involved in cleaning the reactors has given further impetus to utilization of solvent cleaning. The more significant benefits of this technique toward a reduction of air pollution have been outlined by a company which is currently experimenting with the method in its 20-year old polyvinyl chloride plant to eliminate reactor openings with the exception of equipment malfunction. These benefits are: a. Eliminates fugitive vinyl chloride leaks due to opening the poly kettle. b. Eliminates emissions from handling, in the open atmosphere, poly kettle cleanings and scrapings, as these typically contain high 4-47 COLOR!TE 008517 levels of residual vinyl chloride. c. Polykettle openings and closings can be eliminated and therefore the polykettles can be made tighter and more leak proof using 2 permanent Opening and closing fittings. There are, however, some problems with reformulation and solvent cleaning. The method of reformulation reported by two new polyvinyl chloride plants may be practical only when the reactor is designed to accomodate the new recipes. The high pH of the new recipes require stainless steel reactors. Without extensive retrofitting, older plants may be unable to change recipes. There are some emissions of the solvent used in the solvent cleaning technique during regeneration and eventual reactor openings. The solvents used are pollutants in themselves and some are expensive. Losses have not been quantified but have been estimated at 4.56 kg (10 lb) per reactor cleaning. Nearly all of the losses are lost to the plants inprocess wastewater. The advantage of the solvent cleaning system is that it reduces the frequency the reactor has to be opened for cleaning which in turn reduces the vinyl chloride emissions. If the frequency of purges is reduced from one every batch to one every 80 batches, then the controlled emissions is 1/80 of the uncontrolled. This would mean a reduction from .14 to 0.0018 kg VCM/100 kg (lb VCM/100 lb) PVC produced. The indirect benefit of solvent cleaning is that as reactor entries are decreased, the amount of inerts in the recovery system decrease which decreases the vinyl chloride emissions from the noncondensable vent purge in the monomer recovery system. (See section 4.4 of chapter 4). It is difficult to quantify this reduction as inerts can enter the recovery system from a number of other sources. 4-48 COLOR!TE 008518 ^`6 f11"'21 cCS s for Reactor -ven i n<j LoSi Controls !. Letter with attacnmari ts from Ralpn Ferrell, Conoco Chemical Co., to Don R. Goodwin, EPA, November 19, 1974. 2. Letter with attachments from 0. R. Mudd, General Tire and Rubber Company to Don R. Goodwin, EPA, June 17, 1974. 3. Conversation with H. E. Jewett, General Tire and Rubber Company, Ashtabula, Ohio, February 20, 1975. 4-49 COLORITE 008519 4.10 EMISSIONS AND CONTROL TECHNIQUES FOR INPROCESS WASTEWATER Vinyl chloride can be contained in the inprocess wastewater from a polyvinyl chloride plant or an ethylene dichloride-vinyl chloride plant. Based on the solubility of vinyl chloride in water at 38C (10QF) and one atmosphere, the inprocess wastewater entering the treatment ponds from either plant can contain as much as 1.33 milligrams of vinyl chloride per gram of water (1.33 lb VCM/1000 lb water)J In a polyvinyl chloride plant, the sources of the ' inprocess wastewater are the reactors, centrifuges, water seals in the compressors, floor and sewer drains, vinyl chloride recovery system, and decanter blowdown. Vinyl chloride may be present in any of these wastewater streams. The average wastewater flow rate fror a polyvinyl chloride plant is about 15.3 liters/kg (1.84 gallons per pound) of product.^>3,4,5,6,8 ac^ua-] vinyl chloride content of the wastewater stream entering the treatment ponds is reportedly between 0.0005 and 0.05 milligram per gram of water (lb/1000 lb)^*^ with an average of about 0.016 milligram per gram (lb/1000 lb) of water. The discharge from the centrifuges accounts for about 56 percent of the vinyl chloride in the total in-process wastewater. Three plants report that the vinyl chloride content of the effluent leaving the treatment ponds is zero (nondetectable)One plant reports finding 21.5 ppm vinyl chloride in untreated wastewater and 0 ppm in treated effluent. It has not been determined what causes this reduction in the vinyl chloride content during treatment. These plants have biological and aeration(mechanical or natural treatment ponds. There are three possibilities to cause this reduction: 1) the vinyl chloride is biologically or chemically reduced, 2) the vinyl chloride is absorbed in the resin which settles out, or 3) the vinyl chloride is released to the atmosphere durlnn aeration. It is assumed, however, that all the vinyl chloride in the wastewater is released to the atmosphere in the 4-50 COLORITE 008520 treatment ponrU, Therefore, based on an average of 0.016 inilligrams of vinyl chloride per gram of water discharge (lh/1000 lb water) it is estimated that 0.025 kilograms of vinyl chloride are released from the treatment ponds at a typical polyvinyl chloride plant per 100 kilograms of product (0.025 lb/100 lb). However, based on the potential maximum vinyl chloride content of 1.33 milligrams per gram of water, 2.04 kg of vinyl chloride could be released per 100 kg product. In a balanced ethylene dichloride-vinyl chloride plant, the sources of the wastewater are the scrubbing systems for hydrogen chloride separation from crude EDC, by-product washing from certain purification process-s, and miscellaneous water wash floor drains. The inprocess wastewater flow rate is about 2.08 liters per kilogram [0-25 gallons per pound) of product.10,11 The actual vinyl chloride content of this wastewater stream entering the treatment pond is reportedly about 0.0034 milligram per gram of water (0.0007 kg per 100 kg of product).10 The wastewater is stripped prior to entering the ponds to recover organics. The vinyl chloride content of the effluent leaving the treatment ponds is reportedly zero (nondetectable),10 Wastewater treatment is similar to that in a polyvinyl chloride plant. As with the polyvinyl chloride plants, it is assumed that all \ the vinyl chloride in the wastewater is released to the atmosphere resulting in an emission rate of about 0.0007 kg of vinyl chloride per 100 kg of product. (.0007 lb/100 lb). However, based on the potential maximum vinyl chloride content of 1.33 milligrams per gram of water, 0.28 kg of vinyl chloride could be released per 100 kg of product. Based on solubility data1, it is estimated that essentially all the vinyl chloride in the wastewater would be released to the atmosphere. In the presence of a large amount of pure air, the partial pressure of vinyl chloride would he extremely small causing the solubility of vinyl chloride in the water to be 4-51 COLORITE 008521 49 _ essentially zero. It appears from reported data ' that the retention time of 3n wart^wazer treatment system is sufficient to allow all the vinyl chloride to be released prior to discharge. This nay be due to evaporation. Vinyl chloride, with a density of 0.9834 at -20C, is expected to rise to the surface of the water. This emission source can be controlled by stripping out the vinyl chloride in a stripping column prior to the treatment ponds. The vent gases from the stripper containing the stripped vinyl chloride can then be returned to the process or treated in the plant vinyl chloride control system. The principal way of stripping is steam stripping. A high temperature of the inprocess wastewater will facilitate stripping, since less steam will be required for heating the water to the boiling point. Stripping can be performed in multistage (multiple trays) columns with a large countercurrent flow of steam, or in batch tanks. Countercurrent operation gives an advantage because the partial pressure of vinyl chloride in the steam entering the bottom of the column is zero. This establishes the maximum driving force for vinyl chloride removal. In a batch operation, steam could be sparged into the stripper providing the heat and agitation necessary for vinyl chloride removal. In either case, mixing is essential for good stripping. I TO In summary, according to the literature it has been demonstrated ' that vinyl chloride monomer concentrations in wastewater can be reduced by increasing vacuum and temperature. With the proper vacuum and temperature any given vinyl chloride concentration can be achieved using the stripping techniques described above. 4-52 COLORITE 008522 trances 1. The Solubility of vinyl Chloride iri Polyvinyl Chloride, Serecs, A. R. . A.C.S. Polymer Reprints, 1974, 2_, p. 197. 2. Personal communication with Dave Francke, Air Products and Chemicals, Inc., Escambia, Florida, November 25, 1974. 3. Personal communication with Bob Luckan, Air Products and Chemicals, Inc., Calvert City, Kentucky, November 25, 1974. 4. Letter with attachments from R. N. Wheeler, Jr,, Union Carbide Corporation to Don R. Goodwin, EPA, June 26, 1974. 5. Personal communication with Doug MoWhortar, b. F. Goodrich, January 28, 1975. 6. Personal communication with Jay Harpring, Continental Oil Comnanv, January 30, 1975. 7. Personal communication with Joe Mudd, General Tire, January 30, 1975. 8. Letter with attachments from John T. Barr, Air Products and Chemicals, Inc., to Leslie B. Evans, EPA, June 24, 1974. 9. Letter from R. E. Van Ingen, Shell Oil Company, to Leslie B. Evans, EPA, January 31, 1975. 10. Development Document for Effluent Limitation Guidelines and New Source Performance Standards for the Major Organic Product Segment of the Organic Chemicals Manufacturing, EPA, April 1974. 11. Robert Bellamy (Houdry Division of Air Products and Chemicals). Telephone conversation with John Christiano (EPA) on February 6, 1975. 12. Vinyl Chloride Removal from Polyvinyl Chloride, Callihan, C. D., and McLaughlin, E., Report for EPA, July 1975, p. 45. 4-53 COLORITE 008523 4.11 PARTICULATE CONTROL Polyvinyl chloride particulate emissions are essentially the product resin from polyvinyl chloride plants which is lost from process equipment, such as dryers, storage bins and silos, bulk loading operations and baggers, and from resin transfer equipment. Polyvinyl chloride product is air conveyed through dryers and collected in fabric filters or centrifugal separators. The resin is then air conveyed to silos or bagging operations. Particulate can be emitted with the air exhaust from any of these points. Particulate (resin) collection devices used in the industry include centrifugal separators and fabric filters. These devices are used either separately, in stages, or in combination and are used primarily to separate the resin from conveying or drying air. The efficiency of the devices corresponds to economic recovery levels and is not necessarily designed for maximum particulate reduction. Table 4-11 lists the different devices used on each facility and subcategorizes the facility where necessary. For instance, it can be seen that four types of dryers are used at polyvinyl chloride plants. Rotary, flash, and fluidized bed dryers are used in the suspension process and spray dryers are used in the dispersion process. The drying chamber in the spray dryers is shaped like a centrifugal separator and serves as a primary product collector to remove larger size resin particles. Therefore, the dryer exhaust from the dispersion process contains very fine particles, which makes it necessary to treat the exhaust gases from spray dryers with fabric filters. Fabric filters have also been utilized to treat the exhaust gases from storage bins, bulkloading operations, and bagging machines. The control devices used on these sources of particulate emissions are discussed below. Particulate emissions from these devices for each 4-54 COLORITE 008524 'aci:iby are presented in Table 4-11. Design collection efficiencies of cbosc- collectors are generally high in order to minimize loss of product. Reported outlet loadings indicate that these collectors generally operate near their design efficiencies. The particulate (resin) being collected is generally about 44 microns in size. This large size makes tfie resin relatively easy to collect in either centrifugal separator or fabric filter. A control device designed for high collection efficiency (99.9 percent) can achieve emission levels of less than 0.0001 kg/kg of product. [8 kg/hr (17.6 Ib/hr) from a 68 million kg product/year plant (150 million lb product/year p'ant)]. 4.11.1 Centrifugal Separators Applied in the Polyvinyl Chloride Industry Centrifugal separators utilize centrifugal and gravitational forces for separation of the resins from the conveying air. The resin laden air enters the separator tangentially which subjects the resins to the separating forces. The centrifugal force drives the dust particles to the collector wall, gravitation drives the concentrated resin downward to the cone outlet, and the resin is discharged into a collection hopper while the cleaned gas flows upward in an inner vortex to the gas outlet tube. The separators utilized in the industry may be installed in single or multiple arrangements in parallel or in series. Separators are generally suitable for separating solid particles in size ranging from 3 to 200 microns. The size of the resins being collected except from a spray dryer is generally over 44 microns. Based on industrial responses to the May 30, 1974, letter transmitted from EPA to the management of companies producing polyvinyl chloride, under the authority of section 114 of the Clean Air Act, collection efficiencies of the centrifugal separator used in the industry 4-5b COLORITE 008525 4.12 DATA DEMONSTRATING CAPABILITY OF SELECTED CONTROL TECHNIQUES The purpose of this section is to present the available data which describe the status of control techniques discussed previously. These data come from emission tests, control equipment vendor studies and pilot studies by polyvinyl chloride producers. The data './ill be outlined and a discussion will be made of important points where necessary. 4.12.1 Stripping In response to a request made under section 114 of the Clean Air Act, a number of producers gave information on stripping dispersion and suspension resins in April 1975. Table 4-5 shows each plant's April, 1975 and projected status of dispersion resin stripping. Table 4-6 shows similar information for the current stripping success of several producers making suspension resins. ,, . Data shown in sections 4.12.1.1 through 4.12.1.3 were given to EPA in the Fall of 1974 in,response to section 114 requests. They show the stripping conditions which were used at that time to achieve certain residual vinyl chloride levels in the polymer resin. -: 4.12.1.1 Company Ai- The values below were obtained by direct steam stripping at 77C (170F) at 380 to 457 millimeters (15 to 18") of mercury vacuum for 10-20 minutes. 4-57 ' COLOR!TE 008526 Suspension Resins ASTM^ Cell Class GPT-2625C GP2-16340 GP3~-15340 GP4-15340 GP6-15343 GpT-14443 GP2-14443 GP3-15433 GP5-15433 GP6-15433 Copolymers C11-8500 Cl T-3500 Prod. 5 5 13 35 24 0 1 1 5 9 1 1 PPM VCM into stripper (40-60) x 103 3 (40-60) x 10 (50-70) x 103 (60-90) x 103 (90-120) x 103 (80-100) x 103 Avg. ppm VCM out of stripper (dry basis) 3,050 2,050 1,200 1,050 950 600^ (80-100) x 103 (80-100) x 103 (90-110) x 103 (100-140) x 103 550 500 450 450 Avg. ppm out of dryer 308 162 104 95 82 25 16 21 15 18 (40-60) x 103 (90-110) x 103 2,100 1,000 280 95 Emission factor La VCM/ 100 kn PVC 0.27 0.18 0.09 0.09 0.08 0.06 0.06 0.05 0.05 0.05 0.18 0.09 --^ASTM cell class is standard definition of resin. ASTM-D-1755 --2/ Based on limited data (Less than three samnles). This company plans to install secondary strippers to further reduce the residual vinyl chloride content shown above by increasing the stripping temperature to as high as 85C (185F) and the residence time to one hcur. 4.12.1.2 Company B3- The values below were obtained by conventional steam stripping at the conditions shown. Values are for 1973 and 1974. 4-58 COLORITE 008527 r,s iun_ P.es 1 ns 4S~M Cell Class T ime (min.) 1973 Temp. Vacuum (c.) ("Hq) ' RVCM2^/ Time (PPm) (min.) 1974 Temp. Vacuum (c.) ("Hq) RVCM^7 (ppm) GPS-15443 40 70 15 8,500 45 SO 13 2,700 GP5-15443 x GPS-15543 40 75 15 8,500 45 80 13 2,400 GP4-16043 / GP-3 15343 a GP-1 16243 * 45 Copolymer 30 80 50 13 10,000 45 15 10,000 30 80 aO 13 2,000l/ 15 10,000 Improvement in RVCM achieved by changing recipe to obtain more porous resin. --^RVCM - Residual V_inyl hloride Monomer Emulsion Resins Time (min.) Dispersion NA--^ Latex naI/ 1973 Temp. Vacuum (c.) (" Hq) RVCM^/ Time (PPm) (min.) 1974 Temp. Vacuum (C.) (" Ha) RVCM^ (ppm) 60 20 7,000. NA 65 18 5,500 65 22 800 NA 60 15 800^ --^Stripping is continuous --2/ RVCM - Residual Vinyl Chloride Monomer --3/Equilibrium has been reached. ~Further reduction of vacuum and increase in temperature ?/ill not achieve reduced RVCM. New technology is required for further RVCM reductions. 4-59 COLORITE 008528 Bulk Resins 1973 1974 AST" GP2-16243 Tine (min.) 120 Temp. (c.) 70 Vacuum (" Ha) 20 RVCM^ Time (Dpm) (min.) 3,000 150 Temp. (c.) 75 Vacuum (" Hq) 25 RVCM^ (onm) 300--^ GP2-49243 ! i GP3-4943 J -/fVCM - Residual V_inyl Chloride Monomer -Function of both increased stripping and increased VCM polymerization conversion Company B is now experimenting with an improved method of stripoinq which improves the efficiency of monomer removal from the oolymer, and for porous particles will reduce monomer to low levels (< 100 ppm). The process uses a continuous countercurrent steam striooing column. The followina is their own description of the system. "The slurry will be fed to the top of a stripping column and allowed to trickle downward countercurrent to a flow of steam ascending the column. Mixed vapors of steam and monomer will be condensed and allowed to flow into a decanter. Monomer can be drawn off and reused in the process. The aaueous layer will be returned to the top of the column so that its monomer content may be added to the overhead stream, with excess water flowing out of the bottom of the column with the slurry. The process has been used to date for only a few of the many recipes represented in [Company B] production. The column is very effective for those resins composed of porous particles. For these resins it is expected that residual monomer levels substantially below 100 ppm, and in some cases less than 10 ppm, can be achieved. For non-porous resins less complete removal of monomer can be achieved." 4*60 COLOR!TE 008529 4.12.1 .3 Company c in' data are based o>i iv.ited plant experience in implementing Research arc Development recommendations. The reduction in vinyl chloride has been achieved by increasing thermal input, vacuum, time, or combinations of tnese parameters during the monomer recovery step. Suspension Resins 1974 - Residual Vinyl Chloride Monomer Homopolymer Low M.W. Homopolymer High M.W. Into dryer 500 ppm 200-300 Out of dryer 100 ppm 100 Dryer emission factor lb VCM/ 100 lb PVC 0.04 0.01C Dispersion-^ 1974 - Residual Vinyl Chloride Monomer Copolymer All 100-150 50 0.0075 Into dryer Out of dryer Dryer emission factor lb VCM/ 100 lb PVC 8,000-22,000 ppm 15-50 ppm 1.50 --^Wacher process 4.12.2 Carbon Adsorption 4.12.2.1 Vendor Data^- One vendor of activated carbon has submitted data from laboratory studies on the control of vinyl chloride by earbon adsorption. The conclusions of the studies were: activated carbon readily absorbs vinyl chloride in concentrations ranging from 50 parts per million (ppm) to over 30 percent by volume (300,000 ppm); one hundred percent removal of vinyl chloride is technically feasible using dual beds of activated carbon; activated carbon saturated with vinyl chloride can be regenerated in-nlace using either steam or hot nitrooen to 4-61 COLORITE 008530 desorb the vinyl chloride; and after 15 cycles of operation (saturation, desorption, a1 j drying), no polymeM zat': on of vinyl chloride had occurred on the bed. The following data were developed by this vendor in their study of the applicability of carbon adsorption to vinyl chloride recovery. The discussion and data are from the company's Bulletin 23-200. "Cyclic Test Results The data in table I represent the results of tests conducted to determine the adsorption and desorption characteristics of activated carbon for a proposed VCM recovery system. A nitrogen stream containing 1 percent by volume VCM was passed through a 4.5-inch deep bed of Pittsburgh Type PBL 6x16 mesh activated carbon at ambient temperature and pressure at a flow of 30 feet per minute (fpm) until VCM breakthrough occurred. At this point, the VCM was desorbed by passing either steam or nitrogen at 300F through the carbon bed. The system was operated for fifteen cycles-using steam as the regenerant for the first ten cycles and hot nitrogen for the last five. As the data in table I indicate, no less in adsorp tive capacity was observed over the entire 15 cycles of 4-62 COLORITE 008531 operation. The f ctuations -,r, capacity resulted from variations in the 1 oj-'cent VC.'-" flow and, in some cases, from incomplete water removal from the carbon following regeneration. On the basis of analyses of the carbon conducted prior to and following the test, it was concluded that VCM had not polymerized in the carbon bed (table II). VCM Breakthrough Studies A series of tests conducted to compare the VCM breakthrough capacities of various grades of activated carbon under conditions of interest to VCM and PVC manufacturers indicates that fine-pore, high surface area carbons such as Pittsburgh Type BPL and Type PCB are the most efficient; and, that fine mesh size carbons produced longer break times and steeper breakthrough curves (figures 1 and 2). Using a gas chromatograph with a sensitivity of 25 ppm, no VCM was observed in the effluent air prior to breakthrough. Tests were also conducted to determine minimum breakthrough characteristics for Pittsburgh Type PCB 12x30 and Type BPL 12x30. The results of these tests, using a Flame Ionization Detector with a sensitivity of 0.1 ppm VCM are depicted in figure 3 and figure 4. On the basis of these breakthrough studies, it was concluded that activated carbon can remove essentially 100 percent of VCM in air until breakthrough occurs, at 4-63 COLOR!TE 008532 which time over 90 percent of the carbon bed is saturated with 7CM vapor. using the data generated during this series of tests, figure 5 was developed using a computer correlation to determine the adsorptive capacity of Pittsburgh Type PCB 12x30 as a function of VCM concentration. Note that even in concentrations as low as 10 ppm. Type PCB carbon's capacity for VCM is 1 percent by weight. The adsorptive capacity of Pittsburgh Type BPL 12x30 as a function of VCM concentration is depicted in figure 6." TABLE I CYCLIC ADSORPTION OF U VINYL CHLORIDE ON BPL 6x16 Cycle 1 3 5 7 9 11 13 15 Adsorbed--Wt. 12.1 9.7 11.9 12.4 9.9 11.8 12.3 12.3 TABLE II CARBON ANALYSIS Apparent Density, g/cc CC14 No. Iodine No. Virgin 0.499 64.1 1113 After Test 0.501 63.2 1106 These studies indicate that a stream containing 50 ppm vinyl chloride passing through a 3.5 inch deep bed of activated carbon at 73 feet per minute will leave the adsorber at less than 10 opm vinyl chloride for 2 hours and 20 minutes of operation. The carbon used was a Pittsburgh Type PCB 12x30. (See figure 3). 4-64 COLOR!TE 008533 t-i TLi 'as 5 and 6 can be used to cal curate the amount of carbon necessary for a given stream. As an r- jmple, a typical rotary system on a Dolyvinyl chloride suspension plant can be described as follows: 170 ppm vinyl chloride on exhaust stream 0.63 kg/100 kg (lb/100 lb) product emission factor 66C (150F) exhaust temperature 8150 kg (18,000 lb) PVC/hr oroduced The amount of vinyl chloride vented in this stream can be calculated from the above data. .63 lb VCM/100 lb PVC x 18,000 lb PVC produced/hr = 114 lb VCM/hr The partial pressure is directly related to the .fnyl chloride content of the stream. 170 ppm x 14.7 psia = 25 x 10 -4 psia -4 Using this calculated partial pressure of 25 x 10 psia on the abscissa of figure 6 and following the line it is represented by vertically to 150F will give a bed capacity of 0.5% on the ordinate of the fioure. .005 = lb VCM collected/lb carbon in the bed The capacity must be halved because of the high moisture content of the stream.' lb carbon required for this drver stream = ^ .0025 = 45,600 lb carbon/hr needed Assuming a breakthrough time of three hours and 2 carbon beds needed 7 , this indicates that 124,000 kg C273,6Q0 pounds) of carbon is needed for this source. 5 4.12.2.2 Polyvinyl Chloride Production Data - One producer of polyvinyl chloride has installed a carbon adsorption unit on a new polyvinyl chloride plant in Pasadena, Texas. This system will treat the gaseous discharges from the slurry blend tanks and the monomer recovery system. In three runs of their pilot study, no polymerization of 4-65 COLOR!TE 008534 R._ ; - 3j% v'wYLCHLORIDi iN AIR FIGURE A - I */. VINYL CHLORIDE IN AIR , for this Study was a 750 BVH air stream containing nt by volume VCM. This stream was passed through a eep bed of activated carbon (60 cc) at 9 fpm. VCM ough was monitored with Bacharach explosion meter wer detectable limit of 50 ppm. FIGURE 2 -- 1% VINYL CHLORIDE IN AIR Test gas for this study was a 3000 BVH air stream containing 1 percent by volume VCM. This stream was passed through a 3.5 inch deep bed of activated carbon at 14.5 fpm VCM in the effluent from the carbon bed was monitored with a Flame Ionization Detector with a sensitivity of 0.1 ppm. FIGURE 5 - ADSORPTION OF VINYL CHLORKJE ON PCB s for this study was a 6000 BVH air stream containing nt by volume VCM. This stream was passed through a deep bed of activated carbon (60 cc) at 75 fpm. A gas itograph with a sensitivity of 25 ppm was used to moni(in effluent air from the carbon bed. FIGURE 3-50 ppm VINYL CHLORIDE IN AIR FIGURES-ADSORPTION OF VINYL CHLORIDE ON PW. tins study was a 15,000 BVH air stream containing ' ''15 stream was passed through a 3.5 inch deep ' .n ca'bon at 73 fpm. A Flame Ionization Detector ' C' 0.1 ppm was used to monitor for VCM in "r fr x -V. ihn i* S +ifS n fxflW 4-00 COLOR!TE 008535 (iilufide v;as found '-`ha carbon bed. The runs vie re made for 79,27, anj 20 f.ycUs on a stream containing 29 mol nercent vinyl chloride 71 mol nercent air. The nominal velocity of the treated stream was 8.84 meters per minute (29 feet per minute) at ambient temoerature (215C or 70CF) and oressure. Data submitted by the company from one run is given in table 4-7. On May 13, 1975, the company reported^ that the production scale unit had gone through more than 700 regeneration cycles since going on stream January 31, 1975. The vinyl chloride monomer content in the exit stream was still below 10 ppm. 4-67 COLORITE 008536 4.12 -3 Incineratiot On October 7, 8, and 9, 1974 the Environmental Protection Agency with ..cott Research Laboratories tested a steam boiler which used chlorinated hydrocarbon as oart of the system's fuel. The steam boiler at the time was burning a combination of twenty one vent streams from the ethylene bichloride, ethyl chloride, and vinyl chloride plants (see figure 9-1). The streams consisted mostly of chlorinated hydrocarbons but the exact flow or composition of each of the twenty one vents was not determined. The oxychlorination vent was not incinerated. The total vent to the boiler was measured and sampled (at 1). The flow rate ranged from 0.425 to 1.7 drv cubic meters per minute (15- to 60 DSCFM), the oercent vinyl chloride in the stream varied from 1.3 percent to 4.0 percent and about 36.8 cubic meters per minute (1300 SCFM) of combustion air was used. The incinerator-boiler was a modified Dixon Firetuhe (6.1 x 1.8 meters or 20' x 6') rated at 4536 kg of steam per hour (10,000 pounds of steam an hour) at 18 atmospheres. During this test the steaminq rate was set at 3890 kg/hr (7,500 lbs/hr). As the heat content of the waste gas went up and down, natural gas was added automatically to maintain this steaming rate. It was, therefore, possible to detect major changes in the composition of the vent gas by observing the natural gas valve position and the draft air valve position. The flue gas from the fire box entered a gas scrubber to remove the HC1. The scrubber was a packed column, 137 cm (54 inches) in diameter and 12.2 meters (40 feet) high. The hot gas was cooled in a quench section of the scrubber by city water sprayed into the gas stream. The scrubbing water for the column was taken from a waste water sump. 4-68 COLORITE 008537 4-69 to waste treatment from plant Figure 4-2. AMERICAN CHEMICAL INCINERATOR TEST, OCTOBER 7-9, 1974. (Data points-A,B,etc.; sample points--!,2,etc.) A level control device maintain a level in the sump by regulating the water to the top of the scrubber. During the test the average pH of waste water was 11,0. The flue gas was sampled after the fire box (point 2) and after the scrubber (point 3). The gas flow was measured at point 3, The vinyl chloride concentration after the fire box (for six runs) averaged 4 ppm. The water into and out of the scrubber was analyzed and no vinyl chloride was found. The data from the six runs indicate that the incinerator was about 99% efficient in combusting vinyl chloride. 4.12.4 Solvent Absorption One company has submitted information on a solvent absorption unit in use at one of their polyvinyl chloride plants. The following is their own description of the system: "The vent gas absorption system used at the Louisville plant was installed in 1950 to recover residual vinyl chloride in vent gases from a process of synthesizing vinyl chloride from acetylene and hydrogen chloride. The process was later adapted to serve solely as a vent gas scrubber following a low temperature monomer condensing system. Inerts from the low temperature (-46C or -50F) condensing system are compressed to 2.36 atmospheres in a liquid sealed compressor using ethylene dichloride as the sealing liquid. The gases are fed into the bottom of an absorption column and pass upward countercurrent to liquid ethylene dichloride flowing downward over [2.54 cm (1") berl] saddles as packing. Unabsorbed gases are cooled in a refrigerated vent condenser to r^~ove solvent before being vented from the system. 4 70 COLOR!TE 008539 * column where 'loped fron the jolveut end returned to the lc-1 to tii-o absorption column for reuse." Operating data from the company indicates that the ethylene dichloride solvent used (circulating at 150 liters or 40 gallons per minute) is capable of controlling emissions to 15 ppm. This is equivalent to 99.9+% efficiency or .01 kg (.02 lb) VCM/hr. The stream is 9.0 standard cubic meters/min. (125 SCFM). 4.12.5 Purge Water System The following calculation for the reactor stripper opening loss was derived from data submitted by one producer on their water purge/gasholder system. According to this submittal^, the company ..." does use a purge water system which forces the monomer from the reactor prior to cleaning and purges it to the gasholder. The average amount of VCM left in the reactor after purging to the gasholder is 3,000 ppm in the vapor." Data Used: 4.000 gal. reactor 7.48 gal,/cu. ft. 3.5 batches between cleaning 10.000 lb./batch Air = .808 Ib./cu. ft. at 25C VCM con. 0.800% or 0.008 VCM/lb. air = 8000 npm Calculation: = 535 cu. ft. (535 cu. ft.) (.0808 lb. air/cu. ft.) = 43.2 lb. air in reactor J 7/(.008 lb. MVC/lb. air) (43.2 lb. air) = 0.35 lb. VCM/opening .00001 lb. VCM/lb. PVC 4-71 COLOR!TE 008540 4.12.6 Process Equipment Purge The data in tables 4.8 and 4.9 show the relationship between equipment size, frequency of purges, and approximate purging emissions when purged to atmospheric pressure for both vinyl chloride monomer and polyvinyl chloride plants. The number of purges are based on estimates of two operating companies. The effect of purging to an assumed level is also shown. 4.12.7 Oxychlorination Process Emissions Data on the oxychlorination process were requested in a letter written under section 114 on April 2, 1975. The data were compiled to compare the emission rates from each of the oxychlorination plants in the U.S. Table 4-10 shows these data. -* 4.12.8 Bulk Polyvinyl Chloride Plants Bulk polyvinyl chloride plants, which can not accept water in the reactors, can purge the reactors by vacuum. The following calculation shows how this vacuum purge can be used to attain the level shown by water purge in section 4.12.7. Postpolymerization reaction Given: 565 ft3 in reactor 15,000 lb of resin are produced per batch 40 lb/ft3 - tapped bulk, density of PVC Attainable vacuum = 650 mm Hg a) Calculate the volume of the gas: 150Q0 lb, 40 1 b/ft3" 375 ft3 565 ft3 in reactor-375 ft3 of resin = 190 ft3 of gas b) Pounds remaining after 3 evacuations to 650 mm Hg 190 ft3 x 379 ib .. ft3- X no 760 x no 760 A no 760 = 0.95 lb. On a pounds per 100 pounds basis .`'95 ;b VCM after evacuation nouo Ib VCM kg VCM fdO ,<g PVC 0.0006 lb VCM locrmpve COLORITE 008541 Lhe Standard 1. [,rater' with attachments fro- J. R. Mudd, General Tire and Rubb \ 2. Letter with attachments from W. C. Holbrook, B. F. Goodrich Chemical Company, to Don R. Goodwin, ERA, November 15, 1974. 3. Letter with attachments from W. P. Anderson, Tenneco Chemicals, to Don R. Goodwin, EPA, October 18, 1974./ 4. "Calgon Bulletin 23-200," Calgon Corporation, Subsidiary of Merck and Company,-Inc*- ------- ------------ -------- - -- 5. Reference 3. 6. - Reference 2. .-- 7. Conversation with R. N. Wheeler, Union Carbide Corporation, South Charleston, West Virginia, February 25, 1975. 8. Conversation with William Lovett,. Calgon Corporation, February.2, 1375. '3. "Letter"with-at"tachments from-^.--Pr-Andersdn"_Tennecoj:heiuTcalsto Leslie B. Evans, EPA, May 13, 1975. 4-73 COLORITE 008542 4.13 Control Techniques Summary This chapter has examined the control techniques which can be applied to control vinyl chloride emissions from each source of emissions in ethylene dichloride-vinyl chloride and polyvinyl chlorioe manufacturing facilities. Emphasis has been placed on identifying the best available control technology for each source of emissions and the emission levels that can be achieved by applying this technology. The following discussion summarizes the associated emission levels for each source of emissions in the ethylene dichloride-vinyl chloride and polyvinyl chloride plants. The emissions from pump, compressor, and agitator seals can be controlled by installing double mechanical seals and maintaining a liquid between the seals at sufficient pressure to cause the liquid to leak into the pump should the seal fail. Vinyl chloride chat is present in equipment that is to be opened for maintenance or inspection can be vented to a control device by purging the equipment with an inert gas such as nitrogen or displacing the contents with water before it is opened. The emissions occurring during loading and unloading from the loading area lines can be controlled by purging the lines to a control device such as an incinerator or carbon adsorption unit. The emissions from slip gauges can also be vented to a control device. Emissions from leaking pressure relief valves can be reduced by installing ]eak proof rupture discs upstream of the relief valve. Emissions resulting from sampling for laboratory analysis can be 'i rtually eliminated by letting the gas that is to be sampled flow -wough the so,, pie flask to a lower pressure point in the process. M"ple flask can then be blocked off and any vinyl chloride that 4-74 COLOR!TE 008543 rV ' the same Is 1: r.es car be i to a control device before r1-,, ; rias,\ is removed. mj fugitive sources within both ethylene dichloride-vinyl chloride and poi. :ny; chloride plants can be monitored with a formal program of leak det;- ion and repair. Tne detection can be accomplished with both fixed poi -: and portable monitoring devices. jinyl chloride can be stripped from the inprocess wastewater and tra1*;-erred to a control device such as an incinerator or adsorber. ,'inyl chloride that is present in the polymerization reactors can be displaced to the monomer recovery system for ruse by filling the reactor with water before it is opened for cleaning, maintenance or inspection. ~he need to open the reactors for cleaning can be reduced by clearng the reactor while it is closed with high pressure water sprays, circulating an organic solvent through the reactor to dissolve any solids that 'iay have accumulated and by a combination of recipe reformulation and reactor design to reduce scale formation. Polymerization reactor safety valve discharges can be avoided by instrumenting each reactor with a pressure or temperature alarm to alert the aerator to take appropriate action. This could include venting the -rector contents to a gasholder where the vinyl chloride can be recyrod or injecting certain chemicals into the reactor to stop the reac " and prevent further pressure build-up. During power failure these cher could be added manually by hydraulic injection systems. V ! chloride that is present in all captive or point sources in the ."'er and polymer plants can be controlled by adsorption on 4-75 COLORITE 008544 activated carbon, by absorption in an organic solvent, or by incineration. Each of these techniques can reduce the vinyl chloride content of the gas being treated to less than 10 ppm. Control levels equivalent to the "add-on" devices discussed above can be achieved in certain point sources in the polyvinyl chloride plant by stripping the slurry leaving the reactors of the residual, unreacted vinyl chloride. These sources, which are downstream of the stripper, include the slurry blend tanks, the centrifuges, the dryers, and the bulk resin storage areas. 4-76 COLOR!TE 008545 *1 Table 4-1. SOURCE DESCRIPTION FOR TYPICAL POLYVINYL CHLORIDE PLATT, ' 68 mm kg/year (150 mm Ib/year) Emission Source Fugitivc a) Transfer operations b) Safety relief valves c) Pumps, compressors, agitator seals d) Sampling for lab. analysis o) Opening equipment for inspection & maintenance f J _ Vacujjjji puncs A steam 9) Inprocess wastewater h) Leaks at flanges, seals, etc. Reactor and stripper losses a) Safety relief bj Reactor opening 3as Volume SCMM^ (SCFM) ACMM (ACFM) N.A.--^ N.A. N.A. N.A. N.A. N.A. N.A. N.A. N.A, N.A. Gas Temp. C (F) VCM Concentration DDmv Emissions kg VCM/ 100 kg PVC (lb VCM/ kg/nr 100 lb PVCl (1b/hr) Ll Y\ l Ambient Ambient Ambient Ambient Ambient 100% 100% 100% 100% 100% Total for all fugitive emissions = 1 .53 (1.53) Total for fugitive emissions 1 . Fugi ti ve t ..,i ss ions ,,i c not broken down by sou on sort ion 114 resDor.^i Total figure tstimrii/vj by me T vi 11 I'.ii 1 unco . = 24.5 (275) /A N.A. N.A. N.A. N.A. N.A. N.A. Ambient Ambient Ambient N.A. N.A. 65.5 (150), I j |f`f. ('" 56.6 (2000) max. 65.0 (2300) 65.5 0 50) 100% 100% Y 100% N.A. \1 1200 X /X t ; 0.20 (.2) `i lf : 0.46 ^^ (.46) ,, / *\ 16.3 (36) / 37.6 ^ (83) 2.a,Losses from Safety Pel ief Va'i ves are i'll0 4540 kg (5000-10,000 lb VCM in a 5-10 minute period. 2.b.Gas volume assumes th steam jets are used to remove VCM from reactor .A. - Not Applicable /pical Dispersion Plant - 13.6 mm kg/yr (30 mm lb/yr}; typical bulk plant - 45.4 mm kg/yr (100 mm lb/yr). tendard cubic meters per minute. COLORITE 008546 COLORITE 008547 ,i:iiUjfi jounce iioijiur rel.. ve ry ;yuium . ./lurry blend tank ,uri f,,gL liorage silos iIl ule 4-1 (continued). SOURCE DESCRIPTION FOR TYPICAL toLYVINYL CHLORIDE PLANT 68 mm kg/year (150 mm Ib/year 1 Gas Volume SC MM (SCFM) ACMM (ACFM) .935 (33) .85 (30) 103 (3636) 109 (3842) N.A. N.A. 1430 1640 (50,400) (58,000) 522 522 (18,450) (19,490) Gas Temp. fC (F) -7 (20) 38 (100) 38 (100) 65.5 050) 38 (100) VCM Concentration ppmv 500,000 Emissi ons kg VCM/ 100 kg PVC (lb VCM/ kg/hr 100 lb PVC) (lb/hr) .48 (.48) 39 (86) 2,000 .42 (.42) 34 4 (76) N.A. 214 .13 (.13) .63 (.63) 10.4 (23) 51 013) is i 67.5 [ 1, 1 .07 '(.07) ____ i__________ - . 5.9 (13) Comments 3.For other types of resi emission factors (kg VC 100 kg PVC) range from (solution) to 0.5 (dispersion). 4.No slurry blend tank in bulk process. Uncontro slurry emissions are ve, by fans to atmosphere fr safety purposes. 5.No centrifuoes in bulk i latex processes. 6.Air volumes are higher dispersion process (215f ACMM or 76 ,000 ACFM) because of use of spray dryers. Emissions much higher in dispersion process (2.41 kg VCM/1 Of PVC). No dryer in bulk latex processes. 7.Storage silo air volume be much lower than this TOTAL EMISSIONS 3.92 (3.92) 319 (705) m Table 4-2 SOURCE DESCRIPTION FOR TYPICAL,ETHYLEI'E DICHLORIDE-VIUYL CH10RIDE PLA.!T 316 mm I n/vr {700 mm lb/y Emission Source 1. Fugitive Gas Volume scmm y ACMH (SCFH) (ACFM) N. 1. Light Ends Vents 2.8-4.5 (100-160) !. Finishing Column 2.8 000} . Oxvchlorination 227-368 Vent (8,000- 13,000} 3-4.8 (105-170) 3.5 (122) 227-368 (8,00013,000) 1 Gas Temn. C (F) N.A, 38 000} 38 (100) 5-38 (40-100) : VCM Concentration nomv II.A. 42,700 99+% 163 Emissions kn VCM/ 100 kci VCM (lb VCW/ kn/hr inn lb VCM) (lb/hr) Total = .1221 Total = 44 (97) .05 0.24 0.036 18 (40) 87 (191) 13 {29} Comments _ 1 Sources are the same as nlant. (See table 4.1.j Total fugitive emission estimated bv mater i .11 balance. 2 Known as ethvlone dichlm finishinu column vent. 3 Known as vinvl chloride finishino column vent. ^N.A. - Not Applicable. ^CMM = Cubic meters ner minute Total .4479 Ju * 162 ._(3yL_ COLORITE 008548 Table 4-3. CONTROL TECHNIQUES k. i_ICADLE TO POLYVINYL CHLORIDE PLANTS TYPICAL SIZE 68 ml kg/year (150 mm lb/year) -` Emission Source Applicable Control Techniques . Fugitive a. Transfer Operations Purge to Control Loading & Unloading Device b. Safety Relief Valve Rupture Discs Leaks & Discharges El are c. Pumps, Compressors Double Mechanical & Agitator Seals Seals d, Sampling for Purge Sample Flasks Laboratory Analysis Back to Process e. Opening Equipment for Maintenance & Inspection Displace Gas to Control Device f. Vacuum Pumps & Steam Jets Vented to Control Device g. Inprocess iJastewater Strip VCM and Vent to Control Device h. Leaks at Flanges, Seals, etc. . Multipoint Fixed & ' Portable Monitoring Devices Reactor & Stripper Losses a. Safety Relief Valve Shortstop, Gasholder b. Reactor Openings Displace Gas to Gasholder ~t(ricontrolTed f Achievable' -- : Emissions ! Emission Levels kg VCM/ kg VCM/ 100 kg 'PVC lt)0 kg PVC (lb VCM/ kg/hr jElb VCM/ kg/hr 100 lb. WC) (lb/hr) 100 lb PVC) (Ib/hr) Comments Total For . All Fugi ti've Total For ! All Fugitive 1. Control Devices include solvent absorbers, carbon adsorption, and incinerati on--each capable of control to 10 ppm. Emission , Sources= 1.53 (1.53) Emission Sources= 125 (275) 0.16 (0.16) 13 (29) Double mechanical seals (1 .c.) are equipped with liquid under pressure between the seals. 1 0.2 {0.2) 0.46 v i (0.46)^ / 16.3 (36) 37.6 (83) (0) .001 (0.001) ^ 0 0 COLOR!TE 008549 * Table 4-3(cont.) CONTROL TECHNIQUES APPLICABLE TO POLYVINYL CHLORIDE PLANTS TYPICAL SIZE 68 Iran kg/year (150 mm Ib/year) Emission Source Applicable Control Techniques Undontrolled Achievable Emissions Emission Levels kg VCM/ kg VCM/ 100 kg PVC 100 Kg PVC (lb VCM/ kg/hr (lb ,VCM/ kg/hr 100 lb PVC) (Ib/hr) 100 Vb PVC) (Ib/hr) Comments Monomer Recovery System Reduce Inerts | Solvent Absorber Carbon Adsorber 0.48 (0.48) 39 (86) 1001 ,(OjOQl) JO 01 {0.001) .001 (0.001) 0 0 0 Slurry Blend Tanks Improved Stripping 0.42 (0.42) 34 (76) .013 (0.013) 1 (2) 4^ t Co no to-1 $d Centrifuge H f-3 K O o 00 tn cn o Dryers Carbon Adsorption Solvent Absorption Incineration Improved Stripping Carbon Adsorption Solvent Absorption Incineration Improved Stripping Carbon Adsorption 1; 1f t ii 1| o.ila (0.13) i i j1 0.63 (0.63) 10.4 (23) 51 013) ,0 0 0 0.004 (0.004) ,o Jo 0 .02 (0.02) .02 (0.02) 0 0 0- 0.5 (1) 0 0 0 1 .8 6. Represents energy reqt (4) ments for 1.8 of dryer at (4) storage Incineration .02 (0.02) 1 .8 (4) oOI o COLORXTE 0 0 8 5 5 1 Table 4-3(con't.) CONTROL TECHNIQUES'APPLICABLE TO POLYVINYL CHLORIDE PLANTS TYPICAL SIZE 68 mm kg/year (150 mm Ib/year) Emission Source 7. Storage Silos i I'O Applicable Control Techniques Improved Stripping Carbon Adsorption Incineration Silo Stripping Uncjonti"dlied Emiss' ons kg VCM/! 100 kg P|VC (lb VCM/ kg/hr 100 lb PVC) (lb/hr) Achievable Emission Levels kg VCM/ 100 kg PVC (lb VCM/ kg/hr 100 lb PVC} (lb/hr) 5.9 03} .002 (0.002) .002 (0.002) .002 (0.002) .002 (0.002) .18 (0.4) .18 (0.4) .18 (0.4) .18 (0.4) Comments - Includes slurry blend tank and vent condenser together. 7) -Dryers and storage silos grouped together. -7Cost of improved stripping in dryer column includes stripping cost for control of slurry blend tanks dryer, and bulk storage. --4/ Direct operating costs. centrifuae s' t r' Table 4-4. CONTROL TECHNIQUES APPLICABLE ETHYLENE DICNLORIDE-TO VINYL CHLORIDE PLATTS TYPICAL SIZE 316 mm kg/yr (700 mm Ib/yr) no to* ta H K O o 0on0 on to Table 4-5. APRIL 1975 STATUS ()f DISPERSION RESIN STRIPPING wWh PROJECTION OF FUTURE CAPABILITIES-7 (I Plant Current Rl/CM^-7 After Stripper (ppm). In Product Projected RVCM {ppm) After Stripper Time to Implement Controls Needed to Meet Proiected Levels A 30,000 B 50,000 C 20,000 D 1500-4000 L 15,000 F 13,000-18,000 1-3 20,000 5 10,000 5-15 4000-6000 - 1-10 6000 10 i 4500 6 months .6 months 48 months - 12-18 months 30 months 500-1000 G 2000-10,000 25 '2000 - -- - - j 400 ; ,j ! 1 14,000-18,000 1 2000 5-30 \ 1200 "\ 1 ll - '; . ............... t ; .I -7 From RV CM responses to March 31, 1975, 1 section i 114 = Residual Vinyl Chloride Monomer i request C I 42 months /: -r. ___-- --------------4^jnonths 30 months - -34 9 'J i ' n i or,' APRIL 1375 Si ITUS 'I- SUSPENSION RESIN STRIPPING 1/ Company i Number of Suspension Resin Grades % of Suspension Resin Production R VCM (ppm) A 1/ by _ 60 2000-4000 40 4000-6000 100 2000-5000 c 5 Grades 100 <400 D ~r~ - -. , 1S3 Grades"-^- 80 20 86.8 5.4 3.8 3.2 .8 400 500-700 0-5<& 100 500 Tooo 4000 F 15 Grades 100 <400 G 4 Homopolymer 6 1500 14 2500 80 100 4 Copolymer 16 300 84 400 H 4 Grades 100 2000-10,000 I 38 400 9 600 25 500 5 T800 15 36(50 8 4000 i^Based on data from responses to 3/31/75 section 114 request. -'All suspension resins to be reduced to <400 ppm R VCM by 7/75. -- Some values are speculative until improved stripping is installed. Sr 4-85 COLORITE 008554 TABLE 1-7 ADSORPTION OF RECOVERED VINYL CHLORIDE MONOMER ON ACTIVATED CARBON Equipment- Steel pipe, 1.61" ID packed with Pittsburgh Type BPL 4 x 10 mesh activated carbon manufactured by the Calqon Corporation, Pittsburgh, Pa. Packed height of bed 5*2". Experimental Conditions- Vinyl Chloride Monomer recovered from a pilot plant polymerization reactor havinq a_qas composition of 29 mol percent VCM and 71 mol percent air was fed to the activated carbon bed at a nominal velocity of 29 feet per minute at ambient temperature (70F)and pressure. Step Adsorption Steam Desorption (20 psia 0.6 lb/min) Nitrogen Drying (250F), (0.3 CFM) Time (Min.) 20-30^ ^ 45-120 60 Direction of Flow Downward Upward Downward Cycle Number Bed Capacity (lbs. VCM/100 lb Carbon) Steam Desorption Steo (min.) 1 19.4 3 15.1 5 18.7 7 15,1 9 18.7 11 18.0 13 17.3 15 18.4 17 14.4 19 18.0 21 12.2 23 11.2 25 9.8 27 6.1 28 8.3 45 45 70 45 75 75 75 75 100 100 no 120 120 120 120 ^ ^ Time varied since adsorption step terminated when VCM breakthrough occurred. Carbon Analysis- After 28 cycles the used carbon was removed1 from the unit and examined. There was no visible evidence of PVC on the carbon or change in carbon color. The carbon was extracted with THF and the extract gave 0.06 weight percent liquid which on anal vs is nrovod to be a phenolic ccmoound however, no PVC was found to be present. Unused carbon extracted with THF yields 0.06 'weight percent of liquid of similar type as the used carbon. 4-36 COLOR!TE 008555 Table 4-8 Ki 1 ograms per Tear of VCM Emitted During Equipment Purge For Typical 316 mm kg/yr (700 mm lb/yr) EDC-VCM. PI-art Class o f--^ equipment Pieces of-^ Equipment Times Purged-^ Each Per Tear Total Purges--'' per year Total Gallons of Equipment Purged Per Year Kq (pounds) VCM-- emitted per /ear 100* VCM at 760 mm Hq absolute Kq {noundc) V1 v\'-' emitted pi r with ,iri riss1;ni r! equipni^nL puru- 0-50 L 0-5133 pumps small heat exenangers 12 1 1/2 18 1 900 9.0 (19.8) 3.4 17.5) 500 5 (11.0) 0.25 (0.55) condensers & accumulators 1 5000 50 (HO) 0,55 r 5000-53000 distillation cc1jmns 1 50000 600 (1099) 10 (22.0) 50,C00 and up 70t000 gallon run down tank oo 10,000,000 pound storage 1/3 23000 230 (506) 4,5 ('0.1) i1/3 665000 6665 (14682) 133.3 (293.7 7459 (16427) s -'information submitted by Jim Mullins, Shell Chemical, in telephone conversation with Leslie Evans, April 8. 1975. K3 %]Equipment reduced to atmospheric pressure before opening, ,, M ^Equipment purged before opening so that when equipment Is opened the vinyl chloride emitted to the atmosphere shall be no more than 25 gallons (at Standard temperature and pressure) or 2t of the volume purged (at STP), whichever is larger. O o 00 in in o\ Table 4-9 Kilograms per Year of VCM Emitted during Equipment Purge From Typical 68 rm kg/yr [150 mm Ib/yr) PVC Plant Si:r of Equipment Ga11ons C-GG vj-EGO 530-5000 530C-50300 S3h200 and '-P Class of-/ Equi pment pumps exchanqers vtinc condensers recovery systems weiqn tanks recovered VCM tanks None 100,000 gallon s forage Pieces of--/ Equipment 10 3 1 3 2 3 Times Purged-^ Each Per Year 1 2 2 3 1 1 Total Purqes^/ Per Year j ota i fiai ions of Equipment Purqed Per Year 11 10 500 6 3,000 2 1,000 6,500 9 4,500 2 3 10,000 15,000 25,000 2 1/4 1/2 50,000 50,000 Ko (oounds) VCM-^ emitted per year 100* VCH at 760 mm Hq absolute 5.0 (11) 79.6 (175.2) 249.4 (549.4) 490.9 (1098.B) 832.8 (1 834.4) Kd (pounds) VCH-1 emtted per year 1.9 (4.2) 4 3 (9.4) / 2.8 (6.1) 9.8 (21.9) ^Scaled up to 150 run pounds per year plant from information submitted by Jobn Darr, Air Products and Chemicals, > i in telephone conversation with Leslie Evans, April 9, 1975. - Equip1 ,cnt reduced to atmospheric pressure before opening T; -Equipment purged before opening so that when equipment is opened the vinyl chloride emitted to the atmosphere shall oe no more than 25 gallons (at standard temperature and pressure) or 2% of the volume puraed (at SIP), whichever is larger. 'T*T 1 l|'W>|P. y-FOOT''- K/T-in Sxmfyuyiipp ' iVir .xli,;- TABLE <1-10. OXYCHLORINATiON PROCESS VENT DESCRIPTION --- EDC,plant capacity C:mparty I'r kg/yr (lb/yr) kg VCN/hr (lh/hr) kg VCM/100 kg EDC (lb/100 lb) Heat value, kcal/SCM (Btu/SCF) Volume flow. SCMM (SCFM) ppm Techno!ogy Control i np 12 00 > U 35 47 (78.64) C 275 id 3) D 73 M62) f 496 M ,!C0) F P* CO r 'uD U H I 134 {293) 210 (466) 90 (200) 97 (216) J 194 (432) K 306 (650) 0.33 (0.74) 0.fll (1.B) 33 (74) 0.003 (0.003) 0.02 (0.02 0.106 (0.106) 0.54 (1.2) 46 (103) 0.0065 (0.0065) 0.077 (0.077) 1.7 (3.8) 6.2 (13.7) 2.6 (5.9) 9.5 (21.2) before in- 0.0112 (0.0112) 0.0236 (0.0235) 0.0235 (0,0235) 0.09 (0,09) 9.0 (20) 0.023 (0.023) -- 365 (41) 200 (7,000) 29 (1,023) 321 (11,260) 172 (19.3) 131 (4,598) -- 159 (5,570) before 10/75 187 (21) 181 (7,337) 258 (29) 454 (15,900) 294 (33) 197 (6,900) 6,349 (713) 8.7 (304) " 200 (22.5) 346 (12 ,125) 16 B.F* Goodrich Fluid Bed 187 Stauffer Fixed Bed ,air 670 range Stauffer Fined (1974) 35- Bed ,air 9, BOO 27 B.F. Goodrich Fluid Bed,air 1 ,770 Uow, oxygen, in 1975 60 4? 42 7,000 170 Ethyl Fluid Bed, air B.F. Goodrich Fluid Bed, air B.F. Goodrich l Fluid Bed, air PPG Fluid Bed Oxygen and Ethylene recyc1e PPG Fluid Bed Oxy gen and Ethylene recycle Stauffer Fixed Bed, None None Second st-d'je Cl j Sonetire Catalytic me i no rat1 ' a plant in opera11cii [ nc i i'c a t ton Le hua 2 vou'.'.ri scrubters , vmt caustic, 10/75 None Absorber Absorber Incineration, no Neat cevery, water sc^vt Planned 3/75 Second stage ul, L 306 (030) 9.0 (20) 0.023 (0.023) 200 (22.5) 346 (12,125) 170 Stauffer Fixed Bed, Second stage Cl^ , late M 112 (250) 0.3 - 0.S3 (0.7 - 1.4) 0.0024-0.0047 (0.0024-0.0047) 62 MM (7 MM) 100 (3,500) 20 - 30 Vulcan Fixed Bed* air None Trices other units and therefore requires supplemental fuel. Engineering study under way on recovery of HC1 and heating value. . separate incinerator witnout heat recovery provides for back up. 2000 lb/hr gas required for primary incinerator. ^Design of production unit under way. COLORITE 008558 ' :P Table 4-11 POLYVINYL CHLORIDE PARTICULATE EMISSION FACTORS Particulate Sources A. Dryer a) Rotarv b) Flash c) Fluidized Bed d) Spray Storage a) bins b) silos Bagging Machine Bulk Loading Resin Transfer Points Control led Control Emissions Technique __________ko/lco PVCl Centrifugal separator Fabric filter Centrifugal separator Fabric filter Centrifuaal separator 0.01 0.006 0.0003 0.0001 Fabric filter 0.0017 Fabric filter Centrifugal separator Fabric filter Fabric filter Fabric filter Centrifugal separator Fabric filter Centrifugal separator & Fabric filter 0.0002 0.0005 0.00015 0.0002 0.001 0.0009 Obtained from averaging reported particulate emission rates from industrial responses to the May 30, 1974, letter transmitted from Mr. Don R. Ooodwin (EPA) under the authority of Section 114 of the Clean Air Act to the manaqement of companies Droducina polyvinyl chloride. 4-90 COLOR!TE 008559 v .'I TCP*!-:Ivr CO'JTQOL LEVELS >'or the reasons described ir, Chapter 2, it was determined that the regulatory approach for vinyl chloride emissions would be to propose a standard under the authority of section 112 of the Clean Air Act based or, best available control technology. Many technical decisions were required in selecting what constitutes best available control technology for the multiple emission sources in ethylene dichloride-vinyl chloride and polyvinyl chloride plants. Therefore, the following criteria were established for making these decisions: (a) The control technology must be in use in one or more plants in the chemical industry and be generally adaptable for use at the plants subject to the standard within the time allowed for compliance under section 112. (b) Costs were considered only when they were grossly disproportionate to the emission reduction achieved. In order to develop an emission standard for each of the emission sources based on the established criteria for "best available control technology", data on control systems were obtained through requests for information under the authority of section 114 of the Clean Air Act, plant visits, consultation with industry representatives and control vendors, one emission test, and two studies under contract to EPA. Except for two emission sources, the emission limits selected for the proposed standard represent control technology which meets these criteria without any question. The two cases about which there is some question are those for which alternative control levels are presented in this chapter. 5- 1 COLOR!TE 008560 The alternative control levels presented are realistic alternatives and represent areas of potential controversy. There are other types of alternatives which could have been presented, but which are not because they obviously do not meet the criteria for best available control technology. For example, alternative control levels could have been presented for each of the multiple emission sources in ethylene dichloride-vinyl chloride and polyvinyl chloride plants. The end result would be a large number of alternatives, most of which could not be considered seriously as candidates for a standard based on best available control technology. Additional alternatives could have been presented with each representing regulation of a differ ent number of emission sources, i.e., the first alternative could consist of regulation of the largest emission source, the second alternative could consist of regulation of that one and the next to the largest emission source, etc. The alternatives "are not presented in this way, because there are control technologies which have been used for each of the types of emission sources in ethylene dichloride-vinyl chloride and polyvinyl chloride plants and regulation of only some of the emission sources was determined to be less than best available control technology. Although alternatives representing regulation of individual emission sources are not presented as such. Chapter 8 (Tables 8-1 and 8-2) does provide information on emissions from each emission source before and after installation of control, and Chapter 7 provides information on costs for control of each emission source. 5-2 f i f I| COLORITE 008561 There are conceivable alternatives representing more stringent levels or control than those included in this chapter. These alternatives are not presented because they represent technology which clearly does not meet the criteria for best available control technology. Also, their impacts cannot be quantified since they are not being used any where and therefore no data are available on them. First, there are technologies which are currently beina researched or for which research is planned, but which have not been used commercially. For example, ozonization and oxyphotolysis are two methods being developed to oxidize vinyl chloride into less toxic substance^. Secondly, there are emission points for which double control measures could achieve a small increment in emission reduction at a disproportionately high cost. For example, two carbon adsorption units could be installed in series so that the second carbon adsorption unit could be used to collect any emissions from the first carbon adsorption unit during breakthrough. Thirdly, a bubble could be placed around an industrial complex and all the air from the complex could be vented through an enormous control device. The alternatives presented in this chapter for each source category type represent the same level of control for all emission sources except one. The impacts, however, are evaluated for an entire plant. This way of presenting impacts tends to reduce the relative differences in the impacts between the alternative control levels. For example, if the emission source in question represents 10 percent of the total emissions, a fifty percent change in emissions 5-3 COLOR!TE 008562 from that source would represent only a five percent change in total emissions from the plant. 5.1 Ethylene Dichloride-Vinyl Chloride Plants The sources of vinyl chloride emissions within typical ethylene dichloride-vinyl chloride plants and their relative contributions to total uncontrolled emissions are shown below: Emission Source Percent of Total Uncontrolled Emissions at the Average Plant (1) Fugitive Emission Sources (2) Ethylene Dichloride Purification (3) Vinyl Chloride Formation andPurification (4) Oxychlorination Reactor 27 11 54 8 100 The alternative control levels for ethylene dichloride-vinyl chloride plants differ in the degree to which the oxychlorination reactor is controlled. The reasons there was some question in selecting an emission limit for the oxychlorination reactor based on the established criteria for "best available control technology" and therefore the reasons alternative control levels are presented for the oxychlorination reactor, are discussed in the following paragraphs. The fugitive emission controls which would be required in ethylene dichloride-vinyl chloride plants are the same for all alternative control levels. Data obtained from the industry indicate that several plants have controlled fugitive emissions to the degree required by the proposed standard through containment, capture, and ducting of the emissions to a control system and through early leak detection and "epair. The level of control required by all alternatives for ethylene 5-4 1 f tf COLORITE 008563 dichloride purification and vinyl ch1 q' ide formation and purification has been attained by at least one existing plant thrcugn incineration. Incineration is also an applicable control method for the oxychlorination reactor. The oxychlorination reactor, however, has a large volume, low hydrocarbon concentration effluent gas stream, and relatively large quantities of fuel would be required for its combustion compared with combustion of the other two point sources of emissions. At most ethylene dichloride-vinyl chloride plants the oxychlorination reactor represents a relatively small source of emissions. Due to process variables, however, there is a wide rang? in the reported emissions from the oxychlorination reactor at the various plants from 0.5 to 46.3 kg/hr (1.2 to 103 Ib/hr). Thus, at a few plants the oxychlorination reactor emissions are relatively large. Thus, the first criterion for "best available control technology" was in question in selecting an emission limit for the oxychlorination reactor; i.e., are the energy costs of the control technology which would be required grossly disproportionate to the emission reduction which would be achieved? Three alternative control levels were identified for the oxychlorination reactor as follows: 1. Require no control of the oxychlorination reactor. 2. Establish the level of the standard for the oxychlorination reactor so that it can be met through control of process variables. In effect, only the plants with the relatively large emissions would have to institute controls. 5-5 COLORXTE 008564 3. Establish the level of the standard for the oxychlorination reactor so that all plants would have to install incineration or equivalent add-on control. The environmental, enerqy and cost impacts of these alternatives are presented in detail in Chapters 6 and 7, respectively. 5.2 Polyvinyl Chloride Plants Alternative control levels for polyvinyl chloride plants are presented only for plants manufacturing dispersion resins. Dispersion resin manufacture constitutes 13 percent of total polyvinyl chloride production. The sources of vinyl chloride emissions within typical polyvinyl chloride dispersion plants and their relative contributions to total uncontrolled emissions are shown below: Emission Source Percent of Total Uncontrolled* 2 * 4 Emissions at an Average" Plant ----- (4_)--Fugitive-Emission Sources 19 (2) Reactor Opening . ---3"" .Relief Valve Discharge 4 (4) Stripper 20' _ -Monomer, Recovery System 8 " (6) Sources Following the Stripper (slurry blend tanks, concentrators, dryers, bulk storage, etc.) 46 100 -- (Emission sources within other types of polyvinyl chloride plants are generally the same as those listed above for dispersion plants. The relative magnitude of emissions from each source in the'other types of polyvinyl chloride plants can be found in Chapter 3.) The alternative control levels for polyvinyl'chloride dispersion plants differ only in the degree of control required for the process equipment following the stripper. For the other emission points listed above, the degree of control required by all the alternative 5-6 COLORITE 008565 control levels for dispersion plants is the same as that required for the other tyoes oc poly/inyl chloride plants. In regard to the other emission sources, data indicate that several plants have demon strated control of fugitive emissions through containment, capture, and ducting of the emissions to a control system, and early leak detection and repair. At least one plant has demonstrated effective control by using water to displace vinyl chloride from a piece of equipment, such as a reactor, to a control system before opening that piece of equipment to the atmosphere. Several plants have demonstrated that reactor relief discharges, which cause short-term peak emissions, can essentially be eliminated by measures such as injecting chemicals to stop a reaction or manually venting gases to a recovery system. Plants commonly recover the vinyl chloride emissions from strippers in a monomer recovery system. Carbon adsorption has been demonstrated as an effective add-on control system for application to the_monomer recovery system. All of these control measures meet the established criteria for "best available control technology" without any question. The reasons there was some question in selecting an emission limit for the sources "following the stripper in dispersion plants based on the established criteria for best available control technology, and therefore the reasons alternative control levels are presented for these sources, are discussed in the following paragraphs. The emissions from the process equipment following the stripper in polyvinyl chloride plants can be controlled in two ways: (1) installation of add-on control devices such as incinerators or (2) strippinq the vinyl chloride free the polyvinyl chloride resin before the resin is COLOR!TE 008566 processed. Under proper conditions, stripping can achieve the same degree of emission reduction as add-on control devices end is much less energy consuming and expensive. Strippina technology has been used commercially at polyvinyl chloride plants in the past, but the technology has been designed to perform only to the extent necessary to recover raw materials for economic purposes rather than for emission reduction; i.e., he.-emperature, retention time, and the vacuum that have been applied are consistent with the economic recovery of vinyl chloride. More __recently, as a result of_ the October 4, 1974,_QSHA.standard, polyvinyl chloride resin producers have been developing stripping technology to further reduce the vinyl chloride content in resins during the stripping operation in order to reduce in-plant emissions and to satisfy fabricator demands for resins which have low concentrations-of vinyl chloride and -.^uthus^do-not-cause-the -fahjdraimrs_.ln_hp-_m- violation nf the OSHA standard. Based on information supplied to EPA by individual companies which have devoted time and resources to further develop stripping, it appears that technology is currently available to strip the majority of resins except - dispersion-resins :to-400 ppm-or lower--This same, degree of control is achievable through add-on control devices. Technology to strip residual vinyl chloride monomer from dispersion resins has not been developed to the same degree as for other resins for several reasons. First, information submitted to EPA under section 114 of the Act indicates that dispersion resins are 5-8 COLORITE 008567 r- rMff-'cijlt to strip '..i th conventional techniques than other resins, because nigher temperatures which can be applied to other resins destroy tre stability of dispersion resins and thus the quality of the product. Polyvinyl chloride producers have devoted more research and development time to improving conventional stripping for other --res mis than--to developing new-technology-for-dispersion -resins, because dispersion resins represent only 13 percent of the total production. Furthermore, the incentive to improve stripping to satisfy fabricator demands for low-monomer content product does not exist for dispersion resins, because the product has always been low it monomer content as a result of loss of almost all of the residual monomer to the atmosphere during the drying operation which occurs after stripping. In general, the loss in drying-dispersion resins is proportionately higher than in drying other resins. Based on this information, it appeared that -best-available-control-technology for dispersion rejjins may not be the same as for other resins. ERA therefore attempted to determine the_.degree of...stripping which could be accomplished for dispersion resins by best control technology. Section 112 requires_.ex.isting_plan_ts to comply with a standard within 90 days of promulgation, but it provides for waivers of up to two years (two and a half years from proposal) for control if "steps will be taken during the period of waiver to assure that the health of persons will be protected from imminent endangerment." EPA therefore endeavored to determine the degree of control technology develop'ant tnat is likely over the next two and a ha^ years. Under 5-9 COLORITE 008568 the authority of section 114 of the Act, EPA requested information from the ten companies that manufacture dispersion resins reqardinq the degree to which these resins can be stripped with technology developed in the next two and a half years. Two of the companies do not plan to make dispersion resins in the future. Two of the companies responded that they could not reach levels below 6,000 ppm. However, some companies have devoted more time and resources to improve the effectiveness of stripping as an emission control measure than other companies. Three of the companies, which appeared to have devoted more time to research and development of stripping technology for dispersion resins, reported that they would be able to strip all resin grades to levels of 2,000 ppm or lower. One of these companies is already stripping each of its resin grades to this level and another of the companies is stripping some of its resin grades to this level. A fourth company, which did not make any predictions, is also stripping some of its resin grades to a level of 2,000 ppm. The predictions of the other two companies ranged between 4,000 and 6,000 ppm depending on the resin type. One company predicted that it would be able to strip dispersion resins down to 400 ppm in four years. Add-on control devices are capable of reducing emissions down to a level equivalent to stripping to 2,000 ppm. Add-on control devices cannot reduce total mass emissions from the equipment following the stripper in dispersion plants as low as they can in the manufacture of other resins, because in general these devices are capable of reducing the vinyl chloride concentration in an e*it gas stream to essentially the same concentration regardless of the level of the incominq concentration. Because of the type of 5-10 COLOR!TE 008569 dry^r* which is used in disfieVsion plants, the gas stream going into the /control device at these plants would be much more diluted than at other plants. Thus, the first jjriteYioTi for "best available control] technology" was-in question Jn selecting an emission limit for the sogrces following the stripper in dispersion plants; i.e., what degree of control which has`been in use in one or more plants would be generally adaptable for use eft the plants subject to the standard within.the time'allowed for compliance under section 112. Add-on controls are currently available - -- - i, for the plants to use. However, since they would have large energy and economic impacts, improved stripping technology is the preferred method of control. Therefore, the question which remained wasewj^t degree of stripping technology is available for the "plants to use, ^it should be noted:that control by stripping differs from control by itineration or other add-on devices, in that with stripping it cannot be-.|ssumed that because one plant is stripping to 2000 ppm, that this technology car%. -j. necessarily be readily transferred to other plants. Stripping tech nology has to be developed experimentally on an individualibasis for the many resins.. Based on this information, three alternative|control levels were identified jfor the sources following the stripper in dis persion polyvinyl chloride plants as follows: (1) Establish the level of the standard so that it ig representative of stripping techno 1-ogy -that is currently available for all grades of dispersion resins 'tft^ll plants. Essential"($, thjs would be equivalent to requiring no control of the femiissjjons from sources following the stripper. 5-1 r COLOR!TE 008570 riti'Vi.i, (2) Establish the level of the standard so that it is representative of stripping technology which has been achieved by one plant for all resin grades and by two plants for some resin grades, and is judged to be available for the remaining plants in two and a half years. This same degree of control can be attained with presently available add-on controls. (3) Establish the level of the standard so that dispersion resins would have to be stripped to the same level as other resins. One company has predicted it can reach this level in four years. Add-on control technology is presently not available to attain this same degree of control. The secondary environmental impacts do not differ much among the three alternatives presented above for dispersion resin plants, and the cost and energy .impacts for one of the alternatives_are_not wellcrrdefitiedr--Therefore-,1--as-opposed -to~the oxych To r.inati on -process, v . for which the first set of alternatives was.T>esen.ted.jji.,,thj^chapter, ryi^nvironraenfal-^and-energy_impacts, were-not-^a major part of -- the "dec1s"f(5Trmaking process in selecting one of the three alternatives as an emission limit for dispersion resin plants. Thus, the "selection of an emission limit for dispersion resin plants involved primarily -based on-the-availability of-stripping--technology.__ However, the environmental and cost impacts of these alternatives using both improved stripping and add-on controls are presented in detail in Chapters 6 and 7, respectively. 5-12 COLORITE 008571 6. ENVIRONMENTAL IMPACTS OF THE ALTERNATIVE CONTROL LEVELS The purpose of this chapter is to identify, quantify, and evaluate the positive and negative environmental impacts of the alternative control levels presented in Chapter 5 for ethylene dichloride-vinyl chloride and polyvinyl chloride dispersion plants. For polyvinyl chloride plants other than those making dispersion resins, there are no alternative control levels and the impacts of the control level of the proposed standard are presented. It should be noted that other types of alternatives and their impacts are discussed in other chapters. Alternative reoulatory strategies are discussed in Chapter 2. These include setting no standards, setting standards under other authorities (instead of section 112) of the Clean Air Act, prohibiting all emissions of vinyl chloride, setting standards for source categories in addition to ethylene dichloridevinyl chloride and polyvinyl chloride plants, etc. Alternative control systems (solvent absorption, incineration, etc.) are identified in Chapter 4. Alternative ways of writing and enforcing the level of the proposed standard and other pollutants considered for regulation are discussed in Chapter 8. Identified in Chapter 4 are eight or more control systems which can be used to reduce vinyl chloride emissions in ethylene dichloride vinyl chloride and polyvinyl chloride plants. As described in Chapter 3, there are a number of emission points both in ethylene dichloride-vinyl chloride and polyvinyl iLl^-ide plants, each of which can be controlled by one of several control systems described in Chapter 4. In addition, there are four or more types of processes in the polyvinyl chloride 6-1 COLORITE 008572 industry, and these process types vary with regard to the number of emission point: and the control systems which are applicable. Due to the complexity of the situation created by the variety of emission points and control systems, this section is divided into two parts. The first part describes the secondary environmental impacts of individual control systems. (The primary impact, or the reduction in vinyl chloride emissions, for each control system is described in Chapter 4.) The second part describes the primary and secdlTdafy environmental impacts which would result-from model plants using a selected combination of control nieaTu'res to attain'the-aTternative control levels (for ethylene dichloride-vinyl chloride and polyvinyl chloride dispersion plants) or the level of the proposed standard (for other types of polyvinyl chloride plants). The second part also compares the incremental quantities of pollutants generated and energy consumed as the result of applying*contfol"meastfres with the quantities of pollutants generated and energy consumed by-unregulated plants. 6.1 Secondary Environmental Impacts of Individual Control Systems The secondary environmental impacts which have been identified for individual control systems applied to ethylene dichloride-vinyl chloride and polyvinyl chloride plants are identified in Table 6-1. For the fugitive emission control techniques the secondary impacts are relatively minor. These include increased electric power usage for monitoring systems and increased fuel consumption for steam to be used in stripping vinyl chloride from process water. The quantities of energy used depend on the type and size of plant 6-2 COLOR!TE 008573 whore the equipment is employed. Also, t.he proposed standard specifies fha` all captured fugitive emissions must be recovered in a monomer : ecosystem or controlled to a level of 10 ppm by incineration, carbon adsorption, solvent absorption, or equivalent. If the captured fugitive emissions were ducted to a control system, there would be the additional secondary impacts which are identified for each of these systems. "" -^^^he-secondary-^rticiuroafflental jiopactsc.of - The -oaLshoIder/water.puVge . --- .;iyS_t&m3JS^`d ,to .cdhtrTmCTTf?Fions'_jfraTi"operiiTig;.of; pol_yyiriyl gchloride ^^j-qjd-aht^'ea'fiTori -Thcl lide" ._ln crteas ed'.tfi quantity of vinyl chloride released into the inprocess wastewater, "and relatively minor increases in energy consumption,.. .Theim:".------- regulations for relief valve discharges could cause some increased ' __ in process equjpmen.t. Use o.f _refrt5rafion-as "T contr-PT. technique "^"rRe^ctor soiveh"t~clearnng'wfCh' teTra'hy'drdTtjran^TH^'dJ'In____ ; conceivably-cause~mal1 'quantities of solvent to be released into the atmosphere", although this has not been quantified.- Also, ___.__ somgjjj.sts^of solvent to water has been reported by_one plant (4.54 kg/batch)^ and some incremental increase in energy consumption would be expected. This control technique is used by plants primarily to reduce employee exposure to vinyl chloride by eliminating the necessity for employees --moving by hand unwanted hardened resin from reactors setween batches. The solid mar -rial is separated horn tin- solvent in . distillation uolu:v subsequent to iPac.tor cleaning and is sold 6-4 COLORITE 008574 TABLE 6-1. SECONDARY ENVIRONMENTAL IMPACTS OP INDIVIDUAL CONTROL SYSTEMS control SYSTEMS FJDHIVC EMISSION1 CONTROLS (monitoring systern and water stri pper GASHOLOEH/WATER PURGE SYSTEM AIR IMPACT JtCLIEf VALVE COCOES REFRIGERATION REACTOR SOLVENT CLEANING Small amounts of sol vent may be released to atmosphere. SECONDARY ENVIRONMENTA1 IMPACTS WATER IMPACT) SOLID WASTE IMPACT Increased water consumption and Increased vinyl chloride In the tnprocess wastewater. i i Some of the solvent may be dis The solvent is recycled. The charged to the Inprocess amount of sol id! materi al col wastewater. lected is the shine whether a reactor is hand-cleaned or 1 solvent-cleaned. i if RCY a I'.-WTiON Increased nowo-r and fuel consurmiLinri Increased onwer con sumption Increased power consumption Increased power consumption Increased power consumption IMPROVED SLURRY STRIPPING SOLVENT ABSORPTION UiHHON ADSORPTION INCINERATION (WITHOUT SCRUBBER} Increased water usage for steam, and Increased vinyl Small amounts of sol vent may be released to atmosphere. chloride, in the inprocess wastewater. '1 ------------------ T"--------- 1--------*-------------------- The solvent Is recycled. The i[ vinyl chloride is stripped out i1 and recover l 4. i Hydrogeh chloric^; nitrogen oxides i Increased water usage for steam desorption and< increased vinyl :hloi*ide In the In'process wastewater. )i ' M! The carbon is continuously de sorbed and reused but K is estimated that1It may have to be replaced every 1 to 3 years. 4 8 1.......... }.. 1 I1 INCINERATION (WITH WATER SCRUBBER) Hydrogen chloride; nitrogen o.Ides Increased water usage; increased vinyl chloride In Inprocess wastewater; hydrogen chloride In water decreases pH to approxi mately 1. Increased fuel consumption for steam Increased power consumption Increased fuel consumption Increased cower consumption Increased fuel consumption Increased power consumption Increased fuel consumption Gost of the fugitive emission controls (except the two Indicated) In themselves have no Impacts. However, If captured fuqitlve emissions are transferred to a control device instead of being recovered, the control of captured figitlve emissions will have the impacts already listed for the various control devices'. COLORITE 008575 solvent would be st-'isued out in a ..wl'-en ipper and recovered d bo . . -..y"' -oi through the absorption .nit. S: ;a conceivably be lost to the (jn cuunti tied. The secondary er ; i. onmer s of carbon adsorption include increased newer consumption er consumption, increased fuel consumption to convert the -water to steam for desorption, and possibly increased quantities of vinyl chloride released into the inprocess wastewater. Although the carbon in an adsorption bed is continually desorbed and recycled, there may"also be some solid waste impact from using "carbon adsorption. The "only available information on carbon adsorption in the ethylene dichloride-vinyl chloride and pol;. vinyl chloride industries is from pilot studies and from one unit 'which was recently insta.ll.ed (19.Z5.) at a polyvinyl >wn at this .time what the bed-lifejo-f^e"ea-ri&eia-~tBed-in-adsorption applied at these plants will be'or wh'etirw^Ttfp^arhon- wi lT~he- regenerable. If polymerization occurs o rPth e--carbon^ tne p^Tyror^--nju?H""be"burned off and the carbon" recycled. __I f characteristics of the carbon, such as the large surface- to-volume ratio, which be it desirable for adsorption are destroyed, however, it must be rep7tH~~-?T- "f-t-is1 possible that the carbon in adsorption devices will have to ; replaced every 1 to 3 years. In this case, 'he is.vJ ca-: - -acid probably be taken to a land-fill for disposal. ' could also he burned in a boiler as a low sulfur 'uC'V'oons y/drvyen chloride emissions. COLORITE 008576 or discarded in a landfill just as it would be if the reactors were hand-cleaned, "he solvent is recycled. Therefore, there is no positive or negative impact of reactor solvent cleaning on solid waste disposal. The secondary environmental impacts from using improved slurry stripping include increased water usage for steam, increased vinyl chloride released into the inprocess wastewater, and increased fuel consumption to convert the water into steam. Primary stripping, which is already used by most plants and consists of raising the temperature of the stripping operation to 75C (167F), requires 3,000 -4,000 kilograms of steam per 10,000 kilograms of product. Improved stripping, which would be used as an abatement technique and consists of maintaining the stripping operation at 75C (167QF), is expected to require an additional 1,500 -2,000 kilograms of steam per 10,000 kilograms of product. The steam used for stripping is condensed and discharged as wastewater. The amount of vinyl chloride released into the inprocess wastewater is expected to be proportional to the amount of steam used, and thus would be increased by improved stripping. If the steam is used in a jacket surrounding the stripper instead of being sparged through the stripper contents, it would not be expected to increase the vinyl chloride released into the inprocess wastewater since it would not come into contact with resin or vinyl chloride. Solvent absorption used to control emissions such as from monomer recovery systems in polyvinyl chloride plants would cause an increase in power consumption. The vinyl chloride collected in the 6-5 COLOR!TE 008577 ST d out In 3 solvent '-trippe*' and recovered ,-t vi'ji.i1,'] bo :i Ihw.unh the absorption ; io concei vabl > be lost to the cugn this has no-, been quanti ri.3J The oocth y environments'! 'o ts of ca,''b^n adsorption include increased power cons v~. Lion, increased wafer consumption, increased fuel consumption to convert the water to steam for desorption, and possibly increased quantities of vinyl chloride released into the inprocess wastewater. Although the carbon in an adsorption bed is continually desorbed and recycled, there may also1be some solid waste impact from using carbon adsorption. The oply available information on carbon adsorption in the ehiylene- dichloride-vinyl chloride and polyvinyl chloride industries is from pilot studies and from one unit which was recently installed (1975) at a polyvinyl chloride plant. Therefore, it is unknown at this time what the bed-life of the carbon used in adsorption applied!at these plants will be or whether the carbon will be regenerate. If polymerization occurs on the carton, the polymer could be burned off and the carbon recycled. If characteristics cf the carbon, such as the large surface- to-volume ratio, which mate it desirable for adsorption are destroyed, however, it must be replaced. It is possible that the carbon in adsorption .Jw-icas will have to be replaced every 1 to 3 years. In this case, the used carbon would probably be taken to a land-fill for disposal. It could also to turned in a boiler as a low sulfur Col. I! * '0 Wj.-top cental e; Cwev-r, to ,;nj -cy cause :h!'Virated hydros , ..;ns hyd .vgen chloride amissi-w-s. C 'o COLORITE 00857B The major secondary environmental impacts identified for control ly ; ,,c i ne; ation ore hydrogen chloride emissions and increased energy consumption. Hydrogen chloride is generated when chlorinated hydro carbons are incinerated. At the present time, only a few plants incin erate chlorinated hydrocarbons, and in most cases this involves incin eration of liquid waste materials at ethylene dichloride-vinyl chloride plants. When incineration is practiced to control vinyl chloride emissions, 0.58 kilogram of hydrogen chloride is produced for each kilogram of vinyl chloride combusted. Depending on the type of polyvinyl chloride process, the amount of hydrogen chloride generated ranges between 0.68 and 1.97 kilograms per 100 kilograms of polyvinyl chloride resin produced. From a typical ethylene dichloride-vinyl chloride plant, incineration would produce approximately 1.11 kilograms of hydrogen chloride per 100 kilograms of vinyl chloride produced. A large prop ortion (90 percent) of the hydrogen chloride from an ethylene dichloridevinyl chloride plant incinerating the emissions from all point sources within the plant would be produced from combustion of the chlorinated hydrocarbons other than vinyl chloride present in the gas streams. Typically, as described in Chapter 4, the hydrogen chloride emissions generated by the incinerator are scrubbed with water or caustic; however, EPA has no regulations for hydrogen chloride which force the use of an absorption unit for this purpose. Therefore, later sections in this chapter quantify emissions of hydrogen chloride with and without scrubber control. Using a scrubber to control the hydrogen chloride emissions increases water usage and increases power consumption. If a caustic scrubber is not u^ed or the hydrogen chloride is not recovered from the 6-7 COLORITE 008579 it n'fluent T.iJ be lowered. ihe - 'vail due -0 tie . > : cy or vi.'iv] coTorid= - j a^d Sec.3T;T1S ts at -->.iaI Ouanti fiei in the following paragraphs are the primary and secondary environmental impacts `which would result ^cm model plants attaining the alternative control levels identified ;n Chapter 5 ('"or ethylene dichlorids-vinyl chloride and polyvinyl chloride dispersion plants) and the level of the preposed standard (fjr other types of polyvinyl chloride plants). For each of the control levels, a combination of the control systems identified in Table r-I has been selected for abatement o" :vissions from various points in a modal plant, fhe model plants consist or both plants that are average-in size and those that are larger than average; the latter are presented to approxi mate "worse-case" situations. 6.2.1 Primary Environmental Impacts The purpose of this section is to quantify the degree to which each control level reduces mass emissions of vinyl chloride and ambient concentrations of vinyl chloride. 6.2.1.1 Mass Emissions The mass emission ra:;s of vinyl chloride from average-sized and la.y:- !.,odel plants attaining varices controllevels are quantified r fable -?. '-'r pur-poses of ccyarison. the mass emission rales fee ... reg,;1 n1 n ;e; pi'.-n-.s are sico ;h;-,n. These unregulated emission e:-s \;e based on dste ..jtair ed vc "e industry in the soring of COLORITE 008580 TABLE 6-2. VIHTL CHLORIDE MASS EMISSION REDUCTION1`Z<1 - - --......................... Kfiort PIAT.T5 |si:r i " KlYfnuf i IvfT M/"r IiKur)____ Cm ss 1 orisM.'-lr (U/llr) Percent Emission Pprlwt tl on ethylene M`chlor1tfe - Wny 1 CM Pi 1 Jlu PI i'i t (JIB lg / y r or 700 'r lbj*r) ' vtj ' t ,yl pni" ilchloride - I'i 1 i i '1 me flonutsrge 1 n|'*r ur l]r>r Tl 1 ii v r) Polvy 1 nyl CIn 1 ortd-e Suspension - [iisfei s Ion Plant - Avq (4s HH kg/yr or inf) lb/yr - H kq/yr or 30 m >b/yr) Pn 5 / v 1 nyl Ctilorl de Si,', ii ns ion - 01 spers 1 on PSnnt - ta^qe {112 MM kq/yr or 250 W lh/yr If m kq/yr or 100 *W lt/yr 1 Pol j v S i y 1 fji lor 1 Ji' 'I'JSpcnstt Plant ,'vq (Til Mf' 1 i/yr or 150 "J1 Wyr} Polyylnyl ChlorlJo Suspension Plant * Large (153 '71 Ig/yr or 35J 'Tl Ib/yr) Polyv1nyl Chlorl Je fl-H HilM . Ayg, (45 T or Ini fM 31,/yr) Polyvinyl Chloride Buik Plant Large (77 Nil kg/yr or 170 !?l kq/yr) Polyylnyl P-slorliki Solution Hant - Aug {11 711 Ig/yr or 24 HU tb./rj 176 (792} 32B (72JJ) 322 (?U) 899 (1076) 330 {735) 772 {1716) 13C (30]} 230 (512} (5J> 19 (42) is (ia> 6f> (133) 190 (4231 DC, 90 81 - total plant (5? dispersion process only) 01 - total plant (S2 - dlspersion process only} - * - autPMATivr n^pnpo^ro sTA'ipARb Ctnlsslons Kg/Mr (Lb/Hr) Percent tml sslori Seduction w (zj) 94 Z3 (ID If (If,) 45 (in) 94 (95 - dispersion process only) process only) 16 (36) 36 (85) 5 (II) 1 (HI O.S (1) 95 5 96 96 98 i,I-'.uregu 1ated emission* based on data submitted to CPA In the spring of 1974. ^The reduction In fugitive emissions cannot ba quantified and Is based on Judgment. sii'iitjs plar t operates EKWO hr/yr. Effl i SS Inr.v Kg/Hr (Lb / 111 j 5 (1!) 10 (23) 17 (26) % L .1.1 I 5 1 III fw ,h .|>L-I . (..r 3f (30) MCl - 1<I ( rt 1 p Ifl lit H7 ,1. ,|,, ....... priLt'SS ml' - CQLORITE 008581 The alternative control' levels for ethylene dichloride-vinyl chloride plants represent three different degrees of emission reduction for the oxychlorination reactor: (1) no control, (2) controlling process variables, and (3) control by incineration or equivalent. The alternatives range in the degree to which they reduce emissions from the entire model plant from 90 to 97 percent. The range is relatively small because the oxychlorination reactor represents only about 8 percent of the total emissions at an average plant. The alternative control levels for the polyvinyl chloride dis persion plant represent three different degrees of emission reduction for the emission sources which follow the stripping operation in the flow of materials through the plant: (1) stripping to a level which has currently been achieved for all grades of all dispersion resins at all plants (2) stripping to a level which in EPA's judgment will be available for all grades of dispersion resins within the maximum time allowed for compliance, and (3) stripping to the same level as required for other resins. Because dispersion resins are typically produced at plants which also produce other types of resins, the emission rates presented in Table 6-2 for the alternative control levels are actually from a model combination suspension-dispersion plant. Since there are no alternative control levels for the production of other types of resins, each of the alternative control levels for the combination plant represents a 95 percent emission reduction in the suspension part of the plant. The emission reduction for the dispersion part of the plant ranges from 52 to 97 percent, depending on the alternativ control level. The variation in emissions due to the alternative 6-10 COLOR!TE 008582 control levels for the dispersion part of the plant would cause the reduction in emissions from the combination plant "o range between 81 and 96 percent. Alternative II would result in a S5 percent reduction in emissions from the dispersion part of the plant and from the combination plant. As stated before, there are no alternative control levels for the production of polyvinyl chloride resins other than dispersion resins. Therefore, Table 6-2 presents the emission reductions which would be achieved by the proposed standard for these other types of resins. The emission reduction is 95 percent or <. eater in all cases. For both ethylene dichloride-vinyl chloride and polyvinyl chloride plants, it is assumed that the alternative control levels/ proposed standard would reduce fugitive emissions by 90 percent. The actual reduction in fugitive emissions which would be achieved cannot be quantified. However, it appears reasonable to assume that the application of best available control technology for each known fugitive emission source would achieve a 90 percent reduction in emissions. 6.2.1.2 Ambient Concentrations Diffusion model calculations were applied to the mass emission rates in Table 6-2 to determine the impact of the alternative control levels (for ethylene dichloride-vinyl chloride and polyvinyl chloride dispersion plants) and the proposed standard (for polyvinyl chloride plants other thw' Those making dispersion resins) on ambient concentrations of vinyl chloride in the vicinity of average-sized and large model plants. For purposes of comparison, diffusion modeling was also used to 6-11 COLORITE 008583 calculate ambient concentrations of vinyl chloride resulting from unregulated emissions. The ambient concentrations were calculated in terms of five-minute averages, 24-hour averages, and annual averages. The expected ambient concentrations of vinyl chloride in the vicinity of unregulated and regulated plants can be found in Tables 6-3, 6-4, and 6-5. Versions C8M3D and C5MCL of a diffusion model were used for calculating the estimated concentrations presented in this report. C8M3D was used for the annual and 24 hour estimates, and is based upon the sector-averaging technique of the EPA Air Quality Display Model; this technique utilizes the univariate Gaussian distribution in each of 16 sectors (22.5 degrees each) around the horizon. C5MCL, used for the 5 minute estimates, is program C8M3D with only a few programming changes which provide concentrations appropriate to the bivariate Gaussian distribution. The models were used in the modes which simulate a rural environment consisting of relatively flat land. Each facility evaluated, be it an average or large plant, is assumed to cover a 100 square meter area. Fugitive losses are assumed to occur homogeneously over this area at 6 meters above ground. All point-source emissions (e.g., dryer vents, etc.) are assigned to one location at the center of the facility, although a stack height is assigned to each such source. Briggs' buoyant plume rise formulae are available as a subroutine in the computer programs. These formulae are used in cases when the analyst determines that significant plume rise night 6-12 COLOR!TE 008584 *1 i j i i i MODEL PLANTS (SIZE) TABLE 6-3. REDUCTIONS IN VINYL CHLORIDE AMBIENT CONCENTRATIONS ESTIMATED RY DIFFUSION MODELINO - 5-MINUTE AVERAGE MAXIMA1 UNREGULATED T AMBIENT.AIR CONCENTRATIONS (5-MINUTE AVERAGE MAXIMA - ALTERNATIVE I ALTERNATIVE 11/ PromSE!) STANDARD PPM) /LTERNfTI7E III Vinyl Chloride Plant - Avg. (31S MM kg/yr or 700 ISI lb/yr) B.7 2. 2 1.5 0.31 Vinyl Cli lor tile Plant- Largo (530 MM ig/yr or 1300 MM ll/yr) Polyvinyl Chloride Suspension Dlsoerslon Plant Avg.; (54 MM kq/yr or 120 MM lb/yr 14 MM kn/yr or 30 MM lb/yr) Polyvinyl Chloride Suspension Dispersion Plant - Large (112 MM kg/yr or 250 MM lb/yr/45 MM kq/yr or 100 MM lh/yr) 16 71003 74003 3. 12 3a 89 2.8 5.3 12 r 71 2.6 6.1 Polyvinyl Chloride Suspension Plant - Avg. (6G MM ig/yr or 150 MM lb/yr) Polyvinyl Chloride Suspension Plant - Large (150 I'M kq/yr or 350 HU lb/yr) 71003 75003 - 6.2 14.0 - The plants were evaluated for neutral, slightly stable, and moderately stable atmospheric conditions. A wind sneed of 0,5 naps was used. Receptors were assumed to he located at GO in intervals from the center of the plant. Effective height of emissions -.v. at stack height. Fugitive emissions were treated as 100 x 100 ro area sources at 6 m above ground. Other sources were all treated as point sources, located at the center of the area source. 3The emissions for Alternative I are based on the plant with the largest emission factor for the oxychlorination process. This is the one plant which would have to install additional control to attain Alternative II control level. 3It was assumed that 2,250 kg (5000 lb) of vinyl chloride were released to the atmosphere during the 5-mlnute period from a reactor relief valve discharge. COLOR!TE 008585 I I TABLE 6-4. REDUCTIONS IN VINYL CHLORIDE AMBIENT CONCENTRATIONS - ESTIMATED BY DIFFUSION MODELING - 24-HOUR AVERAGE AX I HA1 [ MODEL PLANTS (SIZE) AMBIENT AIR CONCENTRATIONS (BA-HOUR AVERAGE MAXIMA - PPM) UllRECULATElT TLTERNAffVE I ALTERNAT1VE I [/PROPOSED STANDARD ALTrWff;] fi f Vinyl Chloride Plant - Avg. (313 MM kg/yr or 700 MM lb/yr) Vinyl Chloride Plant - Large (590 iifl kg/yr or 1300 IIH lb/yr) Polyvinyl Chloride Suspension Dispersion Plant - Avq. (5^ MM kg/yr or 120 MM lb/yr/14 MM kq/yr or 30 MM lb/yr) Polyvinyl Chloride Suspension Dispersion Plant - Large (112 MM T kg/yr or 250 MM lb/yr/45 MM kg/yr or 100 MM lb/yr) 0.97 l.B 11 27 0.122 0.22? 1.7 4.0 0.094 0.17 0.29 0.66 0.044 0.17 0.22 0.51 Polyvinyl Chloride Suspension Plant - Avg, (63 MM kg/yr or 150 MM lb/yr) Polyvinyl Chloride Suspension Plant - Large (159 Mil Lg/yr or 350 JIM lb/yr) If! ' i 23 '. .' i 0.30 0.70 COLOR!TE 008586 The plants were evaluated for neutral, slightly stable, and moderately stable atmospheric conditions. A wind speed o-f 0.5 nips was used. Receptors were assumed to be located at 80-m intervals from the center of the plant. Effective height of emissions was at stack height. Fugitive emissions viene treated as 100x100 in area sources at 6 m above ground. Other sources are alt treated as point sources, located at the center of the area source 2The emissions for- Alternative I are based on the plant with the largest emission factor for the oxychlortnation process. This is the one plant which would have to install additional control to attain Alternative II control level. J TABLE 6-5. REDUCTIONS IN VINYL CHLORIDE AMBIENT CONCENTRATIONS - ESTIMATED CY DimJSIDN MODEL INC ANNUAL AVERAGE MAXIMA1 i'OUCL PLANTS (SIZE) AMBIENT AIR CONCENTRATIONS (ANNUAL AVEPAGF MAXIMA - PPM) UNREGULATED ALTERNATIVE I AmL-TiEtKRHNAATiIiVvEt i1i/`^'SOTPAN^DSAERDD ALTERNATIVE III Vinyl Chloride Plant - Avg. (318 MM ky/yr or 700 MM lb/yr) Vinyl Chloride Plant - Large (590 lift kg/yr' or 1300 MM lb/yr) 0.17 0.32 0.0192 0.0352 Polyvinyl Chloride Suspension - 0.60 0.10 Dispersion Plant - Avg. (54 MM kg/yr or 120 MM lb/yr/14 MM kg/yr 3 or 30 MM lb/yr) 0.016 Q.03n 0.038 0.015 0.023 0.037 .L Polyvinyl Chloride Suspension t'1 Dispersion Plant - Larqe {112 CM kg/yr or 250 MM lb/yr/45 MM kg/,yr or 100 m Ib/.yr) 1.4 0.24 0.030 0.088 Polyvinyl Ciilorlde Suspension Plant - Avg. (68 U.`1 i g/yr or 150 I'M lb/yr) Polyvinyl CM Toride Suspension Plant - Large (159 MM kg/yr or 350 MM lb/yr) 0.75 : 1.8 - `' *. :1 - 0.051 ** 1 0.12 1 The plants were evaluated using meteorological data from Houston, Texas. Receptor? were assumed to be located at 80 m Intervals from the center of the plant. Effective height of emissions was the stack height. Fugitive emissions were treated as 100 x 100 m area sources at 6 m above ground. Other sources are all treated as point sources, located at the center of the area source. n The emissions for Alternative I are based on the plant with the largest emission factor for the oxychlorination process. This is the one nlant which would have to Install additional control to attain Alternative II control level. COLORITE 008587 occur. Otherwise, the stack height usually was used as the effective height of emission; in one case, a non-buoyant jet plume was assigned a fixed, non-zero plume rise. The meteorological and source variables required for executing the programs are as follows: (a) Wind direction, wind speed, and atmospheric stability for the meteorological condition(s) to be evaluated. (b) Source variables (1) Stack height (height of emission). (2) Effluent temperature and effluent volume flow rate; or effluent temperature, effluent velocity, and stack diameteir;~or~ an assigned fixed plume rise. (3) Afternoon mixing depth (assigned a value of 1500 meters in these analyses; hence, reflection is negligible).------ -- . ... . (4) Source coordinates (in units of the programmed-grid system). (5) Width of square area source (a value of O.-Q -denotes point sources). (6) Emission rate. (7) Half-life pollutant (assumed infinite for vinyl chloride and hydrogen chloride). (8) Various program-control parameters. A total of at least 119 data records (i.e., 119 lines or 119 punched cards) are required for each job on the computer. About 300 computer jobs were required for this task. Listing the input data would thus require about 600 pages; therefore, they cannot be included in this report. 6-16 COLOR!TE 008588 Table 6-6 presents the compounding effects of a cluster of plants within 5000 meters of each other on ambient concentrations of vinyl chloride. The plant cluster used for the modeling is patterned on a real plant cluster, and consists of one polyvinyl chloride and three ethylene dichloride-vinyl chloride plants. A map showing the relationship of these four plants to each other and the distances among them is shown in Figure 6-1. The two cases presented in Table 6-6 differ only in the sizes of plants used in the model. In the first case, the plant sizes approximate the sizes of the plants in the real plant cluster. The polyvinyl chloride plant has a production rate of 122 million kg/yr (270 million lb/yr) and the three ethylene dichloride-vinyl chloride plants have production rates of 68 million kg/yr (150 million lb/yr), 118 million kg/yr (260 million lb/yr), and 375 million kg/yr (825 million lb/yr). In the second case, the plant sizes are the same as the -- " model plants used for the calculations" in TaETes-6^3,- 6-4,`-'-and 6-5. There are two average-sized and one large model ethyTeT\e""dichloridevinyl chloride plants and one large model polyvinyl chloride combination ^suspens.ion-djsj3ersion plant. For all cases, ambient concentrations were calculated on the basis of unregulated and regulated emissions. The purpose of doing the diffusion model calculations for the plant cluster was to illustrate the degree to which locating plants in close proximity to each other would increase the projected maximum concentration of vinyl chloride in the vicinity of any one plant. To achieve this purpose, it was unnecessary and unduly timeconsuming to do the diffusion model calculations for all the 6-17 COLORXTE 008589 VINYL CHLORIDE AMBIENT CONCENTRATIONS - CLUSTER OF FOUR h'HYLENE DICHlORIDE - VINYL CHLORIDE AND POLYVINYL CHLORIDE PLANTS1 - 5 MINUTE, 24-HOUR AMD ANNUAL AVERAGE rA UNREGULATED AND REGULATED i CASE C/N II CO ! SITUATION 1 [ UNREGULATED HEFTING THE PROPOSED STANDARD 1 ] UNREGULATED MEETING THE PROPOSED STANDARD VINYL CHLORIDE CONCENTRATION - ppm 5- Itino Average Max. t 24-Hour Average Max. 7100 ^ 11.0 ! ................ 0 ! ( 0.31 Annual`Average "ax. 0.61 0.051 76002 25.0 1.5 3.1 ; 0.50 0.090 Ti,e sizer, and relationships of these plants are sliowri in Figure 6-1 for Case I rtijd in Figure 6-2 for ! I. 2U,. was assumed that 2,250 kg (5000 lb) of vinyl chloride were released to the atmosphere during the 5-minute period from a reactor relief valve discharge. COLOR!TE 008590 VCM (=3 MM kg/yr) /V^ VCM (113 MM kg/yr) ^aa"' '*o. A Pvc (iZ2i'.i.',l kg/yr) 7 / ?v / VCM (375 MM kg/yr) Figure 6-1. Map of four plant cluster - Case I. VCM (318 MM kg/yr) " " " 2? 3680 W pvc (159 MM kg/yr) VCM (313 MM kg/yr) X^ X* ?/ / x VCM (530 MM kg/yr) Figure Q-2, Map of tour plant cluster - Case II. 6 -19 COLOR!TE 008591 alternatives. Thus, calculations for the regulated emissions ,,cre done only for Alternative II for ethylene dichloride plants. Alternative II for polyvinyl chloride dispersion resin manufacture, and the proposed standard for polyvinyl chloride suspension resin manufacture. All of the values in Tables 6-3 through 6-6 represent the point of maximum concentration. In other words, if ambient samplers were placed so that they covered all of the ground space around a plant, the numbers in the tables represent the sampler location with the highest concentration which would be measured. In calculating the ambient concentrations, realistic "worst case" meteorological conditions were used. In order to determine the worst case meteorological con ditions for the 5-minute and 24-hour averaging times the modeling calculations were conducted for each situation using different atmospheric stability conditions. These included neutral, slightly-stable, and moderately stable. A wind speed of 0.5 mps was used in all cases. For the annual averaging time, actual meteorological data from Houston, Texas were used. For both ethylene dichloride-vinyl chloride and polyvinyl chloride plants, fugitive emissions comprise a significant proportion of the total emissions. The relative contributions of an area source and a point source to the maximum ambient concentration can vary considerably, depending on the stability class, the averaging time, and the point source plume rise used for a given case. An area source among point sources may dcmi-ate ambient annual and 24-hour maximum concentrations, jt be a minor contributor to the 5-minute maximum concentration, even 6-20 COLOR!T 008592 though emissions do not change. This is due to the plane geometry of the diffusion of emissions from the source as viewed from the receptor, and due to the increasing variability of meteorological conditions as time increases. As explained in Chapter 2, there is no known threshold level of effects for vinyl chloride. The Occupational Safety and Health Administration promulgated a standard of 1 ppm (8-hour average) and 5 ppm (15-minute average) for worker exposure, but this standard is not based on a threshold level of effects. Since there is no yardstick against which to compare the ambient modeling results in Tables 6-3 through 6-6, only the relative Tnagnitude of the results when compared with each other is discussed here. In comparing the ambient concentrations for the different --alternative control levels, it is important to-remember that the numbers in the tables represent the maximum concentrations OTily. "The relative ^"difference between the ambient concentrati-ons-for-two given-alternatives "_niay''be"greater or less at the point of maximum concentration than at some other point at a different distance from the source. The alter native control levels for ethylene dichloride-vinyl chloride plants, - for-example,-differ only in the degree to which one of several emission points is controlled. The relative difference in the maximum ambient concentrations for the alternative control levels therefore depends on how much that particular emission point contributes to the maximum concentration. If the meteorological conditions selected to obtain the maximum concentration are such that the area source (fugitive emissions) is a much greater contributor to the maximum concentration than are the 6-21 COLORITE 008593 point sources, a change in the emissions from the one point source may ! ake little difference in the maximum ambient concentration. It would be expected, however, to make a difference in the concentrations found at some other distances from the plant. In reviewing the results for the alternative control levels for ethylene dichloride-vinyl chloride plants, it is found that there is a greater difference between the 24-hour average maximum ambient concentrations for Alternatives I and II than for Alternatives II and III. The opposite is true for the 5-minute average maximum ambient concentrations. The emissions used in the model for Alternative I are based on the emission factor for the oxychlorination reactor at the one plant which would have to implement substantial control for that process to attain the emission level of Alternative II. In other words, the difference in the concentrations for Alternatives Taninris"that difference which would occur for only one pi ant"77 A1 ternatTve 11 were adopted as the proposed standard for the oxychlorinatiorTreactor. This is because the other plants are already essenTTaTly 'attaiTTlTfg the emission level required by Alternative II for the oxychlorination reactor. Requiring all plants to control the oxychlorination reactor to the level achievable by incineration (Alternative III) would result in lower 5-minute average maximum ambient concentrations but would make little difference in the maximum 24-hour average ambient concentrations. In reviewing the results for the alternative control levels for polyvinyl chloride combination suspension-dispersion plants, it is found that there is a much larger difference between the maximum concentrations for Alternatives I and II than for 6-22 COLOR!TE 008594 Alternatives II and III. Requiring that emissions from the sources following the stripping operation for dispersion resins be reduced to a level equivalent to stripping to 2000 ppm (Alternative II) would achieve a twenty-fold improvement in the maximum 24-hour average ambient concentration at an average plant (from 4.0 to 0.29ppm) compared with requiring no control of the sources following the stripping operation (Alternative I). In comparison, requiring that emissions from the sources following the stripping operation for dispersion resins be reduced to the level of the proposed standard for other resins [equivalent to stripping to 400 ppm (Alternative III)] would '-esult in a relatively small additional reduction in the ambient concentration at an average plant (from 0.29 to 0.22 ppm 24-hour average). For polyvinyl chloride suspension plants, the proposed standard would also achieve a twenty-fold improvement in the 24-hour average maximum concentration (from 10 to 0.30 ppm). '- In Table 6-6 the maximum ambient concentrations calculated for the plant cluster occur in the vicinity of the polyvinyl chloride plant in both "cases, because it is the largest-source of emissions in the cluster. The data in the table indicate that the maximum ambient concentration for a model polyvinyl chloride plant is not significantly increased when that plant is located in this particular plant cluster with three ethylene dichloride-vinyl chloride plants. This does not necessarily mean, however, that the average ambient concentrations at other locations around the plants would not be increased by the effect of the cluster. It also does not necessarily mean that the maximum concentration for either type of plant would not 6-23 COLOR!TE 008595 be increased by another type of cluster such as one containing four large polyvinyl chloride plants. 6.2.1.3 Possible Transformations in Ambient Air^ No results on the reactions and rates of disappearance of vinyl chloride from the ambient atmosphere are available at present. Limited laboratory studies on the stability and persistence of vinyl chloride in air have, however, been completed. Vinyl chloride vapor concentrations in containers of various materials appear to be essentially constant over periods of many days. The peak absorption of vinyl chloride in the ultraviolet region is far below the solar cutoff (around 290 rm), so that vinyl chloride would not undergo reaction in sunlight in the absence of other reactive chemical species. When irradiated with simulated solar radiation in the presence of nitrogen oxides (nitric oxide and nitrogen dioxide), vinyl chloride in the parts per million concentration range does react to form a variety of products. The reaction products identified include ozone, nitrogen dioxide, carbon monoxide, formaldehyde, formic acid, formyl chloride, and hydrogen chloride. Although vinyl chloride should disappear significantly in traveling over longer distances, the conversions anticipated within a few kilometers downwind of emission sources would be small. No mechanism is presently known for removal of vinyl chloride from the air at night. Biological sinks, such as microbiological removal in soil, may be of significance in depletion of vinyl chloride over long time periods, but such sinks would not be expected to be 6-24 COLORITE 008596 important in terms of urban scale transport of vinyl chloride. Thus, for a first approximation, vinyl chloride in the immediate vicinity of vinyl chloride emission sources can be considered a stable pollutant. The usual meteorological dispersion equations can thus be applied to approximate concentrations in the vicinity of emission sources. Because of strong nocturnal inversions during the fall and winter, build-up of vinyl chloride from emission sources might be of particular concern during such periods. There are, however, no data on this. 6.2.2 Secondary Environmental Impacts The secondary environmental impacts, or the environmental impacts resulting from use of the control systems to attain the level of the proposed standard and alternative control levels, are discussed in the following paragraphs. Two factors should be remembered when reviewing this section. First, the secondary impacts for ethylene dichloride-vinyl chloride plants attaining the level of control of Alternative II are not presented because they would vary for individual plants, depending on the type of control used for the oxychlorination reactor. For individual plants, control of the oxychlorination reactor to attain the emission level of Alternative II could range from no control to a process change to incineration. Therefore, the secondary impacts for Alternative II could range between that of Alternative I, which represents no control of the oxychlorination reactor, to that of Alternative III, which represents incineration of the emissions 6-25 COLOR!TE 008597 Viin'nn mmm iKrr<nt frnr, the oxychlorination reactor. Data are unavailable on the secondary impacts of controlling process variables, but they are expected to be negligible. Most existing plants can attain the Alternative II control level without additional control of the oxychlorination reactor; however, one existing plant would possibly have to use incineration. Second, there are two types of control technology which polyvinyl chloride plants can use to achieve the second alternative control level for polyvinyl chloride dispersion resins and the proposed standard for the other types of polyvinyl chloride resins; (1) improved stripping and (2) add-on controls such as incineration. Environmental impacts are presented for both types of control technology. The improved stripping option is sometimes referred to as Case A and the incineration option is sometimes referred to as Case B. Case A and Case B are equivalent in terms of the level of control achieved, and thus have the same primary impact. 6.2.2.1 Air Impact The major secondary air impact of the control equipment which could be used to meet the proposed standard and alternative control levels for vinyl chloride is the production of hydrogen chloride from control by incineration. Hydrogen chloride is a hygroscopic, colorless gas with a strong, pungent, and irritating odor. Because of its high solubility in water, the gas fumes in moist air. An aqueous solution of hydrogen 6-26 COLORITE 008598 chloric'? is called hydrochloric acid. Emissions of hydrogen chloride are readily converted to hydrochloric acid fumes and droplets in air or when inhaled into the lungs. The strong dehydrating properties of hydrogen chloride can result in serious burns of the skin or mucous 2 membranes. Hydrochloric acid is extremely corrosive to most materials. Inhalation of hydrochloric acid causes coughing and choking, as well as inflammation and ulceration of the upper respiratory tract. Irritation of the eye membranes is another effect, and exposure to high concentrations can cause clouding of the cornea. The teeth can also be affected, and erosion may result. Hydrogen chloride and hydrochloric acid are also phytotoxicants that damage the leaves of a great variety of plants. Several episodes of plant damage from hydrochloric acid emissions have been reported. Mists of hydrochloric acid are not as dangerous to humans as hydrogen chloride gas, because the acid has no strong dehydration effect 2 on the tissues. The limited studies available on hydrogen chloride health effects pertain to occupational exposure, and indicate that no organic damage results from exposures equal to or above 7,000 ig/m^ (5 ppm). The American Conference of Governmental Industrial Hygienists (ACGIH) has adopted a ceiling level of 5 ppm as the threshold concen- 2 tration for hydrogen chloride for an 8-hour day, 5-day week. The National Academy of Sciences (NAS) has recommended some guide line ambient concentrations for hydrogen chloride for short term public exposures, or those exposures "occurring at predictable times and 6-27 COLORITE 008599 arising from single or, occasionally, repeated events." The recommended short-term public limits are 6,000 ig/m~3 for 10 minutes, 3000 tg/rn3 for 30 minutes, 3000 \q/m 3 for one hour daily, and 1000 vg/m3 for five hours/day, three to four days/month. These levels are time-weighted averages; excursions above these levels are likely to produce objectionable 23 odors and/or irritation. West Germany has established 5 ppm as the permissible work-station concentration and also an ambient air quality standard of 0.5 ppm 3 (approximately 700 tg/m ) of hydrogen chloride for a 30minute mean average, with a maximum of 1.0 ppm (1,400 ig/m 3 ) 2 . 3 Russia has established 15 ig/m (0.009 ppm) as a 24-hour maximum average for ambient air concentrations of hydrogen chloride and a maximum of 50 ig/m of hydrogen chloride (0.03 ppm) for a single exposure. The standard for a 24-hour average is below the concentrations which might cause reflexive reaction of the sensory organs. Czechoslovakia 3 has established a maximum ambient air concentration of 28 j.g/m , with a one-time exposure maximum of 98 tg/m 3 . 2 6.2.2.1.1 Mass Emissions Tables 6-7, 6-8, and 6-9 provide information on the emissions of hydrogen chloride that would occur if incineration (without subsequent scrubbing) is used to control vinyl chloride emissions from ethylene dichloride-vinyl chloride plants and polyvinyl chloride plants. Table 6-7 contains emission factors for individual sources within ethylene dichloride-vinyl chloride plants and the various types of polyvinyl chloride plants. These emission factors 6-28 COLORITE 008600 w TABLE 6-7. EMISSION FACTORS FOR HYDROGEN CHLORIDE RESULTING FROM INCINERATION OF ^MISSION POINTS IN ETHYLENE DICHLORIDE-VINYL CHLORIDE (EDC-VCM) AND POLYVINYL CHLORIDE (PVC) PLANTS Emission Points Hydrogen Chloride Emissions - KG/100 KG Product Suspension PVC Dispersion PVC Bulk PVC Solution PVC Monomer Recovery System 0.273 0.284 0.853 0.176 EDC-VCM Slurry Blend Tank 0.239 0.193 -- -- -- Dryer 0.398 1.370 -- 0.472 -- Bulk Storage 0.057 0.097 0.131 -- -- Popo Blowers Screeners Grinders EDC and VCM Purification Processes Oxychlorination Reactor Transfer Points 0.028 -- --- 0.028 0.019 -- -- ... -0.028 --0.028 0.648*1 0.421*1 0.0468*1 COLORITE 008601 *1 Includes HCL from chlorinated hydrocarbons in the gas stream besides vinyl chloride. TABLE G-8. HYDROGEN CHLORIDE HASS EMISSIONS FUUI1 MODEL ETHYLENE DICHLORIDE-VINYL CHLORIDE PLANTS USING INCINERATION TO ATTAIN THE ALTERNATIVE CONTROL LEVELS EMISSIONS KG/HR (LB/HR) ' AVERAGE PLANT (318 MM kg/yr or 7UD MM lb/yr) LARGE PLANT (590 MM kg/yr or 1300 MM lb/yr) ALTERNATIVES WITHOUT SCRUBBER CONTROL WITH SCRUBBER1 CONTROL WITHOUT SCRUBBER ' CONTROL WITH SCRUBBER1 CONTROL I 275 (608) 5.5 (12.2) 571 (1129) 10.2 (22.6) Il2 III 442 (976) 8.8 (19.5) 821 (1813) 16.4 (36.3) Ch g "'Assumes the scrubber has a control efficiency of 98 percent. ^Data for Alternative II are not presented because the hydroqen chloride emissions from incineration to attain the emission level of Alternative II would vary for individual plants, depending on the type of control system used for the oxychlorination process. For individual plants, control of the oxychlorination process to attain the emission level of Alternative II could range from no control to a process change to incineration. Therefore, the hydrogen chloride emissions for Alternative II could range between that of Alternative I, which represents no control of the oxychlorination process, to that of Alternative III, which represents incineration of the emissions from the oxychlorination process. Most existing plants can attain Alternative II control level without controlling the oxychlorination process; however, one plant would possibly have to use incineration. COLORITE 008602 TABLE 6-9. HYDROGEN CHLORIDE MASS EMISSIONS FROM MODEL POLYVINYL CHLORIDE PLANTS USING INCINERATION TO CONTROL A MAXIMUM NUMBER OF EMISSION POINTS Model plants Emissions, kg/hr (lb/hr) Without scrubber With scrubber control control 1 Polyvinyl chloride suspension plant -avg. (68 MM kg/yr) (150 MM lb/yr) 77 (170) 1.8 (4.0) Polyvinyl chloride suspension plant - large (159 MM kg/yr) (350 MM lb/yr) 181 (398) 4.0 (8.8) Polyvinyl chloride combination suspension dispersion plant - avg. (54 MM kg/yr or 120 MM lb/yr) (14 MM kg/yr or 30 lb/yr) 93 (204) 1.9 (4.1) Polyvinyl chloride combination suspension dispersion plant - large (136 MM kg/yr or 300 MM lb/yr) (23 MM kg/yr or 50 MM lb/yr) 206 (453) 4.1 (9.1) Polyvinyl chloride bulk plant - avg. (45 MM kg/yr) (100 MM lb/yr) 53 (117) 1.0 (2.3) Polyvinyl chloride bulk plant - large (77 MM kg/yr) (170 MM lb/yr) 90 (199) 1.8 (3.9) Polyvinyl chloride solution plant (only one) (11 MM kg/yr) (24 MM lb/yr) 9 (19) 0.18(0.4) 1 Assumes the scrubber has a control efficiency of 98 percent. 6-31 COLORITE 008603 ,,ere used to calculate the total mass emissions found in Tables 6-8 and -"-9. Table 5-8 gives the hydrogen chloride emissions from an average sized and a large model ethylene dichloride-vinyl chloride plant attainir each of the alternative control levels by using incineration. Table 6-9 gives the hydrogen chloride emissions from model polyvinyl chloride plants attaining the proposed standard by using incineration to control emissions from the maximum number of emission points where it could be appropriately applied. For dispersion resin manufacture, hydrogen chloride emissions when using incineration to meet the Alternative II control level are shown. Incineration would not be needed to attain Alternative I and could not be used (at least at the present time) to attain Alternative III. At ethylene dichloride-vinyl chloride plants, there are other chlorinated hydrocarbons in effluent gas streams besides vinyl chloride, such as ethylene dichloride and ethyl chloride, which would also be converted to hydrogen chloride in the incinerator. These are included in the factors in Table-6-7 and in the calculated emission rates in Tables 6-8 and 6-9. Not included in the mass emission rates in Table 6-8 is the hydrogen chloride which is already emitted from the process equipment in ethylene dichloride-vinyl chloride plants without incineration control. This equipment includes the oxychlorination process, vinyl chloride distillation column, ethylene dichloride reaction vessel, ethylene dichloride recovery unit, storage tanks, and ethylene dichloride washing. Based on estimates submitted by one plant, 20 which uses the Stauffer process and controls the hydrogen chloride emissions 6-32 COLORITE 008604 f i om all the process equipment listed above except the ethylene dichloride washing, there would be 17 kilograms (39 pounds) per hour in addition to the emissions shown in Table 6-8 for the 318 million kilograms per year ethylene dichloride-vinyl chloride plant and 26 kilograms (81 pounds) per hour in addition to the emissions shown for the 590 million kilograms per year ethylene dichloridevinyl chloride plant. If an ethylene dichloride-vinyl chloride plant incinerates chlorinated hydrocarbon wastes, there would be additional hydrogen chloride emissions. One average-sized ethylene dichloride-vinyl chloride plant reported an emission rate of about 1 kilogram (2 pounds) per hour from incineration of liquid chlorinated hydrocarbon wastes with 99.9 percent efficient scrubber control. 21 6.2.2.1.2 Ambient Concentrations The mass emissions of hydrogen chloride in Tables 6-8 and 6-9 were used in diffusion modeling to calculate the maximum ambient concentrations of hydrogen chloride which would occur in the vicinity of the model plants using incineration to control vinyl chloride emissions. The maximum ambient concentrations in the vicinity of model ethylene dichloride-vinyl chloride plants attaining the alternative control levels are in Table 6-10. The maximum concentrations in the vicinity of model polyvinyl chloride plants attaining the proposed standard (or the Alternative II control level in the case of dispersion resin manufacture) are in Table 6-11. In the case of the ethylene dichloride-vinyl chloride plants, the hydrogen chloride emissions from a plant attaining the 6-33 COLORITE 008605 ALTERNATIVE CONTROL LEVEL T1 II4 PLANT SIZE AVERAGE LARGE ETHYLENE DICHLOrSfVINYL CHLORIDE PLANTS ESTIMATED BY DIFFUSION MODELING 1 AMBIENT AIR CONCENTRATIONS - ug/m3 WITHOUT SUBSEf UENT SCRUBBING WITH SUBSEQtJENT SCRUBBING 5-MINUTE AVERAGE 50,0002 73,0002 24-HOUR AVERAGE ! 6,6002 7,6002 5-MINUTE AVERAGE 1 ,5002 2,8002 24-HOUR AVERAGE 23CT 4302 AVERAGE 3,0003 1 III LARGE 3,2003 2703 2803 1,70G2 2,4002 2202 2502 1'The plants were evaluated for moderatelyiunstable wind speeds. Receptors are assumed to be located at 80-m intervals from the center of the plant. Alljsources are point sources. G\ 10 4The wind speed is 0.5 mps. ! '| 1I i i 3The wind speed is 4.0 mps. i 4 Data for Alternative II are not presented because the hydrogen chloride emissions resulting from control systems used to attain the emissi6n level of Alternative II would vary for individual plants, depending on the type of control system used for the oxychlorination process. For individual plants, control of the oxychlorination process to attain the emission level of Alternative II could range from no control to a process change to incineration. Therefore, the ambient confeent rat ions of hydrogen chloride for Alternative II could range between that of Alternative I, which represents no control of the oxychlorination process, to that of Alternative III, which represents incineration of the emissions from the oxychlori nation process. Most existing plants can attain Alternative II control level without controlling the oxychlorination process; however, one plant would possibly have to use incineration. COLOR!TE 008606 TABLE 6-11. HYDROGEN CHLORIDE AMBIENT CONCENTRATIONS PROM INCINERATION or VINYL CHLORIDE EMISSIONS AT POLYVINYL CHLORIDE PLANTS - ESTIMATED BY DIFFUSION MODELING' 1 Ambient 3 air concentrations, pg/m Model plant (size) Polyvinyl chloride suspension plant - average (68 MM kg/yr) (150 MM lb/yr) Polyvinyl chloride suspension plant - large (159 MM kg/yr) (350 MM lb/yr) Without scrubber control 5-minute | 24-hour average^ j average^ 230 9.2 330 12 With scrubber control 5-minute average 24-hour average^ 254 2.0 302 2.4 CO CM Polyvinyl chloride suspensiondispersion plant - average (54 MM kg/yr or 120 MM lb/yr) (14 MM kg/yr or 30 MM lb/yr) Polyvinyl chloride suspensiondispersion plant - large (136 MM kg/yr or 300 MM lb/yr) (23 MM kg/yr or 50 MM lb/yr) Polyvinyl chloride bulk plant average (45 MM kg/yr) (100 MM lb/yr) Polyvinyl chloride bulk plant large (77 MM kg/yr) (170 MM lb/yr) Polyvinyl chloride solution plant (11 MM kg/yr) (24 MM lb/yr) 300 14 380 23 300 21 410 19 47 3.2 2.2 352 2.9 386 2.8 454 3.0 6.46 0.46 Receptors are assumed to be located at 80-m intervals from the center of the plant. 2Effective height of emissions is at stack height. All sources are point sources. The plants were evaluated for very unstable atmospheric conditions; the wind ^speed was 3 mps. The plants were evaluated for moderately unstable atmospheric conditions; the v/ind speed was 4 mps, except for bulk ar.d solution plants controlled for which the wind speed was 1 mps. 4The plants were evaluated for very unstable atmospheric conditions; the wind speQd c-was 1 mps. The plants were evaluated for very unstable atmospheric conditions; the wind speed was 4 mps. The plants were evaluated for very unstable atmospheric conditions; the wind SDeQd was 0.5 mps. K 6-35 COLORITE 008607  amative I control level are only about 60 percent of the hydrogen chloride emissions from a plant attaining the Alternative III control level. The maximum ambient concentrations are higher, however, for the model plant attaining the Alternative I control level. This is due to the fact that Alternative III, unlike Alternative I, includes incineration of emissions from the oxychlorination reactor. The oxychlorination reactor has a large volume gas stream. The large gas volume in Alternative III would cause a much higher plume rise and greater diffusion of emissions before they reached ground level than would occur in the case of Alternative I. EPA does not have a standard for public exposure to ambient con centrations of hydrogen chloride, and thus no yardstick with which to compare the projected 5-minute and 24-hour maxima in Tables 6-10 and 6-11. The values in the tables can be compared with the ACGIH adopted ceiling for occupational exposure, the NAS guidelines for short-term exposure, and the West German, Russian, and Czechoslovakian standards cited previously. It should be noted, however, that the value of such comparisons is limited by the fact that these standards and guidelines all have different averaging times and that their averaging times do not necessarily correspond with those of the values in the tables. It should also be noted that the values in the tables do not include the hydrogen chloride which is already emitted from process equipment in ethylene dichloride-vinyl chloride plants. 6-35 COLORITE 008608 The values for Alternative I in Table 6-10 (without scrubber control) for ethylene dichloride-vinyl chloride plants show that the projected 5-minute average maxima far exceed all of the standards and guidelines for both occupational and ambient exposure. The maximum 24-hour averages are approximately the same as the ACGIH adopted ceiling level for occupational exposure (7000 ig/m , 8-hour average) - --3 and one of the NAS guidelines for short term-exposure (6000 \g/m , 10-minute average). The 5-minute average maxima for Alternative III are lower than those for Alternative I, and are approximately the same 3 as the NAS guideline for a short-term exposure of one hour (3000 ig/m ). The 24-hour average maxima for Alternative III ate also lower than those for Alternative I and are below all recommended guidelines and standards except for the Russian and Czechoslovakian 24-hour average standards (15 tg/m3 and 28 ig/m3 , respectively). The values for polyvinyl chloride plants (without scrubber control) in Table 6-11 show that the 5-minute average maxima are below all the recommended guidelines and standards for short-term exposure except for the Russian and Czechoslovakian standards. The same applies to the 24-hour average maxima when comparing them with the recommended guidelines and standards for long-term exposure. 6.2.2.1.3 Technology Available to Abate Hydrogen Chloride Emissions The principal technique for controlling hydrogen chloride in an exhaust gas is absorption (scrubbing). Hydrogen chloride readily absorbs in water which provides a suitable scrubbing medium. There are 6-37 COLORITE 008609 mm many types of scrubbers (absorbers) that can be used. Among these are packed columns, spray columns, venturi scrubbers, and jet scrubbers. The operation of these scrubbers is essentially the same. That is, hydrogen chloride bearing gas is introduced in one end of the scrubber, and the gas is counter-currently contacted by the absorbing medium, usually water. Weak acid may be used instead of, or with, water. The part of the scrubber which comes into contact with the gas must be constructed of an acid-alkali proof material. In general, non-metallic materials should be used, such as stoneware, ceramics, carbon and graphite, and plastics or fiberglass reinforced plastics, if the temperature is low enough. For high temp eratures, rubber-lined steel, protected with carbon brick set in furan cement, or carbon steel coated with epoxy and high-grade 34 nickel alloy brick, are excellent forms of construction. ' Effectiveness If pure water is the absorbing fluid, hydrogen chloride can be absorbed with almost 100 percent efficiency. 5 *5 6 If weak acid is used, the efficiency will range from 85 to 99+ percent, depending upon the weak acid concentration and subsequent hydrogen chloride vapor pressure. The hydrogen chloride emission levels which can be achieved for vinyl chloride and polyvinyl chloride plants using scrubbers to control the incinerator effluent are presented in Tables 6-8 and 6-9 for the various model plants. Tables 6-10 and 6-11 present the maximum 5-minute average ambient concentrations and the maximum 24-hour average ambient concentrations of hydrogen chloride which are estimated by diffusion modeling to result from the 6-38 COLOR!TE 008610 emission levels for incinerator-scrubber control presented in Tables 6-8 and 6-9. The ambient concentrations for Alternative I are again higher than for Alternative III for the same reasons discussed in section 6.2.2.1.2. The values in Tables 6-10 and 6-11 can be compared with the guidelines and standards cited before. Again, however, the limitation with regard to the different averaging times and the fact that the values do not include hydrogen chloride emissions from process equipment in ethylene dichloride-vinyl chloride plants should be noted. The values for ethylene dichloride-vinyl chloride plants in Table 6-10 (with scrubber control) show that even though the 5-minute average maxima for Alternative I are higher than those for Alternative III, they are in the same range. They are above all the guidelines and standards for short-term exposure except for the NAS guidelines for exposure for 10 minutes, 30 minutes, and 60 minutes-(-6^000, 3,000, and 3,000 ig/m , respectively). The 24-hour average maxima for Alternative I are again higher than those for Alternative III, but in the same range. They are both below the ACGIH ceiling, the NAS guidelines, and the West German standard, but above the Russian and Czechoslovakian standards. The values for polyvinyl chloride plants (with scrubber control) in Table 6-11 show that the 5-minute average maxima are generally below all guidelines and standards for short-term exposure except for the Russian standard in four out of seven cases. The 24-hour average maxima, on the other hand, are below all guidelines and standards for long-term exposure. 6-39 COLORITE 008611 Cos t.s of Contro 1 D:-tailed information on the costs of incinerator-caustic scrubber control of model plants is contained in Chapter 7, The total capital cost of a scrubber for the model plants would be approximately half of t'ne total operating cost of the incinerator-scrubber unit. 6.2.2.2 Water Impact 6.2.2.2.1 Increased Water Consumption Table 6-12 lists the incremental increases in water consumption by model ethylene dichloride-vinyl chloride plants using incineratorscrubbers to control vinyl chloride emissions to attain the alternative control levels. Table 6-13 lists the incremental increases in water consumption by model polyvinyl chloride plants using either improved stripping or incinerator-scrubbers to meet the proposed standard (or Alternative II in the case of dispersion resin manufacture). In the case of the improved stripping option, an increase in water consumption would be caused by the water purge system for reactors, carbon adsorption for the monomer recovery system, and improved stripping for the sources following the stripper. In the case of the incineration option, an increase in water consumption would be caused by the water purge system for reactors and the incinerator-scrubber system for the monomer recovery system and the sources following the stripper. Alternatives I and III are not shown for dispersion resin manufacture. Alternative I would cause the same increase in water consumption as the improved stripping option for Alternative II, but would include only the water consumption for the water purge and the carbon adsorption unit. Alternative III would be essentially the same as the improved stripping option for Alternative II, but may require additional water for steam for stripping. The quantities of 6-40 COLORITE 008612 TABLE 6-12. INCREASED WATER CONSUMPTION BY MODEL ETHYLENE DICHLORIDE-VINYL CHLORIDE PLANTS USING AN INCINERATOR-SCRUBBER TO ATTAIN THE ALTERNATIVE CONTROL LEVELS MODEL PLANTS AVERAGE-SIZED PLANT (318 MM KG/YR OR 700 MM LB/YR) Base Water Consumption^ MM 1/yr (gal/yr) ALTERNA TIVE I ALTERNATIVE II2 WATER CONSUMPTION PERCENT MM 1/YR INCREASE IN (GAL/YR) WATER CONSUMPTION 2653 (700) 3.6 (0.96) O.U LARGE PLANT (590 MM U/YR OR 7* 1300 MM LB/YR) 4927 (1300) 6.7(1 .8) O.U ^Based on 8.31 1/kg product (1 gal/lb) reported to be used at two vinyl chloride plants.^ 2 Data for Alternative II are not presented because the water consumption resulting from control systems used to attain the emission level of Alternative II would vary for individual plants, depending on the type of control system used for the oxychlorination process. For individual nlants, control of the oxychlorination process to attain the emission level of Alternative.il could range from no control to a process chanqe to incineration. Therefore, the water consumption for Alternative II could ranqe between that of Alternative I, which represents no control of the oxychlorination process, to that of Alternative III, which represents incineration of the emissions from the oxychlori nation process. Most existinq plants can attain Alternative II control level without controlling the oxychlorination process; however, one plant would possibly have to use incineration. Ai TERNAItVE III WATER PERCENT CONSUMPTION INCREASE IN MM 1/YR WATER (GAL/YR) CONSUMPTION 121 (32) 4.5T 224(69) 4.51 COLOR!TE 008613 TABLE 6-13. INCREASED WATER CONSUMPTION BY MODEL POLYVINYL CHLORIDE PLANTS USING VARIOUS CONTROL SY5THV, TO ATTAIN THE PROPOSED STANUARD/ALT ERNAT1VE II (DISPERSION PLANTS) M, 'FI PI ANTS SUSPENSION PLANT - AVG. (68 MM kg/yr or 1 SO MM lb/yr) BASE WATER CONSUMPTION HM 1/yr (HM qal/yr) 1046 (276)1 CASE A (IMPROVED STRIPPING OPTION) WATER CONSUMPTION MM 1/yr (MM aal/vr) PERCENT INCREASE IK WATER COHSUHPTION 140 (37) freactor water purge] 27 (7) [slurry stri ppifiql fi.R (2.8) fwater stripping] 2.3 (0.6V [carbon adsorption] T7?rxw^l nflwr 17* CASE B (INCINLRATOH-SCRUIlHr.il OPTION) WATER CONSUMPTION KM 1/yr (HM nal/vr) TERCLNT INUU ASr IN WATER CONSUmn 140 (37) [reactor water purge] 440 (116) [incinera tor-scrubber] 07 (23) [water stripping] SW"n76TT5TM 6 41 SUSPENSION PLANT - LARGE [15b MM kg/yr or 3SH MM lb/yr) 2440 (64 4)1 326 (R6) [reactor water purge] 63 (16) [slurry stri pp 1 nq ] 16 (4.2) [water Stri pping] 5.3 (1.4)3 [carbon adsorption] ?ToTTTlD7.6) [ TOTAL J !7i 326 (66) [reactor water purge] 1024 (270) [incinera tor-scrubber] 203 (54) [water stripping] rarrwmtt--------- 64* DISPERSION PLANT - AVG. (1 4 MH kg/vr or 3D Ml lb/yr} 209 (55)' DISPERSION PLANT - LARGE (45 MW kg/yr or 100 MM lb/yr) 697 (1[I4)1 20 (7.5) [reactor water purqe] 49 (13) [slurry stripping] 1A (0.36) [water stripping] 0.5 (0,1)3 [carbon adsorption] TKTTTO.4'}' {WAIT 93 (25) [reactor water purge] 163 (43) [slurry strlppi nq] 4.6 (1.7.) [water stripping] 1.5 (0.4)J [carbon adsorption] 2ET.TW.5) ITOTJUl 38 i 36* 20 (7.5) [reactor water purge 1 440 (116) [incinera tor-scrubber] 18 (4.7) [water stri pplnq] 486 (128.2} TCffiE 93 (25) [reactor water ourqe] 1465 (306) [incinera tor-scrubber] 60 (16) [water strfpnlnn) 161B [427] TOTAL 232* 212% BULK PLANT - AVG. (45 RM kg/yr or 100 MH lb/yr) 114 (30)' Negligible [slurry stripping] 5.6 (1.4) [water strlnotngj 1.5 [0,4)3 [carbon adsorption! rrri .aiTfwsrr' 121 (32) [incinera tor-scrubber] 5.6 (1.5) [water s trioninol r^T3T'drroTO~ ill1' BULK PLANT - LARGE [77 MM kg/yr or 170 MM lb/yr} 193 (50) 2 Neoliqibl'e [slurry stribotnq] fit 205 (54) [incinera tor-scrubber] 111c 9.6 (2.6) [water 9.5 (2.5) [water stripping] 2.6 (0.7)3 [carbon strinpinol TitttfciyTmr- adsorption^ COLOR!TE 008614 ^Based on 15.35 t./ko product (1.84 gal/lb), the average of water consumption rates reported to be used at seven polvvinvl chloride plants The range in rates of water consumption by these seven plants was fron* 4.0 to 45 1,7kg (0.4B to 5.5 gal/lb).ID-13>14- 2 Based on data fron one plant, 24 3 For the purpose of a rough approximation, data from one plant2 5 were used and a linear relationship between water consumed and production rate was assumed. water consumed by base model ethylene dichloride-vinyl chloride and polyvinyl chloride plants are also included in Tables 6-12 and 6-13 to give some perspective. The figures for the base plants represent the average values reported by two ethylene dichloridevinyl chloride plants, seven polyvinyl chloride suspension and dispersion plants1^'11,12,14,15,16,17^ one po|yV-jnyi chloride bulk plant.There was a wide range of values reported by the polyvinyl chloride suspension and dispersion plants, from 4.0 to 45 1/kg product (0.48 to 5.5 gal/lb). 6.2.2.2.2 Wastewater from the Control Process The two water pollutants generated or increased as the result of the application of controls identified in Chapter 4 are vinyl chloride and hydrogen chloride. Vinyl Chloride--Amount Generated Small increases in the quantities of vinyl chloride released ~Tntcrplafltrlnprocess wastewater would result from using the water purge system for polyvinyl chloride reactors, scrubbers for control of hydrogen chloride emissions from incineration, carbon adsorption (the desorption process), and improved slurry stripping. Table 6-14 presents the quantities of vinyl chloride which would be released into the .inprocess wastewater at model ethylene dichloride-vinyl chloride plants using incinerator-scrubbers and at model polyvinyl chloride suspension plants using the water purge system, incinerator-scrubbers and/or carbon adsorption to control vinyl chloride emissions. For purposes of comparison. Table 6-14 also shows the quantity of vinyl chloride reported to be released into the wastewater from base model plants in the cast with no ERA regulations in effect. The figures for the 6-43 COLORITE 008615 TABLE 6-14. QUANTITIES OF VINYL CHLORIDE RELEASED INTO THE PLANT iNPROCESS WASTEWATER BY SYSTEMS WHICH CAN BE USED TO MEET THE PROPOSED STANDARD/ALTERNATIVE II CONTROL LEVEL (DISPERSION PLANTS) Mode) Plants Vinyl Chloride Released Into Water from a Base Plant Vinyl Chloride Released into Water from Water Purge Systenr Vinyl Chloride Released into Water from Incinerator Scrubber System Vinvl Chloride Released into Water from Carbon Adsorption3 Vinvl Chloride Plant -Avg. (318 MM kg/yr) (700 MM lb/yr) 2,227 kg/yr 1 (4,900 lb/yr) NA 3 0.64 kg/yr (1.4 lb/yr) NA3 Vinyl Chloride Plant"Large {590 MM kg/yr) (1300 HM lb/yr) 4,131 kg/yr ' (9,100 Ib/vr) NA 3 1 .2 kg/yr (2.6 lb/yr) NA3 Pol y v i ny 1 Chlori de Suspension Plant -Avg. (68 Mil kg/yr) (150 Mil lb/yr) 6,810 kg/yr 2 (15,000 lb/yr) 42,000 kg/yr (92,000 lb/yr) 2.0 kg/yr (4.5 lb/yr) 13,000 Polyvinyl Chloride Suspension Plant -Large (159 Mil kg/yr) (350 MM Ib/vr) 15.890 kg/yr 2 (35,000 lb/yr) 98,000 kg/yr (215,000 lb/yr) 4*8 kg/yr {10.5 lb/yr) 31 ''Based on loss of vinyl chloride into Hie plant process water at one vinyl chloride plant - 0.0007 kq vinyl chloride/100 kg product (0.0007 lb/100 lb).33 This plant uses a waste water stripper. 'Based on average loss of vinyl chloride into the plant process water at three polyvinyl chloride plants - 0.01 kf vinyl chloride/100 kg product (0.01 lb/100 lb). The range of the three plants was from 0.00022 to 0.027 kg vinyl chloride/100 3 kg product. Not applicable. 4 Based or, data from one plant which indicate that the concentration of vinyl chloride in the water from the water 5 purge system is 300 ppm. 0 The values for carbon adsorption are based on the assumption that the steam from desorption is condensed in the I'lOnc.'se' recovery system, and that the condensed steam would be saturated with vinyl chloride at 70F and 60 psig, absolute. The values for carbon adsorption, and in fact for the water purge and incinerator scrubber are not directly comparable to the values for the base plant. The values for the base plant were likely to he measured after tnc inprocess wastewater was exposed to the atmosphere, and thus under atmospheric conditions of temperature and pressure. The figures presented assume that carbon adsorption is used for the monomer recovery system only. COLORITE 008616 base ethylene dichloride-vinyl chloride plants represent one plant response^ and the figures for the base polyvinyl chloride 14 15 16 plants represent the average of three plant responses. ' ' Technology Available to Prevent Pollution Studies indicate that any vinyl chloride released into the water, even though it may be measurable in the plant wastewater, is not measurable downstream. 22 studies were recently conducted by the EPA Environmental Research Laboratory in Athens, Georgia, to determine the pathways by which vinyl chloride is lost from aquatic systems. Bacterial degradation of vinyl chloride was found to be negligible, and vinyl chloride did not affect bacterial growth under test conditions. No sorption to bacteria, algae or fungi could be detected. Data are not yet available on sorption to inorganic particulate. Equilibrium approximations suggest that under poor transfer conditions sorption to inorganic particulate may be significant. Based on solubility dataj it is estimated that essentially all the vinyl chloride in the inprocess wastewater would be released to the atmosphere. In the presence of a large amount of pure air, the partial pressure of vinyl chloride would be extremely small causing the solubility of vinyl chloride in the water to be essentially zero. It appears from reported data (see Chapter 4, section 4.10) that the retention time of a wastewater treatment system is sufficient to allow all the vinyl chloride to be released prior to discharge. This may be due to evaporation. Vinyl chloride, with a density of 0.9834 at 20C, is expected to rise to the surface of the water. Vinyl chloride emissions into the water and subsequently into the 6-45 COLOR!TE 008617 air can be prevenred by a water stripper. The techno 1ouy o` water stripping is described in detail in Chapter 4, section 4.1C and involves application of heat or vacuum to remove vinyl chloride from the wastewater. The vinyl chloride which is removed can subsequently be transferred to a monomer recovery system or to a control device. Cost of Control Technology Information on the cost of water strippers can be found in Chapter 7. Hydrogen Chloride--Amount Generated Table 6-15 quantifies the water reject rate from a scrubber and the amount of hydrogen chloride which would be released into the wastewater for the model ethylene dichloride-vinyl chloride plants using incinerator-scrubbers to meet the various alternative control levels. The same information is provided in Table 6-16 for model polyvinyl chloride plants using incinerator-scrubbers (Case B the incineration option) to attain the Alternative II control level in the case of dispersion resin manufacture and the proposed standard in the case of manufacture of other resins. Incinerator-scrubbers would not be used to attain the Alternative I control level and could not (at least at the present time) be used to attain the Alternative III control level in the manufacture of dispersion resins. For ethylene dichloride-vinyl chloride plants, the hydrogen chloride which would be released into "he wastewater due to incineration of fhn rhlt-nn?1-:d uydroca.drons other than -iny 1 chloride in the foienn Stro-'S -.t included in - n.;,: cul ai 1 ons in Table 6-ij. COLOR!TE 008618 9 Alternative TABLE 6-15. ' INFORMATION ON WATER EFFLUENT FROM INCINERATOR-SCRUBBER SYSTEMS AT MODEL ETHYLENE DICHLORIDE-VINYL CHLORIDE PLANTS ATTAINING THE ALTERNATIVE CONTROL LEVELS Model Plant Size Water Reject Effluent Rate 1pm (gal/min) HC1 Collected1 kg/hr(lb/hr) Water Effluent pH HCf'X Out' Caustic Needed To Neutralize kq/hr (lb/hr) 1 T ii2 '""4 Average-Si zed PI an r (318 MM kg/yr or 700 MM Ib/yr) Large Plant (590 MM kg/yr or 1300 MM Ib/yr) 8 (2) 14 (3.7) 269 (596) 501 (1106) -1 60% -1 60% 296 (656) 551 (1217) III Average-Sized 258 (67) PI ant (318 MM kg/yr or 700 MM Ib/yr) 433 (956) 0.1 3% Large Plant (599 MM kg/yr or 1300 MM lb/yr) 479 (124) 805 (1777) 0.1 3% 476 (1052) 385 (1955) ^Assumes 98 percent efficiency 2Data for Alternative II are not presented because the hydrogen chloride emissions from incineration to attain the emission level of Alternative II would vary for individual plants, depending on the type of control system used for the oxychlorination process. For individual plants, control of the oxychlorination process to attain the emission level of Alternative II could range from no control to a process change to incineration. Therefore, the hydroqen chloride emissions for Alternative II could range between that of Alternative I, which represents no control of the oxychlorination process, to that of Alternative III, which represents incineration of the emissions from the oxychlorination process. Most existing plants can attain Alternative II control level without controlling the oxychlorination process; however, one plant would possibly have to use incineration. .ODLl PI '.MTS (SIZE) TABLE 6-16. INFORMATION ON WATER EFFLUENT FROM INCINERATOR-SCRUBBER SYSTEMS AT MODFl POLYVINYL CHLORIDE PLANTS CONTROLLING A MAXIMUM NUMBER OF EMISSION POINTS WITH INCINERATION .WATER REJECT EFFLUENT RATE LPM (GAL/MIN) HCL COLLECTED KG/HR (LB/HR) 1 WATER EFFLUENT PH HCL % OUT caustic nLlor: TO NFUTRALI/i KG/HR (i_ B/h i') NS1'..,,' iOii PLANT-AVG. <iA: Mi-, kG/YR OR i 50 MM LB/YR) 934 (242) 75 (167) 1.5 0.13% 82 (104) COLORITE 00862 M,Si .'SION PLANT-LARGE ' 1 fvj XG-'Yk OR N 0 ` i1! \ U,' \ .I) 2123 (563) Li.lTiYAi tCN "JfSTOTT- J' rERSi.jN T'!.AVT-AVG. ;./YR GR ' , . ,,-i L.-./YR/M MM or ' NS LB/YR) 1683 (436) CO. J 1 t'if-'i r I Ul'i SiJ..;Pi.\S EON 01 ..NILS) '. I PLANT-LARGE < j/YR OR 300 M.i LS/3 MM KG/YR ON GO l.C/Yk) SULK PL, ff-.V/G. MH ./YK OR IDO MM i__ ft) 3423 (887) 258 (67) r--cK plant-;, .:-:ge (77 ,'ii'i KG/YR or 170 MM IS/Yft) 436 (113) _____SOLUTION PlANT___________ (11 MM KG/YR OR 74 MM LB/YR 76 (20) .ur.es 98 percent collection efficiency 177 (390) 91 (200) 202 (444) 52 (115) 88 (195) 8.8 (19) 1.5 0.13% 1 .6 0,09% 195 (429; 100 (220) T.6 1.0 1.0 1.3 0.1% 0.3% 0.3% 0.9% 72? i 1, t L:7'':/ ! 9/ 1 i | 9.7 (01) ! However, not included in the table is the hydrogen chloride which ray already be released into the wastewater at ethylene dichloride-vinyl chloride plants using scrubbers to control hydrogen chloride emissions from process equipment and/or hydrogen chloride emissions from incinerators used to dispose of liquid chlorinated hydrocarbon wastes. The pH of the water effluent from the scrubber resulting from the hydrogen chloride emissions into the water is also included in Tables 6-15 and 6-16 for the various model plants. As can be seen from the table, the hydrogen chloride absorbed would cause the water leaving the scrubber to have a low pH (about 1.0). This acidic effluent could cause the total plant effluent to have a low pH since the scrubber effluent would be a sizeable portion of the total effluent stream. Technology Available to Prevent Pollution The water effluent guidelines for ethylene dichloride, vinyl chloride, and polyvinyl chloride plants specify that all new and existing plants must maintain the pH of water effluent between 6.0 and 9.07,8 (39 FR 12506 and 39 FR 14678). In order to meet these-guidelines, the hydrogen chloride from the scrubber stream could be recovered or neutralized prior to discharge to the plant effluent system. Generally, the concentration of the recovered acid would be too low to be sold or recycled. However, further processing would allow the production of strong acid or anhydrous hydrogen chloride. Extractive distillation would probably be necessary to accomplish this additional concentration. Ethylene dichloride-vinyl chloride plants appear to be the only ones with wastewater streams where hydrogen chloride recovery is feasible. If it were recovered at a balanced ethylene dichloride-vinyl chloride plant, it could be used as a raw material in 6-49 COLORITE 008621 the process. The byd< c-jen chloride concentrations of tiie effluents from scrubbers in the different types of polyvinyl chloride plants are too low (1 percent or less) to make hydrogen chloride recovery feasible. In these cases, the scrubber effluent can be neutralized by adding caustic (NaOH) to the water in the scrubber or after it leaves the scrubber. The amount of caustic needed depends on the hydrogen chloride concentration of the effluent. Tables 6-15 and 6-16 list the amount of caustic needed for neutralization for each model ethylene dichloride-vinyl chloride and polyvinyl chloride plant. Approximately 1.1 kilograms of caustic are needed to neutralize one kilogram of hydrogen chloride. Costs of Technology to Abate Acidic Effluent The costs of caustic used to neutralize the hydrogen chloride collected irr the scrubber water are included in the annual direct operating costs in Chapter 7 for the model ethylene dichloride-vinyl chloride plants and polyvinyl chloride plants attaining the various control levels. The data used to develop the cost figures in Chapter 7 indicate that the current cost of caustic is about $0.77/kg ($0.35/lb). The fraction of the annual direct operating cost attributable to caustic would vary from plant to plant depending on such factors as the production rate, volumetric flowrate, and the type of control applied to the oxychlorination reactor. However, as an example, caustic for model ethylene dichloride-vinyl chloride plants attaining the Alternative I control ie^el would be about $279,000/yr (or ' f percent of the annual direct "e''a t: "g cc s . The cost of caustic for morel ethylene 6 i oh i ^rideu-50 COLORITE 008622 bn about ^310,000/yr (or about 30 percent of the annual direct operating cost). The cost of caustic is a smaller fraction of the total annual direct operating cost for Alternative HI than for Alternative 1, because fuel would be a large part of the operating cost for Alternative III. 6.2.2.3 Solid Waste A typical polyvinyl chloride plant (68 million kg product/yr) would require 3,450 kg (7,600 lb) of carbon in a carbon adsorption unit to control the monomer recovery system. As explained in section 6.1, since carbon adsorption has had only limited use in the ethylene _ dichloride-vinyl chloride or polyvinyl chloride industries, the bed-life of the carbon is not known at this time. However, it is judged that the carbon may have to be replaced every 1 to 3 years, or that the typical plant using carbon adsorption on its monomer recovery system may have to discard as much as 3,450 kg of carbon/yr. In comparison, based on information obtained from a similar but larger plant, 18 the total solid waste generated by an average-sized plant is estimated to be 1.8 million kg/yr (2.6 million Ib/yr). Besides bulk there may be additional problems associated with disposal of the carbon due to residual vinyl chloride or other con taminants collected on the bed. Problems of this nature have not been qualified or quantified at this time. It is conceivable that the waste carbon could be burned in a boiler to recover some of*#the heat value of the material; however, potential air pollution problems such as emissions of hydrogen chloride from combustion of chlorinated hydrocarbons would exist. 6-51 f | t ) -' * i COLORITE 008623 6.2.?.4 hois? and Radiation As indicated in Table 6-1- tb:-"9 are no known noise or rwJ'c;t ;on impacts associated with the controls. 6.2.2.5 Energy Considerations In Tables 6-17 and 6-18, incremental energy requirements are estimated for the model ethylene dichloride-vinyl chloride plants and polyvinyl chloride dispersion plants attaining the alternative control levels identified in Chapter 5. In Tables 6-19 and 6-20, incremental energy requirements are estimated for the model polyvinyl chloride suspension and bulk plants attaining the control level of the proposed standard. The energy estimates in these tables are based on the energy requirements used to calculate the operating costs for various pieces of equipment in Chapter 7. For ethylene dichloride-vinyl chloride plants, the energy costs are shown for control by incineration only. For polyvinyl chloride plants, the energy costs are shown for both options available to the plants for meeting the proposed standard (or Alternative II in the case of dispersion resin manufacture). These options are improved stripping (Case A) and add-on control technology (Case B). Incineration is the only type of add-on control technology for which energy costs are presented because incineration is the control technique for which most data are available, it is the most likely type of add-on control technology to be used for ^any emission sources, and it is expected to be the most enen-p/ -jnsuming type of add-cn control technolcg to Table 6-?! compares the energy coo sump!ion rates at various model plants ' th and wi f ' control:. As ip'iur..".: m 're ronsumption at ethylene di r,l ori J,, - I r v ! k I r i .k uj b-6? ' ion ;.n meet the COLORITE 008624 f TAELi'6-17. INCREASED ENERGY CONSUMPTION - ETHYLENE DICHL0RIDE-V1NY,. CHl OR\[1L PLANT (318 MM kg VCM/yr)(7G0 MM lb VCM/yr) ATTAINING THE ALTERNATIVE CON'ROL EFWo- ~ ...... ............. EMISMuN POINT 1. Fugitive Emissions ' ALTERNATIVE I POWER CONSUMPTION {1000 kwh/yr) TUEL CONSUMPTION MM KCAL/YR (MM BTU/YR) 1322 none ' " " ALTERNATIVE II1 ."LTFPNATI'.T ROVER COfiSU'TT (1 000 KWH/Y1') 'V "" PO/L/ (UM ;;T(!/Y 1322 tV'S'-c 2. Point Source Emissions A. EDC Purification D. VCM Formation and Purification C. Oxychlorination Process 1 ,140 Negligible 1 ,140 74,600 (296,000) TOTAL 1 ,272 Negligible^ 1,272 74,690 (?)(> ,000) Data for Alternative II are not presented because the increased energy consumption for attaining the emission level of Alternative II would vary for individual plants, depending on the type of control used for the oxychlorination process. For individual plants, control of the oxychlorination process to attain the emission level of Alternative II could range from no control to a process change to incineration. Therefore, the increased energy consumption for Alternative II could range between that of Alternative I, which represents no control of the oxy chlorination process, to that of Alternative III, which represents incineration of the emissions from the oxychlorination process. Most existing plants can attain Alternative II control level without controlling the oxychlorination process; however, one plant would possibly have to use incineration. 2 This power is needed for the multipoint vinyl chloride detector. All other methods used to contain nr captor'1 fugitive emissions consume negligible quantities of energy. It is assumed that any captured fugitive emissions which are renuirod to be controlled, will be controlled by the incinerator used to control point source emissions. Thus, energy consumed for control of captured fugitive emissions is included in the energy consumption figures for the point source emissions. ^Effluent stream sustains combustion without auxiliary "fuel. COLORITE 008625 , TFRNATIVE I 1 table: a-?3, n'KE'otO eneww MjPN;nvE n CASE A *1 Emission PC' lit Method of control Fuel j Power consumption consumption MM keal/yr ! (1000 kWhr/yr) (MM Btu/yr) Method of control Power consumpti on (1000 kWhr/yr) Fuel consumption MM keal/yr (Hi Btu/yr) 1. Fugitive emissions^ A. Leaks from equipment 6. Inprocess wastewater Multi-point detector Water stripper 330 5 None 3000 (11,000) Multipoint detector Water 330 5 None 3000 (11,000) Z. Point source emissions A. Reactor opening fi. Relief valve discharge Water purge/ gasholder system C, Stripper Carbon 0. Monomer recovery system adsorption E. Sources following the stripper (slurry blend tanks, dryers, bulk storage, etc.} No additional control 62 3 None 400 (1400) Water purge/ gasholder system Carbon adsorption Improved stripping (2000 ppm) 62 3 610 None 400 (1400) 32,000 (126,000) TOTAL 400 3400 (12,400) 1010 35,400 (138,400) ^lt Is assumed that any captured fugitive emissions which are required to be controlled will be controlled by the incinerator or carbon adsorbe1- used to centre1 pcint source emissions. COLORITE 008626 Pj-f.lv Cj-lCv.:Ik PLANT (14 `;,1 kj/yr or 30 " ` lb/yr) ALTERNATIVE II (cont'd.) CASE 5 ALTERNATIVE m Method of control Power consjir.pt ton (1000 kWhr/yr) Fuel consumption KM kcal/yr (Ml! Bty/yr) Method of control Power consumption (1000 k'.'hr/yr) Fuel consumption MM kcal/yr (MM Btu/yr) Multi-point detector water stri pper Water purge/ gasholder system Incineration Incineration 330 34 62 4 j 24 ....... 4950 None 34,000 (136,000) Multipoint detector Water stripper 330 5 None 3,000 (11,000) None 334,000 (1,325,000) 1 i 368,000 1l (1,461,000) Mater purge/ gasholder system Carbon adsorption 62 3 None 400 (1400) (Data unavailable. This level of stripping Improved Stripping has not been demonstrated commercially in (400 ppm) any plant.) "-- (Data unavallable. This level of stripping has not been demonstrated conrrercially in any plant,)________ 6-55 COLOR!T 008627 Table 6-19. INCREASED ENERGY CONSUMPTION--SUSPENSION POLYVINYL CHLORIDE PLANT [68 MM kg/yr (150 MM lb/yr)] MEETING PROPOSED STANDARD _Case A ic:inn point .. 1 i-j. . 1 ''0 emissions A. Leeks from equip- "iCT'it l'. ^process waste- water Method of control Multipoint detector Water stripper Power consumption, 1000 kWh/yr 330 11 Fuel consumption, MM KCal/yr (MM Btu/rr) None 13,000 (53,000) . Method of control Case B 1 Power consumption, 1000 kWh/yr --1 Multipoint detector Water stripper 330 132 ------------ -------- Fuel consumption, MM KCal/yr (MM Btu/yr) Hone 171 ,000 (681 ,000) Pol,:1, source e:uiss ions A. Reactor opening w. Relief valve tli ocharge C. 5 c-ri pper D. Monomer recov ery cyst;.. E. Sources fcl- lowing stripper (slurry blend *nks, dryers, ... 1 k storage, f'tr ^ Water purge/ gasholder system Carbon adsorption Improved stripping 219 3 1 ,260 None 400 (1,400) 18,000 (70,000) Water purge/ gasholder system Incineration Incineration 219 4,560 None 321 ,000 (1,270,000) : 1 COLOR!TE 008628 Total 1 ,823 31 ,400 (124,400) 5,241 1 492,000 j (1,951,000) [ is assumed that any captured fugitive emissions that are required to be controlled will be controlled by uie incinerator or carbon adsorber used to control point source emissions. P Emission point Table 6-20. INCREASED ENERGY CONSUMPTION--BULK POLYVINYL CHLORIDE PLANT [45 MM kg/yr (100 MM lb/yr)] MEETING PROPOSED STANDARD Method of control Case A Fuel Power consumption, consumption, MM KCal/yr 1000 kWh/yr (MM Btu/yr) Method of control Case B Power consumption, 1000 kWh/yr ---- ---- .. - -- ~ Enel consumption, MM KCal/yr (MM Btu/yr) 1. Fugitive emissions^ A. Leaks from equipment Multipoint 330 None Multipoint detector detector B. Inprocess Wastewater Water 3 1,000 Hater stripper (4,000) stripper 2. Point source emissions A. Reactor opening Gasholder 23 None Gasholder B. Relief valve discharge system system 330 Rnne 3 1 ,000 (4,000) 23 None C. Monomer recovery system D. Sources following stripper (baggers bulk, loading bulk storage, etc.) Carbon adsorption Improved stripping 3 1 ,000 400 (1,400) 14,000 (57,000) Incineration Incineration 1 ,140 53,000 i | (210,000) ; ! Total 1 ,359 15,400 (62,400) 1 ,496 ! 54,000 .(214,000) ^It is assumed that any captured fugitive emissions that are required to be controlled will be controlled by the incinerator or carbon absorber used to control point source emissions. COLOR!TE 008629 TABLE 6-El. COMPARISON OF ENtRGY CONSUMPTION BY MODEL Pi ANTS WITH AND WITHOUT CONTROLS Model plant (average size) Ethylene dichloride vinyl chloride plant (318 MM kg/yr) (700 MM lb/yr) Total base energy ^ usage (fuel)! MM KCal/yr Type of control 1,014,3002 Using incineration to attain alternative I control level Total energy Increase in eneray usage of control-j consumption as result equipment (fuel), of applyinq controls, MM KCal/yr percent 1 ,450 0.1 Ethylene dichloride vinyl chloride plant (318 MM kg/yr) (700 MM lb/yr) 1,014,3002 Using incineration to attain alternative II control level Generally the sa me as al ternati ve I. Possibly the sam e as alternative II for one plant Ethylene dichloride vinyl chloride plant (318,MM kg/yr) (700 MM lb/yr) 1,014,300Z Using incineration to attain alternative III control level 76,050 7 Polyvinyl chloride suspension plant (68 MM kg/yr) (150 MM lb/yr) 223,3503 Using improved strip ping to attain the proposed standard 33 ,490 15 Polyvinyl chloride suspension plant (68 MM kg/yr) (150 MM lb/yr) 223,3503 Using incineration to attain the proposed standard 498,000 223 Polyvinyl chloride dispersion plant (14 MM kg/yr) (30 MM lb/yr) 44.6703 Using improved strip ping to attain alter native II control level 36,160 81 Polyvinyl chloride dispersion plant (14 MM kg/yr) (30 MM lb/yr) 44,6703 Using incineration to attain alternative II control level 373,680 836 Polyvinyl chloride bulk plant (45 MM kg/yr) (100 MM lb/yr 33.4064 Using improved strip ping to attain the proposed standard 16,960 50 Polyvinyl chloride bulk plant (45 MM kg/yr) (100 MM lb/yr) 33,406^ Using incineration to attain the prcrosed Standard 55,70 166 ^Tne power usage has been convened to fuel, acsunmq 7u percent boiler efficiency. 'Based on data submitted by c 1; 1 :1J 3Based on data submitt/e' e,, fQ(Jv y;r-*3: 1 Based on 10/S data ? : fed cn? pi f COLORXTE 008630 Alternative I control level would be r.eoliciible. To meet the Alternative III control level we.. 7H, however, result in an increased fuel consumption of 74,600 million k i localories/yr (296,000 million BTU/yr). This, combined with increased power usage (1,272,000 kwh/yr) would increase energy consumption at a model plant by about 7 percent. The higher fuel consumption for Alternative III is due to the relatively large quantity of supplemental fuel which would be required to support combustion of the relatively large volume, low concentration gas stream from the oxychlorination reactor at ethylene dichloride-vinyl chloride plants. These plants could possibly reduce this energy impact to some extent because they are typically located in large petrochemical complexes. The heat value of both the supplemental fuel and the hydrocarbons in the waste gas stream could possibly be used as steam in other parts of- the-petrochemical complex. As indicated in Table 6-18, the energy consumption at polyvinyl chloride dispersion plants attaining the Alternative II control level with improved stripping would be increased over the energy consumption of plants attaining the Alternative I control level by a factor of 10. This is due to the fact that Alternative II requires control of the sources following the stripper in the flow of process materials through the plant and Alternative I does not. The sources following the stripper constitute a substantial portion of the total plant emissions. For polyvinyl chloride dispersion plants, as for other types of polyvinyl chloride plants, controlling the sources following the stipperwith incineration (Case 3) -ather than improved stripping (Case A) would cause a much greater increase in energy consumption. Since improved 6-59 COLORITE 008631 .. . nt. i neration achieve the sane degree of control, the ..-c rather than fl-'A would be in the position of deciding which of -ete control techniques would be used. Due to the high costs of energy consumption which would result from controlling with incineration, plants would be expected to use improved stripping as the control technique instead of incineration. Since the degree of improved stripping required by Alternative III has not been used at any dispersion plants, data are not available on the quantity of energy that would be required to meet this control level. 6-60 AwBr COLOR!TE 008632 .'a U.S. Environmental Projection Agency, Orficc of Researo. a,.c Deve 1 oprent, Scientific and Technical A:-sassten_t Report on Vinyl Chloride and Polyvinyl Chloride, '.iasnington, D.C. , June 1975. 2. NAPCA, U. S. Department of Health, Education, and Welfare, Preliminary Air Pollution Survey of Hydrochloric Acid, A Literature Review, Raleigh, North Carolina, October 1969, pp. 3, 4, 12, 13. 3. Scrubber Handbook. Ambient Purification Technology, Inc., :uly 1972. 4. Sahals, S. L. and Schwartz, R. A., Construction Materials for Wet Scrubbers, Koch Engineering Company, Chemical Engineering Progress, August 1974. 5. Hulswitt, E. E., Adiabatic and Falling Film Absorption of Hydrogen Chloride, Astro iletalTurgicaTTorporation, Chemical Engineering Progress, February 1973. 6. Kemper, S. K., Seiler, E. N., Bowman, D. H., Air Pollution Control Association Journal, March 1970, pp. 139-143. 7. Environmental Protection Agency, "Plastics and Synthetics Point Source Category Effluent Guidelines and Standards," Federal Register, Volume 39, No. 67, April 5, 1974, Part II, pp, 12506, 7. 8. Environmental Protection Agency, "Organic Chemicals Manufacturing Point Source Category. Effluent Guidelines and Standards and Proposed Application to Pretreatment Standards," Federal Register, Volume 39, No. 81, April 25, 1974, Part II, pp. 146787"^ 9. Schwartz, W. A. et al., Engineering and Cost Study of Air Pollution Control for the Petrochemical Industry Volume 3 Ethylene Dichloride Manufacture by Oxychlorination, Prepared for the Envi ronmental "P'rotectTon"Agency" Houdry Di vi si on --Ai r Products and Chemicals, Inc., Pennsylvania, November 1974, p. ED-39. 10. Joe Mudd (General Tire Company). Telephone conversation with Susan Wyatt (EPA), January 30, 1975. 11. Doug McWhorter (B. F. Goodrich, Louisville, Kentucky). Telephone conversation with Susan Wyatt (EPA) on January 28, 1975. 12. Jay Harpring (Continental Oil Company, Abeerdeen, Mississippi). Telephone conversation with Continental Oil Company on January 30, 1975. 6-61 COLOR!TE 008633 13. Letter from R. E. Ingen, Shell Oil Company, to Leslie B. Evans, EPA, January 31, 1975. 14. Dave Francke (Air Products and Chemicals, Inc., Escambia, Florida). Telephone conversation with James Eddinger (EPA) on November 25, 1974. 15. Bob Luckan (Air Products and Chemicals, Inc., Calvert City, Kentucky). Telephone conversation with James Eddinger (EPA) on November 25, 1974. 16. Letter with attachments from R. N. Wheeler, Jr., Union Carbide Corporation to Don R. Goodwin, EPA, June 26, 1974. 17. Robert Bellamy (Houdry Division of Air Products and Chemicals). Telephone conversation with John Christiano (EPA) on February 6, 1975. 18. Solid Waste Questionnaire for 1973, Jefferson County Air Pollution Control District, Louisville, Kentucky. 19. Harlan Jewett (General Tire). Telephone conversation with Charles F. Kleeberg (EPA), February 20, 1975. 20. Letter with attachments from R. E. Van Ingen, Shell Chemical Company, to Don R. Goodwin, EPA, July 5, 1974. 21. Robert Troutner (Shell Chemical Company). Telephone conversation with Susan Wyatt (EPA). 22. "EPA Urges Prompt Steps by Chemical Industry to Reduce Vinyl Chloride Air Emissions", Environmental News, EPA, Washington, D.C., June 11, 1974. 23. "Guides for Short-Term Exposures of the Public to Air Pollutants, II. GliISS for Hydrogen Chloride," The Comittee on Toxicology of the National Academy of Sciences - National Research Council, Washington, D.C., August, 1971. 24. Robert Fine (Occidental Petroleum Company, Burlington, New Jersey), telephone communication with Susan Wyatt (EPA) on September 8, 1975. 25. W.P. Anderson (Tenneco, Cleveland, Ohio), telephone communication with Susan Wyatt (EPA) on SeDtemter 9, 1975. 26. Harlan Jewett (General Tire). Telephone conversation with Susan Wyatt (EPA), June 1975, 6-62 COLOR!TE 008634 7. ECONOMIC IMPACT ANALYSIS 7.1 INDUSTRY ECONOMIC PROFILE 7.1.1 Ethylene Dichloride Any analysis of the polyvinyl chloride industry must begin with a dis cussion of ethylene dichloride because about 80 percent of the ethylene dichlor ide produced in the United States gees directly to the production of vinyl chloride and, ultimately, polyvinyl chloride resins.^ As a result, the producers of ethylene dichloride are extremely dependent upon the polyvinyl chloride resin industry. Domestic demand for ethylene dichloride in 1974 2 amounted to 4.7 billion kilograms. 7.1.2 Vinyl Chloride Based upon July, 1975 capacities, an estimated 92 percent of the vinyl chloride produced in the United States was produced by the pyrolysis of ethylene dichloride. The other 8 percent was made by the addition of hydro- 3 gen chloride to acetylene. The 1974 estimated domestic production of vinyl chloride amounted to 2.6 billion kilograms.^ An estimated 97 percent of the vinyl chloride produced in the United States is used to produce polyvinyl chloride homopolymer and copolymer resins.'* As a result, the existence of the vinyl chloride industry hinges on polyvinyl chloride production. Recent estimates indicate that approximately 940 workers 7-1 COLORITE 008635 are directly engaged in the production of vinyl chloride in the United States.*' 7.1.3 Polyvinyl Chloride In 1974, estimated production of polyvinyl chloride resins in the United States amounted to 2.2 billion kilograms, and, at an estimated average unit sales value of 25.0 cents per pound (55 cents per kilogram), the production value was approximately 1.2 billion dollars.^ In 1975, polyvinyl chloride resins were produced by 23 companies, at 41 plants, by one or more of 4 processes--suspension, emulsion, bulk, and solution. 7.1.4 Vertical Integration and Industry Concentration Vertical integration is that situation wherein a producer owns not only the producing plant but also either a raw material supplier and/or a plant that uses the producer's product. There is a limited amount of vertical integration within the polyvinyl chloride industry from the production of ethylene dichloride through the pro duction of polyvinyl chloride resin. Five companies produce all three products (i.e. ethylene dichloride, vinyl chloride, and polyvinyl chloride), while six teen companies manufacture only one of the three products. Six firms produce two of the three products. Table 7-1 illustrates the amount of vertical inte gration for the entire industry. Since plants that produce vinyl chloride also generally produce ethylene dichloride, plants in the sector of the industry are often times referred to as ethylene dichloride-vinyl chloride plants. 7-2 COLORITE 008636 There is a great deal of concentration in the production of ethylene di chloride-vinyl chloride and polyvinyl chloride. A few firms in each industry account for much of the total capacity. V'ith regard to vinyl chloride produc tion, out of a total of 10 firms, 2 account for 41 percent of the industry's capacity. The five largest firms account for 78 percent of total industry capa city. In the polyvinyl chloride industry, out of a total of 22 firms, 5 account for approximately 47 percent of total industry capacity. The 9 largest firms account for an estimated 67 percent of total industry capacity. (Figures derived from Tables 3-2 and 3-3). 7.1.5 Polymerization of Polyvinyl Chloride Resins hy Process As mentioned earlier, polymerization of polyvinyl chloride is achieved by four processes. Suspension polymerization accounts for 78 percent of domestic polyvinyl chloride capacity and is practiced by nearly all producers. Emulsion polymerization accounts for 13 percent of total capactiy and is practiced by 11 companies. Six percent of all polyvinyl chloride resins are produced by 4 companies using the bulk polymerization process; and 1 company accounts for O 3 percent of the total polyvinyl chloride capacity using the solution process. 7.1.6 Polyvinyl Chloride Consumption by End Use Polyvinyl chloride resins are an intermediate product which have a wide variety of end uses. Polyvinyl chloride resin consumption by general cate gories of end use for 1974 is summarized in Table 7-2. Consumption of polyvinyl chloride increased 10.5 percent annually from 1969 to 1974. The most significant growth categories were building and con struction (19.9 percent annually), miscellaneous-mainly credit cards (18.9 percent annually), and packaging (8.4 percent annually,)^ 7-3 COLOR!TE 008637 shJ.-j be nw.ed J(ai: tui_l domestic demand for polyvinyl chloride resins decreased by 2.4 percent in the period 1973-1974. The major areas in which de creases occurred were electrical uses (14.4 percent), building and construction (6.4 percent), and apparel (4.6 percent).10 Some of the more common uses within each category are: Building and Construction - pipe, pipe fittings, and conduit; flooring; siding; windows and other rigid profiles, swimming pool liners; lighting; weatherstripping; rainwater systems. Household furnishings - furniture upholstery; wall coverings; shower cur tains; garden hose; appliances. Consumer Goods (recreation and apparel) - phonograph records; footwear; toys; outerwear; sporting goods; baby pants. Electrical Uses - coated wire and cable. Packaging - hardware and pharmaceutical packaging; food packaging; bottles; coatings. Transportation - upholstery and seat covers; vinyl tops; auto floormats. Miscellaneous - laminates; medical tubing; credit cards; novelties.11 7.1.7 Polyvinyl Chloride Substitutes Discussions with industry representatives have led to the conclusion that substitutes exist for a number of present polyvinyl chloride applications. Although these substitutes do exist, there would be a certain delay in obtaining adequate quantities of the substitute materials, and prices of the substitutes would generally be higher than polyvinyl chloride. Table 7-3 contains a list of the major polyvinyl chloride uses and possible substitute materials. 7-4 COLORITE 008638 7.1.3 Inc .5try Employment Total direct employment in the vinyl chloride industry and the polyvi-''1 chloride industry is estimated to be: Vinyl Chloride 940 Polyvinyl Chloride 5,600 Additionally, it is believed that as many as 2,000,000 jobs are indirectly related to the production of polyvinyl chloride. 12 7.1.9 Increases in Industry Capacity Three new polyvinyl chloride plants were started between the fourth quarter of 1974 and the second quarter of 1975. These plants (Georgia-Pacific at Plaquemines Louisiana, Shintech at Freeport,-Texas,. and Tenneco at Pasadena, Texas) accounted for additional industry capacity of 310,000,000 kilograms per year. During the same period of time, however, two polyvinyl chloride plants ceased production (Olin at Assonet, Massachusetts - 70,000,000 kilograms per year and National Starch at Meredosia, Illinois - 4,500,000 kilograms per year) so that the net increase in industry capacity was approximately 235,500,000 kilograms per year. This represented a net-increase in industry capacity of approximately 10 percent. In addition to the expansions noted above, several companies have indi cated that additional increases to industry capacity will be forthcoming. These expansions, detailed in Table 7-4, would result in additional capacity of approximately 520,000,000 kilograms, or 20 percent of current industry capacity. The timing of these expansions is not known with any degree of cer tainty and it is possible that some projects could be indefinitely delayed if the industry believes that future prospects in the polyvinyl chloride resins market are not promising. 7-5 COLORITE 008639 Announced capacity expansion plans in the ethylene dichloride-vinyl chloride sector of the industry are currently limited to the construction of a new plant by Borden, Inc., at Geismar, Louisiana. This plant is expected to have a capacity of approximately 135,000,000 kilograms per year of vinyl chloride and be on-stream in 1976. Other ethylene dichloride-vinyl chloride plants may be constructed if future projected polyvinyl chloride production volumes are to be attained. One projection indicates that a total of approximate ly 300,000,000 kilograms of vinyl chloride capacity will have to be added in order to satisfy demand in 1980.^ This means that one more ethylene dichloride-vinyl chloride plant, in addition to the Borden plant mentioned above, may be constructed in the near future. 7.1.10 Product Price Histories Both vinyl chloride and polyvinyl chloride rosin prices had a general and significant downward trend throughout the 1950's and 1960`s as a result of improving technology and capacity increases. The price of vinyl chloride has moved from a high of 13.5</lb in 1954 to a low of 4.75d in the late 1960's and early 1970's. 15 Since the early 1970's vinyl chloride prices have risen rapidly in response to increased production costs based primarily on raw material price increases. June, 1975 list prices ranged from 9-12d/lb. General purpose suspension process polyvinyl chloride resin listed at 38t/ lb in 1954 and decreased to a low of lOtf/lb in 1968-^ Since 1968 the trend has been consistently upward with substantial increases in 1974. June, 1975 list prices ranged from 24-28^/1b. Both homopolymer and copolymer dispersion grade resins have historically -.an priced hie! than suspension grade resins. Dispersion grade prices were stable in the ;-.."iod fr'c.-a 195G through 1371, though as with suspension resins 7-6 COLORITE 008640 prices fell from 1950-1950. Recently, dispersion grade prices have risen with ethylene cicnlcride, vinyl chloride, and suspension g-ade resin prices. Jure, 1975 list prices ranged from 34-37d/lb. Recent price changes for ethylene dichloride, vinyl chloride, and poly vinyl chloride are shown in Table 7-5. Actual selling prices are sometimes lower than the list prices as stated above, but the amount of the discount varies due to various factors (supply- demand relationships, existence of long-term contract commitments, etc.). It is not known to what extent discounting is currently being employed in the industry, if at all. 7-7 COLORITE 008641 7.2. COST ANALYSIS OF ALTERNATIVE EMISSION CONTROL SYSTEMS 7.2.1 Introduction For each of the various emission control systems identified in Chapter 4 for ethylene dichloride-vinyl chloride and polyvinyl chloride plants, installed capital and total annualized costs are estimated. This section primarily deals with the costs for controlling model ethylene dichloride-vinyl chloride and polyvinyl chloride plants to achieve various emission levels. Each of these model plants is of such process configuration and size as to be fairly representative of a typical existing plant in the industry. Although the individual plant control costs will vary to a greater or lesser degree from these model plant costs, this section also presents, in Table 7-6, formulas that can be used to scale the model plant costs up or down in order to approximate control costs at an existing installations. Naturally, control costs at existing installations are quite difficult to estimate without detailed, plant-by-plant engineering studies. Whereas Table 7-6 is believed to be representative of control costs in the aggregate, the table is not intended to provide anything other than general estimates of plant-by-plant control costs. The model plant costs are based on data obtained from the individual companies through requests for information under the authority of Section 114 of the Clean Air Act. Cost da"a has also been available frcm the Industrial Gas Cleaning Institute (IGCI), who, under an ERA contract, has provided infor mation bas-d on o'is from acts ! verdo''" of control equipment. Both sets of cost data iia^e b~en used cy CPA in developing the model plant air pollution control costs. 7-8 COLORITE 008642 Two major kinds of costs have been developed herein: installed capital certs erd total annualised costs. The installed capital cost for each con trol alternative includes the purchased cost of the major equipment and auxiliary equipment and the cost for site preparation and installation of the equipment, and design engineering cost. No attempt has been made to include costs for research and development, possible lost production during equipment installation, or losses during startup. The total annualized cost is comprised of three categories: the direct operating cost, the annualized capital charge, and the monomer recovery credit. The first accounts for operating and maintenance costs, such as: ' Labor and materials needed to operate the control equipment; ' Maintenance labor and materials; ' Utilities, which include fuel, electric power, water, steam, and inert gas. The annualized capital charge accounts for depreciation, interest, administrative overhead, property taxes, and insurance. The depreciation and interest portion is computed by use of a capital recovery factor, the value of which depends on the device operating life (5 to 20 years. In this report) and the interest rate. (An annual interest rate of 10 percent has been assumed.) Administrative overhead, taxes, and insurance have been fixed at an additional 2.5 percent of the installed capital cost per year. The monomer recovery credit accounts for the value of the vinyl chloride recovered by the control equipment. Herein, a credit of $.10 per pound of vinyl chloride has been assumed. The total annualized cost is then obtained simply by adding the direct operating cost, the annualized capital charge, and the monomer recovery credit. COLOR!TE 008643 Four main emission points have been identified for the balanced ethylene dichloride-vinyl chloride plant, and seven each for the suspension and dispersion polyvinyl chloride plants (see Tables 7-7 through 7-9). The bulk polyvinyl chloride modal plant has four points of emission. (See Table 7-10). (Since only one solution process polyvinyl chloride plant is currently in operation, a special model plant has not been developed for the solution process. Control costs for the plant have been developed, however, and are included in the analysis in Section 7,3.) Each of the emission points may, in turn, be controlled by one or more control measures, so that a number of control configurations are possible. The data costs identified in this section, however, are those which would be incurred by the model plant using a selected combination of control measures to attain the alternative control levels identified in Chapter 5 for ethylene dichloride-vinyl chloride plants and polyvinyl chloride dispersion plants. For polyvinyl chloride plants not making dispersion resins, there are no alternative control levels, and costs are shown for model plants using a selected combination of control measures to attain the level of the proposed standard. For polyvinyl chloride plants, two types of control can be used to attain the emission level of Alternative II in the manufacture of dispersion resins and the emission level of the proposed standard in the manufacture of the other resins. Costs are presented for both types of control. 7.2.2.1 Ethylene Dichlorlde-Vinyl Chloride Model Plant Table 7-7 illustrates the balanced ethylene dichlorida-vinyl chloride model plant control costs at the two alternative levels of control. Alternative I evolves f w ' i o'' r , .on redjction and incineration r t the ethylene dichlcride 7-1 0 COLORITE 008644 pjri fi'cauicr: and the vir(i/i chloride iormaticn and purification processes. Control of the oxychlorination process is not induced in this alternative. Alternative III includes incineration of the oxychlorination process in addition to fugitive controls and incineration of the aforementioned ethylene dichloride and vinyl chloride processes. Included among the fugitive emission reduction measures are monitoring to detect points of high emissions, installa tion of dual mechanical pump and compressor seals and rupture disks, and various control systems for process sampling and transfer operations. (These costs are presented on an item-by-item basis in Table 7-11). Costs for stripping vinyl chloride from inprocess wastewater are not included because the existing plants generally already use water strippers. As illustrated by Alternative I in Table 7-7, control of fugitive emissions and incineration of ethylene dichloride and vinyl chloride monomer processes will require a total capital expenditure of $889,000 at the 318 million kg/yr (700 million lb/yr) model plant. Annualized costs amount to $793,000/yr, or 0.24d/ kg (0.11 (/lb) of vinyl chloride produced at capacity. In order to control the oxychlorination process emissions it is necessary to spend an additional $1,014,000 in installed capital and $864,000/yr (0.29/kg=0.13<i/lb) in annualized costs. Total control costs for Alternative III then becomes $1,903,000 in installed capital and $1,657,000/yr (0.53d/lb=0.24d/lb) in annualized costs. Overall control of emissions is approximately 90 percent for Alternative I and 97 percent for Alternative III. Note that Alternative II is not considered for the model plant in Table 7-7. This is so because the increased costs for attaining the emission level of Alternative II would vary for individual plants, depending cn the type of cont-ol system used for the oxychlorination process. For individual plants, control a' tin's process to attain the Alternative II level could range from no ccntro1 to a process change to incineration. Correspondingly, the control 7-n COLOR!TE 008645 Uj^zs for Alternative II could range between t'nat of Alternative I, which represent?, no control of the process, to that of Alternative HI, which involves thermal incineration. In any case, no definitive cost data has yet been developed for any oxychlorination control except incineration. 1.2.1.2 Suspension Polyvinyl Chloride Model Plant As mentioned earlier, two control configurations (each of which corresponds to the same alternative, an overall control efficiency of 95 percent) have been applied to the model suspension and bulk polyvinyl chloride plants. One control option (Case A) is the improved stripping option. This case assumes that the polyvinyl chloride resin can be stripped to a level of 400 parts per million. To illustrate the substantial difference between the cost impacts, a second case (B) has been developed for the suspension and bulk model plants. This case is the incineration option and is intended to show the approximate cost level that would be realized if incineration viere used for vinyl chloride control at certain emission points. The suspension process model plant costs are shown in Table 7-8. The control costs for Case A include various fugitive emission reduction techniques. These methods include those to control the ethylene dichloridevinyl chloride model plant plus water stripping to remove vinyl chloride from the process water streams in the plant. This system consists of a large vessel (plus auxiliaries) in which the monomer is flashed from the water under vacuum by contacting with open steam, followed by separation of the resultant water vapor from the monomer by condensation of the water. Following condensation, the monomer is sort to the plant monomer recovery system. In addition to th-se fugitive controls, Case A involves the installation of a 7-12 COLORITE 008646 gasholder-purge water system to control the reactor opening and relief valve discharge emission points. The gasholder is merely a vapor conservation or surge tank, whose function is to collect vinyl chloride monomer vapors in air from these points and release them steadily to the monomer recovery system, thereby permitting the system to operate at a steady flow condition rather .dun intermittently. The reactor water purge system, which operates in conjunction with this gasholder, is a system designed to purge the vinyl chloride monomer vapor left in the reactors after completion of the reaction cycle to the gasholder by the introduction of water. Case A also includes the installation of improved reactor pressure and temperature recorder-controllers, along with an automatic reaction quenching (short-..topping) system, both of which would minimize monomer losses from relief valve discharges. The new recorder-controllers would afford better control of the polymerization reaction itself, while the automatic short-stopping system permits the plant to quench reactions in the event of an emergency. Also included in Case A is an improved stripping operation. The improved " stripping removes some of the monomer from the reactor products, so that this vinyl chloride monomer is not emitted further downstream, from the slurry blend tank, centrifuge dryer, storage silos, inprocess wastewater, etc., as is presently the case with uncontrolled plants. The cost of installing ------- such a system is a function primarily of the size and construction parameters. of the stripper vessel(s) (usually stainless steel tanks), which, in turn, depend on the weight of material processed or (alternatively) the polyvinyl chloride production rate. Accordingly, the costs for the model plant have been scaled directly with production (see Table 7-6). 7-13 COLORXTE 008647 Control of the low-volume (approximately 15 ACFM) stream from the monomer recovery system with carbon adsorption is also included in Case A. Despite the low volumetric flowrate, installed capital cost is substantial ($333,000) because even the smallest adsorption unit requires nearly the same amount of design effort, fabrication labor, and instrumentation as do the larger devices. Total installed capital costs for the 68 million kg/yr (150 million Ib/yr) model suspension process polyvinyl chloride plant are 54,462,000 for Case A. Annualized costs for the model plant are $1 ,222,000/yr (1,8<t/kq=0.81<t/lb of PVC at capacity). The second control configuration, Case B, includes the same fugitive con trols, improved instrumentation, automatic quench system, and gasholder-water purge system of Case A plus new slurry blend tanks and an incinerator-caustic scrubber for abating emissions from the slurry blend tank, centrifuge, monomer recovery system, dryer, and bulk storage and transfer points. The relatively high volume of these combined streams (about 81,000 ACFM) means a heavy capital investment for the incineration system, where the higN control efficiency speci fied (99 percent) requires a substantial direct operating cost, due to the high amount of fuel necessary to attain this level. Because the slurry blend tanks currently installed in polyvinyl chloride plants cannot withstand more than a few ounces of pressure before failing, it appears that new higher pressure blend tanks would need to be installed, so that the vent stream from this point could be tied to the incinerator. The new tanks (costing an estimated $140,000 each) would have a 25,000 gallon capacity (each) and would be fabricated from robber-lined carbon steel. Note that the Case A and Cass 8 costs for fugitive controls differ *ubstantially. This discrepancy exists because, with Case 3, all of the process 7-1 4 COLOR!TE 008648 rater in tp;:r;t (about 2,150 1 iter/min=570 gal/min) trust be stripped, as compared with only the more concentrated streams (totaling 160 liter/min) v;i th Case A. This is because the more dilute streams are from the centrifuge, which is one of the sources following the stripper. In Case A, improved stripping would be used to attain the emission limit for the sources following the stripper In Case B, add-on controls would be used for these sources. Thus, vinyl chloride emissions from the wastewater from the centrifuge would have to be controlled bywater stripping in Case B. The increased water loading effects a higher capital cost and a much higher annualized cost tor Case B water stripping. For Case B, the total installed capital cost for the suspension process model plant is $6,714,000, an increase of 50 percent over Case A. Annualized costs for Case B are $5,497,000/yr (8.l/kg=3.7<i:/ib), an increase of over 300. percent over Case A. 7.2.2.3 Dispersion Polyvinyl Chloride Model Plant Two alternatives are presented here. The first of these includes all the Case A controls specified for the suspension plant, except improved stripping to 400 PPM. Instead, it is assumed that the slurry is stripped to about 30,000 PPM which is the stripping level'-corresponding to the baseline, uncon trolled plant. Thus, there are no controls on the slurry blend tank, spray drier, and bulk storage and transfer points. The costs ($2,295,000 capital; $803,000/yr annualized) are the lowest, but so is the overall control efficiency (52 percent). The fugitive control costs for Alternative I are somewhat higher than those for Alternative II, Case A. The reason is that improved resin stripping in Alternative II, Case A would reduce the amount of vinyl chloride in both the resin and the water in which it is contained, so that additional control would not be required for the water from the centrifuge to attain the emission limit. In Case B, in the absence of improved resin stripping, the water from the csnliifnye as well as the rest of the plant water would rave to be controlled by water stripping to attain the emission limit, 7-15 COLOR!TE 008649 Oases Ac. S fot Alternative II correspond, respectively, to improved slurry dripping to 2000 PPM and incineration. The kinds of control equipment specified for Alternative II, Cases A and B, for the model plant are identical to those already presented for the suspension plant Cases A and B, respectively. How ever, due to differences in process equipment and production capacity (14 million kg/yr for dispersion versus 68 million kg/yr for suspension), the costs and emission reductions are different. Table 7-9 clearly illustrates this. Table 7-9 also points out the penalties incurred by dispersion process plants if improved stripping cannot remove the monomer to an acceptable level and incineration must be used instead. Annualized costs for Alternative II, Case B, for example, are 35.9</kg (16.3(f/lb) whereas Alternative II, Case A, has an annualized cost of 9.9<t/kg (4.5/lb). Installed capital costs increase from $3,319,000 for Case A to $5,287,000 for Case B, an increase of nearly 60 percent. Another Alternative (III) is identified in Chapter 5 for dispersion plants. This would involve the same control configuration as Alternative II, Case A, except that the slurry would be stripped to 400 PPM, rather than 2000 PPM. However, costs for attaining this stripping level are currently unavailable because this degree of stripping has not been demonstrated coirmercially in dispersion resin manufacture. Therefore, Alternative III does not appear in Table 7-9. 7.2.2.4 Bulk Polyvinyl Chloride Model Plant Case A here also involves the same controls as Case A for the suspension plant, except that because this kind of plant uses no water in its process, no gasholder- viter purge system is installed. Case B, the more stringent covt-wise, post'm-ites the Case A fugitive controls and reactor controls plus 7-16 COLOR!TE 008650 an incireracor-caustic scrubber for the monomer recovery system end product transfer end storage points. The total installed capital cost for the model bulk plant is 51,312,000 for Case A. and $1,606,000 for Case B, an increase of 22 percent. Total annualized costs increase 70 percent from 2.0<t/kg (0.90d/lb) for Case A to 3.4<t/kg (1.5/1b) for Case B. 7.2.3 Cost-Effectiveness of Vinyl Chloride Controls Table 7-15 presents the cost-effectiveness of alternative vinyl chloride control options. This table is based upon emission factors presented in Chapter 3 of this document plus control costs for control of the model ethylene - dichloride plant and the-model suspension process rolyvinyl chloride plant. The cost-effectiveness of various control options would differ at individual plants due to variances in emissions and individual control costs but the cost-effectiveness ratios presented in Table 7-15 are believed to be generally applicable to existing plants. The cost-effectiveness relationships in Table 7-15 are based upon esti mates of the total annualized costs (including recovery credits) for various control techniques. For^-example, control of fugitive emissions at the model ethylene dichloride-vinyl chloride plant would result in controlling 765,000 Ib/yr of vinyl chloride emissions at a total annualized cost of $366,000/yr. This yields a cost-effectiveness ratio for this control option of 0.43, a ratio that ranks sixth out of ten in terms of overall cost-effectiveness. The most cost-effective option that has been evaluated, control of the monomer recovery system emissions, is twenty-four times more cost-effective than the option of controlling fugitive missions at ethylene dichloridevinyl chloride plants. 7-17 COLOR!TE 008651 7.3 ECONOMIC IMPACT ANALYSIS OF ALTERNATIVE CONTROL .SYSTEMS 7.3.1 Introduction The purpose of this section is to present an evaluation of the anticipated economic impact of alternative systems for control of vinyl chloride emissions at ethylene dichloride-vinyl chloride plants and polyvinyl chloride plants. The impact analysis addresses both new and existing ethylene dichloride-vinyl chloride plants and polyvinyl chloride plants. Two different control scenarios were evaluated for new ethylene dichloridevinyl chloride plants. These scenarios correspond to Alternative I and Alternative III for ethylene dichloride-vinyl chloride plants, previously discussed in section 7.2. Three control scenarios, corresponding to Alternatives I, II, and III for ethylene dichloride-vinyl chloride plants were evaluated for existing plants. Similarly, different control scenarios were developed for new and existing polyvinyl chloride plants. These scenarios correspond to the polyvinyl chloride plant control options previously presented in section 7.2. The basic thrust of the analysis was to determine the impact upon plant profitability of various control systems. This examination led to other considerations such as industry-wide price increases resulting from control expenditures and the availability of capital for investment in control equip ment. Estimation of potential plant closures also resulted from this analysis. In addition to the costs that would be required solely for control of emissions to the air, consideration has also been given to the cost of compliance with the EPA water effluent guideline regulations and OSHA regulations. The approximate costs of complying with the water effluent regulations have been cal culated based on information received from the E ffi^mt O'-delines Division of EPA. These costs have U',, been analyzed in detail and ;-."1 erase.;tod only to give a general estimate or rat the total FPA-ger,oi ated costs eve for the ethylma 7-18 COLOR!TE 008652 u i c' 1 ori de-v i ny 1 chloriue a :c polyvinyl chi critic industries. '.Mth regard to OS'-m. costs, it rss been assured that sc significanc incremental costs over and above the EFA air emission control costs would be necessitated by the current GSHA regulations. It has been assumed that the cost of OSHA regulations could be generally approx''mated by the cost of the fugitive control package that has bet:, included in the air emission control cost totals for both ethylene dichloridevinyl chloride plants and polyvinyl chloride plants. Costs for control of vinyl chloride emissions to the air that are presented in this section, then, include the costs that are believed to be required by the OSHA standards. 7.3.2 Discussion The analysis of the impact of alternative cor.t o! levels at both new and existing ethylene dicnloride-vinyl chloride plants and polyvinyl chloride plants relies heavily on three main factors. The first of the three factors is the estimation of the level of profitability at a given plant before any controls are applied. This estimation is important since the use of a pre control profitability level that is too high would tend to underestimate the., number of potential closures after controls are applied and use of a pre-control profitability level that is too low would tend to" overestimate the number of closure candidates after control. The determination of pre-control profitability is relatively straightforward for new plants but is extremely difficult to achieve with any degree of accuracy for existing plants. Plant-by-plant variations in a number of factors make exact determinations of profitability at existing plants almost impossible. Estimates of existing plant profitabilities before controls have been made, however, but they are intended to be viewed as general indicators rather than specific determinations. All estimates of return on investment for existing plants presented in this report have been developed by EPA based cn general plant parameters that are in the public domain. Individual plants 7-19 COLORITE 008653 could conceiveably have different profitability levels than the ones presented in this analysis depending upon their unique set of operating conditions and parameters. In general, it is believed that the profitability estimation methodology is sufficiently accurate to use as a basis to reach general conclu sions regarding the impact of various control levels but that caution must be used when discussing specific plant profitabilities. The second factor that weighs heavily in the impact analysis is the estimation of control costs for specific plants. Again, this is relatively straightforward for new, model plants but is difficult for existing plants. Generalized cost algorithms have been used to determine control costs at existing plants and these algorithms may or may not be applicable to any one .. specific plant. It is believed that the algorithms can be generally applied to existing plants, but any estimation of specific plant costs is difficult. The third factor that is of considerable importance in the impact analysis is the determination of what actually constitutes adverse economic impact. This particular determination is the key to the economic impact analysis. This analysis has used two primary parameters'of economic impact, the first being the 10 percent price increase parameter and the second being the negative return on investment parameter. Based upon conversations with industry repre sentatives it has been assumed that price increases for polyvinyl chloride resins <jf up to 10 percent could be accommodated by the Industry without significant ill effects. Price increases of more than 10 percent, however, were considered to be condusive to appreciable substitution of other products for polyvinyl chloride resins and products. No attempt has been made to test the assumption that a 10 percent price increase would have minimal impact. It is ex^'cmely doubtful that such a da term1'nation could ever be made on a before-the-fact basis with any degree of accuracy. It would appear that 7-20 COLORXTE 008654 f'e use of a 10 percent price norease is a reasonable one, but the exact point at which sub 3tituitions c1' ''per ased imports becomes a sinriMeant problem is a ratter of conjecture. The second inpact parameter that has been used extensively in this analysis is the negative (or zero) return on investment parameter. This _.:<,isicn rule hypothesized that plant closures would probably occur at the cost level at which individual plant profitability became zero or negative. Whereas this is believed to be a good general parameter to estimate the point at which plant closures would occur it is important to realize that some plants would close at some level of profitability that was greater than zero but still less than that rate which was needed oy management in order to justify continued operation of the facility. On the other hand, a plant might be operated at some negative rate of return if the alternative to operating the plant in such a manner was even less attractive from either an economic or a non-economic viewpoint. Therefore, it cannot be predicted with any degree of certainty at which point a given plant will close. The use of negative return on investment, however, is probably the best such indi cator if one indicator has to be selected. Whereas the return on investment concept considers capital requirements in an indirect manner, it does not directly address the issue of whether or not incremental control capital can be obtained by a given plant. In general, it can be said that if the post-control return on in vestment is equal to the pre-control return on investment and the firm is a relatively large one with secure lines of credit and favorable cash flows, then the control capital will probably be raised given that there are not cMer projec : that yield even high- returns. For any given plant, however, it is not possible to determine that amount of capital that could be raised at any given time. As an example, it will be shown in the analysis of control 7-21 COLOR!TE 008655 scenario ?2 fo>' existing polyvinyl chloride plants that the total incremental capital requirements are approximately 20 percent of the current replacement value of the plants in the industry and that individual plants are estimated to vary between 10 percent and 38 percent. In this scenario four plants were listed as potential closure candidates based upon a return on investment analysis. If these plants did close, then even though the industry average incremental capital requirement would still be approximately 20 percent the range at existing plants that remained open would be 10 percent to 26 percent. There are no valid and acceptable general decision rules that would allow a decision to be reached regarding the affordability of either percentage. Some firms that had better alternative investments or limited access to funds might find 10 percent unaffordable while some other plant might find that even 26 percent was easily obtainable. It is possible that firms that were not identified as closure candidates based upon a return on investment" analysis might possibly close due to lack of capital, but there are not valid means of estimating the number of additional closures, if any, without individual plant data. 7.3.3 Ethylene Dichlorlde-Vinyl Chloride Plants - Existing Plant Economic Impact Analysis '~ 7.3.3.1 Existing Ethylene Dichloride Plants One factor that complicates the analysis of the impact of various control levels at existing ethylene dichloride-vinyl chloride plants is that there are four plants in the Industry that produce ethylene dichloride but do not produce vinyl chloride. Two of these plants would probably be required to incur air emission control costs. The other two plants would not be affected by the proposed regulation since they do iq utilize -,.`:y oxychlorination process. In order to evaluate the impact of various control levels on ethylene 7-22 COLOR!TE 008656 dichlorice-vinyl chloride plants it was necessary to separate these facilities and first calculate the 'impact of the various control levels on ethylene dicrloride plants cnly. These calculations resulted in an estimated price increase for ethylene dichloride that would then be passed on to vinyl chloride plants. The impact of various control levels at vinyl chloride .'.ants could be coupled with the ethylene dichloride expected price increase to show the cumulative effect of the various control levels at existing vinyl chloride plants. Costs for control of both air and water emissions are included. Table 7-16 details the development of the water pollution control costs used in the analysis. Table 7-17 shows the estimated capital costs resulting from imposing Alternative I or Alternative II control levels at existing ethylene dichloride plants. These costs include the estimated costs of complying with the water effluent guideline regulations as well as controlling air emissions. Capital costs for control of air emissions include only estimated costs for control of the ethylene dichloride purification process emission point, since this is the only emission point affected by the proposed regulation. Accordingly, no fugitive controls are included. Capital costs are estimated based on the cost algorithms developed earlier in this chapter. No attempt has been made to refine the cost estimates through specific plant contacts. It is conceded that individual plants could incur control costs that might differ from what is shown in Table 7-17, but it is believed that the estimates reasonably represent the level of control costs that would actually be incurred. Similarly, Table 7-18 shows the estimated annualized costs resulting from control Alternative I or Alternative II at existing ethylene dichloriJe plants. 7-23 COLORITE 008657 r.otod before, nc f.ntive control costs are included and the costs shown are estimated annualized costs for control of the ethylene dichloride purifi cation process emission point only. In order to estimate the economic impact upon specific plants of the control costs presented in Table 7-17 and 7-18, it has been necessary to estimate the individual plant return on investment both before and after control. The level of return on investment after control and the relative change in this level from the pre-control level are the bases upon which determinations of adverse economic impact have been made. The calculation of the pre-control rate of return on investment is based upon th'e assumption that the level of profitability of any existing plant that produces only ethylene dichloride can be generally estimated by using the economic parameters developed in Table 7-33 for new ethylene dichloridevinyl chloride plants. This approach has a number of shortcomings, such as the use of new plant economics to estimate existing plant economics and the use of ethylene dichloride-vinyl chloride plant economics to develop ethylene dichloride plant economics. The second limitation was the result of a lack of economic data for ethylene dichloride plants. Since generally similar processes are used for both types of plants, however, and prices and, presumeably, profit levels are similar in nature, it was felt that the use of ethylene dichloride-vlnyl chloride plant economics could reasonably be used to approxi mate ethylene dichloride plant economics. Table 7-19 details the assumptions used to calculate plant profitability levels for existing ethylene dichloride plants and gives an example of the calculational steps. Once the pre-control profitability levels have been estimated for existing ethylene dichloride plants it is then possible to add to these 7-24 COLORITE 008658 pU 'ts the estimated additional capital requirements tor Alternative I cr Alter native II (Table 7-17) ora the additional annualized costs (Table 7-1$) arvr then determine the change in profitability at each plant resulting from the estimated control costs. Table 7-20 summarizes the estimated' change in profitability at existing ethylene dichloride plants as a result of incurring Alternative I or Alternative II control costs. Note that two separate calculations of post control return on investment have been made. One calculation shows the level of plant profitability if no price increases are assumed. The second calcu lation shows the level of profitability if an industry-wide price increase of 0.08</lb of ethylene dichloride (0.7 percent of the base price of 12/lb) is assumed. The price'increase was calculated as the amount required by an average plant to recover the Alternative I or Alternative II annualized control costs, both air and water, and also obtain a 15 percent pre-tax return on the incremental control capital. The 15 percent rate of return was chosen to reasonably approximate the assumed rate of return at a typical existing plant. (Note that Table 7-33 and Table 7-19 show a pre-tax rate of return of 13.4 percent for the new ethylene dichloride-vinyl chloride plant that was used to construct the estimated profit ability levels at existing ethylene dichloride plants.) It is expected that the relatively minor ethylene dichloride price increase of approximately 0.08/lb (0.7 percent) will be passed on to ethylene dichloride consumers. This would mean that the-most serious decrease-in profitability .. - would be a decrease of 17 percent at the Vulcan/Geismar plant followed by a decrease of 16 percent at the Diamond Shamrock/Deer Park plant. With the exception of a 9 percent decrease in estimated profitability at the Ethyl/Houston plant, all other changes in profitability are either minor decreases, no change at all, or increases. No plant is forced into a zero profit position, or a net loss, as a result of Alternative I or Alternative II control costs. For the purpose 7-25 COLORITE 008659 0f predicting pebble plant closures the decision rule that was used was that a plant would regain open unless its estimated control costs, after allowance for an industry-average price increase, were equal to or greater than its estimated pre-control level of profitability. The net result of Alternative I or Alternative II control costs on existing ethylene dichloride plants, then, is to increase the price of ethylene dichloride to vinyl chloride plants and other users of ethylene dichloride and to reduce somewhat the profit ability of some of the existing plants in the industry. The minor nature of the price increase is assumed to result in essentially no decrease in demand for ethylene dichloride. This conclusion, when coupled with the conclusion that no existing ethylene dichloride plants will close as a result of Alternative I or Alternative II controls, leads to the judge ment that no significant adverse economic impact will accrue to the ethylene dichloride industry as a result of Alternative I or Alternative II controls. Even though it appears that no significant adverse impact will accrue to the ethylene dichloride Industry as a result of Alternative I or Alter native II controls, it is conceivable that capital availability could be a problem for some plants. It is not possible, however, to accurately estimate the magnitude of the problem. It seems logical to assume that those plants that experience either no change or an increase in the post-control return on investment compared to the pre-control return on investment would probably want to raise the capital for the control devices since the post control earnings would either be improved, or at least not decreased, compared to the pre-control earnings. Conversely, plants that experience a relative decrease in profitability may be hesitant to rai'.a the control capital. So many factors enter into decision to invest money in an existing plant for pollution ccrcrol equipment, some of th. . . ,.on-financial, that it is 7-25 COLORITE 008660 : c. 3jib]e to say with any ^ taifity whether the management of a given plant will invest ciJitional capital in control devices even if the plant would appear to have a better return on investment after control than it did before control. About the only aspect of the issue that seems clear r. that the firms that own the various ethylene dichloride plants are 'orally large, integrated petrochemical and chemical companies that would supposedly have access to sufficient capital to invest in the additional control equipment. Whether a firm would actually choose to invest those funds in control devices, however, cannot be predicted with any degree of certainty, particularly for these firms that are experiencing post-control decreases in profitability compared to the pre-control case. Since the increases in total plant replacement capital has been calculated to be on the order of 1-4 percent for existing ethylene dichloride plants complying with Alternative I or Alternative II, it would seem that the magnitude of the additional capital requirement would not prove to be a significant obstacle to raising the required capital. A similar analysis was undertaken for evaluation of Alternative III controls at existing ethylene dichloride plants. Table 7-21 details the estimated capital requirements for Alternative III controls at existing ethylene dichloride plants and is similar in nature to Table 7-17. Table 7-22, similar to Table 7-18, shows the estimated plant-by-plant annualized costs resulting from Alternative III controls. Finally, Table 7-23 shows the estimated change in plant profitability resulting from the imposition of Alternative III control costs on existing ethylene dichloride plants. In this case the estimated profitability is even mure markedly decreased for the Diamond Shamrcck/Deer Park plant and the Vulc*rw'Saismar plant. Return 7-27 COLORITE 008661 on investment at the Diamond Snamrock/Deer Park facility decreases from an estimated 3.2 percent before control to 1.9 percent after control and after an industry-wide price increase of 0.08</lb, a relative decrease of 59 percent. Similarly, estimated profitability decreases by 55 percent for the Vulcan/ Geismar plant. In each case, however, even though the decreases in profit ability are sizeable, neither decrease is sufficient to force either plant into an estimated loss or zero profit position. This leads to the conclusion that plant closures in the ethylene dichloride industry would not occur even at the Alternative III level, even though estimated plant profitability at the two plants mentioned above would be adversely impacted in a seemingly appreciable manner. Again, the issue of capital availability could be a problem for some plants, but, as was pointed out in a preceding paragraph, not enough is known about the factors influencing such investment decisions to be able to reach any firm conclusions in this area. In the case of Alter native III, additional capital requirements at the plant level over an uncon trolled facility range up to 8 percent, as opposed to a maximum increase of 4 percent for Alternative I or Alternative II. It would seem, however, that this amount would also not prove to be too large to be raised, given that the plant owners decided to do so. 7.3.3.2 Existing Vinyl Chloride Plants The analysis of the impact of alternative control levels on existing vinyl chloride plants utilizes a similar methodology to the one used in the existing ethylene dichloride plant analysis. As in the previous analysis, the emphasis will be upon the estimated impact of alternative control costs upon plant profitabillty. Table 7-24 presents the estimated plant-by-plant incremental capital requirements resulting from the imposition of Alternative I controls, including 7-28 COLORITE 008662 ,.ater eifluent costs, at existing vinyl chloride plants. Tor those vinyl chloride plants that do rot have ethylene dichloride planes associated with then ('`cncchen/Geisnar and Ter.neco/Houston), the capital requirements include fugitive controls plus incineration of the vinyl chloride formation and purification process emission point. For those other vinyl chloride r.Unts that have ethylene dichloride plants associated with them the capital costs only include fugitive controls. This is because it has been assumed that the ethylene dichloride purification process emission point and the vinyl chloride formation and purification process emission point can both be controlled with a single incinerator. This incinerator cost has been charged to the ethylene dichloride plant'and has be ;n considered in the analyses of the impact of the alternative control levels at existing ethylene dichloride plants. The estimated plant-by-plant annualized costs resulting from Alternative T controls are shown for existing vinyl chloride plants in Table 7-25. As pointed out In the previous paragraph, all plants with the exception of Monochem/Geismar and Termeco/Houston are incurring only fugitive 'controls. The two aforementioned plants are incurring fugitive costs plus annualized costs for incineration of the vinyl chloride formation and purification process emission point. Note that all plants have been assessed a charge corresponding to the estimated industry-wide price increase for ethylene dichloride of 0.08f/lb. This is the same charge that was utilized in the previous discussion of the impact of various alternatives on existing ethylene dichloride plants. The impact of A1 ?.:--; Mye I controls on the estimated profi tability of existing vinyl chloride plants is shewn in Table 7-26. The calcu lation of the estimated level of pre-control profitability at existing vinyl 7-29 COLOR!TE 008663 chloride plants shown in Table 7-26 utilized the same methodology as the calculation of pre-control profitcbility at evisting ethylene dichloride plants. This methodology was detailed in Table 7-19. Note that two post-control profit ability levels have beer, calculated. One shows the estimated return on invest ment for a given plant after control if a price increase is not assumed. The other shows the estimated profitability level that would result if a price increase sufficient to recover industry-average annualized costs plus a 15 percent pre-tax return on capital is assumed to be passed on to the users of vinyl chloride. The price increase assumed in Table 7-26 is 0.36</lb, or 3 percent of the base sales price of 12</lb of vinyl chloride. It is expected that this price increase will be passed on to the users of vinyl chloride. These users, essentially all of them being polyvinyl chloride producers, are not expected to appreciably reduce their consumption of vinyl chloride when faced with the 3 percent price increase. The polyvinyl chloride producers are expected to attempt to pass along to the fabricators of poly vinyl chloride resins the vinyl chloride price increase. This topic will be discussed in more detail in a subsequent section of this chapter. Referring to Table 7-26, it is seen that if a price increase of 0.36d/lb of vinyl chloride is assumed to be passed forward to the polyvinyl chloride producers then none of the plants will be placed in a zero profit or a loss position. Six plants, however, all of them with smaller than average capacities, will suffer a reduction in profitability ranging from a 6 percent reduction to a 53 percent reduction. No plant closures are anticipated as a result of imposing Alternative I control costs on the industry since all plants remain profit able, although marginally so In soma instances. As noted before in the section dealing with the analysis of alternative control levels on existing ethylene dichloride plants, it is difficult to reach any firm conclusions 7-30 COLORITE 008664 regarding the 'ss^e of capital availability for purchase of control equiprc-n: for* existing plants. Increases in plant capital are estimated to vary between 8-11 percent or estimated replacement capital for Alternative I controls, an amount that would not seem to present a large acquisitional problem particularly since the firms in the vinyl chloride industry are '-'"orally the same firms as the firms in the ethylene dicloride industry and are large concerns with supposedly established lines of credit and access to capital funds. As pointed out previously, however, a decision not to invest in a control device could be made no matter what the economics of the situation might indicate due to the presence of other considerations. It should be realized that a combination of increased capital require ments plus a severe reduction in plant profitability could lead to plant closures. A plant would not necessarily have to experience a loss before the plant owners decided to close it. Even though no closures are expected to result from the imposition of Alternative I controls on the vinyl chloride industry, it must be realized that the possibility of closures does exist. The costs of complying with Alternative II controls at existing vinyl chloride plants has also been evaluated. The results of this analysis are only slightly different than the results of the Alternative I analysis since only one plant incurs a different level of costs for Alternative II than for Alternative I. Alternative II assumes that the one plant will have to incinerate the oxychlorinatlon process emission point in addition to controlling fugitive emissions and emissions from the vinyl chloride for mation and purification process emission points. All other plants are assumed not to incinerate the oxychlorinatlon process emission point. The plant in question may not have to use incineration in order to meet the proposed standard since less expensive control options nay be avail- 7-31 COLOR!TE 008665 able. Since the nature and costs of these alternative options are not known, incineration has been used as a worst-case estimate. Table 7-27 details the estimated capital requirements for the Alternative II control level, including both air emission control costs and water pollution control costs. Similarly, Table 7-28 details the annualized costs estimated for Alternative II controls at existing vinyl chloride plants. Finally, Table 7-29 presents the estimated changes in plant profitability resulting from Alternative II controls. Note that the only change in this .table compared to Table 7-26 (Alternative I Profitability Suirmary) is to change the post control profitability levels at one .plant. This plant now suffers a 15 -percent reduction in profitability relative to the base case if Alternative II controls are Imposed compared to a 9 percent increase in profitability if Alternative I controls are imposed. (Both calculations assume a price increase for vinyl chloride of 0.36</lb.) A similar conclusion regarding the impact of Alternative II controls on existing vinyl chloride plants is reached as was reached in the Alternative I analysis, namely that no closures would result but that plant profitability would be reduced in some cases. Even though one plant incurs an estimated replacement plant capital increase of 13 percent for Alternative II as opposed to 9 percent for Alternative I, it would not seem that this would pose a significant capital availability problem. Finally, an analysis of Alternative III controls on existing vinyl chloride plants has been evaluated. Table 7-30 details the estimated capital costs for this alternative which assumes that all plants having an oxychlorination process emission point would have to incinerate the emissions. Not all plants have this emission point, however, and those that do not irour the same costs for Alternative III as for Alternative II and Alter- 7-32 COLORITE 008666 --.t've I. ',.-o of the plants t^at bn/e ttr_! oxychlorindtion process c-riss-ion J,'C ire .> i ready inn ifiera t in.y the emissions in order to meet existing state "eg:; 1 aticns. The estimated annualized costs for Alternative III controls at existing v'ryl chloride plants, including a charge for higher ethylene dichloride prices . ^ijlting from emission control costs, is presented in Table 7-31. Industryaverage total costs increase from 0.29d/lb at the Alternative I level to 0.39d/lb at the Alternative III level, an increase of 34 percent. Finally, the impact on plant profitability of the Alternative III controls is shown in Table 7-32. The results are not appreciably different than shown in the previous tables^that summarize tnc Alternative I and Alternative II profitability impacts. As before, no plants are forced into a zero profit or net loss position, assuming that an industry-wide price increase for vinyl chloride of 0.49<t/lb (4 percent of the base price of 12</lb) can be passed on to the vinyl chloride users. This.leads to the conclusion that no plants would close as a result of complying with the estimated Alternative III costs. Individual'plant profitability decreases for six plants, however, ranging from a seemingly minor 2 percent to a seemingly appreciable 55 percent. Again, the most severe impact is experienced by the smaller plants. Increases in estimated plant capital for control equipment are approximately 8-16 percent of the estimated plant replacement capital. In general, the larger increases occur at those plants that also incur the greatest decreases in profitability, a factor that tends to indicate that some closures might occur at the Alternative III con trol level. It is impossible to state with any certainty, however, that a certain plant might close as a result of the Alternative III control level, but it must be recognized that the possibility of closures does exist at 7-33 COLOR!TE 008667 this level. The possibility of some plant closures also exists at the Alternative I and Alternative II levels, however, so it cannot be said that only at the Alternative III control level does the problem of poten tial plant closures exist. It is interesting to note that the plants that were the more severely impacted at the Alternative I/Alternative II level are not necessarily the most severely impacted at the Alternative III control level. The impact tends to shift to different firms under the Alternative III scenario instead of just getting worse for the firms impacted in the Alterna tive I and Alternative II scenarios. This results from the fact that some plants do not have an oxychlorination process emission point to -control. In summary then, It is concluded that the economic impact of the three alternative control levels for existing vinyl chloride monomer plants that have been evaluated is primarily to increase monomer prices on the order of 3-4 percent and reduce the profitability level of some plants, generally the smaller ones, on the order of 2-55 percent. Some other plants, generally the larger ones, experience increases in profitability on the order of 3-31 percent as a result of the alternative control strategies. Mo plants are expected to close as a result of incurring the alternative control costs, even though the possibility of some plant closures does exist at all three control level. The price increase of 3-4 percent appears to be small enough so that no appreciable reduction in demand for vinyl chloride monomer will occur. 7-34 COLOR!TE 008668  : 'J:~~ - a~ i~y sis ' sial impacs of two alternative control levels !~as roan ev?.'- .a ted i"or a motel now ethylene dichloride-vinyl chloride plant. In addition, r'\; impact of meeting only the ERA water effluent guideline regulations has 1 .-'i; determined. The results of this analysis are detailed in Table 7-33. Table- 7-33 shows that a new ethylene dichloride-vinyl chloride plant would suffer a decrease in profitability from 6.7 percent to 5.1 percent as a result of meeting the water effluent guidelines. A price increase of 0.17c/lb of product, or 1.4 percent of the base price of 12/lb, would be required to restore the pre-control profitability level of 6 7 percent. Total investment increases from 4.83<t/lb/yr to 5".17<t/lb/yr as a result of adding the water effluent controls, an increase of 7 percent. A new ethylene dichloride-vinyl chloride plant that does not incinerate the oxychlorination vent is modeled by Alternative I in Table 7-33. This plant would require a total price increase of 0.29</lb in order to maintain the precontrol profitability level of 6.7 percent, a relative price increase of 2.4 percent. Total investment increases by 10 percent over the totally uncontrolled plant. It is important to realize that the above statistics include the costs of the water effluent guidelines as well as the costs for control of emissions to the air. The plant that only controlled air emissions would require a price increase of 0.12<t/lb (1.0 percent) and would experience a total capital increase of 3 percent. A new ethylene dichloride-vinyl chloride plant that did incinerate the oxychlorination vent is modeled by Alternative III in Table 7-33. This plant would require a price increase of 0.44^/lb (3.7 percent) in order to maintain -u'econtro! profitability. 7- Lai investment would increase by 13 percent. Again, 7-35 COLOR!TE 008669 these- statistics include water effluent costs. A plant that only controlled air emissions would require a price increase of 0.27d/lb (2.3 percent) to maintain pre-control profitability. The increase in total investment would amount to 6 percent if only air emission controls were included. It is believed that the cost increases associated with either Alternative I or Alternative III would not prove to be a significant deterrent to the construction of new ethylene dichloride-vinyl chloride plants. It would appear that the costs of both the effluent regulations and the air emission control requirements at either the Alternative I level or the Alternative III level could be passed on to the polyvinyl chloride producers. This cost pass-on would preserve the pre-control profitability level at the new ethylene dichloride-vinyl chloride plant and the plant owner should have no disincentive to construct the new plant. Two factors lead to the conclusion that new ethylene dichloride-vinyl chloride plants will be able to raise prices by an amount sufficient to maintain pre-control profitability. The first factor is that existing ethylene dichloride-vinyl chloride plants will also be required to incur control costs of the same magnitude as those calculated for new plants. This industry-wide pollution control cost increase will to be reflected in higher prices for vinyl chloride. A new plant, therefore, will not be at price disadvantage relative to existing plants. The second factor leading to the conclusion that vinyl chloride prices will increase is that substitutes for vinyl chloride exist only for a very small percentage of the total end-use applications. Almost all of the vinyl chloride that is produced is used in the production of polyvinyl chloride. This lack of substitute raw materials for the polyvinyl chloride producers means that they have little choice other than to accept higher vinyl chloride prices and 7-36 COLOR!TE 008670 then attempt to reflect these higher prices in increased prices to the fabri cators of cne resins, and ultimately, the consuming public. Whereas it is true that large increases in the price of polyvinyl chloride resins could lead to a decrease in demand for vinyl chloride, it does not appear that vinyl chloride price increases of even 4 percent or so would be enough to cause a significant reduction in demand. An increase of 4 percent in the price of vinyl chloride would translate into an increase of approximately 2 percent in the price of polyvinyl chloride resins. Discussions with industry representatives have led to the conclusion that price increases for polyvinyl chloride resins of up to 10 percent could be tolerated without significant impact so it would appear that a price .ncrease of 4 percent in vinyl chloride could be ultimately passed on to the fabricators of poly vinyl chloride resins with no adverse consequences. This subject of poly vinyl chloride price increases will be addressed in more detail in a subse quent section of this chapter. _ It would not appear that capital availability would be a problem for new ethylene dichloride-vinyl chloride plants. The model plant shown in Table 7-33 has a base (uncontrolled) capital requirement of 4.83it/lb/yr, or $33,810,000. The capital Increase at the Alternative III level to 5.444/lb/yr would be an increase of $4,270,000 or 13 percent. It would seem that if prices could be raised by an amount sufficient to restore pre-control profitability then It should be possible to generate the additional control capital since it would be earning the same return as the capital that was being used for the uncon trolled plant. 7-37 COLORITE 008671 7.3.5 POLYVINYL CHLORIDE PLANTS-EXISTING PLANT ECONOMIC IMPACT ANALYSIS 7.3.5.1 Introduction In an attempt to estimate the economic impact of alternative control levels at existing polyvinyl chloride plants four control scenarios have been developed. Control scenario #1 is the least stringent and assumes that all dispersion process plants will utilize the Alternative I control system (stripping to 30,000 parts per million) and that all other plants will utilize Case A controls (improved stripping). Control scenario #2 assumes that dispersion process plants will utilize the Alternative II, Case A control system (stripping to 2000 parts per million) while all other plants utilize Case A (improved stripping) controls. Control scenario #3 assumes that dispersion process plants utilize the Alternative - - . II, Case B control system (incineration) and that all other plants will utilize the Case A (improved stripping) control system. Control scenario #4 is the most stringent and assumes that dispersion plants will utilize the Alternative II, Case B (incineration) system and that all other plants will utilize the Case B (incineration) control system. In all of the control scenarios it is the cumula tive effect of air and water pollution controls at ethylene dichloride plants, vinyl chloride plants, and polyvinyl chloride plants that is being evaluated. As in previous sections, the methodology of analysis will emphasize price increases, plant profitability levels, and incremental capital requirements. 7.3.5.2 Control Scenario #1 This control scenario assumes that all dispersion plants utilize Alternative I controls (stripping to 30,000 parts per million) and that all other plants utilize Case A (Improved stripping) controls. Table 7-34 details the estimated plant-by-plant capital requirements for control scenario ?1. Capital requirements for air emission control systems at 7-38 I.91U PI jWPniMIM.!.1- >!. COLOR!TE 008672 : L ' aV C 1-- - 1 ^ `."l t. IJ J'. : tnms deveiero , :sori (Table 7-r) . 1 isorichms, coupled with specific cl-ii.t information and as sump':ions rereading process types, reactor sizes, and various other cto, s led to the estimation of the air pollution control costs. The wafer effluent control costs at individual plants have been estimated sing the cost information presented earlier in this report (Table 7-16) and supplied by the Effluent Guidelines Division of EPA. With regard to the water pollucion control costs, these costs are included to give only a general estimate of the magnitude of effluent guidelines compliance costs. No analysis has been given to these costs since the primary thrust of this report is to estimate the impacts resulting from various air pollution control systems. The capital costs shown in Table 7-34 represent an average increase in esti mated replacement plant capital for all affected plants of approximately 19 percent. Individual plant incremental capital requirements are estimated to vary between 9 percent and 37 percent. The estimated plant-by-plant annualized costs for control scenario #1 are shown in Table 7-35. Note that a charge for vinyl chloride has been included in the cost summary that is the amount necessary to recover industry-average control costs, both air and water, at existing ethylene dichloride-vinyl chloride plants. In a manner similar to the methodology previously described, it has been possible to estimate the pre-control profitability of existing plants and then determine the change in profitability due to imposition of emission control costs on the uncontrolled plant. The methodology for determining the profitability : existing polyvinyl chloride pi arts is identical to the methodology employed for existing ethylene dichloride plants and vinyl chloride plants. (Refer to Table 7-19). 7-39 COLORITE 008673 It must be emphasized that the profitability levels shown in this section well as the previous sections dealing with ethylene dichloride plants and nyl chloride plants were derived from generalized financial information veioped for model plants. These profitability levels are thought to generally proximate the profitability levels at existing plants. Table 7-36 presents a summary of the estimated profitability levels d changes in profitability resulting from imposition of control scenario #1 ntrol costs. Note that the average price increase for this scenario is 15<t/lb. Since approximately 10 percent of the industry sales are of disrsion process resins that sell for about 34</lb and the other 90 percent the sales are at about 246/1b, this results in an average price for all les of approximately 256/1b. The 2.156/1b price increase for scenario #1 an increase of 8.6 percent in this average price. _ Examination of Table 7-36 reveals that there are 4 plants (Occidental/ ^Rsville, Jennat/Torrance, Jennat/Tucker, and Jennat/Somerset) that are aced in an estimated loss position (negative return on investment) after the erage price increase has been passed on to resin users. Another 17 plants :perience a net decrease in return on investment due to the imposition of ie scenario #1 control costs ranging from 1 percent to 57 percent. The gaining 20 plants either experience no decrease in profitability or else a ilative net increase in profitability ranging up to 9 percent. It is itimated that the 4 plants that are placed in the negative profitability asltion by control scenario #1 would probably be closed unless mitigating ircumstances not considered in this analysis came into play. These four lants represent less than 1 percent of the total industry capacity of ,600.000,000 kg/yr. Based on total polyvinyl chloride industry employment of 7-40 COLORXTE 008674 'OXir.v'X i' . Tij'C-C as , r';Jit or c l.'.u of c;,,i <] a icrcr; ertioned r-1 ac, Tie prise- increase to resin fabric? tcrs of 2.15^/lb (8.5 percent) rosultir.g "-ori control scenario 1 is ast imated to res id t 8: a pries increase to the vcars of the fabricated products of approximately 1-4 percent. This ir. price of consumer goods fabricated from polyvinyl chloride resins was estimated based on the assumption that the resin cost amounted to 10-50 percent of the final cost of the fabricated product. The remainder of the fabricated product cost would be comprised of fabrication labor, utilities, depreciation, interest, and miscellaneous c ^head charges. A resin price increase of 8.6 percent (which translates into a maximum fabri cated goods price increase of 4 percent) is not believed to be sufficient to result in any appreciable substitution of other products for polyvinyl chloride fabricated resins or in any appreciable increase in imports of either polyvinyl chloride resins or fabricated products. This conclusion is based upon the assumption that a relative price increase of 10 percent is the maximum price increase that could be passed forward to the fabricators of polyvinyl chloride resins and, ultimately, the consuming public before appreciable reductions in demand for polyvinyl chloride products took place. This assumption is based upon conversations with industry representatives. It would seam that the 10 percent price increase parameter is a reasonable one upon which to base conclusions of economic impact, but it is granted that a more sophisticated analytical tool would be of much value. In the event that no price increase for polyvinyl chloride resins ..odd be obtained. Table 7-35 reveals that one additional plant (KeysorCentury/Saugus) would be nla'od in a no;'.-ive profitability position and might be subject to closure. This would mean that a total of five plants 7-41 COLOR!TE 008675 might close if control scenar io #1 was implenented \-r. trout any price increases for polyvinyl chlorite resins. 7.3.5.3 Control Scenario 2 This control scenario assumes that all dispersion plants utilize Alter native II, Case A controls (stripping to 2000 parts per million) and that all other plants use Case A (improved stripping) controls. Table 7-37 shows the estimated capital requirements for all existing polyvinyl chloride plants for control scenario #2. The estimation or these costs employed the same methodology as described above for control scenario #1. The capital costs shown in Table 7-37 represent an average replacement plant capital increase for all affected plants of approximately 20 percent. Individual plant capital requirements are estimated to vary between 10 percent and 38 percent. Table 7-38 details the estimated plant-by-plant annualized costs for control scenario #2. These costs, as do the capital costs shown in Table 7-37, include charges for control of water effluent emissions. Table 7-38 also includes a cost pass-on from ethylene dichloride-vinyl chloride plants to recover costs for control of air and water emissions at these facilities. Table 7-39 shows the impact on plant profitability of the costs resulting from control scenario #2. Note that in this case the estimated average price increase for all resins is 2.35<t/lb, or 9.4 percent of the overall average resin price of 25/lb. Table 7-39 shows that the 4 plants that were placed in a negative profitability position by control scenario 1 (Occidental/ Hicksville, Jennat/Torrance, Jennat/Tucker, Jer.nat/Somerset) are also placed in a negative profitability position 'y control scenario #2. There are no additional firms placed in a negative p- -lability position by this scenario, assuming an average price increase of ,3'3y/lb. Of the remaining 37 poly- 7-42 COLORITE 008676 /'"'S ; f, , cHc-'idfr pi; r?, lh '-'for ?. net decrease in /..-^t i uac i . ~y -,; T^e remaining 19 pi ^nt hn\ ir'.rease-d prof"'tat i 1 itips as a 'i cf the control scenario ranging up to a rst increase of 13 Percent. In this case the average price increase to resin fabricators is 2.35C/lb, ' ' percent). Again assuming that resin prices make up 10-50 percent of - cost of the fabricated product, the price increases to the final users of the fabricated products is estimated to be on the order of 1-5 percent, an amount not believed to be sufficient to cause significant sub stitution or imports. The anticipated plant closures for control scenario i2 are the same as control scenario #1 (Occidental/Hicksville, Oennat/ Torrance, Jennat/Tucker, and Jennat/Somerset) and would result in a loss of domestic polyvinyl chloride capacity of less than 1 percent and a loss of approximately 30 jobs. As in the case a control scenario #1, one additional plant (KeysorCentury/Saugus) would be placed in a negative profitability position if an average price increase was not possible. This would mean that a total of five plants might close if control scenario #2 was implemented without any price increases. 7.3.5.4 Control Scenario #3 This control scenario assumes that all dispersion plants utilize Alter native II, Case B controls (incineration) and all other plants use Case A (improved stripping) controls. Table 7-40 shows the estimated capital requirements, including water pollution control capital, for control scenario #3. Once again, the esti mation methodology was she same m -'ibed for control scenario #1- The capital costs smews in Table 7-40 reprr.ssnt an average replacement plant capital increase for all affected plants of approximately 24 percent. 7-43 COLORITE 008677 v dual replac~ent plant capita; requirements are estimated to vary etween 1C percent and 44 percent. Table 7-41 shows the estimated annualized costs, including water pollution ontrol costs, for control scenario #3. As in previous scenarios, a charge for ir and water pollution control costs at ethylene dichloride-vinyl chloride >lants has been included. Table 7-42 details the estimated impact on plant profitability resulting 'rom control scenario #3. For this case the average resin price increase is estimated to be 3.56sf/lb or 14.2 percent of the overall average resin price jf 25<t/lb. Table 7-42 further indicates that a total of 7 plants (Occidental/ licksville, Jennat/Torrance, Oernat/Tucker, Jennat/Somerset, Monsanto/ Springfield, Jnion Carbide/South Charleston, and Uni royal/Painesvilie) would be placed in a negative profitability position and would be potential closure candidates. ur of the aforementioned plants were identified as potential closure candi dates for control scenario #1 and scenario #2. Of the remaining 34 plants, 10 would suffer relative net decreases in profitability of up to 74percent while 24 plants would experience relative net increases in profitability ranging up to 40 percent. The above discussion assumes that an average price increase ofapproximately 3.56</lb (14.2 percent) will be passed on to resin fabricators. It will be recalled from the discussion of the impact of control scenario #1 on existing polyvinyl chloride plants that a 10 percent price increase was believed to be the point at which appreciable substitution of other products for polyvinyl chloride would occur. It is possible, then, that a price increase of 14.2 percent would not occur. This _ijld mean that all firms would experience lower post-control profitability levels than shewn on Table 7-42. Accordingly, some idditional plant closures might occur depending upon the actual amount of 7-44 L r m COLORITE 008678 :e increase. In this case. ho ' 5 the erica increase was United -_o TO pt-fi'er', r;-,are would be- no additional closure candidates in non -co the 7 mentioned above. In this case the Increase in the price cf fabricated products would be expected to be on the order of 1-7 percent given that a net resin price Increase of approximately 14 percent ccrid be effected. A resin price increase of 10 percent is expected to result in an increase to the fabricated product consumer of 1-5 percent. The seven plants mentioned above comprise approximately 5 percent of the total domestic polyvinyl chloride capacity. It is estimated that about 250 jobs would be lost if these plants closed. Table 7-42 reveals that a total of 13 plants might close if no price increases for polyvinyl chloride resins could be obtained and control scenario #3 was implemented. These fourteen plants comprise approximately 18 percent of the total industry capacity and are estimated to employ approxi mately 1000 people. 7.3.5.5 Control Scenario 4 This control scenario assumes that all dispersion plants will utilize Alternative II, Case B (incineration) controls and that all other plants will utilize Case B (incineration) controls. Table 7-43 details the estimated capital requirements, including water pollution control capital, for control scenario #4. The capital costs shown in Table 7-43 represent an average replacement plant capital increase for all affected plants of approximately 29 percent. Individual plant capital requirements are estimated to vary between 12 percent and 45 percent. --le 7-44 details bhe annualized cost requirements, including a charge Ter controls at the ethylene dichloriria-vinyl chloride plant for this scenario. 7-45 COLOR!TE 008679 Again, uhe methodology used in Tables '-43 and 7-44 is identical Lo the or:e utilized in the analysis of the preceding scenarios. The estimated inpact upon plant profitability resulting from control scenario #4 is shown in Table 7-45. Note that in this case the average price increase has been calculated to be 6.04b/lb (24.2 percent). Assuming a price increase of this magnitude results in 6 plants experiencing a post-control return on investment that is either zero or negative. These 6 plants (Occidental/Hicksville, Jennat/Torrance, Jennat/Tucker, Jennat/Somerset, Monsanto/ Springfield, and Union Carbide/South Charleston) would be potential closure candidates. Of the remaining 35 plants, 13 experience a relative net decrease in profitability of up to 78 percent as a result of control scenario #4 and 22 plants either experience no net change or else a relative net increase in profitability of up to 81 percent. The statistics presented above are based upon a price increase of 24.2 percent. If the actual price increase in the industry was limited to 10 percent for reasons cited previously, it is estimated that 4 more plants (Diamond Shamrock/Delaware City, Keysor-Centory/Saugus, Pantasote/Passaic, and Uni royal/Painesville) would join the list of closure candidates. The net result of a 24.2 percent increase in resin prices would be an estimated price increase for fabricated products of 2.5-12 percent, an amount that could conceivably lead to appreciable substitution or increased imports. It was estimated that 6 plants might close if control scenario #4, including a 24.2 percent price increase, was implemented. These six plants account for approximately 3 percent of the total industry capacity are esti mated to employ 150 people. If only a 10 percent price increase was effected, then theoretically little or no substitution or increased imports would occur, but a total of 7-46 COLOR!TE 008680 ;o r ; i: o; are o p i oy acprox' e (y ' U jJ I - - c-isa '.o-xjp'er price increases arc* anticipc he order cc 1-5 pes'-nt, 7-45 indicates that a total of 30 plants night close if no price .. was obtained and control scenario 44 was implemented. These 30 plants account for approximately 58 percent of total industry capacity and are esti mated to employ 3200 people. 7.3,6 Pc 1 yvin.yl Chloride Plants - New Plant Economic Impact Analysis 7.3.6.1 Introduction The economic impact of various air emission centre, levels on new suspension, dispersion, and bulk process polyvinyl chloride plants has been evaluated. For suspension process plants only one level of emission control has been evaluated but two methods if attaining the emission level are discussed - an improved slurry stripping system and an incineration system. For dispersion process plants two alternative emission levels are presented, one of which could be met by a system based on resin stripping to existing levels and the other could be met by either a system based on stripping to 2000 parts per million or an incineration system. For bulk process plants only one level of emission control has been evaluated. As with the suspension process plant either an improved stripping system or an incineration system could be used to attain the emission control level at the bulk process plant. 7.3.6.2 New Suspension Process Plants The results of utilizing various control systems at a typical new sus- p-nsicn process polyvinyl chlor- 1 j plants : shown in Table 7-48. Note that the ,, -'.trolled suspension process plane, generates a return on investment of 9.3 percent, ud rate of return decreases to 8.2 percent for a plant that 7-47 COLOR!TE 008681 r'' ioT ! ' ' f. ) (' ' c , ;,,i price ircro^se thet cculc! a ly, .-on conversations with industry representatives. Referring back to Table 7-46, it is seen that the Case A scenario, v/hich includes air amission control costs and water effluent costs at the suspension process polyvinyl chloride plant as well as increased vinyl chloride prices due to air and water controls at ethylene dichloride-vinyl chloride plants, results in a price increase of 8.8 percent beJng required maintain the pre-control profitability level, a level somewhat below the 10 percent cut-off level. The Case B scenario, however, results in a price increase of 21.9 percent, well above the 10 percent cut-off point. Even if all water effluent costs were not incurred and no increase in vinyl chloride prices was incurred either, the resulting costs for the air emission controls alone would result in a price increase of 19 percent which is still well above the cut-off point. If it can be assumed that the fugitive control package used at the model suspension process plant duplicates the OSHA-required controls then the price increase for EPAgenerated air controls would drop from 19 percent to 16 percent, a level that is still appreciably higher than the 10 percent cut-off point. Total plant capital requirements at a typical new suspension process polyvinyl chloride plant increase by approximately 19 percent as a result of adding Case A controls. This increase of 19 percent is not believed to be large enough to deter construction of a new facility. This conclusion is drawn based on the az.umption that prices for polyvinyl chloride will be raised by an amount sufficient in gw-c-rate the sane profit cn the incremental control capita] as 7-49 COLOR!TE 008682 -,nly y , vii 11 .ve to ' i- v j. r- w~s i - m' i., `-'iC- p-'iiceaing . _- ~- e < i s w"u o 1 an13 wil 1 r :ro Lie -'^rced to raise prices by auprcxi- ?.vp1> 10 percent so any new facility that incurs a price increase will be CJ pacing with existing firms that have also incurred approximately the same price increase. In summary, then, it appears that utilization of the Case A (improved stripping) control system would not be a deterrent to the construction of new suspension process polyvinyl chloride plants but that utilization of the Case B (incineration) control system would seriously deter the construction of any new suspension process plant. 7.3.6.3 New Dispersion Process Plants The results of utilizing various control systems at a new dispersion process polyvinyl chloride plant of 14,000,000 kg/yr capacity are shown in Table 7-47. Mote that the uncontrolled plant generates a relatively low return on investment of 3.1 percent. Imposition of the water effluent costs and the increased vinyl chloride costs due to controls at the ethylene dichloride- vinyl chloride plant leads to a reduction in profitability to 2.5 percent and would require a price increase of 1.7 percent to maintain the pre-control profitability level of 3.1 percent. Total plant capital requirements increase from 55.75/lb/yr to 56.5Sd/lb/yr, an increase of 1.5 percent. The model dispersion plant that utlizes the Alternative I control system (resin stripping to 30,000 parts per million) plus incurs water effluent costs and increased vinyl chloride charges experiences a drop in profitability to 0.1 percent if no price increase is obtained. A price increase of 11.0 percent would be requir-d to restore the pre-control profitability level of 3.1 peo:er,t. Total pi one capita in this case increases by 15 percent. Similarly, the model dispersion plan- 'n the term tive II, Case A scenario would 'upouBW COLOR!TG 008683 .3int^tn ore-contfol ero^it- 1 : Wo increase in total capital of 21 percorf. The Ai tenia tive II. Case E seen... ':o leads to a price increase of 52.9 percent or-'-1 ? total capital increase of 33 percent. Us1'"., the 10 percent price increase parameter discussed previously leads `<-n the conclusion that a new dispersion process polyvinyl chloride plant of approximately 14,000,000 kg/yr capacity would not be constructed at either the Alternative II, Case A control level or the Alternative II, Case B control level. It is questionable whether a new dispersion process plant of approxi mately 14,000,000 kg/yr capacity would be constructed at the Alternative I control level. The required price increase to maintain pre-control profit ability at 11.0 percent is admittedly higher than the 10 percent cut-off level, but only marginally so. It is altogether possible, however, that new disparison process poly vinyl chloride plants of the size modelled in Table 7-47 would not be constructed in the future even if no pollution control regulations, either air or water, were applied to them. This is because smaller plants apparently have marginal profitabilities before any control costs are incurred. It is likely that larger dispersion process plants would be constructed in the future, however, due to the fact that economies of scale would make these facilities more profitable than smaller plants. Table 7-48 details the estimated effect of economies of scale on dispersion process polyvinyl chloride plants by showing the economics of an uncontrolled 45,000,000 kg/yr plant and how these economics are altered by imposition uf various control systems. Note tha-. "he unu.;;v;-riled rt with a capacity of 45,090,000 kg/yr has a return on investment ir the face (uncontrolled) case of 7.5 percent as opposed to 3.1 percent for the li,CCC/,30 kg/jr plant, for the larger plant it is seen 7-51 COLORITE 008684 ,. , Ik. C L aLility of s:-',i2 not the price Increase to maintain t"i ra*.,'* ' f Drofittne Alternative II, Case A option (stripping to 20'jQ parts per millicr) at 1C.5 percent, only marginally above the 10 percent cut-off figure. The Alternative II, Case B scenario (ircineration) is well above the 10 percent cut-off point and would remain so even if all other control costs except for the EPA-generated air emission costs were removed. It is concluded based upon the information presented in Table 7-47 and 7-48 that new dispersion process plants will be able to comply with all emission control costs required by the Alternative II, Case A scenario (stripping to 2000 parts per million), including water pollution control costs, at large dispersion process plants (approximately 45,000,000 kg/yr capacity or greater) but not at plants that are appreciably smaller than 45,000,000 kg/yr capacity. Smaller plants, however, on the order of 14,000,000 kg/yr capacity would probably only be able to comply with the Alternative I scenario (stripping to 30,000 parts per million). Total plant capital costs in the Alternative II, Case A scenario increase by approximately 14 percent for a plant with a capacity of 45,000,000 kg/yr, an amount that would not appear to appreciably, deter construction of new facilities since pre-control profitability is expected to be maintained through price increases. As was pointed out in the preceding section, an industry-wide price Increase of approximately 10 percent will be caused by the impact of control regulations on existing plants. The new plant, therefore, will be able to raise prices and generate a pre-control level of return on Its total capital investment, including the incremental control capital requirement. In summary, then, it is concluded that the Imposition of Alternative I controls (stripping to 10,000 parts per million) mould probably not be a deterrent to the ...os true in on of new dispersion process polyvinyl chloride ?-52 COLORITE 008685 -' s 0t - - -..I . K-S , cue . OUb i . .a . :t`j 'a 2005 pa-'ts per million) noclr iHit ne a cerorrvn; cc >,na cc'' A l_rce new disport'cn plants wire -acities of 45,000,Git hg/yr cr and that imposition of Alternative II, Case B controls (incinerat* .-n) would prove to be a serious deterrent to the construction of any new dispersion process polyvinyl chloride plants. '/.3.5.4 `lew Bulk Process Plants The results of utilizing various control systems on a typical new bulk or polyvinyl chloride plant are shown in Table 7-49. This plant has a return on investment for the uncontrolled case of 9.3/. This base plant return on investment decreases to 7.7 percent for the plant that incurs water pollution control costs and increased costs for vinyl chloride. This case requires a 2.9 percent increase in prices to maintain the pre-control profitability level of 9.3 percent. Total plant capital increases from 21.15</lb/yr to 21,99<t/lb/yr, an increase of 4 percent. The plant that then incurs Case A (improved stripping) control costs in addition to the water effluent costs and the increased vinyl chloride costs requires a price increase of 7.7 percent to maintain pre-control profitability and experiences a total plant capital increase of 10 percent. Similarly, the plant that incurs Case B (incineration) control costs in addition to the effluent costs and the increased vinyl chloride costs requires a price increase of 10.5 percent to maintain pre-control profitability and incurs a total plant capital increase of 12 percent. It is concluded, based upon the results shown in Table 7-37 and the analytical methodology used previously, that a significant barrier to the con struction of new bulk process polyvinyl chloride plants would not exist for cither the Case A (improved strippi g) control scenario or the Case B {incin erate.e; control scenario. Cven cbor^1' .be price increase required to maintain pre-control profitability in the Cc-.. 3 situation is marginally higher than the eut-cf* point, it dees not seem to be an appreciable difference. 7-53 COLOR!TE 008686 7 ,: 7 Sir nary 7.3.7.1 Ethyl ene 3: chi oride-Vl nyj Chloride- Plants The followir,g is a summary of the economic cnaiysis cf alternative con trol levels at new and existing ethylene dichloride-vinyl chloride plants: 1. New ethylene dichloride-vinyl chloride plants are judged to be able to afford either Alternative I controls (no control of the oxychlorination vent) or Alternative III controls (control of the oxychlorination vent). Incremental capital requirements for a typical new facility with a capacity of 318 million kg/yr (700 million lb/yr) are as follows: Incremental Control Capital ($ Millions) Alt. I Alt. Ill Air $0.9 1.9 Water 2.4 2.4 Total $3.3 4.3 % Increase Over 10% 13% Uncontrolled Plant The price increase required to maintain pre-control return investment at the typical new facility mentioned above are : Price Increase Alt. I Alt. Ill Air 0.12(f/lb 0.27 Water 0.17 0.17 Total 0.29 c/lb 0.44 % Increase Over Base Price of i2C/lb: 2.4% 3.7% 7-': COLOR!TE 008687 tx ir,irid;r/iC,' -nc^'o! ;c':; !j:: ^ ,, ' - J ,, ^ 2 C lU C Q Z 0 . to comply iall rent 'j' V('i fhouc s-y n r icanc a wo rse econo mic impact. Tne foil-,.dog tibia lists t^e reic-,a. ` z p ^ r rr. 610 r 5 r o r, s i der (r'i : Cortro 1 Alterna ti ve I II III Fir"imated Plant Closures: None None None Net Change in Return on Investment After Price Increase Range: Industry Average: 27"-(17%) 0 27%-(17%) 0 27%-(59%) (n) Increase in Estimated Replace ment Plant Capital Range: Industry Average: 1-4% 3% 1-4% 3% 1-8% 3% Industry Total Incremental Control Capital ($ Millions) Air Controls: Water Controls: Total: $5.1 11.9 17.0 5.1 n.o 17.0 6.6 11.9 18.5 Price Increase Due To: Air Controls: Water Controls: Total: % Increase Over Base Price of 12c/1b 0.046<t/lb .034 .030 d/lb 0.7% .046 .034 .030 0.7% .046 .034 .080 0.7% 7-55 COLORITE 008688 'istiric c'Heidi. jrt judged to be able to comply with all control cptims v/ithout significant adverse economic impact. The following table lists the relevant parameters considered: Control Alternative I II III Estimated Plant Closures: None None None Net Relative Change in Return on Investment After Price Increase Range: Industry Average: 9%-(53%) 4% 9%-(53%) 0 31%-(55%) 4% Increase in Estimated Replace ment Plant Capital Range: Industry Average: 8-11% 8* 8-13? 9% 8-16% 11% Industry Total Incremental Control Capital ($ Millions) Air Controls: Water Controls: Total: $8.7 23.0 $31.7 10.3 23.0 33.3 19.6 23.0 42.6 Price Increase Due to: Air Controls: 1 Water Controls: 1 Total:1 % Increase Over Base Price of 12d/H 0.194/lb 0.17 0.364/lb 3.0? 0.19 0.17 0.36 3.0% 0.32 0.17 0.49 4.1% includes control cost pass-on frem Hhylone dichloride plants. 7-56 COLORITE 008689 /.3.7.2 ;'r. The fol !.;.,if,g is a v mary c.` ... cruml c analysis of various control levels at a-'-: ar.d existi-; pcly/inyl chloride plants: 1. Typical new suspension process polyvinyl chloride plants are judged to be able to afford Case A (improved stripping) controls but unable to afford Case B (incineration) controls. The incremental capital requirements for a new suspension process plant with a capacity of 68 million kg/yr (150 million Ib/yr) are as follows: Incremental control Capital ($ Millions) Case A Case B Air Controls: 4.4 6.7 Water Controls: 1.3 1.3 Total: 5.7 8.0 % Increase Over Uncontrolled Plant Capital: 19% 27% The price increase required to maintain pre-control return on investment at the new suspension process plant is: Price Increase Air Controls:"' Water Controls:"' Total:' Case A 1.59*/1b 0.52 2.1U/lb Case B 4.74 0.52 5.25 % Increase Over Base Price is 2*k/lb 8.8% 21.9% 'incluk-s control c^-k pass-on fro a ethylene dichloride-vinyl chioride plant. 7-57 COLORITE 008690 The -;i,;po ; ' ':r AUerna ti ve I con^'o''- (strigp iiM to ^ :.0C0 ojires pa* rni 1 lien/ v.'uuld probably not be a deterrent. to the construction of raw dispersion process plants except possibly those of very snail capacities. The imposition of Alternative II, Case A controls (strip ping to 2,000 parts per million) would probably not be a deterrent to the construction of large new plants with capacities of 45 million kg/yr (100 million lb/yr) or more. The imposition of Alternative II, Case B controls (incineration) would probably be a serious deterrent to the construction of any new dispersion process polyvinyl chloride plants. The capital requirements for two sizes of new dispersion plants are as follows: Air Controls: Water Controls: Total: % Increase Over Uncontrolled Plant Capital: 14 Million kg/yr (30 Million lb/yr) Incremental Control Capital ($ Millions) Alt. I Alt. II Case A Alt. II Case B 2.3 3.4 5.3 0.2 0.2 0.2 2.5 3.6 5.5 15% 21% 33% Air Controls: Water Controls: Total: % Increase Over Uncontrolled Plant Capital: 45 Million kg/yr (100 Million lb/yr) Incremental Control Capital ($ Millions) Alt. I Alt. II Case A Alt. II Case B $2.8 4.8 12.3 ___ 0_.8__ 0.8 0.3 3.6 5.6 13.1 9% 14% 34% 7-53 COLORITE 008691 . ' 1 ' ' !* i - " J'l'J 0 1 { *LU: ' - . nvess- .. ;] level,, , v;j ?, iz of fi'JV: si on jic-'CS a; a as to. sovis: Air Controls:"* Water Controls:"* Total:1 % Increase Over Base Price of 34/lb H Million kg/yr (30 Million lfc/yr) Price Increase 'Alt. I Alt. II Case A Alt. i: Case B 3.4d/lb 5.41 17.58 0.40 0.40 0.40 3.74<t/l b 5.81 17.98 11. OX 17.0% 52.9% includes control cost pass-on from ethylene dichloride-vinyl chloride plants. Air Controls:1 i Water Controls: Total:1 % Increase Over Base Price of 34<j/lb 45 Million kg/yr (100 Million Ib/yr) Price Increase Alt. I Alt. II Case A Alt. II Case B 1.62%/lb 3.13 13.30 0.47 0.47 0.47 2.09<t/lb 3.60 13.77 6.2% 10.6% . 40.5% 1Includes control cost pass-on from ethylene dichloride-vinyl chloride plants. 7-59 COLORITE 008692 3, New bulk pro 35 plants woulu probac'i.y not be precluded ftot. constructicn by .::sr Case A controls (improved stripping) or Case B controls (incineration). The incremental capital requirements for new bulk process plant with a capacity of 45 million kg/'yr (ICO million lb/yr) are as follows: Incremental Control Capital (S Millions) Case A Case B Air Controls: $1.3 1.6 Water Controls: 0.8 0.8 Total: % Increase Over Uncontrolled Plant Capital $2.1 10% 2.4 12% The price increases required to maintain pre-control return on invest ment are as follows: Price Increase Case A Case B Air Controls: Water Controls:' Total % Increase Over Base Price of 24(t/lb 1.34<t/lb 0.50 1.84<t/lb 7.7% 2.02 0.50 2.52 10.5% "'includes cost pass-on from ethylene dichloride-vinyl chloride plants. 7-60 COLORITE 008693 bs'ir- -j'6 ! -tj" Co'ilrol ^csnaric -! ass' .t i.. ' tr a! ' c. spcrsi an pnc; ..3 P1 c,," ^ utilize Ale: '.,:;ve I cc^ Aro 1 5 rq `.c 3 0,u00 part-; cur rillicr) arid thal all sr plants will utilize Casa A controls (irpM.iveij stripping}. Control scenario #2 assumes that all dispersion process plants will utilise Alternative II, Case A controls (stripping to 2,000 parts per million) and that all other plants will use Case A controls (improved stripping). Control scenario #3 assumes that all dispersion plants will utilize Alternative II, Case B controls (incineration) and that all other plants will use Case A controls (improved stripping). Control scenario *4 assumes that all dispersion plants J11 use Alternative II, Case B controls (incineration) and that all other plants will use Case B controls (incineration). The economic impact of complying with the various control scenarios is summarized below: Control Scenario #1 #2 #3 |4 Estimated Plant Closures: % of Total Plants: 44 10% 10% 76 17% 15% % of Total Capacity: 0.5% 0.5% 4.7% 2.8% Estimated Job Losses: 30 30 250 150 Net Relative Change in Return on Investment After Price Increase: 1 Range: 9%-(57%) 13%-(50%) 40%-(74%) 81%- Industry Average: 0000 ''Excluding estimated closur 0 Ol i 1 \j Hi Q l.C'S. 7-51 COLORITE 008694 1 Percent Increase in Total Estimated Replacement Plant Capital: Range: 9ri-37% Industry Average: 10% Control Scenario n 7* 10-38% 20% 10-44% 24% 12-^5% 29% Total Industry Incremental Control Capital ($ Millions) Air Controls: Water Controls: Total: $167.4 48.3 215.7 183.0 48.3 231.3 225.6 48.3 273.9 293.3 48.3 341.6 Price Increase (d/lb) Due to Air Controls:1 Water Controls:1 Total:1 % Increase Over Base Industry Weighted Average Price of 25/lb Estimated Price Increase in Consumer Goods Estimated Impact of Price Increase on Substitution, Imports 1.63 0.52 2.15 8.6% 1.83 0.52 2.35 9.4% 3.04 0.52 3.56 14.2% 5.52 0.52 6.04 24.2% 1-4% 1-5% 1-7% 2.5-12% Negligible Negligible Moderate Substantial "'includes control cost pass-on from ethylene dichi oride-vinyl chloride plants. 7-62 COLOR!TG 008695 in the event that pH~.es "or polyvinyl chloride resir: could not be increased, it it -sol that 5 plants night choose c'osure over control if either control scenario "1 or control scer.a-ic m2 was implemented. These five plants account for approximately 1 percent of total industry capacity and are estimated to employ a total of ?0 people. If control scenario 43 was implemented without a price increase it is estimated that 13 plants might close. These 13 plants account for approximately 18 percent of total industry capacity and are estimated to employ a total of 1000 people. If control scenario #4 was implemented without a price increase it is estimated that 30 plants might close. These 30 plants account for approximately 53 per cent of total industry capacity and are estimated to employ a total of 3200 people. The impact upon the industry of current 0SHA regulations has been determined assuming that a) the cost for 0SHA controls can be approximated by the cost of the fugitive control package required by all EPA alternatives, and b) there are no 0SHA costs incremental to the EPA-generated costs. Given these assumptions it was determined that the 0SHA regulations would have the same impact on plant closures as either control scenario #1 or scenario #2, that is, four plants would be expected to close. The EPA requirements, then, would have no incremental effect on plant closures i-> the industry until the levels of control rep,anted by scenario 43 and sce^a-io 44 were attained. The above assumptions yield estimated 0SHA capital ^ecjirements of approxi mately 337 million of which $29 million would be re:--'"ad at polyvinyl chloride plants and $8 million would be required at -I'.yiene dichloridevinyl chloride plants. Estimated OSHA-required anr.-E''"ced costs would t-a 7-63 COLOR!TE 008696 $25 million of which $19 million would be required at polyvinyl chloride plants and $5 million would be required at ethylene dichloride-vinyl chloride plants. The price increase in polyvinyl chloride resins resulting from the above costs would be approximately 0.5^/lb, or 2.0 percent of the current average price of 25/lb. 7-64 COLOR!TE 008697 7 A REFERENCES 1. Stanford Research Institute, "Ethylene Dichloride", Chemical Economics Handbook, January 1372, p, 651.50318. 2. Stanford Research Institute, "Ethylene", Chemical Economics Handbook, February, 1975, pp. 648.5053Y-648.5054G. 3. In-Depth Study of Vinyl Chloride Production, Houdry Division of Air Products and Chemicals, December 6, 1974, p. PVC 6-11. 4. Stanford Research Institute, "Polyvinyl Chloride Resins", Chemical Economics Handbook, March, 1975, p. 580.1882M. 5. Stanford Research Institute, "Polyvinyl Chloride Resins", Chemical Economics Handbook, September 1973, p. 580.18820. 6...Foster D. Snell, Inc,, Economic Impact Studies of the Effects of Proposed OSHA Standards for Vinyl Chloride, September 27, 1974, pv III-3. 7. Stanford Research Institute, "Polyvinyl Chloride Resins:, Chemical Economics Handbook, March, 1975, pp. 580.1883 Y,Z. 8. Compiled from data submitted to EPA under Section 114 of the Clean Air Act. 9. Arthur D. Little, Inc., Vinyl Chloride Monomer Emissions from the Polyvinyl Chloride Processing Industries, May, 1975. (Draft Report to EPAf. 10. Foster D. Snell, Inc., op, cit., Exhibit III-14. 12. Foster D. Snell, Inc., op. cit., p. 111-3 and p. 111-8; Arthur D. Little, Inc. United States Polyvinyl Chloride Industry, Impact Analysis, August 1974, P- 1- 13. Chemical Marketing Reporter, July 14, 1975. ; 14. Hydrocarbon Processing, May, 1974, p. 83. 15. Stanford Research Institute, op. cit., pp. 580.1883V-580.1883W. [ f i ..... 16. ibid. 17. ibid. 7-65 COLORITE 008698 I able 7-1 Vertical Integration in the EDC/VCM/PVC Industry Company Air Products Allied Chemical B. F. Goodrich Borden Continental Oil Diamond Shamrock Dow Chemical Ethyl Corporation Firestone General Tire Georgia-Pacific Goodyear Great American Chemical Jennat Keysor-Century Monochem, Inc. Monsanto Occidental Petroleum Pantasote Company PPG Industries Robintech, Inc. Shell Oil Co. Plant Capacities (Millions of Kilograms/Yr) EDC VCM PVC 0 0 95 295 155 0 455 455 400 0 0 145 455 330 220 120 0 170 1 ,615 555 45 370 190 80 0 0 180 0 0 230 0 0 100 0 0 95 0 0 30 00 7 0 0 15 0 135 0 0 0 30 0 0 82 0 0 35 835 360 0 0 1 ,075 6 730 165 0 7-65 COLORITE 008699 Company Shi?!i7-Ch Stauffer Ch Tenneco Chemicals, Inc. Union Carbide Uniroyal Inc. Vulcan TOTALS: 5,605 75 115 0 0 0 0f KlJogrims/y PVC 50 150 215 Iso 50 2,609 COLORITE 008700 Table 7-2 1974 PVC Consumption by End-Use Category Mi 11ions of Kiloqrams Ti Tot. Apparel 104 5 Building and Construction 851 39 Home Furnishings 223 10 Recreation 130 6 Electrical 161 7 Packaging 147 7 Transportation 116 5 Miscellaneous 184 8 Exports 145 7 Other 119 5 2,180 100 SOURCE: Modern Plastics, January 1975, p. 51. 7-63 COLORITE 008701 OS $ i 0 i 0 ' ' . 1.41 1 - ' i . . C,' t. Arnnrel Baby pants lootvear Outcrv. :sr Building and construction Extruded foam moldings Flooring Lighting Panels and siding Pipe and conduit Pipe fittings Rainwater systems Swimming pool liners Westherstripping Window, other profiles Electrical Wire and cable Home Furnishing Appliances Furniture Garden Hose Housewares Wall coverings & wood surfacing film Packaging Blow molded dottles Closure liners and gaskets Coatings Film Sheet Recreation Records Sporting goods Toys Transportation Auto mats Auto tcps Upholsy and seat covets : i l;utes , /C Resin Usage `li ill c /is of Kilograms 1S73 1974 12 12 66 63 31 30 26 22 202 156 56 39 44 320 505 41 44 16 IF 18 19 16 16 26 24 188 161 20 21 145 144 18 17 51 N.A. 54 58 Possible ^ Substi tubes'1 Rubber Rubber Other synthetic fibers Wood Wood Glass, styrene Wood, polyester Steel, ABS, polyethelene Steel, ABS, polyethelene Wood, aluminum Rubber Rubber, urethane Wood,steel, aluminum Rubber, polyethylene Other plastics in some applications Wood, melamine Rubber, nylon Styrene, rubber Paper, melamine 39 34 9 10 99 59 57 35 37 66 65 25 28 38 37 18 19 15 13 3 84 Glass, cans Rubber None Acrylics, styrene Polyethylene, nylon polyester None Rubber, leather None Ruboer Steel Nylon, polyesters 7-69 COLOR!TE 008702 Market Miscellaneous Agriculture (including pipe) Credit cards Laminates Medical tubing Novelties Stationery supplies Tools and hardware Export Other TOTAL PVC Resin Usage Millions of Kilograms 66 72 8 10 23 24 23 23 78 18 20 8 10 66 145 42 119 Possible j Substitutes^ ... ._ Aluminum, polyethyl None None None None Polyester None None None 2,180 2 ,151 SOURCES: 1) Modern Plastics, January 1974, p. 51 2) Discussions with industry representatives. 7-70 COLORITE 008703 T; hi e_ 7_-4 Jliiicad PYC Can-nJiy Expansions aid Closures <:/ Loca tj_on_ Expansions to Existing Facilities: rode;1 IlViopolis, Illinois Diamond Shamrock Deer Park, Texas Goodyear Plaqucmine, Louisiana Stauffer Delaware City, Delaware Air Products Calvert City, Kentucky B. F. Goodrich Louisville, Kentucky Capacity Increase (Millions of Kiloqrams) 90 90 45 5 115 N.A. TOTAL EXPANSIONS New Facilities Certain-teed Rico Chemicals Lake Charles, Louisiana Guayanilla, Puerto Rico 345 135 70 TOTAL NEW FACILITIES 205 Closures Monsanto Springfield, Massachusetts 30 NET CAPACITY ADDITIONS (Expansions Plus New Facilities Less Closures) 520 SOURCES: Chemical Marketing Reporter, Schnell Publishing Co., May 20, 1974, page 9 'and page 18, non-confidential data supplied by industry under Section 114 of the Clean Air Act; and Chemical Engineering, September 30, 1974, page 112. 7-/1 COLORITE 008704 Table 7-5 Prices of Ethylene Dichloride, Vinyl Chloride and Polyvinyl Chloride Product 1974 May 13 1974 July 8 1974 1975 October 21 June 23 Ethylene Dichloride 9<f/lb 9.5</lb 9.5tf/lb ll-12d/lb Vinyl Chloride 7-lOd/lb 7-loe/lb 9-12d/lb 9-12<t/lb Polyvinyl Chloride Homopolymer Suspension Dispersion 17-22.54/lb 20-24<t/lb 22-25<t/lb 24-28^/1b 30d/lb 30-33d/lb 32-34d/lb 34-37<f/lb Copolymer Suspension 19-24.5d/lb 20-26^/1b 24-26tf/lb 24-26<t/lb SOURCE: Chemical Marketing Reporter, Schnell Publishing Company, various issues. 7-72 COLORITE 008705 Table 7-6. Summary of Algorithms Used for Computing Model Plant Costs and Credits rl ,b Control Method Expected Installed Capital Direct Operating Annualized Capital Tr, 1 Anri,.-.1 Process Point(s) Controlled Life (Years) Cost AlgorithmCost Aigori thruCharge Algorithm' Cr. . 'i ..... . 1. fugitive a. Multi-Point Vinyl Chloride Detector Fugitive emissions at VCM 4 Id C-$60,000 (constant) 0C=$26,400 (constant) ACC=d.lrSOBC PVC plants for all VCM plants; for all VCM plants; $150,000 (constant) $66,000 (constant) for all PVC plants for all PVC plants t. Portable Hydrocarbon Fugitive emissions at VCM 4 10 C-$7,000 (constant) 0C=$25,700 (constant) ACC=0.1H7fiC Detector PVC plants for all VCM 4 PVC for all VCM & PVC plants plants c. Sample Flask Con trol System ! CO Fugitive emissions at VCM & 12 C=$l 50 ,000 (constant) 0C-$63,OOO (constant) ACC-0.171 EC -PVC plants for al1 VCM plants for all VCM plants (cost for six (cost for six systems) systems) $25,000 (constant) $10,500 (constant) for all PVC plants for all PVC plants d. Transfer Operation Controls Fugitive emissions at VCM 4 12 C=$60,000 (constant) OC-$161,7O0 (constant) ACC-0.1718C PVC plants for all VCM and PVC for all VCM and PVC plants plants e. Pupture Discs Fugitive emissions at VCM 4 10 C=$353P+S5,890 0C=0.15C PVC plants (for PVC plants) ACC-0,187CC C'182,000 0C=$12,400 (for all VCM plants) (for all VCM plants) f. Dual Mechanical Seals Fugitive emissions in VCM 4 20 C*$91,000 (constant) 0C=$31,700 (constant) ACC-0.1425C (on Pumps, Compressors, PVC plants for all VCM plants for all VCM plants and Agitators) C=$2 ,150P+$46,500 OC-$277Pr$16,200 ACC-0.1425C (for PVC plants) (for PVC plants) 1) - i T/l tac-cog.i TAl>0'>0.17'rr T/ir=CC rfl .1 7CC TAC-CC+0.142SC T AC-CC+0.1425C COLOR!TE 008706 Table 7-6 Summary of Algorithms Used for Computing Hodel Plant Costs and Credits'a ,b Cortrol Method Expected Installed Capital Direct Operating ______ Process Point(s) Controlled life (Tears) Cost AlgorithmCost Algorl thm Annualized Capital Total >"-or ;.11 , d Charge Mgonthnr Cost A_ly ' tnv_ g. Collection Header System h. V.1 :..r Stripping Fugitive emissions at VCM t PVC plants Inprocess waste water streams from PVC plants 12 20 i. Monomer Recovery Credit Attributable to Fugitive Control Methods --CJ C=$84,200 (for all PVC and VCM plants) C = $2 ,700P*59 (Susp. , Dlsp.Partial) C-$10,Ba0P0'56 (Susp. , Disp.Tota1) o go c*$i .nopu-ba (Bulk) 0C=$31 ,400 (for all PVC and VCM plants) ACC=0.171SC 0C=S6 .240+T0.05C+ $304P (Susp., Disp.Partial) ACC-0.1425C OC=t6,240+$0.05C+ $3,910P (Susp., Disp.Total) OC=$6,240+J0.05C+$32P (Bulk) 0C=($109.3P)d (VCM plants) 0C=($l,350P)d (Susp. PVC plants) 0C=($1 ,020P)d (Disp. PVC pi ants) 0C=($432P)d (Bulk PVC plants) TAC=CiC r 0. !71rC TAC=0:i0.1J25C Z. Improved Reactor Instrumentation Relief valve discharge on-PVC reactors 10 C-$2 ,400P 0C=$240P ACC=0.1S7SC TAC=OC+0.187EC 3, Automatic ShortStepping >1. ',yi, Slurr> Blend Tanks 5.a. Gasholder Relief valve discharge on PVC reactors Slurry blend tanks in PVC plants Reactor opening and relief valve discharge in PVC plants 10 C-$3,000N 10 C=$280,000(1 20 C$2.510VR0,73 0C=$150K oc=o 0C*tl0.6VR ACC=0.1B78C ACC=0.1878C ACC=0.1425C TAC=OC+0.187SC TAC^OC+O.187 EC TAC=OC+C.142;C COLORITE 008707 COLORITE 008708 Control ' thod b. Reactor Water Purge System 6, Improved Stripping 7. Carbor Adsorption 8. Incineration VJ S<JI1 Table 7-6. Summary of Algorithms Used for Computing Model Plant Costs and Credits'1'13 Expected Installed Capital Process Point(s) Controlled Life (Years) Cost Algorithm Reactor opening and relief valve discharge In PVC plants C=$219[NVr]0-6 Slurry blend tanks, spray or rotary dryers, and bulk storage and transfer operations in PVC pi ants 20 C=$101 ,600P0'53 (Susp. plants) c^m.GOop0,53 (Dlsp, plants) C=$5 ,090P*53 (Bulk plants) Direct Operating Cost Algorithm OC=53,120+50.06C+ $0.104[NVR] Annualiaed Cap i tai To L 11 11 | , L i i Charge Algorithir Cott t'r' 0C=$S2 ,600+50.19C+ ACC=0,1425C $1 ,450P (Susp. plants) T,'7>0'>rA' ;^c 0C=$52,600+$0.19C+ $11 ,400P (Disp. plants) OC^SB.OOOP (Bulk plants) Monomer recovery system in dispersion and suspension PVC plants 10 C=5333,QQ0(con- $20,300(constant) ACC-0.1S7EC stant) for al 1 for al1 PVC plants PVC plants TAC^oc+o.idrcr EDO purification and VCM for mation and purification, (only) in VCM plants EDC purlflcation, VCM forma tion and purification, and oxychlorination process in VCM plants Slurry blend tanks, centrifuge, monomer recovery system, dryer and bulk storage and transfer operations in suspension PVC plants 10 10 10 C=$355,000(constant) for al1 VCM plants C=j524,300V1n0,53 0C=S81,000+$398P ACC=0.187:C OC'563,200+50.05C+ 5443P+549,300Vjn ACC-0.1 -97 PC C*$101 ,100P06 (for 22<P<40) C=$33 ,700PoU'g3 (forP>40) 0C=$67,310P`74 ACC=O.1078C 1AC--0L+3.1 7E t V.r-rr.'). i^'EC Tf coc+o.^r; re Table 7-6. Summary of Algorithms Jsed for Computing Model Plant Costs and Credits a ,b Control Methods Expected Process Point (s) Controlled Life (Years) Slurry blend tanks, monomer recovery system, spray dryer, and bulk storage and transfer operations in dispersion PVC plants 10 Monomer recovery system and product transfer operations in bulk plants 10 Installed Capital ,,Cost Algorithm C=$2 65, GOOP0.6 (for 4,5<P'7.9) C=|142,400P0,9 (for P>7.9MM Ib/yr) C=$l07 ,200P0'4 (38<P<92) C*$43 ,EOOP.0.6 (92 <P <162) C=$9,390P0,9 P>162 9. Monomer Recovery Credit Attributable to Mon-Fugitive Control Methods: Direct Operating Cost Algorithm 0C=$2B5,100P 0.74 OC=S30,600P 0.74 0C=(J2,378P) (Susp. PVC plants} Annualited Capital Total Annual 1 red Charge Algorithm1* Cost ft I g or I thir ACC=0.1678C TAC=0C+0.1876C ACC-0.1878C TAC-OC >0.1678C 0C=($2,122P) (Disp. PVC plants} 0C=(SI,879P) (Eulk PVC plants) COLOR!TE 008709 CTi r (Table 7-6 continued) ?Refer to nomenclature for item(s) represented by symbol (s). "All costs i,'e expressed In 1st quarter 1975 dollars. ^Annualized capital charge is computed by multiplying sum of capital recovery factor (CRF) and administrative charge (0.025) by installed capital cost (r\ "Parentheses indicate that value is a credit, rather than a cost. Nomenclature C = installed capital cost CC - direct operating cost , P = '/CM or PVC production rate in 10 Ib/yr ACC = anncal'ved capital charge TAC = total annualired cost or simply "annual cost" = volui e of Pl'C reactor in gallons Nk = nuriujr of reactor lines; N= I to*- production rates up to 50 xlO^lb/yr (inclusive) N'Z for production rates above 50 xlO^lb/yr and up to (but not including) IGOxlO^lb/yr N = 3 for production rates equal to or greater than 100xU)U>/yr Vijn - incinerator inlet volumetric flowrate in thousand SCFM, COLORITE 008710 Table 7-7. Control Costs^ for Model Balanced EDC-VCM Plant (318 Mil Hon kg/yr = 700 Minion lb/yr) Process Emission Points 1, Fugitive 2. EDO Purlflcatlon 3. VCM Formation and Purification 4. Oxychlorination TOTAL3 Annual Cost^ Percentage Emission Reduction (By Weight) Control Techniques ALTERNATIVE I Installed Capital Cost (See Table 7- 11) *534 Incineration *355 Total Annualized Cost $366 $427 Control Techniques ALTERNATIVE ITT2 Installed Capital Cost (Same as Alt, I) $534 Incineration $1 .369 Total Annualized Cost $366 SI,291 Incineration Ho Control (Incl. Above) 0 (Incl. Above) Incineration 0 Incineration (Incl . Above) (Incl . Above) (Incl. Above) (Incl. Above) *889 $793 0.24t/kg [0.114/lb] *1 .903 $1,F57 0.53<t/kq [0.24i/1 b] 90 97 JaII costs In thousands of 1st quarter 1975 dollars ^Costs to meet the Alternative II control level have not been Included here (see text for explanation) ^Totals are rounded to the nearest thousand dollars ''Based on production at 100 percent capacity COLORITE 0087X1 1 r' Table 7-8. Control Costs^ for Model PVC Suspension Plants (6B M111I on kq/yr = 150 Million Ib/yr) Process Emission Points Control Techniques 1. Fugitive (See Table 7-12} l . Relief Val,e Discharge Improved Reactor Instrumentation Automated "Short-Stopping" of Reactions 3. Relief Valve Discharge, Reactor Opening Gasholder Reactor Water Purge System 4. Slurry Blend Tank and Centrifuge {Incl. with Dryer) 5. Monomer Recovery System Carbon Adsorption 6. Dryer Improved Stripping Operation 7. Bulk Storage and Transfer Improved Stripping Operation Credit for Recovered Monomer CASE A Installed Capital Cost 1806 $360 Total Annual 1 ted Cost $340 $104 $ 54 $ 13 $1,257 $206 $232 $ 54 $333 $1,446 $ 83 $753 (Incl. Above) (Incl, Above) -- ($357)4 Control Techniques (See Table 7-12) (Same as Case A) (Same as Case A) CASE B Installed Capital Cost $933 $360 Total ftnnur! 1 ^ ?ed Cost 1905 $104 $ 54 < 13 (Same as Case A) $1 .257 $206 $232 $ New Slurry Blend Tanks'1 incineration Incineration $840 $158 $3,064 $4,134 (Incl. Above) (Incl. Above) Incineration (Incl. Above) (Incl, Above) -- ($103)4 Total Annual Cost Overall Control Efficiency (Percent ty Welgnt) $4,462 95 $1,222 l.M/kg [O.BU/lb] $6,714 95 $5,497 B.U/kg F3.7C, COLOR!TE 008712 (Table 7-8 continued} costs in thousands of 1st quarter 1975 dollars. Slurry blond tank emissions are controlled by Incineration, as are emission points 5, 6, and 7. Installation of new. higher pressure blend ttanks is also necessary before the emissions car be vented to any add-on control device. 'Does not include monomer recovery credit attributable to most fugitive emission controls (see Table 7-19). Recovery credit for all fugitive ^controls except water stripping has been incorporated Into the fugitive total annualized cost. -Parentheses indicate number Is a credit, rather than a cost. ^Totals are rounded to the nearest thousand dollars. "Based on production at 100 percent capacity. O COLOR!TE 008713 9 Table 7-9. Control Costs1 for Model PVC Dispersion Plants (14 Million kq/yr = 30 Million tb/yr) Process f-.isstcm Points Control Techniques ALTERNATIVE I2 Installed Total Capital Annualized Cost Cost ALTERNATIVE II, CASE A3 Control Techniques Installed Cap11 a 1 Cost Total Annualized Cost ALTERNATIVE 1!, CASE r/'^ Control Techniques Installrd Total C ar. >ti. 1 AnnU`'l 'i 'JC-rl 1. F u g 11 i so 2. Relief Val.e Oi sd'jrge 3. Relief Vn' ,e Discharge, Reactor Opening 4. Slurry Blond Tank (See Table 7-13) $535 Improved Reactor Instrumentation $ 80 Automated "ShortStopping" of Reactions t 12 Gasholder $1.257 Reactor Water Purge System $ 78 None 6, Monomer Recovery System 6. Spray Cry or Carbon Adsorption None $333 .- 7. Bulk Storage and Transfer None Credit for Recovered Monomer^ .. -- $506 $ 23 $3 (See Table 7-13) (Same as Alt. 1) $481 $ 80 (Same as Alt. I) $ 12 $387 $ 23 $3 (See Table 7-11, (Same as A1t. !) (Same as A1t. I) !6`5 S 80 SI? ; ,Ca b r- CO $232 $ 21 (Same as Alt. I) $1,257 (Same as Alt. 1) - $ 78 -- (Incl. With Dryer) -- $ 83 (Same as Alt. I) $333 .. .. ($ 64)8 Improved Slurry $1,078 Stripping Opera tion Improved Slurry Stripping Opera tion (Incl. Above) - $232 $ 21 (Seme as A1t, I1 (Same as Alt. 1) <!.? / $ 7f $ .1 -$ 83 New Slurry Blend Tanks6 Incineration $280 ; 52 S3,245 s-Y-O- $754 Incineration (Inc' (Incl. Tbovo,1 f-hove) (Incl. Above) Incineration ($140)8 (!nc!. (Incl . Z'-bC'Vp) : L 0 VO ) (t 49)8 TOTAL9 Annu.il Costi1n0 0vero 11 Control Efficiency (Perce" t by l.'ei ght) $2,295 $803 5.94/kg [2.74/16] 52 $3,319 $1,363 9.94/kg [4.54/lb] 96 $5,287 $4,292 35.SPY [1C.3 Or COLORITE 008714 (Table 7-9 continued) Iaii costs In thousands of 1st quarter 1975 dollars. Corresponds to Alternative I in Chapter 5 (stripping to approximately 30,000 PPM). Corresponds to Alternative II in Chapter 5 (stripping to 2000 PPM). Corresponds to Alternative II in Chapter 5 if Incineration must be used. Costs for meeting Alternative II! control levels [stripping to 400 Pm) are not Included In this table, because no such information is ,presently available (see text). "Slurry blend tank emissions are controlled by incineration, as are emission points 5, 6, and 7. Installation of new, higher pressure blend ,tanks is also necessary before the emissions can be vented to any add-on control devices. Coes rot include monomer recovery credit attributable to fugitive emission controls (see Table 7-13). Recovery credit for all fugitive controls, ^except water stripping. has been incorporated into the fugitive total annualized cost, jlotals are rounded to the nearest thousand dollars. Based on production at 100 percent capacity. CO (S3 COLORITE 008715 Tabic 7-10. Control Costs^for Model PVC Bulk Plants (45 Million kg/yr - 100 Million Ib/.yr) Process [miss ion Points 1. fugitive Control Techniques (See Table 7-14) 2. 1 f 1 ief Val ve ill scnai cjs Improved Reactor Instrumentation Automated "ShortStopping" of Reactions 3. Monomer Recovery System Carbon Adsorption 4. Product Transfer Improved Stripping ? 7V Credit for Recovered Monomer CO Total^ Annual Cost5 Overall Control efficiency {Percent ty Height) CASE A Installed Capital Cost $645 $240 Total Annualized Cost $414 $ 69 $ 36 $9 Control Techniques (Same as Case A) (Same as Case A) (Same as Case A) CASE B Installed Capital Cost $645 $240 T ntal Annualized CtJE.t $414 $ 69 $ 36 $9 $333 $ 58 - $ 83 $508 ($iaa)3 Incineration Incineration $1 ,312 $895 2.04/kg [0.90<t/lb] 96 $685 $1,053 (Incl. Above) (Incl. Above) -- ($ 19)3 $1,606 $1,526 3.4t/kg [l.Si/lb] 96 IaII costs in thousands of 1st quarter 1975 dollars. ^Does not Include monomer recovery credit attributable to most fugitive emission controls {see Table 7-14). Recovery credit for all fugitive -controls, except water stripping, has been incorporated Into the fugitive total annualized cost. ^Parentheses Indicate number is a credit, rather than a cost. -Totals are rounded to the nearest thousand dollars. sBased on production at 100 percent capacity. COLORITE 008716 Table 7- 11. Surrmary of Fugitive Emission Control Costs for Balanced Ethylene DIchlorlde-VInyl Chloride Model Plant (Production Rate = 318 Mill ion kg/yr = 700 Million lb/yr) Control Measure Installed Cost9 Annual Direct Operating Cost Annualized , Capital Charqes0 Total Annualized Cost0 1. Multi-Point Vinyl Chloride Detector $60,000 $26,400 $ 9,600 $36,000 2. Portable Hydrocarbon Detector 6,700 25,700 1,300 27,000 3. Sample Flask Control Systems 150,000 63,000 25,800 88,800 4. Transfer Operation Controls 60,000 161,700 10,300 172,000 5. Collection Header Sys'eem0 84,200 31,400 14,500 45,900 6. Rupture Discs 82,500 12,400 15,500 27,900 7. Dual Mechanical Seals 91,000 {on Pumps & Compressors) Monomer Recovery Credit (Items 1 through 7) -- 31,700 (76,500)e *f 13,000 -- 44,700 (76,500)e,f COLORITE 008717 TOTALS (Rounded to nearest thousand $) $534,000 $276,000 $90,000 $366 ,000 9r (Tabic 7-','; continued) fAll costs computed as of 1st quarter 1975. ., `ncludf-s: depreciation, interest, and administrative charges (taxes, insurance, ovarnead). cYSvj "cGoai annuall2ed cost" equals the sum of "annual direct operating cost" and "annualized capital charges Yo^-jxs of piping necessary to connect equipment undergoing maintenance or inspection to either tho monomer .recovery system or to an add-on control device. ^Parentheses Indicate a credit, not a cost. ., fB-y definition, control measures 1 through 7, taken together, reduce all fugitive emissions_by D&f, octets i plant emission by 2435. This results in a recovery credit of 0.1093 kg VCM/100 kg product in VCM model plant COLORXTE 008718 7-12. Summary of Fugitive Einiss lontrol Costs for Suspension nlcrace Model Plant (Production Rate = 60 Million kg/yr = 15Q Million lb/yr) Control Measure Installed Cost3 1. Multi-Point Vinyl Chloride Detector $150,000 2. Portable Hydrocarbon Detector 3. Sample Flask Control Systems 6,700 25,000 4. Transfer Operation Controls 60,000 5. Collection Header Sy .tom 84,200 6. Rupture Discs 58,900 7. Dual Mechanical Seals 369,100 (on Pumps, Compressors > and Agitators) Monomer Recovery Credit (Items 1 through 7) -- 8. Water Stripping (Partialr 51,700 Annual Direct Operating Cost $66,000 25,700 10,500 161,700 31,400 8,800 57,800 {202,500)e'2 54,500 CASE A TOTALS (Rounded to nearest thousand $) 8A. Water Stripping (Total Plants CASS 8 TOTALS5 (Rounded to nearest ousand $) $806,000 179,400 $933,000 $214,000 601,200 $761 ,000 - Annualized , Capital Charges0 $24,100 1,300 4,300 10,300 14,500 11,100 52,600 -- 7,400 $126,000 25,700 $144,000 "r rn - Total Annualize* Costc $9C ,100 27,000 14,800 172,000 45,900 19,900 110,400 (202,500)2 61,900 $340,000 626,900 $905,000 COLORITE 008719 1 (Table 7-12 continued) 'See Table 7-11 for all alphabetical footnotes. z3y definition, control measures 1 through 7, taken together, reduce all fugitive emissions by 901, or total plant emissions by 34%. This results in a recovery credit of 1.35 kg VCK/130 kg product in the suspension model plant. The credits attributable to water stripping have been incorporated 0into the credit listed in Table 7-3. This pertains to stripping of water streams from: recycle tanks, pump seals, and reactor water .purge system. This pertains to stripping of all water streams included in item 8 plus all other water streams -in the plant. "'Case 3 total costs are the sum of costs for items 1 through 7 plus item 8A. COLOR!TE 008720 V- vi . Summary of Fugitive Enussi ^^ontrol Co Tae'.e 7-13. s Is for Hi spersion iloride Modal Plant (Production Capacity - 14 Million kg/yr = 30 Million Ib/.yr}'1 v.or. i r'u i i" co $ure Installed Cost9 Annual Direct Operating Cost Annualized , Capital Charges0 Total Annual iced Costc 1. Multi-Point Vinyl Chloride Detector $150,000 $66,000 $24,100 $90 ,100 2, Pcrtaole Hydro carbon Detector 6,700 25,700 1,300 27,000 3. Sample Flask Control Systems 25,000 10,500 4,300 14,800 4. Transfer Operation Controls 60,000 161 ,700 10,300 172,000 5. Collection Header System 1jO 3G 6. Rapture Discs 84,200 17,700 31 ,400 2,700 14,500 3,300 45,900 6,000 7. Dial Mechanical Seals 118,200 lor, Rums, Compressors, and Agitators) Monoror Recovery Credit {Items 1 through 7) -- 25,400 (30,600)e'2 16,800 -- 42,200 (30 ,600 )e 8. Hater Stripping (Partial) 19,500 16,400 2,900 19,300 COLORXTE 008721 ALTERNATIVE li, CASE A 10iALS (rounded to nearest thousand $} 8A. Water Strippin. g 4 (Total Plant) ALTERNATIVE I AND ALTERNATIVE I-, QpE B TOTALS'1 $481,000 72,800 $535,000 $309,000 127,300 $420,000 $78,000 10,400 $85,000 $387,000 137,700 $505,000 0*3 0' - 7-13 continued) 2[b? vee i alO: l 7t-i1l1 dGi'iniJ-1on. fiio7ir aalill control aa l*pphuuaubbe(<tiivcuali footnotes. measures 1 through 7, taken together, reduce all fugitive emissions i oy r,rs 90' , or total plant emissions by 17%. This results in a recovery credit of 1.02 kg VCM/100 kg product [he dispersion model plant. The credits attributable to water stripping have been incorporated ma. .credit 1 .sted in Table 7-9. "This pertains to stripping of water streams from: recycle tarks, pump seals, and the reactor wa ter ,uroe system. . ,,, 'T'nis pertains to stripping of all water streams included in item 8 plus all other water streams `^Alternative I and Alternative II, Case B total costs are the sum of costs for items 1 through 7 ;>. u item 8A. Since Alternative I includes neither "improved slurry stripping" nor "incineration" to itr. it is assumed that all water streams in the plant would need to be stripped. COLORITE 008722 -r- :' t.1 rr>T,ni'n yp^wiMtfussas 1 0 i d 7 -14. Summary of Fugitive tu , Control costs ior uuik /o'iWi.r/': Chloride Medel Plant (Product ion Capacity = 45 Million kb/yr = 100 Million lb/yr)1 V/Gtvcro i i icQSifrG Installed Cost3 Annual Direct Operating Cost Annualized , Capital Charges0 Total Annualized Costc 1. Multi-Point Vinyl Chloride Detector $150,000 $66,000 $24,100 $90,100 2. Portable Hydro carbon Detector 6,700 25,700 1,300 27,000 3. Sample Flask Control Systems 25,000 10,500 4,300 14,800 4, Transfer Operation Controls 60,000 161,700 10,300 172,000 5. Collection Header System0 84,200 31 ,400 14,500 45,900 6. Rupture Discs 41,200 6,200 7,700 13,900 7. Dual Mschanical Seals (on Pumps, Compressors and Agitators) 3 8. Water Stripping Monomer Recovery Credit (Items 1 through 7) 61,500 15,900 -- 43,900 10,300 (43,200)e*2 37,300 2,300 ----- 81,200 12,600 (43,200)e*2 TOTALS (rounded to nearest thousand $) $645,000 $312,000 $102,000 $414,000 COLOR!TE 008723 '- r 7~ i4 continued) T..ble 7-11 for ail alphabetical footnotes. Cu <S> L2y dev'nit ion, control measures 1 through 7, taken together, reduce all fugitive c--... s giant emissions by 13%. This results in a recovery credit of 0.432 kg VCM/100 kg pro model plant. The credit attributable to water stripping has been incorporated into the credit lieu 31f.ahbisle 7-10. pertains to stripping of pump seal water, only. COLORITE 008724 iable 7-15, Cost-Effectiveness of Alternative Vinyl Chloride Control Methods Emission Source Model EDC-VCM Plant 1. Fuqi ti 'a. 2. tDC Fir,linin' , VCM Finishing anc Purification 3. Oxychlorination Process Total Captured Emissions (Thousand Ib/.yr) 765 2030 0 Total Alternative I (EDC-VCM) i > NJt 1. Fugitive 2. EDC rim's ring, VCM Finisring and Purification 3. Oxychlorination Process 2795 765 2030 237 Total Alternative III (EDC-VCM) Model PVC Plant (Suspension) 1. Fugitive uxcl. Water Stripping) 2, Relief Valve Discharge, Reactor Opening 3. Monomer Recovery System 4. Slurry Tank, Centrifuge, Dryer, Bulk Storage and Transfer 5, Water Stripping 3032 2025 989 718 1815 69 Total Case A (PVC) 5616 Total CE ? Annualized Ratio*1 Cost (e/lb VCM) (Thousand $/yr) Removed) Relationship to CE - Most Cost Effective Ranr__________ Option________ 366 407 0 793 366 427 864 1657 0.48 0.21 N.A. 0.28 0.48 0.21 3.65 0.55 6 3 N.A. N.A. 6 3 9 N.A. 24:1 11:1 N.A. N.A. 24:1 11:1 183:1 N.A. 278 306 11 572 55 1222 0.14 0.31 0.02 0.32 0.80 022 2 4 1 5 7 4 7:1 16:1 1:1 16:1 40:1 11:1 COLORITE 008725 @ fable_7jJ_6.__ ERA Water Effluent Regulations - Compliance Costs for EDC, VCM, and PVC Plants to Meet the 1983 (Best Available Technology) Requirements* 1. Calculation of cost pass-through from EDC plants to VCM plants: A. Capital required to meet BAT B. 15% before-tax profit {15%xA) C. Annualized cost to meet BAT D. Total annual recovery (B+C) E. Model plant capacity (Ib/yr EDC) F. Unit cost pass-through (D t E) $661,618 99,243 132,312 231,555 684,000,000 0.034*/lb EDC Calculation of costs incurred at VCM plants: A. Capital required to meet BAT B. Annualized costs to meet BAT C. EDC cost pass-through (1.58#EDC/#VCM) D. Total annual cost to meet BAT (B+C) E. Model plant capacity (lb VCM/yr) F. Unit cost (D * E) G. Unit capital requirement (A * E) $1,179,753 235,929 188,020 433,949 350,000,000 0.12<t/lb VCM 0.34$/lb VCM/yr 3. Calculation of costs incurred at PVC plants: A. Capital required to meet BAT B. Annualized costs to meet BAT C. Model plant capacity (lb PVC/yr) D. Unit cost (B * C) E. Unit capital requirement (A C) $1,262,086 272,331 150,000,000 0.18*/lb PVC 0.84*/lb PVC/yr SOURCE; Control costs developed from material supplied by EPA's Effluent Guidelines Division. *1983 BAT requirements are identical to New Source Effluent Standards. \ ft ... l i l i 7 7-94 COLORITE 008726 f f Table 7-17. Existing EDC Plants - Capital Summary Alternative I or Alternative II Jlarr; jwner/Locatlon V '. , Gnomical/Bacon Rouge r. Gcocirich/Caivcrt City rtinenr.al Oil/Lake Charles : none! Shamroci-./Deer Park iv Char a 1/Freeport w Chun' cal/Cys ter Creek i Che;,in cal / PIacuemine hyl Cc=rp./Baton Rouge r.-'l Corp./Hosjjton t./^ucyani 11 j/Lace Charles el 1/C. 'r Par!; e; l/ivorco 'E C r'l C c T !j 'l 'vf / ! `C ten Corbide/Texas City 1 ean/Goismar Capacity (Million lb/yr) 650 1000 1000 260 1300 1100 1160 550 260 835 1000 1200 1155 150 150 240 12,320 ,Estimated Qapi tal Requi yeinent Air1 Water" Total $(000) $(003) $(000) C/Ib/yr $355 355 355 355 355 355 355 355 355 355 355 355 355., O0 '3 355 $629 957 967 251 1257 1064 1122 532 251 808 967 1161 1127 145 145 232 ?9C`1322 1322 6C6 1612 1 <'- 19 1477 887 606 1163 1322 1616 Utf nag 14b 537 i'1 , ', . -i C. 1 3 0.2a 0.1 2 0.13 o.: ' 0.16 0.2 3 0.1' 0.1 3 * 1. lJ . ' 0.10 0. i o 0.2^ $5,120 $11 ,915 $17,035 n,ij COLOR!TE 008727 `includes only ,incineration of the EDC purification process emission point. Costs derived from Table 7-G except fcr - Stauffer Chemical/Long Beach for which actual costs were available. Affluent costs based on data presented in Table 7-16. "'Assuited co require no air emission controls. - Table 7-18. Existing EDC Plants - Annualecl Cost Summary Alternative I or Alternative II Plant 0\,rer/Location Capacity (Million Ib/.yr) Allied Chemical/Baton Rouge E. F. f.oodrich/Calvert City Contlne.Wdl Oil/Lake Charles Diamond Shunrock/Deer Park Cow Chemical/Freeport Dow Chemical/Oyster Creek Dow Chemical/PIaquemlne Ethyl Cor,;./Baton Rouge Eery! Coro./Houston PPG/Cuayani1 la OCrt PPG/i.ake Charles Shell/Deer Park Shell/Were' Staurfcr/u..: j 3eacr, Union Carbioe/Taft Union Carbide/Texas City Vulcan/Geismar 650 1000 1000 260 1300 1100 1160 550 260 835 1000 1200 1165 300 150 150 240 12,320 Air* $(G00)/yr $283 546 438 285 220 427 283 255 208 347 267 506 427 177, 03 274 $4,943 Water'1 $(0Q0)/yr $126 193 193 50 251 213 224 106 50 162 193 23? 225 58 29 29 46 $2,380 Total Annualizee 7 c $(000)/yr 4/lb 2 Ca; $409 739 631 335 471 640 507 361 258 509 460 738 652 235 29 29 320 O.OC 0 . in f '1 V C. 04 0.06 0.04 0.27 0,1 G :. 06 0.03 C . 02 0.02 0.13 $7,323 0.06 'includes only incineration of the EDC purification process emission point. -Stauffer Chemical/Long Beach for which actual costs were available. ^Effluent costs based on data presented m Ta! ^Assumed to require no air emission controls. Costs derived from Table 7-6 except To COLORITE 008728 TabU- 7-19_._ _Exi_stjrg_ EDC Plant Profi tabi 1 ity Calculations and Assumptions (Before Control) f'dhi3tGr IL Size ("ill !on lb/yr) Plant Investment (<i/1b/yr) Working Capital (<j/lb/yr) Total Investment (<f/lb/yr) Average Sales Price Cost of Sales (Excl. Dcpr., SG&A) Depreciation SG&A Total Cost Profit Before Tax Profit After Tax Return on Investment Vrom Table 7-33. New VCM , Plant 700 4.03 0.80 4.83 12.00 /1b 10.65 0.40 0.30 11.35'"" 0.65 0.325 6.7% Existing EDO Plant 1300 3.35 0.67 4.02 12.00 10.66 0.33 0.25 11.23 0.77 0.385 9.6% Explanation - Scale at 0.7 Exponent - Ratio to Plant Investment - Assume Constant - Assume Constant - Ratio to Total Investment - Ratio to Total Investment COLORITE 008729 Table 7-20. Existing EDC , larts - Profitability^ Summary Plant Owne".'Location Allied Chenical/Baton Rouge ij. F. Goodrich/Calvert City Continental Oil/Lake Charles Diamond Shamrock/Deer Park Dow Chemical/Freeport Dow Cliemlcal/Oyster Creek Dow Chemi cal / PI aquani ne Ethyl Coro./Bacon Rouge Ethyl Corp./Houston PPG/Guayanilla PPG/Lake Charles Shell/Deer Park Shell/Lorco Stauf/ r/Long Beach Onion Carbide/Taft onion Carbicie/Texas City Vulcan/Geismar Alternative I or Alternative II Before Control After Control, No Price Increase After Control, Price 2 Increase^ 6.4% 8.3 8.3 3.2 9.6 8.8 9.0 5.8 3.2 7.5 8.3 9.1 9.0 3.5 1.5 1.5 2.9 5.6% 7.3 7.4 2.1 3.8 7.8 8.3 5.0 2.3 6.7 7.5 8.1 8.1 2.8 1.4 1.4 1.8 6.4% 8.2 8.3 2.7 9.8 8.7 9.2 5.7 2.9 7.5 8.4 9.1 9.0 3.4 1.9 1 .9 2.4 Rel ati vi Change i n,, Ror 0A (v->T 0 (16) 2 0) 0 (2) (9) 0 1 0 0 (3) 27 27 (17) COLORITE 008730 iProfit after tax + investment (estimated). ^Price increase assumed to be sufficient to recover total annualized costs plus a 15% pre-tax return Calculation (refer to Tables 7-17 and 7-18 for cost details): Price Increase = 0.15 ($17,035,000) + $7,323,000 12,320,000,000 = 0.08<t/1 b EDC 4ROI after control (with price increase) relative to ROI before control. '( ) denotes decrease. V Table 7-23. Existing EDC Plants - Profitability^ Summary Plant Owner/i-Gcation Allied Chemical/Baton Rouge B. f. Gooarich/Calvert City Continental 011/Lake Charles Diamond Shamrock/Deer Park Cow Chemical/Freeport Dow Chemv..l/Gyster Creek Dow Chf.nr; cul/P'laquemine Ethyl Corp./Baton Rouge Ethyl Ccrp./Houston PPG/Guayani1 la PPG/Lake Charles Choi 1/Deer Park Shell/Norco Stauffer/Long Beach Union Carbide/Taft Union CarUide/Texas City Vulcan/Ge'i smar Before Control 6.4% 8.3 8.3 3.2 9.6 8.8 9.0 5.8 3.2 7.5 8.3 9.1 9.0 3.5 1.5 1.5 2.9 Alternative III After Control, No Price Increase 5.6% 7.3 7.4 0.8 8.8 7.8 8.3 5.0 2.3 6.7 7.5 8.1 8.1 2.8 1.4 1.4 1 .8 After Control, Price ? Increase^ 6.4% 8.2 8.3 1.9 S.S 8.7 9.2 5.7 2.9 7.5 8.4 9.1 9.0 3.4 1.9 1 .9 2.4 Relative Chat'ae ir;3 ROI 0. (VlT 0 (59) 2 V c (2) (9) n i 0 0 (3) 27 27 (17) ^Profit after tax + Investment (estimated). ^Since only two plants incur greater control costs at the Alternative III level than at the Alternative I/Alternative level (Diamond Shamrock/Deer Park and Vulcan/Gelsmar), the price increase of 0.08</lb resulting from Alternative 1/ .Alternative II was retained for this alternative. ^ROI after control (with price increase) relative to ROI before control. "( ) denotes decrease. COLOR!TE 0 0 8 7 3 ! 1 ; Owner/Location Allied Chsrrical/Baton Rouqe 3. 7. Occcriak/Calvert City Cro-..-.enrs' Oil/Lake Charles , .cr.d hi',. . .ck/Deer Park Do w C h en /cal / 6 r e e po r t Dow Chemical/Oyster Creek Dow Chami ca 11? 1 aquem 1 ne Eth-'l Coro./Baton Rouge Ethyl Coro./Houston 'J rG/Guoty^ i'j i 1 i u PPG/take Clio' les Shell/Deer P,v a Shell/i-.or:o CL.uffcr/L'.>'ij Peach ctmer. (..'oice i-*rt Lnion C-rbto^/Texas City i u i Co< 11 / vj 5 h- . Table 1-22. Existing EDC Plants - Annualized Cost Summary Alternative III Capacity (Million lb/yr) .Annualized Costs ? Air1 Water^ $(000) /.vr $(000)/yr Total Ar..-,-j $(000)/yr 650 1000 1000 260 1300 1100 1160 550 260 835 1000 1200 1165 300 150 150 240 $283 546 438 772 220 427 283 255 208 347 267 506 427 177, 033 618 $126 193 193 50 251 213 224 106 50 162 193 232 225 58 29 29 46 $409 739 631 772 471 64 C 507 361 263 ; ;n rvn 728 652 235 29 29 664 12,320 $5,724 $2,380 $8,104 COLOR!TE 008732 'Includes or!1;/ incineration of the EDO purification process emission point. .pStaaffer Gnomical/Long Beach for which actual costs were available. ^Effluent costs based on data presented in Table 7-16. "Assumed to require no air emission controls. Costs derived from Table 7-6 9 Table 7-23. Existing EDC Plants - Profitability^ Summary Plant Owner/Location Allied Chemical/Baton Rouge B. F. Goodrich/Calvert City Continental Oil/Lake Charles Diamond Shamrock/Deer Park Dow Chemical/Freeport Dow Chemical/Oyster Creek Dow Chemical/PIaquemine Ethyl Corp./Baton Rouge Ethyl Corp./`Houston PPG/Guayanilla PPG/Lake Charles Shell/Deer Farr Shell/Norco Stauffer/Lor.g Beach Union Carbide/Taft Union Carbide/Texas City Vulcan/Geismar ATternative III Before Control After Control, No Price Increase 6.4% 8.3 8.3 3.2 9.6 8.8 9.0 5.8 3.2 7.5 8.3 9.1 9.0 3.5 1.5 1.5 2.9 '' 5.6% 7.3 7.4 0.8 8.8 7.8 8.3 5.0 2.3 6.7 7.5 8.1 8.1 2.8 1 .4 1.4 1 .8 After Control, Price ? Increase^ 6.4% 8.2 8.3 1.9 9.8 8.7 9.2 5.7 2.9 7.5 8.4 9.1 9.0 3.4 1.9 1 .9 2.4 Relative Change in., ROI0 ,^..4 (' f) 0 (59) 2 (i) 2 (2) (9) 0 1 G 0 (3) 27 27 07) Iprofit after tax * investment (estimated). , , ,, ^Since onlv two plants incur greater control costs at the Alternative III level than at the Alternative ^/Alternative level (Diamond Shamrock/Deer Park and Vulcan/Geismar), the price increase of 0.08</lb resulting from Alternative 1/ Alternative II was retained for this alternative. "ROI after control (with price increase) relative to ROI before control. ^( ) denotes decrease. COLOR!TE 008733  '.i11 -11 / tecs ti on . ;i srm ' - . ' v: 1 vert City -i, v i estl aka sort ,i\t..... : .1; C;'--; er Creek , Chcr.,.i... ml.vmmine Liv/l i'c. . -3r , : Rouge ,r,yl Co /,io iOion modm-i/m imm rG/0 ...yani" 1 ml 1/ leer Pur. -1 1; ' f co mm. 'tv. 'men .C ^0/ VJ/. :b1e 7-24. Existing VCM Plants - Capital Summary AT ternative I Capacity {Million Ib/yr) Air1 $(000) Estimated Capital Requm Water Total $(000) $(000) c/! b/yr 340 1,000 730 180 700 340 270 150 300 500 300 900 700 170 255 6,835 $ 534 534 534 534 534 534 534 534 889 534 534 534 534 534 889 $8,720 $1,146 3,371 2,461 607 2,360 1,146 910 506 1,011 1,685 1,011 3,034 2,360 573 860 $23,041 $1 ,680 3,905 2,995 1 ,141 2,894 1,680 1,444 1,040 1,900 2,219 1,545 3,568 2,894 1 ,107 1,749 $31,761 U -r ! 0.49 0.53 0.4. ,, .4 1 Ur i . *r. r..o CiTaT oo COLOR!TE 008734 .. vludas rmif'ce control costs plus incremental incineration costs at the VCM plant. mvcs acrvvi'.-.. mom Table 7-6. -C, (ucr.c costs based on data presented in Table 7-16. Table 7-25. Existing VCM Plants - Annualized Cost Summary Alternative I Plant Cwner,'Location Allled/Geismar B. F. Goodricri/Calvert City Continental Oil/Westlake Dow Chemical/Freeport Dow Chemical/Oyster Creek Dow Chemical/Plaquemlne Ethyl Corp./juton Rouge Ethyl Corp./Houston Monochem/Geismar PPG/Guayanilla PPG/Lake Charles Shell/Deer Park Shell/Norco Stauffer/Long Beach Tenneco/Houston Capacity (Mill ion lb/yr) 340 1,000 730 180 700 340 270 150 300 500 300 900 700 170 255 6,835 Annualized Costs r, Air1 Water $(000)/yr $(000)/yr EDC Charge15 ${000)/yr Total $(000)/yr c/1 b at Cpty $ 405 333 362 422 365 405 412 426 676 387 409 344 365 423 663 $6,397 $ 229 674 492 121 472 229 182 101 202 337 202 607 472 115 172 $37607 $ 432 1,270 927 229 889 432 343 191 381 635 381 1 ,143 889 216 324 $8,682 $1,066 2,277 1 ,781 772 1 ,726 1,066 937 718 1 ,259 1 ,359 992 2 ,C4 1 ,726 754 1,159 $19,686 0.31 0.23 0.24 0.43 0.25 0.31 0.35 0.43 0.42 0.27 0.33 0.23 0.25 0.44 C. 45 0.29 COLORITE 008735 Includes fugitive control costs plus incremental incineration costs at the VCM plant. ?Costs derived from Table 7-6. ^Effluent costs based on data presented in Table 7-16. Increased fDC charge to recover annualized costs at EDC plants plus a pre-tax return of 15% on capital. Assumes 1.58 lb EDC/lb VCM. Table 7-26. Existing VCM Plants - Profitability Summary Alternative I . O'rC".'/Location A1 11 ed C r, en 1 c a I / G e i srna r A. F. Gocdrich/Calvert City Coniine;"al Ci1/Westlake Dc,: A-or.ical/r^aeport Dow .. or:, i c a 1 / Cy s t e r Creek i.i.e:v;cal/PlaqueinIne Cr.hyl Zero./Baton Rouge Ethyl Cr./Houston y o n o c h em ' G a i r ma r "'-'T/Duc. /uni 11 a Chi'les CncMl/Dr-er ,A.rk ii'-i'/M' 'CO 'nneco/- -ou s cl t Before Control 4.0% 8.3 6.8 2.1 6.7 4.0 3.3 1.5 3.5 5.4 3.5 7.8 6.7 1 .9 3.1 Estimated ROI (Return in Investment)^ After Control No Price Increase After Control Price Increase Relative Change i n-, ROI 1.3% 5.2 4.0 4 (0.8)4 3.8 1.3 1.1 (1.5) 0.2 2.7 0.8 4.8 3.8 O.o) (0.4) 4.1 9.0 7.4 1.5 7.3 4.1 3.1 0.7 2.3 5.8 3.5 8.5 7.3 1 .2 2.1 3 8 /(o29n\r4 9 3 . (6) (53) (20) 7 0 9 9 (37) (32) COLORITE 008736 iproflc avtar tax * investment. "Trie.: `;ncre:.sc assumed to be sufficient to recover total annualized costs plus a 15% pre-tax return on total capita Caation (refer to Tables 7-24 and 7- 25 for cost details): Price Inc.-ease = 0.15 ($31 ,761,000) + $19,686,000 = 0.36*/lb VCM :?.0I attar control (with price increase) relative to ROI before control. ) denotes decrease/loss. Table 7-27. Existing VCM Plants - Capital Summary Alternative II Plant Qwner/Location Allied/Geismar 8. F. Goodrich/Calvert City Continental Oil/Westlake Dow Chemical/Freeport Dow Chemical/Oyster Creek Dow CheiViical/PIaquemine Ethyl Corp./Baton Rouge Ethyl Coro./Houston Monochem/Geismar PPG/Guayani'lla PPG/Lake Charles Shell/Deer Park Shell/Norco Stauffer/Long Beach Yenneco/Houston Capacity (Million lb/yr) 340 1,000 730 180 700 340 270 150 300 500 300 900 700 170 255 6,835 Ai r"* $(000) Estimated ijapi tal Requirement Water1" fatal $(000) $000) c/Ak/y: $ 534 534 2,070 534 534 534 534 534 889 534 534 534 534 534 889 $10,256 $1 ,146 3,371 2,461 607 2,360 1,146 910 506 1,011 1,685 1,011 3,034 2,360 573 860 $23,041 $1,680 3 ,905 4,531 1 ,141 2,894 1 ,680 1 ,444 1 ,040 1 ,900 2,219 1 ,545 3,568 2,894 1 ,107 1 ,749 $33,297 0.49 0.39 0.62 0.63 0.41 0.49 0.53 0.69 0.63 0.44 0. 52 0.40 0.41 0.65 0.69 0.49 COLORITE 008737 ^Includes fugitive controls plus incremental incineration costs at the VCM plant. ?Costs derived from Table 7-6. effluent costs based on data presented in Table 7-16. Table 7-28. Existing VCM Plants - Annualized Cost Summary i Alternative II t Plant Gwncr/Location fi ied/Ge i smar 3. r, Goodricn/Calvert City Continental Oi1/Westlake Cow Chemical/Freeport Dow Chemical/Oyster Creek Dow Cnemical/?!aquemine Ethyl Corp./Saton Rouge Ethyl Corp./Houston Mor.ocncir./Ceismar PPG/Guayanilla PPG/Lake Charles She!1/Qeer Park She'll/Norco Stauffer/Long Beach Tenneco/Fiouston Capacity (Million Ib/yr) 340 1,000 730 180 700 340 270 150 300 500 300 900 700 170 255 6,835 Annualized CoStS a Air" Water`d $(000)/yr $(000)/yr $405 333 1 ,315 422 365 405 412 426 676 387 409 344 365 423 663 $7,350 $229 674 492 121 472 229 182 101 202 337 202 607 472 115 172 $4,607 EDC Charge^ ${000)/.yr Total $(000)/yr $/lb Cap. $432 1,270 927 229 889 432 343 191 381 635 381 1 ,143 889 216 324 $8,682 $1 ,066 2,277 2,734 772 1,726 1,066 937 718 1,259 1 ,359 992 2,094 1,726 754 1 ,159 $20,639 0.31 0.23 0.38 0.43 0.25 0.31 0.35 0.48 0.42 0.27 0.33 0.23 0.25 0,44 0.45 0.30 I Includes fugitive control costs plus incremental incineration costs at the VCM plant. ..Costs derived from Table 7-6. TEffluent costs based on data presented in Table 7-16. ^Increased IOC charge to recover annualized costs at EDC plants plus a pre-tax return of 15% on capital. Assumes 1.5a lb EDC/lb VCM. COLOR!TE 008738 ( COLORITE 008739 Table 7-29. Existing VCM Plants - Profitability Summary Alternative II Plant Owner/Location Allied Chemical/Geismar 3. F. Goodrich/Calvert City Continental Oil/Westlake Dow Chemical/Freeport Dow Chemical/Oyster Creek Dow Chemlcal/Plaquemlne Ethyl Corp./Baton Rouge Ethyl Corp./Houston Monochem/Geismar PPG/Guayanilla PPG/Lake Charles Shell/Deer Park Shell/Norco Stauffer/Long Beach Tenneco/Houston Before Control 4.0/ 8.3 6.8 2.1 6.7 4.0 3.3 1.5 3.5 5.4 3.5 7.8 6.7 1.9 3.1 Estimated ROI (Return in. After After Control, Control No Price Price Increase Increas 1.3 5.2 2.5 (0.8) 3.8 1.3 1.1 (1.5) 0.2 2.7 0.8 4.8 3.8 (1.0) (0.4) 4.1* : ' 9,0. 5.8 1.5 7.3 4.1. 3.1 0.7 2.8 5.8 3.5 8.5 7.3 1.2 2.1 1profit after tax * investment. . ^Assumes same price increase as Alternative I (00..003366tf//1lbb)). fROI after control (with price increase) re" 1;Jive to ROI before control. *{ ) denotes decrease/loss. J Relative Change in, p.or 3 (185)44 (29) 9 3 (6) (53) (20) 7 0 9 9 (37) (32) Table 7-30. Existing VCM Plants - Capital Surranary Alternative III Plant Owner/Location A11ied/Geismar B. F. Goodrich/Calvert City Continental Oil/Westlake Dow Chemical/Freeport Dow Chemical/Oyster Creek Dow Chemical/Plaquemlne Ethyl Corp./Baton Rouge Ethyl Corp./Houston Monochem/Gcumar PPG/Guayanllla PPG/Lake Charles Shell/Deer Park thell/Kcrcc Stauffer/Long Beach Tenneco/Houston Capacity (Million Ib/.yr) 340 1,000 730 180 700 340 270 150 300 500 300 900 700 170 255 6,835 Air1 $(000) Estimated Capital Requirement Water^ Total $(000) $(000) <t/1 b/yt $2,087 2,937 2,070 534 654 534 1,574 534 889 382 1 ,650 2,147 2,147 534 889 $19,562 $1,146 3,371 2,461 607 2,360 1,146 910 506 1,011 1,685 1,011 3,034 2,360 573 860 $23,041 $3,233 6,308 4,531 1 ,141 3,014 1 ,680 2,484 1 ,040 1,900 2,067 2,661 5,181 4,507 1 ,107 1 ,749 $42,603 0.95 0.63 0.62 0.63 0.43 0.49 0.92 0.69 0.63 0.41 0.89 0.58 0.64 0.65 0.69 0.62 ^Includes fugitive control costs plus Incremental incineration costs at the VCM plant. ?Costs derived from Table 7-6. Effluent costs based on data presented in Table 7-16. COLOR!TE 008740 J J 9 Table 7-31. Existing VCM Plants - Annualized Cos t Summary Alternative III Plant Owner/Location A11ied/Geismar B. F. Goodrich/Calvert City Continental Oil/Westlake Dow Chemical/Freeport Dow Chemical/Oyster Creek Dow Chemical/Plaquemine Ethyl Coro./Baton Rouge Ethyl Corp./Houston Monochem/Geismar PPG/Guayanilla PPG/Lake Charles Shell/Deer Park Shell/Norco Stauffer/Long /each Tenneco/Houston Capacity {Million lb/yr) 340 1,000 730 180 700 340 270 150 300 500 300 900 700 170 255 6,835 Annualized Costs ,, Air Water*" ${000)/.yr $(000)/yr $1,756 2,073 1,315 422 137 405 984 426 676 381 1 ,033 1,366 1 ,377 423 663 IT3T477 $229 674 492 121 472 229 182 101 202 337 202 607 472 115 172 $4,607 EDC ,, Charge0 $ C 000)/.yr Total ${000)/yr 5/lb Capa $432 1,270 927 229 889 432 343 191 381 635 381 1,143 889 216 324 $8,682 $2,457 4,017 2,734 772 1 ,498 1 ,066 1 ,509 718 1,259 1,353 1 ,616 3,111 2,738 754 1,159 $26,766 0.72 0.40 Q. 38 0.43 0.21 0.31 0.5G 0.43 0.42 0.27 0.54 0.35 0.39 G .44 0.46 0.39 i Includes fugitive control costs plus incremental incineration costs at the VCM plant. gCosts derived from Table 7-6. ^Effluent cost.; based on data presented in Table 7-16. Increased EDC charge to recover annualized costs at EDC plants plus a pre-tax return of 15% on capital. Assumes 1.58 lb EDC/1b VCM. COLORITE 008741 Table 7-32. Existing VCM Plants - Profitability Summary Alternative III Plant Owner/Location Allied Chemical/Gelsmar 6. F. Goodrich/Calvert City Continental 011/Westlake Dow Chemicai/Freeport Dow Chemicai/Cyster Creek Cow Chem1ca 1/R a qu em1n e Ethyl Corp./Baton Rouge Ethyl Corp./Houston Monochem/Geismar PPG/Guayani11 a PPG/Lake Charles Shell/Deer Park Shell/Norco Stauffer/Long Beach Tenneco/Houston Before Control 4.0% 8.3 6.8 2.1 6.7 4.0 3.3 1.5 3.5 5.4 3.5 7.8 6.7 1.9 3.1 Estimated RQI (Return on Investment)^ After Control, No Price Increase After Control, Price p Increase^ Relative Change in, ROr (1.7)4 3.2 2.5 (0.8) 4.2 1.3 (1.0) (1.5) 0.2 2.7 (0.7) 3.5 2.4 (1.0) (0.4) 1.8% 8.1 7.1 2.3 8.8 5.1 2.4 1.4 3.7 6.9 2.7 8.3 6.9 2.1 3.0 (55%)4 (2) 4 10 31 28 (27) (7) 6 28 (23) 6 3 11 (3) COLOR!TE 008742 ^Profit aftc ' tax * investment. ``Price ino :-ase assumed to be sufficient to recover total annualized costs Calculation (refer to Tables 7-30 and 7-31 for cost details): Price Increase = 0.15 ($42,603,000) + $26,766,000 6,835,000,000 ~ = 0.49/lb VCM ^ROI after control (with price increase) relative to R0I before control. 4( ) denotes decrease/loss. plus a 15% return on total capital. Table 7-Si. Financial Impact of Alternative Control Levels on New FC(I-VCM PIar Uncontrolled Plant Plant Meeting Effluent Regulations Only0 Plant Investment (C/lb/yr) Working Capital Total Investment 4.03 0.80 4.83 4.37 0.80 5.17 Average Sales Price 12.00 i/lb 12.00 Ethylene (0.49 #/# 0 11.25 */#) Chlorine (0.67 #/# 0 6.5*/#) Depreciation Other Manufacturing Costs Selling, General, Admin. Total Cost 6.51 4.36 0.40 0.78 0.30 1T735 5.51 4.36 0.43 0.87 0.30 11.47 Profit Before Tax Profit After Tax 0.65 0.325 0.53 0.265 ROI* 6.7% 5.1% Price Increase Required to Maintain PreControl ROI C/lb % -- 0.17 -- 1.4% Effluent Regulatic Plus Alt. I Alt. I] 4.50 4.64 0.80 5.30 0.80 b .44 12.00 12.00 5.51 5.51 4.36 4.36 0.45 0.96 0.30 11.58 0.46 1.08 0.30 11.71 0.42 0.21 0.29 0.145 4.0% 2.7% 0.29 2.4% 0.44 3.7% *Return on investment (profit after tax -ftotal investment). SOURCE: a) Information on uncontrolled plant economics based upon: Final Report - Economic Impact Studies of the Effects of Proposed OSHA Standards for Vinyl Chloride, Foster D. SnelT) Inc., September ?77T97TrT;<h''ibit iy-TT~|Modified by EPA to reflect current raw material prices and VCM sales prices.) b) Effluent costs from Table 7-15. c) Alternative I and Alternative III control costs from Table 7-7. NOTE: Plant size of 700 millions pounds per year. COLORITE 008743 Table 7-34 Existing PVC Plants - Capital Summary Control Scenario #1 ocation i i./A 'crt City Mr ti;.acolri '/ 7. a in ` _ VAvon Lake i ". cr,/:i---n ny b. r', .ecr ' cn/Lf'fig Beach 3 /Louisville /. '.'Podricktown .lorei I i l s j A, i' ; . C _ iii'" L't' b:,n ti. ' l i /Aberdeen `.i l. /Oklah ,i:a City ; ./'Del a',,are Ci ty n A'.-iv Deer Park Ji . v1Tt ! CO. i /1 . : 3iid '.'Ut&U r.; J \ 11 G jti. ;V T1- ; -;wn - abj'la f r" cjo cTTii ne r/r, rails cine .-'itchburg n,.:. ,, ./ ucr:;;,.-c ; j i, ric / i c rtL' v Jenna t/Jcn.-'set Aryscr ... .r... r,/Saugus .unsar,c.o/Spr , ngfield Ocde : i) Petroleum/Burlington Cdu;.d Pewd eum/Hicksville J * _ r *, 1 ' - . 1 ui ! tu ./J i i - j j Ik nutate c. d r.t Pleasant ilc tiii Lech/ sville Capacity {Million lb/.yr) 135 75 260 220 115 145 140 140 175 260 220 100 270 100 180 230 170 125 220 100 105 70 4 6 5 35 70 170 15 60 95 250 . ... i____ Estimated Capital RGQuir&mGnt Air1 Water Total tt/lb/yr $(000) $(000) $(000) $4,315 3,537 5,585 5,121 4,057 4,371 4,089 4,354 4,743 6,087 5,986 4,247 6,181 3,865 4,643 5,338 4,176 4,172 5,240 4,298 1,350 3,521 1,173 1,184 1,179 2,459 2,105 1,718 2,049 2,850 3,820 5,530 $1,134 630 2,184 1,848 966 1,218 1 ,176 1,176 1 ,470 2,184 1,848 840 2,268 840 1,512 1,932 1,428 1,050 1,848 840 882 588 34 50 42 294 588 1,428 126 504 788 2,100 $5,449 4,167 7,769 6,969 5,023 5,589 5,265 5,530 6,213 8,271 7,834 5,087 8,449 4,705 6,155 7,270 5,604 5,222 7,088 5,138 2,232 4,109 1,207 1,234 1,221 2,753 2,693 3,146 2,175 3,354 4,618 7,630 4.04 5.56 2.99 3.17 4.37 3.85 3.76 3.95 3.55 3.18 3.56 5.09 3.13 4.71 3.42 3.16 3.30 4.18 3.22 5.14 2.13 5.87 30.18 20.57 24.42 7.87 3.85 1.85 14.50 5.59 4.86 3.05 9 COLORITE 008744 "facie 7-04 corn;. Shintcch/Freeport Stauffer/Delaware City Stauffer/Long Beach Tenneco/3urlington Tenneco/F'lemington Tenneco/Pasadena Union Carbide/South Charleston Union Carbide/Texas City Uni royal/Painesvilie 220 175 150 165 70 240 60 300 no 5,755 5,673 5,074 5,767 4,940 3,487 4,698 2,629 8,055 3,725 $167,391 1,848 1,470 1,260 1,386 588 2,016 504 2,520 924 $48,342 7,521 6,544 7,027 6,326 4,075 6,714 3,133 10,575 4,649 $215,733 3.42 3.74 4.6C 3.53 5.82 2.80 5.22 3.53 icL3. 3.75 Dispersion Plants at Alternative I (stripping to 30,000 ppm), all other plants at Case A {improved stripping). ,,Co$ts developed using Table 7-6 and specific plant process information. ^Effluent costs based on Table 7-16. Table 7-35. Existing PVC Plants - AnnuaHzed Cost Summary Control Scenario #1 Plant Cvmar/Locatfon iPr .cv- 'Culvert City i.1 fTv. cnsacola 8. P, Goec.-iL.i-i/Avon Lake 8. f. Gocct'ch/Henry l. . . Co; ,-ich/Long Beach : , r C-jOCfich/LoulSVine B, uoodi'li;. Pedricktown 8-.. : Boroen/Leorni(ijuer Continental Gil/Aberdeen Conti Hi.tal Oi) /Ok 1 a S .;na Ci ty DiEsmond hirrrock/De 1 aware Ci ty DianurJ Si',a:i..-cck/Deer Park ' Dow Chem1c a i ' !*, l d 1 a n d Etc '1/Baton iOttge Firot tone/Pe rryvills Fire stone/P oitstown Genera 1 Tire./Athtabula Gtcrgi -? a c i f;/? laquamine Goodyear/irs. /era Falls Good year/P laoneiTilne Great Axer 1 ct./i/Fi tchburg Je^uaz/'forr-iAce do acker dennat/SoiV-i-rset Keysor-Cji, tory/Saugus Mens ''oprincfield Occics, 1 Petroleum/Burl ington Occidental Pctroleum/HIcksville Pantasota/Passaic----------------------Pantasote/Point Pleasant Ro bi n tec n/ Pa 11, es v i 11 e Capacity (Million lb/yr) 135 75 260 220 115 145 140 140 175 260 220 100 270 100 180 230 170 125 220 100 105 70 4 6 5 35 70 170 15 -------- 60---------95 250 Annyalized Costs,, ATP -- Water1" $(000) $(000) $1,205 1,087 1,431 1,392 1,166 1,252 1,400 1,206 1,254 1,449 1,508 1,251 1,458 1,137 1,340 1,325 1,370 1,180. 1,315 1,226 919 1,161 623 625 624 891 818 1,199 806 ' 932 1,134 1,343 $243 135 468 396 207 261 252 252 315 468 396 180 486 180 324 414 306 225 396 180 189 126 7 n 9 63 126 306 27 "108 171 450 VCM , Charge $(000) Total ${000)/.yr <t/lb Capaci $486 270 936 792 414 522 504 504 630 936 792 360 972 360 648 828 612 450 792 360 378 252 14 22 18 126 252 612 54 216 342 900 $1,934 1,492 2,835 2,580 1,787 2,035 2,156 1,962 2,199 2,853 2,696 1,791 2,916 1,677 2,312 2,567 2,288 1,855 2,503 1,766 1,486 1,539 644 658 651 1,080 1,196 2,117 887 1,256 1,647 2,693 1 .43 1 . J9 1.09 1.17 1 .55 1.40 1.54 1.40 1.26 1.10 1.23 1.79 1.08 1.68 1.28 1.12 1.35 1.48 1.14 1.77 1.42 2.20 16.10 10.97 13.02 3.09 1.71 1.25 _____ ELfl]___ 2.09 1.73 1.08 COLORITE 00874$ Table /-ub U'jr.t. Smntech/F reeoort Stauffer/Dei aware City Stauffer/Lonq Beach Tenneco/Burlington Tenneco/Flemington Tenneco/Pasadena Union Carbide/South Charleston Union Carbide/Texas City Uniroyai/Painesvllle 220 175 150 165 70 240 60 300 no 5,755 1 ,404 1,402 1,597 1,393 1,081 1,102 915 2,066 1,211 $49,198 396 315 270 297 126 432 108 540 198 $10,359 792 630 540 594 252 864 216 1 ,080 396 $20,718 2,592 2,347 2,407 2,284 1 ,459 2,398 1 ,239 3,68b 1 ,805 $80,275 1.18 1.34 1 .60 1.38 2.08 1 .00 2.07 1 .23 1.64 1.39 Dispersion plants at Alternative I (stripping to 30,000 ppm), all other plants at Case A (improved stripping). 2Costs developed using Table 7-6 and specific plant process information. ^Effluent costs based on Table 7-16. JVCM charge from Table 7-26 (footnote #2). COLOR!TE 008747 Table 7-36. Existing PVC Plants - Profitability Summary Control Scenario #1 i i - n 0 i or/L near ;cn Air Prodacts/Calvert City Air Prodrcti/Pcnaacola Z. r. Goodrich/Avon Lake 3. F. Goadricn/Henry r>. F. Go k'ich/Long Beach L. F. Go..' .1' cM/LauisviT1 e B. F. Gooc en/Pedricktown Gord.'-rs/n Urol is I'orden/Leori, nster Lootin': rLA Oil/Aberdeen Contioonsal Oi1/Oklahoma City [.ia:~o i Shc.mr .a/Delaware City Diamond Shar.i -/Deer Park Dow Chemical/pi s'* and ; lhyl/Baton Rouge ,ri r as tone/P erryvi lie Fires tone/Pc 11 -own V or era 1 Ti r e/ A: hta bu 1 a Cor rg ia-PaciTic/?laquemine 'aodytar/iiiagara Falls Goodyear/PI aquamine ' rcat AaieriiWin/Ki tchburg nat/Torrance uarr.a t/Tuckor Jarr.j L/Sor.ierset 'M.ysor- Century/Saugus .'.on sent.:/Springfield Occident:.] Petroleum/Burlington -trident-] Petroloum/Hicksvilie Estimated ROI (Return on Investment) After After Control, Control, Before No Price Price 2 Control Increase Increase^ 9.3% 6.5 13.2 12.2 8.5 9.8 9.5 9.5 10.8 13.2 12.2 7.8 13.5 7.8 11.0 12.5 10.0 8.9 12.2 7.8 9.5 6.1 0.6 1.3 1.0 3.4 6.0 12.7 0.7 4.9 1.9 8.5 7.5 4.1 5.3 4.8 5.1 6.3 8.4 7.2 3.1 8.6 3.3 6.4 7.8 7.2 4.5 7.5 3.1 5.6 1.4 (5.6) (4.1) (4.6) (1.3) 3.7 8.4 (5.0) 9.3 5.5 13.9 12.7 8.2 9.8 9.3 9.5 11.1 13.7 12.3 7.0 14.1 7.3 11.3 13.0 10.2 8.8 12.7 7.0 10.2 4.S (4.8) (3.2) (3.7) 1.5 6.0 13.8 (3.0) Relative Change in, rot 0A (i5 %y 5 4 (4) 0 (2) 0 3 4 1 (10) 4 (60-i ) 4 2 0) 4 (10) 7 (20) (900) (346) (470) (57) 0 9 (529) COLOR!TE 008748 i;:; Table 7-36 cort. Pantasote/Passalc Pantasote/Point Pleasant Roblntech/Palnesvll le Shlntech/Freeport Stauffer/Delaware City Stauffer/Long Beach Tenneco/Burlington Tenneco/Flemlngton Ter.neco/Pasatlena Unicn Carbide/South Charleston Union Carbide/Texas City Uniroyal/Pairsesville 5.5 7.5 13.0 12.2 10.8 9.9 10.5 6.1 12.7 5.4 14.2 8.3 1 .2 3.1 8.3 7.4 6.0 4.7 5.7 1.6 8.4 2.8 8.5 3.8 4.6 7.0 13.7 12.5 10.8 9.1 10.4 5.1 13.8 4.9 14.0 7.9 (16) (7) r l 0 (8) fl) 06) 9 (9) CD (5) i?rofit after tax * total Investment (estimated). Increase in price required to recover total annualized cost plus a 20% before-tax return on total contre'1 cap Calculation (refer to Table 7-34 and 7-35 for cost details): Price Increase = 0.2 ($215,733,000) + $80,275,000 5,755,000,000 3 = 2.15<t/lb 4ROI after control (with price Increase) relative to ROI before control. ( ) denotes aecrease/loss. COLORITE 008749 COLORITE 008750 Plant Owner/Location Air Products/Calvert City Air Products/Pensacola B. F. Goodrich/Avon Lake B. F. Goodrich/Henry B. F. Gooorlch/Long Beach B. F. Goodrich/Louisvllle B. F. Goodrich/Pedrlcktown Borden/11iopolis Borden/Leominster Continental Oil/Aberdeen Continental Oil/Oklahoma City Diamond Shamrock/Delaware City Diamond Shamrock/Deer Park Dow Chemical/Midland Ethyl/Baton Rouge rirestone/Perryvilla Firestone/Pottstown General Tire/Ashtabula Georgia-Pacific/Plaquemine Goodyear/Niacara Falls Goodyear/Plaquemine Great American/Fitchburg Jennat/Torrance Jennat/Tucker Jennat/SChierset Keysor-Century/Saugus Ilcnsanto/Springfield Occidental Petroleum/Burlington Occidental Petroleum/Hicksville Pantasote/Passaic Pantasote/Peint Pleasant Robintech/Painesville HI S'"' ------- ' Control Scenario #Z Capacity (Million lb/yr) 135 75 260 220 115 145 140 140 175 260 220 100 270 100 180 230 170 125 220 100 105 70 4 6 5 35 70 170 15 60 95 250 i___ Air' $(000) Estimated Capital Requirement Water1- Total $(000) $(000) i/lb/ $4,315 3,537 6,681 6,374 4,057 5,187 5,106 4,354 4,743 6,087 5,986 4,948 6,181 3,865 5,970 5,338 6,197 4,172 5,240 4,298 1,350 3,521 1,526 1,622 1,576 2,459 3,711 1,718 2,049 2,850 3,820 5,530 $1,134 630 2,184 1,848 966 1,218 1 ,176 1,176 1,470 2,184 1,848 840 2,268 840 1,512 1,932 1,428 1,050 1,848 840 882 588 34 50 42 294 588 1,428 126 504 798 2,100 $5,449 4,167 8,865 8,222 5,023 6,405 6,282 5,530 6,213 8,271 7,834 5,788 8,449 4,705 7,482 7,270 7,625 5,222 7,088 5,138 2,232 4,109 1,560 1,672 1,618 2,753 4,299 3,146 2,175 3,354 4,618 7,630 4.04 5.56 3.41 3.74 4.37 4.42 4.49 3.95 3.55 3.18 3.50 5.79 3.13 4.71 4.16 3.16 4.49 4.18 3.22 5.14 2.13 5.87 39,00 27.87 32.36 7.87 6.14 1.85 14.50 5.59 4.89 3.05 i Tabic 7-37 cont. II Shintech/Freeport Ctauffer/Delaware City S+suffer/Long Beach Tenneco/Burlington Tenneco/Fleminqton Tenneco/Pasadci.a Union Carbicij/South Charleston Union Carbicie/Texas City Ui: ir oya1/Painesville 2k 175 150 165 70 240 60 300 110 5,755 5,673 6,171 5,767 6,119 3,487 4,698 3,560 8,055 5,124 $183,022 1,848 1,470 1 ,260 1 ,386 588 2,016 504 2,520 924 $48,342 7,521 7,641 7,027 7,505 4,075 6,714 4,064 10,575 6,048 $231,364 3.42 4.37 4.68 4.55 5,82 2.80 6.77 3.53 5.50 4.02 Dispersion plants at Alternative II, Case A (stripping to 2,000 ppm), all other plants at Case A {improved stripping gCosts developed using Table 7-6 and specific plant proces information. Effluent costs based on Table 7-16. COLORITE 008751 Table 7-38. Existing PVC Pl^ls - Annualized Cost Summary Control Scenario #2 Plant Owner/Location Air Products/Calvert City Air Products/Pensacola 8. F. Goodrich/Avon Lake B. F. Goodrich/Henry L.. F. Goodrich/Long Beach B. F. Goodrich/Louisville B. F. Goodrich/Pedricktown Barden/11iopolis Borden/Leominster Continental Oil/Aberdeen Continental Oil/Oklahoma City Diamond Shamrock/Delaware City Diamond Shamrock/Deer Park Dow Chemical/Midland Etnyl/Baton Rouge Fi restore/Perryvi 1 le Firestone/Pottstown General Tire/Ashtabula Georgia-Pacific/Plaquemine Gocdyear/Niagars Falls Goodyear/Plaquemine Great American/Fitchburg Jennat/Torrance Jennat/Tucker Jennat/Sorrserset Keysor-Century/Saugus Monsanto/Springfield Occidental Petroleum/Burlington Occidental Petroleum/HIcksville Pantasote/Passalc Pantasote/Point Pleasant Robintech/Painesville Capacity (Million lb/yr} 135 75 260 220 115 145 140 140 175 260 220 100 270 100 180 230 170 125 220 100 105 70 4 6 5 35 70 170 15 60 95 250 Annyal ized Costs,, fiTr* Water"* $(000) $(000) $1,205 1,087 2,034 2,104 1,166 1,682' 1,949 1,206 1,254 1,449 1,508 1,616 1,458 1,137 2,100 1,325 2,682 1,180 1,315 1,226 919 1,161 817 858 838 891 1,784 1,199 806 932 1,134 1,343 $243 135 468 396 207 261 252 252 315 468 396 180 486 180 324 414 306 225 396 180 189 126 7 11 9 63 126 306 27 108 171 450 VCM Charge1* $(000} Total ${000)/.yr i/lb Capacity $486 270 936 792 414 522 504 504 630 936 792 360 972 360 648 828 612 450 792 360 378 252 14 22 18 126 252 612 54 216 342 900 $1 ,934 1,492 3,438 3,292 1,787 2,465 2,705 1,962 2,199 2,853 2,696 2,156 2,916 1,677 3,072 2,567 3,600 1 ,855 2,503 1,766 1,486 1,539 838 891 865 1,080 2,162 2,117 887 1,256 1,647 2,693 1 .43 1.99 1.32 1.27 1.55 1 .70 1 .93 1 .40 1 .26 1.10 1 .23 2.16 1 .08 1 .68 1 .71 1 .12 2.12 1.48 1.14 1.77 1.42 2.20 20.95 14.85 17.30 3.09 3.09 1.25 5.91 2.09 1.73 1 .08 COLOR!TE 008752 i abl c 7-ja cent* Shintccn/Freeport Stauffer/Oelaware City Stauffer/Long Beach Tenneco/Burlington Tenneco/Flemington Tenneco/Pasadena Union Carbide/South Charleston Union Carbide/Texas City Unircyal/Palnesvllle 220 175 150 165 70 240 60 300 110 5,755 1,404 2,005 1,597 2,051 1,001 1,102 1,469 2,066 2,023 $58,163 396 315 270 297 126 432 108 540 198 $10,359 792 630 540 594 252 864 216 1 ,080 396 $20,718 2,592 2,950 2,407 2,942 1 ,459 2,398 1 ,793 3,686 2,617 $89,240 I .18 1.69 1 .60 1.76 2. OP 1 .00 2.99 1.23 2.38 1 .55 Dispersion plants at Alternative II, Case A (stripping to 2,000 ppm), all other plants at Case A (improved stripping). 2Costs developed using Table 7-6 and specific plant process information. -Effluent costs based on Table 7-16. JVCM charge from Table 7-26 (footnote #2). COLOR!TE 008753 Table 7-39. Existing PVC ts - Profitability Summary Control Scenario it2 riant Cv/net'/LOcation Air iVsducts/Ca : vert City Air Products/Periacola C. F. Oojcrich/Avon Lake 5, F. Coodrich/Henry 2, F. Soodrich/Long Beach . F. Ooodrich/Lou i sv 111 e . F. Cioojrich/Pedricktown Corden/11 iopcl Is Borden/, .coniaster Continental 011/Aberdeen ' - rAinorrca'i Ci i/0k 1 ahoma City r Ci'.cnd Sh;.rr,roci..'Delaware City C'ione Biurroci-./Deer Park Crw LiKviciil/Midland l i \j 1 / itCi. ton wO u & Fi res ^ro/Por i 1 le FI rcstone/Po '.'.a- .own Cereral T! re/Ashtabula Ceorgia-Pacific/Plaquemine ' lOodyuii'r/N'i &QaPit r311 s do a dy : a r/P la qc era i n e Croat : ;r, e r 1 c a n / i: C t c h b u r g Jannat/Torrance oenisat/Tucker Jennat/Somerset Keysor-Cer.tury/Saugus Monsanto/Springfield Occidental Petroleum/Burllngton Occidental Petroloum/Hicksvilie Estimated ROI (Returri on Investment) After After Control, Control, Before No Price Price 2 Control Increase Increase^ Relative Change in, R0IJ 9.3 6.5 13.2 12.2 8.5 9.8 9.5 9.5 10.8 13.2 12.2 7.8 13.5 7.8 11.0 12.5 10.0 8.9 12.2 7.8 9.5 6.1 0.6 1.3 1.0 3.4 6.0 12.7 0.7 4.9 1.9 7.7 7.0 4.1 4.4 3.9 5.1 6.3 8.4 7.2 2.3 8.6 3.3 5.3 7.8 6.0 4.5 7.5 3.1 5.6 1.4 (7.0) (5.3) (6.0) (1.3) 2.1 8.4 (5.0) 9.7 5.9 13.5 12.6 8.6 9.2 8.7 10.0 11.5 14.2 12.8 6.5 14.6 7.7 10.4 13.5 9.1 9.2 13.2 7.4 10.7 5.2 (6.1) (4.3) (5.1) 1.7 4.5 14.3 (2.8) 4A (9 j 2 3 1 (6) 8 5 6 3 5 (17) 8 (1) (5) 8 (9) 3 8 (5) 13 (15) (1117) (431) (610) (50) (25) 13 (500) Table 7-39 cont. Pantasote/Passaic Pantasote/Point Pleasant Robintech/Painesvil1e Snintech/Freeport Stauffer/Delaware City Stauffer/Long Beach Tenneco/Burlington Tenneco/Flemington Tenneco/Pasadena Union Carbide/South Charleston Union Carbide/Texas City Uniroyal/Painesvil1e 5.5 7.5 13.0 12.2 10.8 9.9 10.5 6.1 12.7 5.4 14.2 8.3 1.2 3.1 8.4 7.4 5.1 4.7 4.7 1 .0 8.4 1.9 8.5 2.2 4.9 7.3 14.2 13.0 10.2 9.6 9.7 5.4 14.3 4.1 14.5 6.5 (11) (3) g 7 (6) (3) (8) OD 13 (24) 2 (22) Iprofit after tax total investment (estimated). ^Increase in price required to recover total annualized cost plus a 20% before-tax return on total control capital. Calculation (refer to Table 7-37 and 7-38 for cost details): Price Increase = 0.20 ($231,364,000) + $89,240,000 5,755,000,000 , = 2.35*/lb ~R0I after control (with price Increase) relative to ROI before control. 4( ) denotes decrease/loss. COLORITE 008755 wammmmr (T,,o`ie cere, nued) t/nission .Source Total Captured Emissions (Thousand lb/.yr) 1J . Fugitive (Excl. Water Stripcing) 2 , belief Valve Discharge, Reactor lining J . I'icrc.i'.ar Recovery System 4 . .;u,r/ "ana, Centrifuge, Dryer, iu'.k S r.i-a.'c- and Transfer 0 . Water 2-ripping 2025 989 2550 (Incl. Above} 81 ta ! Case d (PVC) 5645 Total Annualized Cost (Thousand $/.yr) CE 2 Ratio (*/lb VCM removed) CE ,, Rank" Rel atknshi p Most Cost Effoctivi OctiorT 278 0.14 2 7:1 306 0.31 4 16:1 4292 1 .68 8 84 :1 (Incl. Above) (Incl. Above)(incl. Above) (Incl. Above) 621 7.64 10 3 2:1 5497 0.97 n 49:1 .^Includes recovery credits. fYotai annualitea cost divided by controlled emissions. eguils nc-c effective. "^CE ,\.lio of o;;Lion divided by CE ratio of most effective option. COLORITE 008756 jl : M ;i Table 7-40. Existing PVC Plants - Capital Summary Control Scenario #3 f' iy lit'i,i;-/;.OC5tion Pro/u,; Wert City (T ^ i .UksCu^j/ Ck C01 81 i:.. F. Jn.:h/Avon Lake F. C ii.'.F-ich/Henry F. f. Cocdi ch/Long '3each t. F. Goodrich/Louisville r . r. C o vir i c h/ P ed r i c k town l"irden/l i iopol is itc-ruen/Lr'; ;i:istor Conti non ...,1 Ci 1/Aberdeen [ oniVitnUi Gil/Oklahoma City Cforiiont. Sharrircc:i/Delaware City ''lieiro'id Sharnrock/Deer Park i'O'.: erernce!/Midland Fthyl/iiafcu.i Rouge Ki v'-esi.on..'/Perryville ; i res Pott s town - --- ------ - vi'i,: Vire/Ai-.uibula /Ji;. ,'-.civ Fr/Plaqu online ,'jj : .'t^.r/.Siag.*. a Falls `CO j,jV:t; '/1' ( : eeifii fts Cr v--,t Americau/l-*i cchburg jciciu/Torraive j nv.t/Tuck.v .i.fu./:/.ci :cot /.eysor-Cesiury/Saugus onsarito/tj.-i ng field sT,oidenui retro'leum/Burlington locidental Petroleum/HIcksville , 'sntasct 0 1 3a SSo i c as .:/ -; : 1 ,i t Pleasant ac cl ;iuc: r./ P an e s v i 11 e - Capacity {Million lb/yr) 135 75 260 220 115 145 140 140 175 260 220 100 270 100 160 230 170 125 220 100 105 70 4 6 5 35 70 ____170______ 15 60 95 250 i Air1 $(000) $4,315 3,537 9,363 9,787 4,057 . 6,765 7,414 4,354 4,743 6,087 5,986 6,159 6,181 3,865 9,745 5,338 14,620 4,172 5,240 4,298 1,350 3,521 1,729 1,907 1,822 2,459 8,850 ___ 1.718 2,049 2,850 3,820 5,530 Estimated Capital Requirement Water" Total ${000) ${000) tn b/ $1,134 630 2,184 1,848 966 1 ,218 1 ,176 1 ,176 1,470 2,184 1,848 840 2,268 840 1,512 1,932 1,428 1,050 1,848 840 882 588 34 50 42 294 588 1.428 126 504 798 2,100 $5,449 l, . (;, 4,167 5.56 11,547 4.44 11,635 5.29 4,923 4.28 7,983 5.51 8,590 6.14 5,530 3.95 6,213 3.55 8,271 3.18 7,834 3.56 6,999 7.00 8,449 3.13 4,705 4.71 11,257 6.25 7,270 3.16 16,248 9.56 5,222 4.13 7,088 3.22 5,138 5.14 2,232 2.13 4,109 5.87 1,763 44.06 1,957 32.66 1,864 37.28 2,753 7.87 9,438 13.48 3.146____ _____1.85 2,175 14.50 3,354 5,59 4,618 4.GO 7,630 3.05 COLOR!TE 008757 Table 1MJ cz,vc. Shintech/Freeport Stauffer/Delaware City Stauffer/Long Beach Tenneco/Burlington Union Carbide/Texas City Unircyal/Painesville 220 175 150 165 300 no 5,755 5,673 8,852 5,767 9,165 8,055 9,539 $225,564 1,848 1,470 1,260 1 ,386 2,520 924 $48,342 7,521 10,322 7,027 10,551 10,575 10,463 $273,906 3.42 5.90 4.68 6.39 3.53 9.51 4.76 Dispersion_plants at Alternative II, Case B (incineration), all other plants at Case A {improved stripping). ^Costs developed using Table 7-6 and specific plant process information. Effluent costs based on Table 7-16. 3 ruoi COLORITE 008758 Table 7-41. Existing PVC PlaT^F- Annualized Cost Summary Control Scenario #3 PI ant Owner/L-cation Capacity (Million lb/yr) Annualized Costs, Air1 Water'1' $(000) $(000) VCM Charge1* $(000) Total ${G0Q)/.yr c,' i e Cap;.- r vr J:,c P /Cod vert City 135 $1,205 t i c;jjctc/F'eriSacoia 75 1,087 !. P. Ccodri,:h/Avon Lake 260 6,120 5. ;T. i'.cdrich/Henry 220 7,064 !). r. C-xm-.ch/Long Beach 115 1,166 B. r. Goodrich/'..`luisvllle 145 4,331 B. r. Coocl'-icii > >-dr 1 cktown 140 5,575 p ji-db- 5i icoc'! is 140 1,206 P'ov'dtii i / i.irOi.vi rsror 175 1,214 Continental Pi'!,/3oerdeen 260 1,449 C mi; ificr.t'/i Oil/Oklahoma City 220 1,508 .'i?.1.- G-..jcrock/Deiaware City 100 3,734 `jiunSufic Sbac-.-ock/Deer Park 270 1,458 Djvf Chetnc.-.!. iiund 100 1,137 ttliyl/tatCii r vjvu- 180 7,483 jrestone/Pcrryvfile 230 1,325 ''irastoae/fctt1. ;.own 170 12,668 .t2i'ii! 0. 1 ! \fcjr. |'| tabula 125 1,180 3vlPi i:it ic/P1 aquernine 220 1,315 xcra .kills 100 1,226 -V-^dT"7^:crt^U^T:H'rS` -- " ---- -------- ----------------- 105 ---------------- 919 ro.-it Arxv K-cn/ti/chburg 70 1,161 j .'iUt/ToiTurce 4 1,460 r .psiit/Tpcker 6 1,758 ; my t/5< -C,crset 5 1,613 keysor-Century/Saugus 35 891 lor.santo/Springfleld 70 8,716 i'cci Jental Petroleum/Burlington 170 1,199 I'ccidental Petroleum/HicksvIlle 15 806 .antuJOta/Passaic 60 932 i ..ntascte/Point Pleasant 95 1,134 NO h i r, r.c n / P n.:v ill e__________________ ___________ 250____________ _____ 1,343 $243 135 468 396 207 261 252 252 315 468 396 180 486 180 324 414 306 225 396 180. - 189 126 7 11 9 63 121 306 27 108 171 450 $486 270 936 792 414 522 504 504 630 936 792 360 972 360 648 828 612 450 792 360 ------- 378 252 14 22 18 126 252 612 54 216 342 900 $1,934 1,492 7,524 8,352 1,787 5,114 6,331 1,962 2,199 2,353 2,696 4,274 2,916 1,677 8,455 2,567 13,536 1 ,855 2,503 1,766 1,486 1,539 1.481 1,791 1,640 1,080 9,094 2,117 887 1,256 1,647 2.693 1 .4 i 1* 2. /: 3.75 1 .'I 3.53 4.52 1.40 'l < J'f. , .1r 1 . OS 1 .68 4. / J 1.12 7.09 1 . `iO 1 .i4 T /' {. ,, p i, 37 : 29.55 32 .S-. 3. C;_12.99 1.25 5.91 2.CS 1.75 1.00 COLORITE 00875 jr Tdule 7-41 coot. Shintech/Freeport Stauffer/Delaware City Stauffer/Long Beach Tenneco/Burlington Tenneco/Flemington Tenneco/Pasadena Union Carbide/South Charleston Union Carbide/Texas City Uni royal/Painesville 220 175 150 165 70 240 60 300 110 5,755 1,404 6,091 1,597 6,580 1,081 1,102 5,704 2,066 7,867 $118,915 396 315 270 297 126 432 108 540 198 $10,359 792 630 540 594 252 864 216 1,080 396 $20,718 2,592 7,036 2,407 7,471 1,459 2,398 6,028 3,686 8,461 $149,992 1 .18 4.02 1 .60 d.53 2. CP 1 .00 10.05 1 .23 7.69 2.61 Dispersion plants at Alternative II, Case B (incineration), all other plants at Case A (improved stripping). ^Ccsts developed using Table 7-6 and specific plant process information. ,Effluent costs based on Table 7-16. "VCM charge from Table 7-26 (footnote #2). COLORITE 008760 Table 7-42. Existing PVC Plants - Profitability Summary Control Scenario #3 i>..V'7Location Air Products/Ca'vert City A'r r'\uvct:,/njRsacola il. ri-'r/Avon Lake 3. F. to. ;,"o -ienry li, F. Goc- r :c.i/Long Beach E. r. Green irh/Leulsville ti. r. G our if1' /Peoricktown Gordon/11 ;. Scrdr.-i./Leoji err Continental t`i 1/Aberdeen Continental :i/Oklahoma City LH;oo;v; Shanreck/Dalaware City OkOoy ck/Deer Park 0;,'.. Ci:orfiical/Midland Ethyl/Gaton Gouge 1- i r i o tone/: or ryv 111 e i Ir-stcne/Pottstown Tin a/Ashtabula Ccorgia-Pec-. oc/Plaquemine Goodyear/Mia;.ora Falls o oo dyea r/ P1 a q u am i ne ... rea t Arner i ca r;/ fi tchburg Aennat/Torrance Jermut/Tucker Jennat/Sem :rset Key s or-Centu ry/Saugus 1-ionsanto/Sprinqfield Occidental Petroleurn/Burlington Occidental Petroleum/Hicksville ______ _____________ Estimated ROI {Return on Investment) After After Control, Control, Before Mo Price Price ,, Control Increase Increase^ ~ 0 i c s \f C '^ngo In.. \nrJ 9.3 6.5 13.2 12.2 8.5 9.8 9.5 9.5 10.8 13.2 12.2 7.8 13.5 7.8 11.0 12.5 10.0 9.9 12.2 7.8 9.5 6.1 0.6 1.3 1.0 3.4 6,0 12.7 0.7 4.9 12.2 1.9 7.9 3.C 12.0 1.2 8.9 4.2 11.2 0.7 7.7 (1.3) 5.5 5.1 12.5 6.3 14.2 8.4 17.3 7.2 15.6 (1.3) 4.7 8.6 17.6 3.3 9.0 (1.2) 6.0 5.9 (1.6) 14.6 2.6 9.5 11.6 7.5 16.1 3.1 9.6 5.6 13.3 1.4 7.2 (12.2) (il.n) (11.1) (9.7) (11.6 (10.3) 0.3) 3.3 (6.9)--------- ____(3.7)_____ 8.4 17.4 (5.0) (1.7) 22 (?v' C- i 21) (''2) 22 31 31 28 {401 30 15 (45) 17 (74) 30 32 23 40 18 (1933) (84C) (1130) (3) {162} 37 (343) COliORITE 008761 Table 7-42 cont. Pantasote/Passaic Pantasote/Point Pleasant Robintech/Painesville Shintech/Freeport Stauffer/Delaware City Stauffer/Long Beach Tenneco/Burlington Tenneco/Flemington Tenneco/Pasadena Union Car./ide/South Charleston Union Carbi, j/Texas City Uniroyal/Painesville 5.5 7.5 13.0 12.2 10.8 9.9 10.5 6.1 12.7 5.4 14.0 8.3 1 .2 3.1 8.3 7.4 0.1 4,7 (1.0) 1 .6 8.5 (4.5) 8.5 (6.6) 6.8 9.5 17.2 15.8 7.3 12.0 6.0 7.4 17.4 1.4) 17.6 (0.9) 24 27 32 30 (32) 21 (4 L 3n\ ) 37 (126) 24 (HD 2?rofit after tax * 'total investment (estimated). ^Increase in price required to recover total annualized cost plus a 20% before-tax Calculation (refer to Table 7-40 and 7-41 for cost details): Price Increase = 0.2 ($273,906,000) + $149,992,000 57755,000,000 3 = 3.56/lb RQI after control (with price increase) relative to ROI before control. ^( ) denotes decrease/loss. return on total control capita COLORITE 008762 Table 7-43 Existing PVC Frants - Capital Summary Control Scenario #4 'jAr:L -at ion 'i 'Vc uiiV'j'/Calvert City ' /r-v-nsjcolc, l ' , \ . Coe:.' cb/Avon Lake 3. r , Co -.'r i ch/Honry . F. Cue cb/Long Beach ' \ Gcov. , ich/loiiisvll le . . Goodrich/Pedricktown oC.-'Ct.n/I i iopol 15 C'.-.i'i/Laciin a star Conti nun:'. ui i/Aberdeen continent... Oi 1/Oklahoma City uiarMnc S'n,.1.',rock/Delaware City CiamDnd SiiaiVircck/Deer Park cow Chernc-..!/Hieland c -ay'i /bev.-' Rouge -A rc-stone/:-erryv 11 le i'ir-iStone/Pottsicwn C. r ara 1 Ti re/A;!:onbu 1 a gia-Pacifi; ''Plaquemine ; o^./car/HiagUi; Falls . 0 cy oa r / P1 a c u c" i i ri e u'-oit Ai'icrican/r i tchburg }i:ro.at/1 oi'ranee J'-nn.jt/Tucrer 1 .! ra A'Sciiirrset -\:yor tui'y/Saugus orsan to/Soring! ie Id O-.aidentc. i kutrcUu.m/Burl ington Occidental PetrcAluum/Hicksvf 11 e Pantasoae/Passaic .'\.r,tascie/Point PI easant ,-o Lantech/ :-ai lucville Capacity (Million lb/yr) 135 75 260 220 115 145 140 140 175 260 220 100 270 100 180 230 170 125 220 100 105 70 4 6 5 35 70 170 15 60 95 250 1 Air1 $(000) $6,362 4,491 12,065 11 ,794 5,831 8,318 8,200 6,468 7,338 9,856 8,889 6,979 10,088 5,433 11 ,189 8,693 15,131 6,081 8,456 5,866 1 ,667 3,874 1,729 1,907 1,822 2,640 8,850 2,263 2,114 3,608 5,041 9,161 Estimated Capital Requirement Water1- Total $(000) $(000) tt 1 b/yr $1 ,134 630 2,184 1,848 966 1 ,218 1 ,176 1,176 1,470 2,184 1 ,848 840 2,268 840 1 ,512 1,932 1 ,428 1,050 1,848 840 882 588 34 50 42 294 588 1,428 126 504 798 2,100 $7,496 5,121 14,249 13,642 6,797 9,536 9,376 7,644 8,808 12,040 10,737 7,819 12,356 6,273 12,701 10,625 16,559 7,131 10,304 6,706 2,549 4,462 1,763 1,957 1 ,864 2,934 9,438 3,691 2,240 4,112 5,339 11,261 'J , ") 'J ri 5.J C. 20 5.91 6.50 6.70 5.46 5.03 4.63 4.88 7.80 4.50 6.27 7.06 4.t2 9.74 J . T/ Ou 4. C8 6.71 2,43 6.37 44.03 32.62 37.28 8.38 13.48 2.17 14.9 3 6.85 6.15 4.50 COLOR!TE 008763 ,i t) i li` cent. Sr,intech/Freeport Stauffer/Delaware City Stauffer/Long Beach Tenneco/Burlington Tenneco/Flenington Tenneco/Pasadena Union Carbioa/South Charleston Union Carbide/Texas City Uniroyal/Painesvi1le 220 175 150 165 70 240 60 300 no 5,755 8,889 10,486 7,150 10,595 4,374 8,927 7,254 13,488 9,080 $293,247 1,848 1,470 1,260 1 ,386 588 2,016 504 2,520 924 $48,342 10 737 11,956 8,410 11,981 4,962 10,943 7,758 16,008 10,804 $341,589 4.88 6.83 5.61 7.26 7.09 4.5C 1 3.93 I .34 9.82 5.94 loispersion plants at Alternative II, Case B {incineration). All other plants at Case B (incineration). ^Effluent costs based on Table 7-16. U) COLORXTE 008764 Table -44. Existing PVC Plants - Annualized Cost Summary Control Scenario #4 Plant Owner/Location Air Products/Oolvert City Air Products/Ptnsacola S. F. Goodrich/Avon Lake B. F. Goodrich/Henry B. F. Goodrich/Long Beach 3. F. Goocirich/Louisville 5. F. Goodricn/Pedricktown Borden,/II iopol is Border/L oo, ni aster Continoata. Oil/Aberdeen lontlnenta! Oil 'Oklahoma City jiamend Siiamroc;-/Delaware City v ifjc-iici Snamrock/Deer Park O' Cheniccl/Viidland irryi/Bauer Gouge Fire scone/Pc rryvi11e Firastone/Pottstown C one tail T i re / As h ta bu 1 a Georg "iC-Pac if ic/Plaquemine . .rO.:yea.r/Niacara Falls b o o dyea r/ P1 a q u am i a e u re a t Ajv.g r i c a n,' F i tc h bu rg Oanriat/Turrar.ce dennat/Tucker Jennat/CesTierset /eysor-Century/Saugtis (Sonsanto/Springfield Occidental Petroleum/Burlington Occidental Petroleum/Hicksvilie Pantasote/Passaic Pantasote/Point Pleasant kobintech/Painesvilie Capacity (Million lb/yr) 135 75 260 220 115 145 140 140 175 260 220 100 270 100 130 230 170 125 220 100 105 70 4 6 5 35 70 170 15 60 95 250 Annualized Costs,, Air Water`d $(000) $(000) $5,126 3,463 10,517 10,357 4,605 7,002 7,189 5,244 6,099 11,203 7,244 5,582 8,364 4,207 9,865 7,381 13,491 4,862 7,155 4,296 1,564 3,229 1,460 1,758 1,613 2,101 8,716 2,080 1,388 2,907 4,026 7,828 $243 135 468 396 207 261 252 252 315 468 396 180 486 180 324 414 306 225 396 180 189 126 7 11 9 63 126 306 27 108 171 450 VCM ~ ChargeJ $(000) Total ${000)/.yr i/lb Capacii $486 270 936 792 414 522 504 504 630 936 792 360 972 360 648 828 612 450 792 360 378 252 14 22 18 126 252 612 54 216 342 900 $5,855 3,868 11,921 11,545 5,226 7,785 7,945 6,000 7,044 12,607 8,432 6,122 9,822 4,747 10,837 8,623 14,409 5,537 8,343 4,836 2,131 3,607 1 ,481 1,791 1,640 2,290 9,094 2,998 1 ,469 3,231 4,539 9,178 4v a. 16 :-.5P b.25 4.54 5.3/ 5.69 4.29 4.03 4.S5 3.83 6.12 3. 4. "5 6.02 3,75 8.4S 4.43 3.79 4.84 2.03 3.1 5 37 .03 25,:' u 32.55 C.u4 1 2,55 1 .7-5 9.79 5.39 4.7 2 3 LV I COLORITE 008765 f Table 7-44 cent. 0S% Shintech/Freeport Stauffer/Delaware City Stauffer/Long Beach Tenneco/Burl ington Tenneco/Flemlngton Tunneco/Pasadena Union Carbide/South Charleston Union Carbide/Texas City Uniroyal/Painesville 220 175 150 165 70 240 60 300 110 5,755 7,244 8,828 5,581 8,964 3,326 7,605 6,240 9,518 8,745 $247,973 396 315 270 297 126 432 108 540 198 $10,359 7'j2 630 540 594 252 864 216 1 ,080 396 $20,718 8,43? 9,773 6,391 9,855 3,704 8,901 6,56* 11 ,138 9,339 $273,050 iDispersion plants at Alternative II, Case B (incineration) All other plants at Case B (incineration). ^Effluent coo:; based on Table 7-16. JVCM charge from Table 7-26 (footnote 2). r 3.8b 5.53 4.26 5.97 5.29 3.71 1C. 94 3.71 8.49 4.85 COLORXTE 008766 1 Table 7-45. Existing PVC Plants - Profitability Summary Control Scenario #4 f-'i o,i i Gwi /'Location Air , r-oducvs/Calvert Citjj/ A1 v- Product::/ vnsacola :G F. Gcodri. .'i/Avon Lake . Goocinc.i/Henry o. i . Cuour i cr./Long Beach F. Goodn'ch/Lnuisvl 1 le G. F. CoodncG/Pedricktown Got aen/I i iopo,:s jorden/Leominoter Continental Oi1/Aberdeen ci.; ;r.entci 0,1/Oklahoma City ..i.onoiK Shamrock/Delaware City l.1 % -a no G.hsmrccK/Deer Park Go ; Cr.omlcal/Midiand '.tnyl/Baton Rouge .reitont/corryville i : ."w'CtL.'fic/'Pottc town - - '.ora. i r, re/Ar. htabu 1 a G" r cj i a - Pa c i f 1 c / P1 a q u em 1 ne u: jdj^'cr/Ni aga ra Palls Co o dyea r/P1 au uam1n e G ra i k\r i c a n / F i tc h b u r g . emUt/ f . iVJOce 0.01011/ E U C k 'c r oannat/Somerset K eyso r-Co n tury/$ ugu s Monsanto/Springfield Occicental Petroleum/Burlington Occidental Pec-cieum/Hicksvine Estimated RQI (Return on Investment)^ Before Control After Control, No Price Increase After Control, Price 2 Increase^ Relative Change - Ain|., 9.3 6.5 13.2 12.2 9.5 9.8 9.5 9.5 10.8 13.2 12.2 7.8 13.5 7.8 11.0 12.5 10.0 8.9 12.2 7.8 9.5 6.1 0.6 1.3 1.0 3.4 6.0 12.7 0.7 (1.0) (3.2) (0.4) (2.0) 0.6) (2.8) (3.4) (0.9) 0.1 (1.0) 1.0 (4.4) 2.1 (2.2) (3.7) 1.3 (2.2) (1.3) 1.1 (2.3) 4.2 (3.4) 02.2) 01.1 01.6) (5.7) (6.9) 7.0 (8.5) 10.6 6.5 13.2 10.6 9.4 8.6 7.8 10.9 12.7 13.1 14.4 5.6 16.2 8.3 8.0 15.0 4.9 10.1 14.6 8.1 17.2 6.3 00.2) (3.7) (9.4) 2.0 0.6} 22.0 (2.9) 14 0 0. 03)4 11 (12) (19) 15 18 0) 18 (28) 20 6 (27) 20 (51) 13 20 4 81 3 (1800) (760 (1040) (41) (127) 73 (514) COLORITE 008767 l 1,111 UI'JB ,.P .... Pantasote/Passaic Pantasote/Point Pleasant Robintech/Painesvllle Shlntech/Freeport Stauffer/Del aware City Stauffer/Long Beach Tenneco/Burlington Tenneco/Flemington Tenneco/Pasadena Union Carbide/South Charleston Union Carbide/Texas City Uniroyal/Painesville 5.5 7.5 13.0 12.2 10.8 9.9 10.5 6.1 12.7 5.4 14.2 8.3 (3.9) (2.4) 1.7 1.0 (2.9) (0.7) (3.7) (3.5) 1.5 (5.2) 2.0 (7.8) r j . -j 8. i 15.8 14.4 8.8 11.2 7.7 6.0 15.4 0 16.1 1 .8 (4 ; C' 18 (19) 15 (27) (21 21 (10C) 13 (78) I Iprofit after tax *total investment (estimated). ^Increase in price required to recover total annualized cost lus a 20% before-tax return on total control capi Calculation (refer to Table 7-43 and 7-44 for cost details): Price Increase = 0.2 ($341)569,000) + $279,050,000 5.755.000,000 _ = 6.04<t/1 b ?R0I after control (with price increase) relative to R0I before control. ^( ) denotes decrease/loss. COLORITE 008768 itwprmr Table 7-46. Financial Impact of Various Control Systems at New Suspension Process PVC Plants Plant Investment (d/lb/yr) 'larking Capital local Investment Average Sales Price (<t/lb) less: Freight Net Sale:. Cost of Sales Der i'fcda i'i on Admin., Selling, R & D, Interest Toini Cost Profit Before Tax Profit After Tax RGI* Price Increase Required to Maintain Pre-control ROI i/lb (V iQ Plant Meeting Plant Meeting Effluent Regulation; Uncontrolled Effluent Regulations Plus Plant__________ (Inc!. VCM Alt. II)**_______________ Case A__________ Case_B___ 14.00 5.75 19.75 14.84 5.75 20.59 17.81 5.75 23.56 15.32 5.75 25.0/ 24.00 1.70 22.30 24.00 1.70 22.30 24.00 1.70 22.30 24.00 1 .70 22.30 15.00 1.40 1.98 18.38 15.48 1.46 1.98 18.92 16.08 1.67 1.98 19.73 18.82 1.78 1.58 22.58 3.92 1.96 3.38 1.69 2.57 1.285 (0.23) -- 9.5fX 8.2% 5.5% -- !: |1 I--Ii 0.71 3.0% 2.11 8.8% 5.26 21.9 ^Return on investment (profit after tax * total investment). **'This case represents a new plant that complies vl/ith the effluent regulations for PVC plants and obtains VCM from an Ait. 11-controlled plant that complies with the water effluent regulations for VCM plants. This VCM cost includes the cost of compliance with effluent regulations at EDC plants as well as Alt. II air emission control costs. New source water effluent regulations, equal to BAT regulations, were used. COLORITE 008769 m-W"... s' 1*0' .... ..........FM> iaU;e 7-Ao cont. NOTt: Model plant size is 150,000,000 Ib/yr. SOURCES: a) Uncontrolled model plant Investment and operating costs based upon: In-Depth Study of Polwi nyl Chloride Production, Houdry Division, Air Products and Chemicals, Inc. Dec embeF67l9 7 4\T- PVC-877Modified by EPA after discussion with Industry representatives.) b) Effluent costs based upon Table 7-16. c) Air pollution control costs from 7-8. d) VCM price Increase from Table 7-26 (footnote HZ}. COLOR!TE 008770 r. Ul Table 7-47. Financial Impact of rious Control Systems at New Dispersion Process i ... Plants . 0 `.iwestment U/lb/yr) vc'-' capital ! . vc stment Sales Price (d/lb) n eight , es r; ( *- \ c; .'nation : > Selling, , Cost R&D, Interest u . 'ore Tax 1 > nr ter Tax Increase Required to Maintain . Mirol ROI Uncontrolled Plant 47.50 8.25 55.75 34.00 1.55 32.45 21.10 4.75 3.20 29.05 3.40 1.70 3.1% Plant Meeting Effluent Regulations (Incl. VCM Alt. II)** 48.34 8.25 56.59 34.00 1.55 32.45 21.57 4.82 3.20 29.59 2.86 1.43 2.5% Plant Meeting Effluent Regulations Pm Alt. I Alt. II, Case A Alt. II, Cast 55.99 8.25 64.24 59.40 8.25 67.65 65.95 3.25 74.21 34.00 1.55 32.45 34.00 1.55 32.45 3-1.00 1.55 32.45 23.60 5.47 3.20 32.27 25.17 5.76 3.20 34.13 36.38 6.32 3.20 45.00 0.18 0.09 (1.68) (13.45) 0.1% -- -- 0.59 3.74 5.81 17.93 -- 1.7% 11.0* 17.0% 52.0% '.turn on investment {profit after tax * total investment). case represents a new plant that complies with the effluent regulations for PVC plants and obtains VCM from an H-controlled plant that complies with the water effluent regulations for VCM plants. This VCM cost includes the ccs>' compliance with effluent regulations at EDC plants as well as Alt. II air emission control costs. Hew source -r effluent regulations, equal to BAT regulations, were used. c: Model plant size is 30,000,000 Ib/yr. ~i.f.LS: a) Uncontrolled model plant Investment and operating costs based upon discussion with Industry representatives. b) Effluent costs based upon Table 7-16. c) Air pollution control costs from Table 7-9. d) VCM price increase from Table 7-26 (footnote #2). n COLOR!TE 008771 Table 7-48. Effect of Economies of Scale on New Dispersion Process '-'VC PI an is Plant Investment U/lb/yr) Working Capital Total Investment Average Sales Price (C/lb) Freight -;t Sales Cost of Sales Oapreciation Acu.l1 n., Selling, l o cs 1 Co S "t ROD, Interest Profit Before Tax Profit After Tax ROP Price Increase Required to Maintain Pre-control ROI C/lb % Uncontrolled Plant 33.10 5.75 38.85 34.00 1.55 32.45 21.10 3.31 2.23 26.64 5.81 2.905 7.5% Plant Meeting Plant Meet ing Effluent Regulations Effluent Regulations PI us (Incl. VCM Alt. II)** Alt. I Alt. II, Case A Ale. II, Ca I 33.94 5.75 39.69 36.74 5.75 42.49 38.68 5.75 44.43 1 h 0 'j 5.75 51.98 34.00 1.55 32.45 34.00 1.55 32.45 34.00 1.55 32.45 34.00 i , C5 32.15 21.57 3.38 2.23 . 27.18 22.34 3.62 2.23 28.19 23.39 3.79 2.23 29.41 31.7? 4.43 2.25 op // I 5.27 2.635 4.26 2.13 3.04 1.52 (6.00) -- 6.6% 5.0% 3.4% -- -- 0.66 2.09 3.60 12.77 -- 1.92 6.2% 10.6% 40.53 - "Return on Investment (profit after tax * total Investment). **This case represents a new plant that complies with the effluent regulations for PVC plants and obtains VCM from an Alt. Il-controlled plant that complies with the effluent regulations for VCM plants. This VCM cost includes the cost of compliance with effluent regulations at EDC plants as well as Alt. II air emission control costs. New source effluent regulations, equal to BAT regulations, were used. nOTt: Hooel plant size is 100,000,000 Ib/yr. COLORITE 008772 '-X: | -j '-.Li )-49. Financial Impact of Variousj Control Systems at New Bulk PrcScess PVC Plants [1 i i Uncontrolljed Plant Plant Meeting Effluent Regulations (Incl. VCM Alt. II)** ! Plant Meeting Effl uent Regulat Plu s Case A Case 6 Irivx -xx.. . 1 r ' ~, 1 1;,. . , '.a.'. lb/yr) 16.72 4.43 21.16 17.56 4.43 21.99 18.87 4.43 23.30 19.17 4.43 73760 .X .x' , Lb /."'.u: (q/lb) 24.00 1.50 22.50 24.00 1.50 22.50 24.00 1.50 22.50 24.00 1.50 22.50 J,Vi , : , -C \ f. t "i i Vi i ..j_ ; ? p, Interest 14.00 1.67 2.91 18.58 14.47 1.74 2.91 19.12 15.27 1.84 2.91 20.02 15.88 1 .86 2.91 20.65 -s'. i\; " ' 1 i ,-*T 0. ' 1 wx 3.92 1.96 3.38 1.69 2.48 1.24 1.85 0,925 1... F . ii vred to Maintain 9.3% 7.7% 5.3% 3.9% COLOR!TE 008773 , ;< -- 0.69 1.84 r, r- n 1 2.9% 7.7% 10.5% v,; rnvvxx.ent (profit after tax total Investment). xxs "xprxe-nts a new plant that complies with the effluent regulations for PVC plants and obtains VCM from an A1 :.':rci ;.;o plan: tiut compl ieswith the water effluenj: regulations for VCM plants.. This VCM cost includes the cost of i'w.ncx v'.',effluent regulations at EDC plants &s: well as Alt. II air emission control costs. New source water .i-'iwrit regulations, equal to BAT regulations, were used. l x Music! x ..t site is 100,000,000 Ib/yr. - ,;x 5: a) Un'. ntrolled model plant investment and operating costs based upon discussion with industry representatives b} Ei'fluent costs based upon Table 7-16. c.) i\vr pollution control costs from Table 7-10. ul 7CM price increase from Table 7-26 (footnote #2). This chapter presents the rationale fc- t he selection of the emission sources, emission limits, ard testing, reporting. and recordkeeping requirements included in the proposed standard. The alternative control levels discussed in Chanter 5 which have been selected as the basis for the proposed standard are identified and the reasons for selecting them are discussed. Some of the data in this chapter are extracted from Chapters 2 through 7___ since those chapters contain the information on which the rationale for the proposed standard is primarily based. Therefore, the references for the data included in this chapter can be found in Chapters 2 through 7. 8.1 Selection of Emission Sources to be Covered By the Proposed Standard For the reasons explained in Chapter 2, EPA has .determined that ethylene dichloride-vinyl chloride plants and-polyjanyJ.-chlxra.de. _______ plants are to be-covered by the proposed standard. As explained in. - - VI Chapter 1, the term "ethylene dichloride-vinyl chloride plant" refers to any plant which produces ethylene dichloride (by the oxychlorination process), vinyl chloride, or both ethylene dichloride and vinyl chloride. As noted in Chapter 5, EPA has concluded that, for purposes of regulating vinyl chloride, best available control technology means control of all emission points within ethylene dichloridevinyl chloride and polyvinyl chloride plants. There are control A technologies which have been used for each type of emission point, and regulation of only so^e of the emission points was determined SSsgKS*: COLOR!TE 008774 to be less than best available control technoloay. Thus, the proposed standard applies to all of the major nrocessina equipment in ethylene dichloride-vinyl chloride and polyvinyl chloride plants. Emissions from both normal operation and from relief discharges are to be regulated. Relief discharges are included because they cause short term high level emissions which can be prevented in almost all cases. Two sources of vinyl chloride need explanation. First, the reactor may, in some polyvinyl chloride plants, serve also as the stripper. When this is the case, the regulation controlling reactors is applicable. Second, the definition of stripper for all resins except bulk resins includes "in the slurry form" so that other vessels, e.g. silos, following this stage of the process will not be considered strippers. Likewise, the definition of stripper for bulk resins does not include silos. The proposed standard also applies to all known fugitive emission sources, including equipment used for loading (or unloading) vinyl chloride monomer into transfer equipment from storage vessels, slip gauges, leakage from seals on pumps, compressors, and agitators, leakage from relief valves, manual venting of gases, opening of equipment such as for maintenance and inspection, flasks used in obtaining samples of vinyl chloride monomer, leakage from equipment, and inprocess wastewater. Although the emissions from each of these sources when considered individually may appear relatively small, they are included in the proposed standa''d because when combined they represent a significant portion of the total mt emissions. Eased on data reported to ERA by individual cnspan'es In the spring of 137^, fugitive emissions represented approximately 70 percent of the u.h;al emissions from polyvinyl chloride COLORITE 008775 pi;,;,, t, apc-'f) ; percent of V,e to:al e ,i sf i ons fro- ri.-vUr.. f i CP 1 o r"i i'll'.-'fr pi:".-;. Inuroocs^ was tewat er is. i r-ic" i ucipci in the i i.; r iijgitive pn i s "ion source; 0 :; : ; e c t to the proposed standard because available data indicate that vinyl chloride contained in water exposed to t>e atmosphere is lost rather rapidly. Precise measurements have so: beer, made to prove that this vinyl chloride is emitted to the air. However, as explained in Chapter 4, section 4.10, data on the solubility of vinyl chloride in water indicate that this is likely to be the case. For several of the fugitive emission sources, the proposed standard applies only to those pieces of equipment "in vinyl chloride service." This term is defined to exclude pieces of equipment such as pumps and storage containers which are used to handle materials other than vinyl chloride and which contain essentially no vinyl chloride. Two fugitive emission sources which were considered for specific regulation but which are not included in the proposed standard as such are vacuum pumps and steam jets. It was concluded that a separate regulation is unnecessary because more general regulations are included which already cover vacuum pumps and steam jets. For example, steam jets used to displace vinyl chloride or other contaminants from equipment are covered by general regulations controlling the removal of vinyl chloride from equipment by any means. 3.2 Rationale for the emission Limits The purpose of tft proposed standard is to minimize the risk to the public neaith by setting emiss1 an limits which will reduce emissions to 8-3 COLOR!TE 008776 trie level attainable with the best available control technology for each emission source ir. ethylene dichloride-vinyl chloride and polyvinyl chloride plants. Since there are many technical decisions involved in developing a standard on the basis of "oest available control technology," EPA has established two criteria for making the technical decisions. The two criteria--use and adaptability, and costs--are discussed in Chapter 5. The final decisions on standards for all emission sources in ethylene dichloride-vinyl chloride and polyvinyl chloride plants were based on data on control systems received through requests for information under the authority of section 114 of the Clean Air Act, on-site observation of plant processes, consultation with industry representatives and control equipment vendors, an emission test, and two studies completed under contract to EPA. See Chapter 4 for the results of these investigations. Evaluation of all data led EPA to conclude that there are only two emission sources for which there was any question in selecting an emission limit based on the established criteria for best available control technology. The reasons why there is some question about these particular emission sources are explained in Chapter 5. These two, the oxychlorination reactor in ethylene dichloride-vinyl chloride plants and the sources following the stripper in the manufacture of dispersion resins in polyvinyl chloride plants, are discussed under 8.2.1 and 8.2.2, respectively. Emission sources for which an emission limit could be seleced without any guest-ion based the established criteria for "best availed:; control technolog/' j. 8.2.3 and 8.2.4. trussed in COLOR!TE 008777 yv i] ,, ci i r : ' r, ^ > i c' n t S ; t y"! ^ r' o T i eh". ; ' i -V i n / i c. i/.j; f.'>~ gv-> o/;.'.'':,. -fun rc-.-r:tor concerned the intci'i L^L'icn of she second criterion for best available control t^chnolo r-', i.e., are the costs of controlling the effluent gas suear from the oxychlorination reactor grossly disproportionate to the degree of emission reduction which would be achieved by that control? As discussed more completely in Chapter 5, EPA identified three alternative control levels for the oxychlorination reactor: (1) no control, (2) that which is equivalent to controlling process variables, and (3) that which is equivalent to control by incineration. The emission factors, mass emissions, percent control, hydrogen chloride emissions, energy consumption, and costs for an average-si zed plant (318 million kilograms or 700 million pounds of vinyl chloride produced per year) attaining each of these alternative control levels are displayed in Table 8-1. The emissions from an uncontrolled plant are also shown. The alternative of proposing an emission limit which is equivalent to control by incineration was rejected for the following reasons. The oxychlorination reactor has a large volume, low hydrocarbon concentration effluent gas stream, and large quantities of supplemental fuel would be required for its combustion. One company has reduced the gas volume from the oxychlorination reactor and the associated energy costs by recycling the process gas stream and using oxygen instead of air to feed into the process. A second company is also planning to install this technology. Although the recycling and oxygen feed methodolcnv can he used for two types of oxychlorination 8-5 COLORITE 008778 TAbIL ,i-l AlTf I'V,']'l, o'MMl `OR TYPICAL [ 318 MILLION KILOGRAMS (700 POUNOS) PER YLAR] ETHYLENE I'JC'HLORlOE-'/INYL CHLORIDE PLANT1 'LTEMLT] jr LTtrua LEVEL EMISSION'S, KG/ion KG KG/NR (LB/1W 16) (LB/MB) CMISMON REHLICTI PERCENT I'i.i" ON! |J\ lEP EMISSIONS h r. r . i v e t' issitvns 0 i 'n /1 ere U , Unride r i fi c '> l or nri l, 0.122(0 1721 0 OSOfn 050) 47.8(106,7) 13 7-43.fi) O.n n,fi 24f:l *A 5 f ? 1 J 0 'J : u, (0 ("( M l f 3 31 1 'i n-tiif,' 1 " Uf.lU'Jl HC1 EMISSIONS FROM CINE RATOS?-SCRUBBER KG/HR (LB/KR) ANNUAL ENEr'G i CONSUMPTION, WKCAL./YR POWER, (mm btu/yr) Oonn KUH/YR) COSTS, CAPITAL, fivftJAL $1000 jinoo ' f i1 11 v o 1 1 1 oris i l 1 ., U rt I'M 1 >nde l Mirwl L.'i r>. m ii so i ' d . Ihu ',,73"' n.01 ?(0 "M) p OOf.fn ono) 4 7(in.f.) U'Oly 00 00 a pnofn 030} n n (f,i n nv) n n-i r or. a i :n'0) in l.ii 6) 1l n a i 4 i 09 0 90 ,,l ' f j 'i.ns 1 l| ............ 1 i,J 1 nde 11 '.I Hr, 1 i i, N >31217 01? 0 ' "10 000} 4.7(10 61 0 [0} y., qo I'M 'Ki, 0 film'O.n,T 0 (0) tin r ,1m FklTcur:-i'i vt ` 1 \ IT ^ j n rn? 3 6(12.6} ft n " vii> ft:,?) --- ------------------------ :n mu : ------------------- - - A F.qnive 1' ,i1' i nns o oim ni?} i, l L11 v I i*m Min,-uie F-,r,i it a o.CHiufa O'1 >\ i. \ i ','1 Cl. or. j.- Foriaation a 1J Pun riCd t ion O.OOOfO OO'I 'i Lxycrl^r na r i-cn CL 00 21/9 Ml?) 1 -(if) (;) ,1(01 0(0) 0 0(1 B) 00 99 00 93 'em n,0Hfr."'' 31 b 4) 97 * 5 5(1?.?) (See fijotnote 3) 8.B{15} Netil loiLk' (See footnote- 3) 74,600 (296,000) 1 ,27? tp (' cc i 41,003 51,037 COLORITE 008779 ^-rijp-es GOOD hr/yr operation. emission factor fs In terms of ethylene dichToHde nroduct from the oxvchlorlnation nrocess. The remaining emission factors in terms of vinyl chloride product. "'kita for Alternative II are not presented because the secondary environmental and economic imnacts resulting from control systems ired tu attain the emission level of Alternative II would vary for Individual plants, depending on the type of control system used for the oxychlonnatlon process. For individual plants, control of the oxychlorination process to attain the emission level of Alternative II could range from no control to a process change to incineration. Therefore* the secondary and economic limnots for Alternative II could ranqe between that of Alternative 1, which represents no control of the oxyclil orinatfon proie^s* to that of Alternative III, which represents incineration of the emissions from the oxyclilorlnation process. Most existing plants can attain Alternative II control level without controlling the cxvchlori nation crocess; however* one plaint would possibly h?ve to use 1ncideration. reactors, further research would he needed to determine whether this technoloqv can be used for each of the types of processes at all of the plants. A third company is conducting a pilot study on controlling the oxychlorination reactor emissions with catalytic oxidation, another method for reducing the high energy costs. This system has not been used commercially for the oxychlorination reactor and it is not known at this time whether it will be feasible for the plants to use. These facts, combined with the fact that the oxychlorination reactor represents a relatively small emission source at an average Diant, led EPA to conclude that the energy costs of incinerating the large volume, low hydrocarbon concentration effluent gas stream from the oxychlorination reactor at the averaqe plant would be grossly disproportionate to the emission reduction achieved. The same factors which were considered in eliminating the alternative of proposing an emission limit achievable by incineration or equivalent favored the alternative of no controls at any plants. If the alternative of no controls for the oxychlorination reactor were adopted, the proposed emission limits for the other two point sources and the fugitive emission sources would still reduce emissions by 90 percent at an average plant. Due to process variables, however, there is a wide range in the reported emissions from the oxychlorination reactor at the various plants from 0.0024 kg/100 kg to 0.106 kg/100 kg ethylene dichloride product (0.0024 lb/100 lb to 0.106 lb/100 lb). In terms of mass emissions per unit time, the emission rates vary between 0.5 to -16.3 kg/hr (1.2 to 103 lb/hr) 8-7 COLORITE 008780 among the plants. Thus, the alternative of no controls foarr the oxychlorination reactor was rejected because at some plants, unlike at the average plant, the oxychlorination reactor represents a relatively large source of emissions and in EPA's judgment, the energy costs associated with incineration of the emissions from the oxychlorination reactor would not be grossly disproportionate to the emission reduction achieved at these plants with the emission rates at the upper end of the range. Thus, the alternative selected as the basis for the proposed standard limits vinyl chloride emissions from the oxychlorination reactor in ethylene dichloride-vinyl chloride plants to 0.02 kg/100 kg ethylene dichloride product. Eased on individual plants' measurements of vinyl chloride reported to EPA under section 114 of the Clean Air Act, this emission level represents best available control technology through control of process variables and can be met at most plants by maintaining operations so that the emission rate (kg/100 kg) does not increase. The proposed emission limit is essentially a cut-off point which requires the plants at the upper end of the range to reduce emissions preferably by instituting process changes, and if this is not possible, by installing incinerators or equivalent add-on control. Incinerators or equivalent add-on control may have to be used to attain the proposed standard at a maximum of one existing plant which has relatively large emissions (in addition to those companies which have already installed, or are already planning to install, incinerators). Eased on available data, emissions from the oxychlorination reactor at fi'o majority of the axis! inn plants rr 1 r,cj the green-,ed s;anOat,i ;n,g; tv COLORITE 008781 below 4.5 kg/nr (10 !b/hr) and the emission:, from no plain would exceed 9.0 kg/hr (20 lb/hr). Although establishing the standard in tin's way does not result in as great an emission reduction as installation of incinerators or equivalent control tor the oxychlorination reactor at all of the plants, the proposed standard is based on a consideration of costs only where the energy costs would be grossly disproportionate to the emission reduction achieved. Furthermore, as technologies using less energy for controlling the oxychl orination reactor are developed, EPA will evaluate the desirability of pronosing a standard which would require a higher degree of control at all plants. 8.2.2 Sources Following the Stripper in Dispersion Resin Manufacture at Polyvinyl Chloride Plants As discussed in Chapter 5, the second part of the proposed standard about which there was some question in selecting an emission limit based on the established criteria for "best available control technology" concerns the sources following the stripper in dispersion resin manufacture. This issue concerned the interpretation of the first criterion for best available control technology, i.e. the degree to which developing control meets the criterion of being available for the plants to use. The three alternatives considered by EPA were (1) establishing the level of the standard so that it is representative of stripping technology that is currently available for all grades of dispersion resins at all plants, (2) establishing the level of the standard so that it is representative of stripping technology 8-9 COLORITE 008782 which has been achieved by one plant for all resin grades and by two plants for some of their resin grades, and is judged to be available for the remaining plants within the maximum time allowed for compliance under section 112, or (3) establishing the level of the standard so that dispersion resins would have to be stripped to the same level as other resins. The issue involved in selecting one of the alternatives as the the basis for the proposed standard for dispersion resin manufacture concerned the time frame in v^hich the degree of stripping required by each alternative would be available for the plants to use. However, to the extent that they could be analyzed, the emission factors, mass emissions, energy consumption, and costs for an average-sized dispersion olant (14 million kilograms or 30 million pounds per year) attaining each of these alternative control levels are displayed in Table 8-2. The emissions from an uncontrolled plant are also shown. Based on all available information, EPA concluded that the alternative of basinq the proposed standard on the degree of stripping technology that is available now for all grades of dispersion resins at all plants does not meet the criteria for best available control technology. This is because, for several reasons which are outlined in Chapter 5, stripping technology has not been developed as a method of controlling vinyl chloride emissions for dispersion resins as it has for other resins. In general, curre"! strirniny has been develcn.. d only to Ihe extent that it is necr'^a.-v for ecor.e purposes. Based on available f-V) COLORITE 008783 ----- -- k-_ : W . l; (] React 'r -1 pi'i Relit- VaWbrr'.neer "ono- r i *" r;? <' ') - 1 .> on 1.3 3 n. rs ,i Proems hflui. : Fbl low.-r : r > S'.. ', ->? r J*: ` ( 41l rr' b 1 er r. t a ir . d-"erc, storaee , etc.) T ''c.ll fe.oi A1- [F.RNaTIV" I Fu t _; i"e r--,l S r- i 'ns 'Je actor f'-'pn l . ? Relief Valve DI^.-.-j-j "A" Stripper n.113 0.001 o noo Monomer Recover- ^ sret O.onj Process Equipment Following the Stc. c-per (slurry Mend Len'* drvers,Storace ,etw .{ 2.78 Total ST*TntA7 i Vl II 3,`)o Fugit. * Eci-'Sions Reatti'r Opening Relief Valve Discha rf,e Stripper 0.113 0.001 o.ooo Monomer Recbver\ Sv stem 0.O01 Process Equipment 0.2OO Following tne Sttiprer (slerr'- 1 e^d tanks, drvvrs, sto -ie etc. Total O.J15 (o (<'' .21 \ (1 l1) (0. C.7b> (o on (0,113) (0.O01) (0 O()0) (o.ooi) (2.75) (2 90) (O.liJ) (0 001', (0. ^O) (0.001) (0.200) (0 3151 ALTER.SATIV7 TIT Fugitive Emission'- Reactor Opening Relief Valve Disced r it' Stnrper Monomer Recovers' Ss sic-. Procci' Ppi'i''*'*>ni Following the Srri-. ie i 0.113 0,001 o ono O.oni O.M (0.113) (0.001) (0.000) (0.001) (0.04) (<slu*--v blend t mV>, drveri, Storage, i1. Total "oTTss"~<o7iTe>T vl 'ill,' t -u, i\Z, 1-.' '/ 2 53 (5 02} 3 '! (0,23) 2''.: (4b.1) 5. (IP.R) 4b.9 (104.J) ioi .5 122.i>; 1.9 (4.24) 0.017(0.037) 0 (0) 5.017(0.037) 46.0 (1 " A.3) 48 ft (i0 fs) l.vl 0.017 0 (4.24) (0.037) (0) 0.017 (0.037) 3 37 (7,50) 5.31 (11.S) 1.91 (4.24) 0.017 (0.051) 0 (0) O.017 (0.037) 0.675 (1.60) ?-62 (5.81) !-. jl l r ivo Fc-OfF M - 90 99 99 + 99+ 0 S'5 90 99 99+ 99+ 3 95 90 99 99+ nn + 97 'Assumes aOOO hr r opq-iation. Assurte-i contnol b approved stripping. .,`lL t'-r.RM consi"-o ::cs Lnl.. ' : I; ' -rO ji ' ,, cp :c')0 r COSTS capital, v.:-; *: 510-0 S1000 l.AQO (12,4001_________ 00 $2^^_________S80 3 35,400 f 138,400) 10102 S3.3192 S13637 Unavailable because this livel of Stripping has not bear. cCrtSt' rc la 1 ly demonstrated. 8-11 COLORITE 008784 data, it is judged that by the time the proposed standard must be implemented, improved stripping technology could be available for plants to use. If this alternative were selected as the basis for the proposed standard, it would provide no incentive to further develop existing stripping techniques to control emissions. Furthermore, although they are more costly in terms of energy, environmental, and economic impacts, add-on controls (e.g. incinerators) are available which could be used to reduce emissions to a much lower level than that represented by this alternative. The alternative of establishing the level of the standard so that dispersion resins would have to be stripped to the same level as other resins was rejected, because the level of stripping required by that alternative (400 ppm) has not been demonstrated for dispersion resins and ERA concluded that the time required for research and development of such technology far exceeds the maximum time allowed by section 112 for compliance (two years from the date of promulgation or two and a half years from the date of proposal). Even the plant which has been most optimistic about achieving this degree of stripping reports that it will be unable to do so for at least four years. Furthermore, this level of control cannot be achieved in the manufacture of dispersion resins by add-on controls, and therefore no options to undeveloped stripping technology would be available for use by the plants, therefore, tin's alternative could necessitate closure of dispersion resin plants until the controls oou'd be dove logon. As stated in rbep!er ?, ERA onoludad that best nvailatle control t r,c1','ol ogy raiser A',-". cl isuro wf plants would `"C the .egroaen a..\ g e H or t i -evp > I \ bird. ibis all?rmt i\c 'O' J` 1 V . . r. : ! ' a . - . m ; .. .' a_ : 1, h 1 r t ,,! i :) i COLORITE 008785 *,,( i,n:,lor;/, i.e. the technology has not been used at any plant and r, Me * o:, r-,-c-,l ly adaptable for use at other plants within the time allov.'ed Ly section 112 for compliance. PA recognizes that the second alternative (stripping to 2000 ppm) represents a level of stripping which currently cannot be achieved for all dispersion resins. Of the eight companies v.'hich presently manufacture dispersion resins and plan to continue manufacturing dispersion resins, this level of stripping has been achieved by one company for all grades of its dispersion resins and by two companies for some grades of their dispersion resins. One of these companies and another company have projected that they will be able to strip all their dispersion resins to 2000 ppm within the maximum time allowed for compliance under section 112. Based on information received from all companies that are known to make dispersion resins, it is EPA's judgment that those companies which are stripping or project they will be able to strip to 2000 ppm are the same ones which have devoted the most time and resources to development of striDDinq as a control measure for dispersion resin manufacture. EPA has therefore concluded that an emission limit requiring stripping to 2000 opm does meet the second criterion for best control technology; i.e. it is a level of control which is generally adaptable for use in polyvinyl chloride dispersion manufacture within the maximum time allowed for compliance under section 112. Furthermore, this same degree of emission reduction can be achieved by add-on controls (e.g. incinerators). Although add-on controls are more expensive than stripoing in terms of environmental, energy, and economic costs, P-13 COLORITE 008786 they do provide an optional method of control for the plants to use. EPA considered proposing the standard to allow averaging of residual vinyl chloride concentrations in dispersion resins with those in other resins, so that a plant could compensate for higher levels in dispersion resins by stripping other resins to a lower level. This concept is judged to be inequitable because for some plants dispersion resins compose less than 5 percent of the total resin production and at other plants they compose 60 or more percent. EPA concluded that it would be more reasonable to recognize the significant differences between dispersion resins and other resins and require application of best available control technology to the processing of each. 8.2.3 Other Stack Emission Sources The proposed standard limits emissions from all equipment used in the ethylene dichloride purification process and the vinyl chloride formation and purification processes in ethylene dichloride-vinyl chloride plants and from all reactors; strippers; containers for mixing, weighing and holding which precede the stripper; and monomer recovery systems in polyvinyl chloride Dlants to a concentration of 10 ppm vinyl chloride. The proposed standard also requires venting of captured fugitive emissions through a control system from which the concentration of vinyl chloride does not exceed 10 ptmi. In EPA's judgment, an outlet concentration of 10 ppm represents best available control technology for these sources and can be achieved by incineration, carbon adsorption, or solvent absorption, done of these control systems has !,:on used by ethylene bichloride- vinyl chlorid o' 'clyvin/l cblorfv plants until recently, and -hr,n by only a r.n n],. Tbn( ^vcu -'non h brh has 'e COLOR!TE 008787 a concentrated effort to obtain data on application of these control systems for reduction in vinyl chloride emissions, there are few data available demonstrating the effectiveness of these control systems when installed at ethylene dichloride-vinyl chloride or polyvinyl chloride plants. EPA did conduct a source test on one incinerator installed at an ethylene dichioride-vinyl chloride plant. The test demonstrated control to a level below the proposed limit of in ppm. One polyvinyl chloride producer has recently installed a carbon adsorption unit to control vinyl chloride emissions from the monomer recovery system and the blend tanks. During the time in which the unit has been operated, it has gone through more than 700 regenerating cycles, and the vinyl chloride content in the exit gas stream has been reported to be below 10 ppm. In addition, one vendor of activated carbon has submitted data from laboratory studies on the control of vinyl chloride by carbon adsorption. The vendor's conclusions from the studies, based on 15 cycles of operation, were that activated carbon readily adsorbs vinyl chloride in concentrations ranging from 50 ppm to over 300,000 ppm; 100 percent removal of vinyl chloride is technically feasible using dual beds of activated carbon; activated carbon saturated with vinyl chloride can be regenerated in-place using either steam or hot nitroqen to desorb the vinyl chloride; and no polymerization of vinyl chloride occurs on the bed. Data are available for a solvent absorption unit which controls emissions from the monomer recovery system in a polyvinyl 8-15 i i f vi&jspf `.vwia* l \ l- f *" -- r t COLOR!TE 008788 chloride plant to a concentration of 15 npm; in EPA's judgment, however, this particular system, which is relatively old and was not designed specifically for vinvl chloride control, does not represent the full capability of solvent absorption in reducing vinyl chloride emissions. EPA believes, however, that' an undated solvent absorption unit, as well as an incinerator or a carbon adsorption unit, will be capable of meeting the proposed standard. The proposed standard limits, for polyvinyl chloride plants, the emissions from process equipment following the stripping operation in the manufacture of dispersion resins (except latex resins) to 0.2 kg/100 kg product and in the manufacture of all other resins (including latex resins) to 0.04 kg/100 kg product. One way in which these emission levels can be attained is by reducing the residual vinyl chloride monomer in dispersion resins to 2000 ppm or less and in all other resins to 400 ppm or less during the stripping operation. This reduction must be completed before the resins continue through the processing equipment following the stripper. This type of control is referred to as improved stripping technology. The proposed standard permits averaging of emissions to the extent that the vinyl chloride content in all grades of any one resin type completing the stripping operation at a plant site in cne calendar day can be averaged o'.er the 24 hour period, [`Resin type" refers to the broad classification of a resin according to the process by v,hich it is manufactured (e.g. dispersion, suspension, bulk, latex, and solution). "Resin grade" is the subcategory of "resin type" whi-.h d-r,c n tvs o ror-in cs a unique resin, i.e. the most exact desc r i pi ' -on of a resin with eo lurther subdivision.] Tbr-so emission 'curls ran 1 * be . ' by r.r-'.on con, su< h as COLOR!TE 008789 incinerators, EkA discourages use of the add-on control devices, however because unlike improved stripping they do rice result in a lower vinyl chloride content in the polyvinyl chloride resin going to fabricating plants. Furthermore, these devices are far more energy consuming for these particular emission sources than improved stripping technology and achieve no more emission control. In fact, those devices have not been used commercially to control the emissions from most of this particular process equipment, because they are much more expensive for the plants to use than improved stripping technology. In EPA's judgment, however, there is no technical reason why they could not be applied. In developing the proposed standard for process equipment following the stripper, it was necessary for .EPA to make decisions concerning the levels of control which should be required for the various resin types and the desirability of allowing averaging among resin grades. The reasons for selecting the -emission limit which is proposed for these sources in the manufacture of dispersion resins_have already been discussed. In regard to the manufacture of other resin types, as a result of the October 4, 1974, OSHA standard, polyvinyl chloride resin producers have been motivated to develop stripping technology to reduce further the vinyl chloride content in these resins during the stripping operation. By improving striDoing technology, producers will not only reduce in-plant exposure levels as required but will also satisfy fabricator demand for resins which have low concentrations of vinyl chloride and thus do not cause the fabricators to be in violation of the OSHA standard. Some companies have devoted more time and resources to improve the effectiveness of R-17 COLORITE 008790 flow valve between the disk arid the relief valve and routinely checking for any flow from the ball check excess flow valve. The proposed standard would require capture and control of emissions of vinyl chloride bearing gases during manual venting from processing equipment. For example, it 'would permit no manual venting of vinyl chloride to the atmosphere to reduce the pressure in reactors during upset conditions or to remove inert gases from vessels used to store vinyl chloride. The gases would instead have to be transferred to a gasholder, a recovery system, another piece of equipment (such as another empty reactor), or to a control system. The proposed standard minimizes vinyl chloride losses from sample flasks durinq sample acquisition by requiring that the sample be collected in a closed system. Vinyl chloride which could be lost to the atmosphere is instead flushed back to the process using this system. The proposed standard requires development of and adherence to a formalized program for detection of leaks from equipment in vinyl chloride service and elimination of these leaks. The formalized program must include a multipoint vinyl chloride detector and portable hydrocarbon monitors. Rather than specifying the number of points to be monitored, the sensitivities of the multipoint detector, the vinyl chloride concentration that indicates a leak, and the actions to ho taken to repair leaks, the proposed standard requires each pkiiit oarer or operator to prepare a program plan contui r, ir.g these speci f I c.c* i(. ns ,.rd to .it the pl.ei to l ho A.'mini si re t or for COLORITE 008791 approval. The plant owner or operator is at the same time required to submit data on background concentrations of vinyl chloride in different areas of the plant to use in determining the vinyl chloride concentration that should be designated as indicating a leak. Since the background concentrations vary among different areas of the plant, the definition of leak may also vary among different areas of the plant. EPA's decision on whether a program is adequate will be based on (1) the date the program will be implemented, (2) the characteristics of the multipoint detector and portable hydrocarbon detector (including the sensitivities of the instruments), (3) the number and location of points to be monitored in comparison with the number of pieces of equipment in vinyl chloride service and the si2e and physical lay-out of the plant, (4) the proposed frequency of monitoring, (5) the vinyl chloride concentration(s) designated as indicating a leak compared with the background concentrations of vinyl chloride in the plant, and (6) the other specifications contained in the nroqram Dlan. This approach has been taken because the number of points which need to be monitored and the background concentrations of vinyl chloride vary depending on the size, configuration and age of a plant and, in the case of a polyvinyl chloride plant, on the number of reactors. Plans, therefore, must be tailored to the design of each individual plant. This approach gives each source the flexibility to develop a plan that it believes to be the most efficient. The proposed standard includes an emission limit for inprocess wastewater which contains at least 10 ppm by weight vinyl chloride, measured directly as the wastewater stream leaves 3-29 COLOR!TE 008792 the process equipment and before it is mixed with wastewater from any other source. This cut-off point was selected because, based on data which are available from polyvinyl chloride plants, it distinguishes between the low volume wastewater streams with high concentrations of vinyl chloride and the large volume wastewater streams with low concentrations of vinyl chloride. In effect, the proposed standard would require control of wastewater streams from pumps used in the monomer recovery system and from monomer recycle tanks where wastewater, which has been entrained with recovered monomer is separated and removed. It would also require control of wastewater which had been used, in accordance with other requirements of the proposed standard, to displace vinyl chloride in equipment before the equipment is opened. It would not require control of wastewater which had been used in the polymerization of vinyl chloride, if improved stripping technology were used to attain the proposed emission limit for the process equipment following the stripper. This wastewater stream was excluded because improved stripping technology indirectly reduces the vinyl chloride content of the wastewater as well as the resin before the wastewater is separated from the resin. However, if an add-on control device is used instead of improved stripping, the combination of all sources of vinyl chloride emissions following the stripping operation in the polyvinyl chloride plant, including inprocess wastewater, is required to meet the total mass emission limit. Thus, in this case, the concentration of vinyl chloride in the inprocess wastewater would not have to bo COLORITE 008793 equal to or greater than the 10 ppm cut-off point to be required to be controlled. The proposed standard of 10 ppm vinyl chloride in the wastewater can be attained by a stripper, which uses heat and/or vacuum to remove vinyl chloride from the water. The proposed standard in effect would require the vinyl chloride which is removed to be recovered by condensing it into a liquid or to be ducted through a control device. Theoretically, by using this method, the vinyl chloride concentration could be reduced to essentially zero. However, as the applied vacuum and heat are increased, the ratio of water to vinyl chloride that vaporizes increases. During the vinyl chloride recovery process, the water as well as the vinyl chloride condenses. Since the water still contains some dissolved vinyl chloride, it would have to be recirculated through the stripper. At some point, as the amount of water which is vaporized is increased, the separation of vinyl chloride from water would be /less efficient. For these reasons, the proposed standard is 10 ppm. Although the standard permits some vinyl chloride to remain in the water, it is estimated that the vinyl chloride emissions from the low volume, high concentration water streams at the average plant would not exceed 0.5 kg/hr (1 lb/hr). At ethylene dichloridevinyl chloride plants, strippers are already used as an inherent part of the process to recover ethylene dichloride from wastewater. Vinyl chloride is also removed from the wastewater. Ihe purpose of the proposed standard is to ensure that the practice continues 8-31 COLOR!TE 008794 and that any vinyl chloride removed from the wastewater is recovered or controlled. R.3 Selection of the Format of the Proposed Standard With the excention of emissions followino the stripoer in dispersion resin manufacture, separate standards have not been established for individual processes or companies. The applicability of carbon adsorption, incineration, or solvent absorption is not dependent on plant age, configuration or type of process. The proposed standard specifies emission limitations for individual emission points. An alternative would have been to specify a total plant mass emission limit in terms of kg/hr. This is not possible, however, when using the best available control technology approach due to the different sizes and configurations of plants. Implementing best available control technology at different sizes of plants obviously results in different emissions per unit time. EPA also considered specifying the limits in terms of total plant mass emissions in kg vinyl chloride per kg product to be measured by material balance. This approach was rejected for several reasons. Due to the variations in configurations among plants, an emission factor, which would necessarily result in the application of best available control technology at each plant at all times, could not be developed. Furthermore, either long-term or short-term material balances would have to be used to measure compliance with such a standard. Long-term material balances have the disadvantage of a long averaging time so that short-term peak emissions are not defected. Short-term material balances, on the other P.md, op1 i. Tactical and COLORITE 008795 imprecise due 10 the large volumes of material which are handled and must be measured, the multiple pieces of equipment in 'which residual materials would have to be measured, and the large number of points where loss to the atmosphere, inprocess wastewater, and solid waste would have to be measured. humeri cal emission limits are used for each emission point where possible; however, equipment and operating procedures are specified for some of the fugitive emission sources from which emissions cannot be measured or calculated or for which it would be grossly impractical to do so. Generally, the reason that these emissions cannot be measured is that they are released into an unconfined area and often from many small sources, and there is no practical testing procedure for obtaining a reliable reading of emission levels. Where equipment or operating procedures are specified, plant owners or operators are generally permitted to use other equipment or procedures demonstrated to be of equivalent effectiveness. Primarily because fugitive emissions compose such a large proportion of the total emissions at ethylene dichloride-vinyl chloride and polyvinyl chloride plants, EPA has determined that control of such emissions by specification of equipment and operating procedures is preferable to the alternative of leaving such emissions unregulated. For example, there are procedural requirements for the reduction of vinyl chloride to a specified concentration in equipment equal to or greater than 5500 1 (1250 gal) before opening it to the atmosphere. Conceptually, EPA could have proposed the standard in terms of a mass emission rate. This could be done by converting the concentration of vinyl chloride to its mass emission equivalents for all sizes of 8-33 COLOR!TE 008796 equipment. Mass emissions, however, could not be measured once the pieces of equipment were opened to the atmosphere because the emissions would not be confined. Consequently, if EPA had stated the standard in terms of a mass emission rate, it would have been necessary, in order to be meaningful, to state the method for determining compliance in terms of concentration of vinyl chloride, i.e., in the same terms as the procedural requirement is now stated. Stating the standard itself in terms of concentration is a much more direct approach and the only practical one. For equipment that is less than 5,500 1 (1250 gal) and for loading and unloading equipment, a mass emission limit in terms of ' liters is proposed. However, this cannot be measured, but must be calculated based on the volume of the equipment and the pressure in the equipment. - The proposed standard includes equipment specifications for leaks from seals on pumps, compressors, and agitators and from relief valves. A numerical standard for emissions from these sources would be imprac tical to enforce since there is no way to test emissions released into an unconfined area. Even if a testing procedure were available, frequent routine testing of all pump, compressor, and agitator seals and relief valves to determine compliance would be burdensome. The proposed standard requires that samples of vinyl chloride be collected in a closed system so that any vinyl chloride remaining in the sample flask from previous sampling flows back into the process. Any vinyl chloride flushed through the apparatus in an attempt to collect a representative sample also flows back into the process. Again, nuir,erica! emission limits can.mt be specified because tmiissi-ms are released into an u:v:on fined sp.'ca and cannot be m . om-?d. tor COLORITE 008797 slip gouges and manual venting, the proposed standard requires that the emissions be captured and ducted through a control system. There is a numerical emission limit specified for the control system. Anotiier problem requiring special treatment is valve leakage. It would be impossible to avoid all valve leakage. However, valve leakage can be held close to zero if a system of regular valve monitoring is used to detect and repair leaks. If EPA were to specify a numerical limitation of zero, it would be impossible to meet at all times. If EPA were to specify a higher numerical limitation, it would permit more leakage than is necessary. This would be incon sistent with requiring control of vinyl chloride emissions to the level attainable by use of the best available control technology. Therefore, EPA is requiring use of a regular program for leak detection and repair. In order to reduce the total emissions from reactors by limiting the frequency of openings, the proposed standard for reactor opening loss is specified in terms of a mass emission rate, i.e. kilograms of vinyl chloride per 100 kilograms of polyvinyl chloride produced. If a concentration standard were used, it would provide no incentive for reducing the frequency of reactor openings, furthermore, the amount of dilution air which could be used to weaken the effect of a concentration standard is difficult to regulate. For these two reasons, EPA concluded that a mass emission rate would be the only effective way to specify the standard. Due to the intermittent nature of the sources of the emissions, the proposed standard for control systems to which ;he captured o-gg COLORITE 008798 emissions are required to be ducted is in terms of concentration. A major part of the polyvinyl chloride plant is a batch operation which causes intermittent emissions of vinyl chloride. In addition, the fugitive emissions which are required to be captured and ducted to a control system in both ethylene dichloride-vinyl chloride and polyvinyl chloride plants occur only on an intermittent basis. Because of the fluctuating air volumes and mass emission rates, it would be difficult, if not impossible, on the basis of available information, to determine the allowable mass emission rates from these control systems. The emission limit for the sources following the stripper in polyvinyl chloride plants is stated in two ways which are essentially equivalent in terms of the quantity of emissions they allow. The reason the emission limit is stated in two different ways is that there are two distinctively different ways to control these sources. Different methods of measurement and enforcement are applicable to the two different control methods. If add-on control devices are selected as the method of control, stack testing must be used to measure the emissions from all the multiple sources simultaneously for a minimum of an hour. If improved stripping is selected, the emissions could be measured in the same way. It is difficult, however, to use conven tional source testing procedures to establish compliance because of the large number of sources that have to be tested. A typical polyvinyl chloride plant has several slurry blend tanks, centrifuges, dryers, and storage silos. Even if the emissions from each of these sources wore determined, the resultant value would not necessarily COLOR!TE 008799 establish the total emissions since monomer would still be escaping from the rosin in bagging operations, warehouses, and railroad tank cars. Where improved stripping is used, there is a much more practical way for determining compliance. Improved stripping technology controls emissions by removing vinyl chloride from polyvinyl chloride resin before the resin moves through the remaining equipment in the process where the vinyl chloride would otherwise be emitted to the atmosphere. Therefore, the simplest way to determine total emissions is to measure the vinyl chloride in the resin as it leaves the stripper and before it is released to the atmosphere. Thus, if add-on control devices are used, the proposed standard is stated in terms of mass emissions to the atmosphere; if improved stripping is used, the proposed standard is stated in terms of the quantity of vinyl chloride in the polyvinyl chloride resin leaving the stripper. In both cases, the standard is stated in terms of a cumulative emission limit for all sources following the stripper to be consistent with the primary technology on which the standard is based (i.e. stripping). Another reason the emission limit for sources following the stripper is stated in two ways is the necessity for two different averaging times. For reasons already explained, a 24-hour averaging time is desirable if improved stripping technology is selected as the means of control. Determination of emissions by measuring the vinyl chloride in stripped resin is amenable to this averaging time. If add-on controls are used, however, the 24-hour averaging time does 8-37 COLOR!TE 008800 not. have the same value. If only one emission limit were given, and it were stated in terms of allowable mass emissions with a 24-hour averaging time, any plants using add-on control devices to meet the proposed standard would have to test emissions from each stack for 24 hours instead of a minimum of one hour, as is required under the proposed standard. This would be unduly burdensome for these plants. Stating the emission limits in two different ways potentially allows plants using add-on control devices to emit slightly more emissions than plants using improved stripping technology. The two emission limits are equivalent if it is assumed that all residual vinyl chloride in the resin leaving a stripper is emitted into the atmosphere at the polyvinyl chloride plant. In fact, however, a small proportion of the vinyl chloride might be left in the resin when it leaves the plant. The discrepancy between emissions allowed by the two emission limits could be avoided by proposing one standard based on emissions into the atmosphere. For plants using improved stripping, the method for determining compliance would be to measure the vinyl chloride in the resin leaving the stripping operation and in the same resin as it leaves the plant; the difference between these measurements would be emissions to the atmosphere between these two points. This method, however, creates enforcement problems, because the resin which is stripped in one batch is typically blended with stripped resin from other batches, and it would be difficult, if not impossible, to trace a be.ten all the way through the process. Complicating this problem, would be the fact thee the resin may be stored at the plant for COLORITE 008801 sonic time before it is shipped. For these two reasons, it would be difficult, if not impossible, to correlate measurements of resin leaving the stripper with those from resin leaving the plant, and EPA would therefore not be able to determine the emissions from any one batch. In addition to that, the concentrations of vinyl chloride in the resin, both in the stripper and in the product leaving the plant, would have to be averaged over a long time (more than the proposed 24 hours). The long averaging time would not be desirable because it would permit more emission peaks and it would be more cumbersome to enforce.. EPA con cluded, therefore, that the most practical and direct approach is to limit the concentration of vinyl chloride in the resin from the stripping operation. It should be pointed out that EPA has determined that this is an emission limitation; since residual vinyl chloride monomer left in the resin after stripping would be emitted into the atmosphere at some point, the limitation on residual vinyl chloride monomer in the resin limits emissions and is, therefore, an emission limitation; it is simply specified in a form which is compatible with the only practical method for determining compliance. To simplify enforcement, the proposed standard for the inprocess wastewater is specified in terms of concentration of vinyl chloride rather than in mass emission limits. If it were specified in terms of mass emission limits, not only the vinyl chloride concentration but also the water flowrates from each of the pieces of process equipment would have to be measured. Due to the large number of pieces of equipment involved, this would not be practical. 8-30 COLORITE 008802 3.a Method for Determining Compliance With the Proposed Standard Provisions which specify the requirements for testing, reporting, and recordkeeping are included in the proposed standard. The purpose of these requirements is to determine compliance with the proposed standard. 8.4.1 emission Vests Test Method 106 is proposed as a reference method primarily for measuring vinyl chloride emissions from stacks. Portable hydrocarbon detectors or Method 106 can be used, except for postpolymerization reactors in the manufacture of bulk resins, to determine the degree to which vinyl chloride has been removed from equipment prior to opening the equipment to the atmosphere. For postpolymerization reactors in the manufacture of bulk resins, these test methods are not appropriate because the reactor would be partially filled with polyvinyl chloride resin at the time the vinyl chloride concentration within it would have to be tested. Therefore, the proposed standard includes provisions for calculating emissions due to opening of the postpolymerization reactors. Test Method 107 is proposed as a reference method for measuring the vinyl chloride content of polyvinyl chloride resin and inprocess wastewater. Multipoint vinyl chloride detectors and portable hydrocarbon detectors are proposed as methods for detecting leaks from process equipment. The proposed standard also includes a requirement that stack emissions be measured on a continuing basis with a vinyl chloride detector. This vinyl ' hlorido detector may be the multipoint vinyl chloride detector required for leak detection, but dees not have to be. Vinyl cnlunde COLORITE 008803 in the samples ':o 11 ectefi by the- detector can be measured by gas ehr'on.atooraphy, or if it i r> assumed that all hydrocarbons measured are vinyl chloride, by infrared spectrophotometry or flame ion detection. The proposed standard allows, upon approval by tPA, the use of equivalent or alternative test methods. 8.4.2 Reporting There are reporting requirements in the general provisions of Part 61 of the Code of Federal Regulations which would apply to the sources subject to the vinyl chloride standard. In addition, there are several different kinds of reports required by the proposed standard. Initial Report First, an owner or operator must submit to EPA an initial written report containing a record of emissions from the sources from which emissions can be measured using Test Method 106. These sources include ethylene dichloride purification, vinyl chloride formation and purification, and the oxychlorination reactor in ethylene dichloridevinyl chloride plants and reactors, strippers, monomer recovery systems, and mixing, weighing, and holding containers in polyvinyl chloride plants. Compliance with the emission limitations for reactor opening loss and the sources following the stripper in polyvinyl chloride plants must be demonstrated using appropriate test methods. Measurements of the vinyl chloride concentrations in the inprocess wastewater at both ethylene dichloride-vinyl chloride and polyvinyl chloride plants are also required as part of the initial emission testing. For those sources which have emissions which cannot be measured (fugitive emission source:), an initial report is required 8-.11 COLORITE 008804 containing a written statement to the effect that certain pieces of equipment have been installed and are operating. These include equipment for minimizing leaks from seals on pumps, compressors, and agitators and from relief valves and equipment used for monitoring leaks. Also required is a written statement to the effect that certain procedures have been incorporated into a Standard Operating Procedure and are being implemented. These include such procedures as removing vinyl chloride from equipment and from loading and unloading lines before opening them to the atmosphere and venting the vinyl chloride removed from the equipment or lines to a control system, venting vinyl chloride from slip gauges during loading or unloading operations to a control system, ducting vinyl chloride emissions from manual venting to a control system, purging the vinyl chloride in each sample flask back to the process during vinyl chloride sampling, and detecting and repairing leaks. Semi-Annual Report A semi-annual report is required which is to contain a record of any emissions in excess of the proposed standard for the formation and purification processes in ethylene dichloridevinyl chloride plants and the reactor, stripper, monomer recovery system, and containers used for mixing, weighing or holding preceding the stripper in polyvinyl chloride plants. These emissions must be measured by a vinyl chloride defector. The vinyl chloride detector reports measurements of vinyl chloride in terms of concentration, except for the omission limit for the o-.ychlorinai.ion reactor, the csion lisa's l'r all t;~. o sources for which c-nu i ru i nq COLORITE 008805 me as.jror.-.onts of v'nyl chloride with a detector are required <*> are seated in terms of concentration. The emission limit for the oxy- chlorination reactor is stated in terms of mass per unit product. For the oxychlorination reactor, the vinyl chloride detector can be used to measure emissions at the same time that the initial stack test is being conducted using Test Method 10G. The results of that test can then be used as a guideline in the future to determine whether the emissions measured on a continuing basis with the viryl chloride detector are in excess of the standard. For polyvinyl chloride plants, the semi-annual report is also required to contain measurements of emissions from reactor opening and, if improved stripping is selected as the control technology to attain the standard, from the sources following the stripper. Measurements of emissions from these two sources are required on a continuing basis because the control technologies required for these two sources are primarily procedures rather than control devices. Attainment of the standard for reactor opening would require a . reduction in the number of reactor openings in addition to displacing the vinyl chloride from the reactor before opening. One emission test, made within 90 days of promulgation of the standard, would give no assurance that the standard was being met on a continuing basis. With regard to stripping, the primary limitations on the degree of stripping being carried out are product degradation and processing time as 'T affects production rate. The degree of stripping is more a function of operating parameters than of the specific 8-43 COLORITE 008806 rquipmont being used. For this reason, even if all the equipment for stripping is installed and operated, routine measurements must be made to ensure that the degree of stripping required by the emission limitation is being carried out on a continuing basis. For botn reactor opening and improved stripping, it is possible that the relationship between the emissions measured and the corresponding operating procedures used to attain the emissions measured can be established. For improved stripping, for example, it may be established that for a given resin grade, a given set of operating conditions (temperature, residence time, and pressure) will result in a certain concentration of vinyl chloride in the resin which is far below the standard. Likewise, for reactor opening, it may be established that a given procedure such as water displacement coupled with a given frequency of reactor opening will result in an emission level below the standard. The general provisions and the proposed standard provide for waiver of emission tests and use of alternative or equivalent test methods. Under the authority of these provisions, EPA could, on an individual basis, permit a plant to record certain parameters (such as temperature, residence time, and pressure for improved stripping) *1. rather than.to conduct emission measurements. Other Reporting Any relief discharge must be reported within ten days of i ts occurrence. These reports '..'ill bo used to determine cr-r.pl iarm.e = nd will permit EPA to study the circumstances surroundinq the l s harqu to d': i nr whether `Jt; di charge louiE COLORITE 008807 8.4.3 Recordkeebing Each owner or operator is also required to keep records of certain information. It is EPA's intention to require little recordkeeping in addition to that which would normally be kept by the plants. For example, the proposed standard would require keeping records of the concentrations of vinyl chloride measured by the vinyl chloride detector(s). Printouts from the vinyl chloride detector(s) are adequate to meet this requirement. Information on detection and repair of leaks is required to be kept in log books. The purpose of.this recordkeeping is to document that the procedures detailed in the program for leak detection and elimination are being carried out. There is also a requirement for keeping records of the temperatures and pressures during reactor operation. Printouts from sensor instruments are adequate to meet this requirement. These records can be used by EPA to determine occurrence of a discharge from relief valves. 8.4.4 Other Methods for Determining Compliance In addition to the requirements for tests, reports and recordkeeping, EPA has at any time the authority under section 114 of the Clean Air Act to require emission tests; inspect equipment, operation procedures, or records; or obtain other information as necessary to determine compliance with the standard. For example, an authorized representative of the Administrator of EPA may inspect the seals on pumps, inspect or observe the implementation of a Standard Operating Procedure for removing vinyl chloride from a piece of equipment before opening it, etc. 8-4S COLORITE 008808 8.5 Evaluation of Need to Set Standards for Polyvinyl Chloride Particulate There are two potential health problems related to exposure to polyvinyl chloride particulate. First, polyvinyl chloride particulate can be a source of vinyl chloride emissions. Second, studies of people occupationally exposed to polyvinyl chloride particulate and animals exposed experimentally to polyvinyl chloride particulate 234 have indicated that the particulate may possibly cause pneumoconiosis. ' ' Polyvinyl chloride and, to some extent, polyvinyl chloride fabricating plants are potential emitters of polyvinyl chloride particulate. 8.5.1 Polyvinyl Chloride Particulate as a Source of Vinyl Chloride Emissions Vinyl chloride emissions due to polyvinyl chloride particulate would occur because the particulate contains residual vinyl chloride monomer. The amount of residual vinyl chloride in the particulate is dependent on the physical properties of the product being manufactured (size and porosity) and the degree to which residual vinyl chloride has been stripped from the product before it reaches the dryer and as it goes through the dryer. In the spring of 1974, based on data from several plants, the product resin was estimated to contain a maximum of 500 - 1,000 ppm vinyl chloride after it had gone through the dryer. The amount of residual vinyl chloride released from the particulate once it is in the environment has not been quantified. Control techniques which are used to control polyvinyl chloride particulate are discussed in Chapter 4, section 4.11. Estimated polyvinyl chloride particulate omission rates from the various 8-46 COLORITE 008809 processes in polyvinyl chloride plants using fabric filters and/or centrifugal separator control are shown in Chapter 4. Based on these emission rates, the total polyvinyl chloride particulate emissions from a 136 million kg product/yr (300 million Ib/yr) suspension plant containing storage bins, storage silos, bagging machines, bulk loading operations, and resin transfer points equipped with fabric filters, and rotary dryers equipped with centrifugal separators are estimated to be 211 kg/hr (465 lb/hr). (Due to the control equipment and plant size selected for this example, 211 kg/hr is estimated to represent a much higher than average emission rate.) Based on data obtained during the spring of 1974, it can be assumed, for the purpose of considering the worst situation without the proposed standard in effect, that this 211 kg particulate/hr contains 1,000 ppm residual vinyl chloride and that all the residual vinyl chloride is released into the atmosphere; therefore, the amount of vinyl chloride emissions from this source (the particulate) would be 0.21 kg/hr (0.46 Ib/hr). This compares with the total vinyl chloride emission rate of approximately 32 kg/hr (70 Ib/hr) from a 136 million kg product/yr (300 million lb product/yr) suspension polyvinyl chloride plant in compliance with the proposed standard. Effect of the Proposed Stand_a_rd on Vinyl Chloride Emissions from Polyvi ny 1 Ch 1 oride P.-.rticulate The proposed standard would indirectly reduce the potential problem which may be associated with emissions of residual vinyl chloride from the particulate through the control techniques (improved stripping or add-on controls) which would be used to 8-47 COLOR!TE 008810 attain the proposed emission limit for the sources following the stripper (specifically, dryers and silos). Particulate emissions in gas streams controlled by add-on control devices such as carbon adsorption would need to be removed prior to the device to ensure its proper operation. Add-on control devices such as incineration and absorption would be expected to remove essentially any particulate remaining in the gas stream subsequent to the particulate removal device. Thus, if add-on control devices are used, there will be essentially no particulate emissions from the dryers or silos, although there would still be emissions from the bagging machines, bulk loading, and resin transfer points. The maximum particulate emissions from the same 136 million kg product/yr suspension plant used as an example above but equipped with add-on control devices on the dryers and silos would be reduced from 211 kg/hr (465 Ib/hr) to 3.5 kg/hr (31 lb/hr), and the maximum amount of residual vinyl chloride released from the particulate containing 1,000 ppm vinyl chloride would consequently be reduced from 0.21 kg/hr (0.46 Ib/hr) to 0.01 kg/hr (0.03 lb/hr). If improved stripping were used to meet the proposed emission limit for the dryers and silos, the quantity of residual vinyl chloride in the resin going into the dryer would be sharply reduced and the quantity of residual vinyl chloride monomer in the resin beyond the dryer would be reduced. However, since proportionately more residual vinyl chloride is removed in the dryer without improved striopine t!\V c.ioh , tie in the renidud vinyl chloride 1 C; COLOR!TE 008811 content of the polyvinyl chloride particulate due to improved stripping would he only from a maximum of about 500 - 1000 ppm to a maximum of 200 - 300 ppm. Using the 211 kg/hr (465 lb/hr) particulate emission rate from the same 136 million kg product/yr suspension plant, but with the reduced maximum residual monomer content (300 ppm instead of 1,000 ppm), the maximum quantity of residual vinyl chloride emitted from the particulate would be reduced from 0.21 kg/hr (0.46 lb/hr) to 0.06 kg/hr (0.14 lb/hr). 8.5.2 Need to Set a Standard for Polyvinyl Chloride Particulate With regard to the potential problem of polyvinyl chloride particulate as a source of vinyl chloride emissions, EPA has determined that the indirect impact of the proposed standard on vinyl chloride emissions from the particulate makes direct regulation of the particulate unnecessary. As calculated in the previous section, for a 136 million kg product/yr suspension plant meeting the proposed standard, the maximum amount of vinyl chloride emissions from polyvinyl chloride particulate would be only 0.01 kg/hr (0.02 Ib/hr) or 0.06 kg/hr (0.14 lb/hr), depending on the type of control technology selected. This emission rate is relatively insignificant when compared with the total emission rate from the plant (32 kg/hr or 70 Ib/hr). With regard to the potential problem of polyvinyl chloride particulate as a possible cause of pneumoconiosis, NI0SH is currently involved in experimental studies on the effects of the particulate on animals. The extent of public exposure (as opposed to occupational exposure) to ambient concentrations of the particulate is unknown 8-49 COLORITE 008812 at this time. Ambient measurements of polyvinyl chloride particulate have not been made by EPA in the vicinity of industrial sources because no technology is currently available for separating polyvinyl chloride particulate from total suspended particulate. As data become available from NI OSH and other sources on the health effects of polyvinyl chloride particulate,EPA may find that it is necessary to reevaluate the need to propose standards for polyvinyl chloride particulate. fi-50 COLOR!TE 008813 References 1. c. D. Call iiian and E. McLau^hl in, Vinvl Chloride jlQmoy e cl j lPxIl Polyvinyl Chloriydc, Louisiana State 'Jn'i vers icy, Baton Rouge, Louisiana, Eebruary 1975. 2. B. Szende, et. al., "Pneumoconiosis Caused by the Inhalation of Polyvinyl Chloride Dust," Med. Lavoro, Vol. 61, r,. 8-9, 1970, pp. 433-436. 3. Bogdan Cylivik, "Histological and Histochemical Changes Observed in Liver During Experimental Polyvinyl Chloride Pneumoconiosis,'' Rocz Akad Med Bialymstoku, Vol. 17, 1972, pp. 93-111. 4. Yu. I. Vertkin and Yu. R. Mamontov, "On the State of the Bronchopulmonary System in Workers Engaged in the Manufacture of Articles Made of Polyvinyl Chloride," Gigiyena Truda, Vol. 14, No. 10, 1970, pp. 29-32. 3-51 COLOR!TE 008814 C'THcP rr:jLAiO'-;v "1X01 RELENTS developed or being developed for VINVL HLORiC'E A :n THEIR RELATIONSHIP TQ THE PROPOSED STANDARD FOR VINYL CHLORIDE 0.", Occupational Safety arid Health Achr.i ni siration (OSHm) 9.1.1 The Emergency Temporary Standard Or, January 22, 1 974, OSHA was informed by the National Institute for Cccuoational Safety and Health (NIOSH) that the B. F. Goodrich Chemical Company had reported that deaths of several of its employees from angiosarcoma, a rare liver cancer, may have been occupationally related. After investigating this report, OSHA concluded that vinyl chloride was the causal agent of the angiosarcomas observed. Subsequently, additional angiosarcoma deaths were reported for workers who had been exposed to vinyl chloride in other plants. On April 5, 1974, based on all available information, OSHA promulgated (30 FR 12341) an emergency temporary standard for vinyl chloride. This standard reduced the permissible exposure level from 500 ppm to a 50 ppm ceiling and established other requirements, including monitoring and respiratory protection. 9.1.2 The Proposed Permanent Standard On May 10, 1974, after reviewing additional information on carcinogenicity in animals exposed to 50 ppm vinyl chloride, OSHA proposed (39 FR 16896) a standard for vinyl chloride and polyvinyl chloride plants. The standard would have limited employee exposure to vinyl chloride to "no detectable level," as measured by a sampling and analytical method sensitive to 1 ppm, of an accuracy of 1 ppm + 50 percent. Other requirements such as monitoring, protective clothing, regulated areas, and respiratory protection were also included in the proposal. 9-1 COLORITE 008815 stripping as an emission control measure than have ether companies. Optimum strinoma consists of a set of operating condition-' which must be developed experimentally on an individual basis 'or the many resins. Based on information supplied to EPA bv individual companies which have devoted time and resources to deveioe improved stripping, EPA concluded that technology is currently available to strip the majority of resins, except dispersion resins, to 400 opm or lower. This same degree of control is achievable through add-on control devices. Some resins are more difficult to strip than other resins due to differences in characteristics such as porosity and heat sensi tivity. Whereas current stripping technology can reduce the residual vinyl chloride content in the majority of the resins other than dispersion resins to below 400 ppm (and in some cases far below 400 ppm), it can reduce the vinyl chloride content in a few resins only to levels as high as 4000 pnm. EPA considered proposing a separate standard based on best available control technology for each of the different grades of resin. This could have conceivably been done based on theoretical factors. However, EPA concluded that it would be difficult, if not impossible, to do this, because the reductions that can be achieved depend on a given system and must be determined by actual measurements on a particular resin for a particular set of conditions. The large number of resin grades makes it impractical for EPA to conduct individual tasting for each one. Available data indAcite thof rest ;-f h, ecu.paries produce sr vo*- ? 1 grad's r.r resin s >,;.f' .v.ecus l / -;ui ,;h'.t ;,!,rn the COLORITE 008816 evades are averaged on a daily basis, the number of resins which can be strioned lo lower than 4fln non is sufficient to offset the few resins which cannot be. The proposed standard allows an averaging tire of 24 hours because, if a plant were processing several grades simultaneously and one qrarfe could not be stripped tn aon pom, the total emissions from stripping all grades to an average of 400 ppm would be no greater than stripping each grade to 400 ppm. The alternative of increasing the averaging time to a week or month was rejected because this would permit higher peak emission levels than averaging on a 24--hour basis. EPA considered proposing a standard which would require the emissions from slurry blend tanks and inprocess wastewater from equipment following the stripping operation to be controlled by add-on devices as well as by improved stripping technology. One relatively new plant decreased the gas volume of the exit stream from slurry blend tanks by replacing air with nitrogen and enclosinq the tanks. A carbon adsorption unit was then installed to control emissions in the reduced gas volume. Although it has not been done by any plant in the industry, there is no technical reason why the inprocess wastewater from centrifuges which follow the stripper cannot be controlled by a water stripper. Such control systems were included in the economic analysis conducted bjr/EPA. The analysis showed that, if plants used improved resin stripping (as opposed to add-on controls) to meet the proposed standard, the costs of these additional systems for slurry blend tanks and inprocess wastewater would be grossly disproportionate to the emission reduction achieved. Rased on available information on COLORITE 008817 {.he emissions from slurry blend tanks after stripping has been used to reduce to 4C0 pen the residual vinyl chloride content in the resin produced by an average plant, the addition of an add-on control device would further reduce emissions by approximately 0.5 kg/hr (1 Ib/hr), i.e. the device would remove an additional 0.1 percent of the original uncontrolled emissions. Collecting the 0.5 kg/hr would increase the capital costs of control to an average plant by about 19 percent and the annual costs by about 13 percent. Similarly, the installation of an add-on control device in addition to improved stripping for the vinyl chloride in centrifuge water would reduce emissions by no more than the add-on control device for slurry blend tanks, and would increase the capital costs of control to an average plant by about 13 percent and the annual costs by 46 percent. The large increase in annual costs would be due to the large quantity of steam which would be required to remove the vinyl chloride from a large volume, lew concentration water stream. Furthermore, if these additional controls were required, plants using add-on control technology would not be able to attain the same level of control as plants using improved stripping technology. The reason for this is that these plants would already be using add-on controls and installing additional add-on controls would have little, if any, effect. The proposed standard limits the emissions of vinyl chloride from opening of reactors, reactor entry purge, venting inert gases from the reactor, and any other contact of the reactor contents with the ambient air, to 0.001 kq/100 kg product. One way the 3-20 COLORITE 008818 stancp-r,i iray be attained is by a combination of (1) reducing the number of ronstor coinings by using high pressure water jets, solvent clearing, or other means to prevent, the need to hand-clean reactors and (2) displacing the vinyl chloride with water tn a gasholder or recovery system before a reactor is opened. The level of the proposed standard is bas-.d on best available control technology as demonstrated by one plant, and there is no apparent reason why the same technology cannot be employed at other plants, except plants which produce bulk resins. This technology cannot be used for postpolymerization reactors in plants producing bulk resins for two reasons. First, the production of bulk resin is a dry process and water used to displace the vinyl chloride from the reactor before opening it would cause a contamination problem. Second, since the resin product is air conveyed from the postpolymerization reactor, the reactor is opened to the atmosphere after each batch. Manufacturers of bulk resins can achieve the level of the proposed standard by evacuating the reactor several times and breaking the vacuum with nitrogen. The number of evacuations would depend on the volume of gas in the reactor and the vacuum involved. A zero emission limit is being proposed for relief discharges which can be prevented. In most cases, such discharges from reactors can be prevented by measures including, but not limited to,properly instrumenting the reactors to detect upset conditions, injecting chemicals to stop the polymerization reaction during upset conditions, venting the reactor contents to a gasholder during upset conditions and ultimately to a recovery system, providing employees with O _0] COLOR!TE 008819 improved training on preventing and handling upset conditions, and utilizing a stand-by source of power. For other pieces of equipment, increasing pressure due to inert gases in the system can be relieved by manual venting to a gasholder or recovery system. The conditions which lead to discharges can also be prevented in most cases by proper handling and transfer of vinyl chloride or materials containing vinyl chloride. Discharges which cannot be avoided by taking such preventive measures, such as those caused by natural disasters, will not be in violation of the proposed standard if the owner or operator notifies EPA within 10 days concerning the nature and cause of the discharge. This notifi cation provision is necessary to permit EPA to investigate the surrounding conditions and determine whether the discharge could have been prevented. For the purposes of the proposed standard, operator error is considered to be preventable. 8.2.4 Fugitive Emission Sources The proposed standard includes emission limits for all known sources of fugitive emissions and is intended to minimize these emissions to the maximum extent possible with available control technology. Some of the emission limits are numerical^ defined. Where it is infeasible to state numerical limits, the standard specifies equipment and procedural requirements. All of the equipment and procedures specified for reducing fugitive emissions, such as removal of vinyl chloride from loading and unloading lines and process equipment before exposure to the atmosphere, dis placement of the contents of a Sump ling f'ia-.k busk to h.e during sampling, a:,n cupiure and cu.f'.il of the m. i s s i c,,, have U a : u.,od by COLORITE 008820 ofie or more ethylene dichloride-vinyl chloride or polyvinyl chloride pi an to end are described in plant responses to inquiries from ERA under the authority of section 114 of the Act. For fugitive emissions, the proposed standard requires that the vinyl chloride concentration in process equipment greater than or equal to 5500 1 (1250 gal) in volume (other than reactors) be reduced to 2 percent by volume at standard pressure and temperature before the equipment is opened to the atmosphere. This can be accomplished by vacuum pump or by displacement with water or inert gases. For process equipment that is smaller than 5500 1 (1250 gal) in volume, the proposed standard requires that the amount of vinyl chloride in the equipment be reduced to 110 1 (25 gal) at standard pressure and temperature before opening the equipment to the atmosphere. Any vinyl chloride removed from the equipment would have to be ducted through a control system. A cut-off point which requires that the vinyl chloride be reduced by a greater percentage in the larger pieces of equipment than in the smaller ones was established based on the reasoning that follows. As shown in Tables 4-8 and 4-9 in Chapter 4, the emissions from opening the larger pieces of equipment would be much greater than from opening the smaller pieces, even with the standard in effect. Furthermore, the larger pieces of equipment are generally designed for purging with inert gases or pulling a vacuum whereas the smaller ones are not. That is, the larcier pieces of equipment have short sections of pipe fitted with valves to which can be connected vacuum or purge lines. Also, in general 8-23 COLORITE 008821 the larger pieces of equipment are already or could be readily equipped so that the vinyl chloride removed from the equipment can be ducted to a control system. The smaller pieces of equipment include such things as pressure gauges, sections of pipe, pumps, and valves. For example, if there were no cut-off point, short sections of pipe fitted with valves would have to be installed in all sections of pipe which could possibly be opened. An extensive collection system would have to be installed to transfer the gases from each of the sections of pipe to a control system. Due to the large number of small pieces of equipment, the ductwork for transferring the gases from the equipment to a control system would be portable. This means that the ductwork would have to be disconnected frequently, and the standard would require that each time the ductwork were disconnected, the vinyl chloride concentration within it would have to be reduced beforehand. However, the standard would permit some vinyl chloride to remain in the ductwork before opening it to the atmosphere. Therefore, at the point where the volume of equipment is less than or equal to the volume of the ductwork, there is nothing to be gained by requiring that the vinyl chloride be removed from the piece of equipment before opening it. Another consideration with regard to small equipment is that much of it is not designed to withstand a vacuum. One example would be pressure gauges. In summary, a cut-off point has been established which is less stringent for smaller equipment in terms of percent vinyl chloride nem'iitted to be emitted from Lie equipment because: COLORXTE 008822 (1) The emissions from opening large equipment are much greater than from opening small equipment, even with the standard in effect. (?) The smaller equipment is not designed to use a vacuum or purge system to remove the vinyl chloride, and in some cases it is not designed to withstand pressure. (3) At some point the vinyl chloride emissions from disconnecting the extensive equipment needed to remove vinyl chloride from every section of pipe or other piece of small equipment and transfer it to a control system would be greater than the emissions from opening the section of pipe or other small equipment. The proposed standard includes a more stringent limitation for emissions from opening of reactors than it does for opening of other equipment. The emission limit for opening of reactors (0.001 kg/100 kg product) has already been discussed. The reason for the more stringent limitation for reactors is that, unlike other equipment, the reactors are typically opened on a frequent and routine basis. The same reasoning explains why the proposed standard includes a separate emission limit for emissions to the atmosphere from disconnecting equipment (hoses, couplings, valves, etc.) used in the transfer of vinyl chloride from storage to transport vessels at ethylene dichloride-vinyl chloride plants and from transport to storage vessels at polyvinyl chloride plants. Although the loading and unloading lines are relatively snail in volume compared with some of the other equipment which can be 8-25 COLORITE 008823 opened to the atmosphere, they are used and disconnected on a frequent and routine basis; i.e., several times per day. The proposed emission limit for each loading and unloading line requires that after each loading or unloading operation before opening any part of the lino to the atmosphere, the quantity or vinyl chloride in all parts of the line that are to be opened is to be reduced to 4.4 1 (1 gal), at standard temperature and pressure. Four and four tenths liters of vinyl chloride at standard temperature and pressure is equal to about 0.0098 kg (0.022 lb) of vinyl chloride. The method for attaining the standard would depend on the volume of the equipment to be opened to the atmopshere. If an entire hose is to be disconnected and opened to the atmosphere, the hose could be evacuated. However, more commonly there would be a couple of valves between the hose and the storage (or transport) vessel with a coupling between the valves. In this case, if only the coupling were to be disconnected and opened to the atmosphere, the percent reduction in vinyl chloride required would depend on the volume of the coupling. If it were 4.4 1 (1 gal) in volume- it would have to be reduced to 760 mm Hg and if it were 8.8 1 (2 gal) in volume, it would have to be reduced to 380 mm Hg, Also, during loading and unloading operations, the proposed standard would require that the emissions from the discharge end of slip gauges used to reusure the vinyl chloride liquid level in transport and storage vessels !r. c,vtured and ducted to a control system, essentially, there would be no omissions from slip gauees. COLOR!TE 008824 Leaks from seals on rotary pumps can essentially te eliminated ry using double mr-cnonical seals or pumps with no souls, such as the type with magnet to magnet drive or a canned pump in which the eddy current passes through the pump fluid. Leaks from seals on reciprocating pumps can be minimized by double outboard seals. Double mechanical seals can be used on agitators and compressors to minimize leaks. The proposed standard includes equipment specifications requiring that these methods, or equivalent, be used to minimize leaks from seals on pumps, compressors, and agitators. The proposed standard also includes equipment specifications requiring that leaks from relief valves be minimized by installing a rupture disk between each relief valve and the equipment served by the relief valve, or equivalent. An equivalent method of control would be to connect the discharge line from a relief valve to process equipment or to a recovery system. If a rupture disk were used as the method of control, there would be a potential problem if a leak should occur from the rupture disk and cause a build-up of pressure between the rupture disk and the relief valve. This is expected to occur infrequently because the reason for requiring the rupture disk is that it is less likely to leak than a relief valve. Although the proposed standard does not require any specific equipment or procedures to prevent the potential pressure build-up, there are several methods available for the plants to use to avoid this potential problem. These include (1) installing a pressure gauge between the disk and valve and routinely checking Die pressure, and {?.) installing a ball check excess 8-27 COLOR!TE 008825 9.1.3 The Promulgated Permanent Standard On October 4, 1974, after a series of hearings, economic and environmental impact studies, and formal comments, OSHA, under provisions of the Occupational Safety and Health Act of 1970 promulgated (39 FR 35890) a standard for vinyl chloride, polyvinyl chloride, and fabricating plants. The standard limits employee exposure to 1 ppm vinyl chloride (averaged over an eight-hour period) effective January 1, 1975. In addition, the regulation establishes a 5 ppm ceiling (averaged over a 15 minute period) in order to prevent exposure of employees to unacceptable high excursions. The standard allows for an action level of 0.5 ppm (averaged over an eight-hour period) in order to minimize the impact of the standard on plant owners and operators who have attained exposure levels well below the permissible limit. Thus, where the results of monitoring demonstrate that no employee is exposed to concen trations in excess of 0.5 ppm, plant owners or operators are in effect exempted from the provisions of the regulation. Further requirements include monitoring of employee exposure (monthly or quarterly depending upon criteria described in the regulation), designation of regulated areas, protective clothing, respiratory protection when the vinyl chloride level is not controlled to the permissible exposure limit, establishment of emergency procedures, warning signs, medical surveillance, employee training, employee medical recordkeeping, and reports on emergencies. In order to comply with the standard, each plant as of January 1, 1975, was required to institute feasible engineering and work practice controls to reduce exposure levels below the permissible exposme limits. 9-3 COLOR!TE 008826 Even if such controls would not reduce exposures below permissible levels, they nevertheless must be implemented to reduce exposures to the lowest practicable level and must be supplemented by the use of respirators to provide the necessary protection, A continuing program of increasing engineering and work practice controls is required until exposures are at or below the permissible exposure limits A plan for achieving control by engineering and work practice methods must be drawn up and made available, upon request, to representatives of OSHA and NIOSH. The regulation, however, does not establish any deadlines for full compliance through engineering controls because OSHA was unable to determine when it would be feasible for most plants to reduce exposure levels to the permissible level. 9.1.4 Amendments and Corrections to the October 4, 1974 Regulation On December 5, 1974, OSHA published (39 FR 41848) corrections to the October 4, 1974 regulation and on December 30, 1974 OSHA amended (39 FR 45012) the October 4, 1974 regulation by requiring that respirators for employee protection contain end-of-service life indicators as of June 20, 1975. The Society of Plastics Industry, Inc. (SPI) challenged the October 4, 1974, OSHA regulation in the U. S. Court of Appeals for the Second Circuit, The Society of Plastics Industry, Inc, v. Occupational Safety and Health Administration, 501 F. 2d 1301 (1975); cert. den. sub, nom. Firestone Plastics Co. v, U.S. Department of Labor, 43 U.S. Law Week 3623 (1975). SPI contended first, that available scientific and medical evidence does not establish that the 1 ppm 9-3 COLORITE 008827 exposure level adopted by OSHA is required by health and safety considerations and, second, that meeting the 1 ppm is technological ly and economically infeasible. In its January 1975 decision, the Court unaminously upheld the standards established by OSHA and stated that they would go into effect in 60 days (about April 1, 1975). In response to SPI's first contention, the Court found the evidence regarding vinyl chloride's dangers "quite sufficient to warrant" OSHA's restrictions. Noting that much of the evidence was based on animal exposure to the chemical, with only indirect human evidence, the Court stated that, "nevertheless, it remains the duty of [OSHA] to act to protect the working man and to act even In circumstances where existing methodology or research is deficient." The Court labeled SPI's second claim as "exaggerated" and found OSHA's standards "clear, definite and certain ... entirely feasible, since the goal of the lowest detectable level can definitely be attained through the combination of technological means and respirators." According to the Court, the affected companies "simply need more faith in their own technological potentialities." The Society of Plastics Industry, Inc. appealed the decision to the U.S. Supreme Court but, as noted in the citation above, the Court declined to review the case. 9.1.5 Relationship of the Proposed CPA Standard and the OSHA Regulation. In response to the OSHA regulation, vinyl chloride companies have adopted some measures which not only reduce employee exposure, but also reduce emissions to the atmosphere, "^ese measures have resulted in 9*4 COLORITE 008828 seme reduction cf fugitive emissions and emission excursions. For example, at man/ of the plants, portable and fixed point monitoring systems have been employed to defect leaks and minimize one source of fugitive emissions. Improved sealing techniques and new pumps have been used in some plants. Nitrogen has been used to purge vinyl chloride from hoses used for product sampling and for transferring vinyl chloride between railroad cars and storage areas at some plants. Levels of vinyl chloride in railroad cars at some plants are now being measured by sonic and magnetic detectors to prevent exposure of car contents to the atmosphere. Some plants have reduced the number of entries into polyvinyl chloride reactors by utilizing jet water sprays and solvent cleaning. Many polyvinyl chloride plants are developing improved stripping both to reduce emissions at these plants and to satisfy the demands of fabricators for whom the most cost-effective approach for meeting the OSHA standard is to use a resin of minimal monomer content. Control devices, such as carbon adsorption, are also being installed in a few plants. Other methods of reducing employee exposure to vinyl chloride, such as respiratory protection, ventilation cf the work place, removing sides of buildings, and installation of tall stacks, do not, however, reduce emissions to the atmosphere, tven though the OSHA regulation requires all employees to institute feasible controls to the fullest extent possible and to continue to improve and apply engineering controls until full compliance is achieved, it does not set any deadlines for such compliance. Further, there is no deadline 9-5 COLORITE 008829 for the required submittal of formal plans demonstrating how plants will achieve the standard. For these reasons, it is difficult 10 evaluate at this time the degree to which the OSHA regulation will reduce vinyl chloride emissions to the atmosphere. It is expected that the plants will respond to the OSHA regulation with a combination of ventilation techniques, emission reduction, and respiratory protection and that this response will not be uni form. 9.2 Environmental Protection Agency 9.2.1 Water Regulations Although the vinyl chloride and polyvinyl chloride industries will have to meet other effluent guideline regulations for BOD, COD, TSS, and pH, there are at this time no plans for developing a water effluent regulation specifically for vinyl chloride. Vinyl chloride concentrations of 2-3 ppm and at times higher have been recorded from manufacturing plant effluents. However, due to the tendency of vinyl chloride to escape from water into the air, it is unlikely that such contamination would persist in downstream water which might be used for drinking purposes.'' Under the authority of the Safe Drinking Water Act of 1974, as amended, EPA has initiated studies of suspected carcinogens in drinking water. In an interim report to Conoress, Preliminary Assessment of Suspected Carcinogens in Drinking Water, June 1974, EPA reported detections of vinyl chloride in surface wafer in Philadelphia, Pennsylvania and in ground water in Miami, Florida, rthvlc-ne Hi chinridpv'nyl chloride riant? and polvvinyl chloride plants ere not the source 9-5 COLORITE 008830 of the detected vinyl chloride since there are no such plants in these two locations. 9.2.2 Pesticide Peculation On April 26, 1974 and July 19, 1974, ERA published in the FEDERAL REGISTER (39 FR 14753 and 26480) an emergency suspension order for specific indoor aerosol pesticides containing vinyl chloride. These regulations have little, if any, relationship to the proposed standard. The amount of vinyl chloride usea in all aerosol products was less than 0.1 percent of total vinyl chloride production (based on 1972 data). A ban on these products, therefore, has little effect on the production of vinyl chloride and, consequently, on the emissions of vinyl chloride at ethylene dichloride-vinyl chloride plants. 9.3 Department of Transportation On July 23, 1974, the Coast Guard proposed in the FEDERAL REGISTER (39 FR 26752) amendments to the bulk dangerous cargoes regulations for the carriage of vinyl chloride monomer. As promulgated on April 16, 1974 (40 FR 17024), these amendments require venting, gauging, monitoring, and cargo transfer systems which provide greater protection to personnel than those previously permitted. The Coast Guard also promulgated, under appropriate emergency rulemaking provisions, amendments not proposed in July 1974, including establishment of regulated areas, use of respiratory protection by employees engaged in hazardous operations and use of warning signs. These amended regulations apply to all tank vessels, both existing and newly constructed, carrying vinyl chloride. 9-7 COLORITE 008831 Currently, the Coast Guard is drafting a new proposal which would require permanently installed equipment for detection of vinyl chloride in cargo pump rooms and employee medical recordkeeping similar to the OSHA requirement. Both the promulgated and the proposed amendments will have little, if any, impact on the proposed EPA standard. 9.4 Department of Health, Education, and Welfare 9.4.1 Food Packages On May 17, 1973, the Food and Drug Administration (FDA) proposed (38 FR 12931) regulations which would eliminate polyvinyl chloride resins in packaging material for use in contact with alcoholic foods. The U.S. Department of the Treasury then withdrew its approval for the use of polyvinyl chloride plastic bottles for distilled alcoholic beverages. This made promulgation of the FDA regulations unnecessary. On September 3, 1974, (40 FR 40S29) FDA proposed regulations which would ban the use of vinyl chloride plastics in bottles, blister packs, boxes, and other semi-rigid and rigid packaging that comes in contact with food. The proposal would also prohibit vinyl chloride plastics in coatings applied to fresh citrus fruits to retain freshness. The proposed regulation would continue to permit vinyl chloride plastics in pliable (plasticized) film-type wraps, gaskets, cap liners, tubing, and package coatings which come in contact with food. FDA considered prcnnsinn a restriction on the use of vinyl chloride plastics in potable water pipes, but 9-8 COLOR!TE 008832 decided not to because Dresent evidence shows little likelihood that vinyl chloride migrates into the potable water from pipes being used to transport the water. Continued FDA approval for vinyl chloride use in water pipes, however, would be contingent upon additional confirmatory studies to be started within 60 days after promulgation of the proposed regulations. 9.4.2 Aerosol Products On August 26, 1974, FDA promulgated (39 FR 30830) a regulation which banned any cosmetic aerosol product containing vinyl chloride. The same regulation classifies any aerosol drug product containing vinyl chloride as a new drug and requires that a new drug application be approved before the product is marketed. Since such a small percent of vinyl chloride was used for aerosol products, the regulation for cosmetic and drug aerosols has little impact on production capacity and, therefore, vinyl chloride emissions at vinyl chloride monomer plants. 9.5 Consumer Product Safety Commission On August 21, 1974, the Consumer Product Safety Commission promulgated (39 FR 30112) regulations concerning household substances in self-pressurized containers having vinyl chloride monomer as an ingredient or in the propellant. The regulations classified such a substance as a "banned hazardous substance" as defined in the Federal Hazardous Substances Act. Again, since such a small percent cf vinyl chloride production v?s '!rivc''ved, t^e regulation has little effect on vinyl chloride production and emissions. 9-9 COLOR!TE 008833 9.6 State Regulations In contacting the officials of several of the States where the majority of the ethylene cichloride-vinyl chloride and polyvinyl chloride plants are located (Texas, Mew Jersey, California, Illinois, Louisiana, Ohio, and Kentucky), it was learned that essentially no regulations exist specifically for the regulation of vinyl chloride. Some of the States do have regulations for hydrocarbons and new construction, however, which indirectly reduce vinyl chloride emissions at some plants. For example, the States of New Jersey2 and Texas 3 require that best control technology be employed to control any pollutant (including vinyl chloride) when a source is newly constructed or modified. The only plants presently required to comply with these regulations are three polyvinyl chloride plants in Texas which must employ what has been specified by the State as best control technology for each emission point, except the dryer. The dryer stack must be designed so that dispersion calculations indicate that the maximum exposure level is below 1 ppm. These three plants may have to install additional controls to meet the proposed EPA standard for vinyl chloride. 4 In granting permits for new construction, Louisiana and c Kentucky use OSHA standards as guidelines for exposu-re of the general population to pollutants for which no EPA standard has been specified. The goal for ambient concentrations of vinyl chloride in both States is 0.05 ppm, or 5 percent of the OSHA standard. 9-10 COLOR!TE 008834 In regard to hydrocarbon standards, most of the States have standards for photochemically reactive hydrocarbons and/or for ethylene. These include Texas and Louisiana where most of the ethylene dichloride-vinyl chloride plants are located. Texas can regulate existing etnylene dichloride-vinyl chloride and polyvinyl chloride plants through the State Implementation Plan hydrocarbon regu lations if the plants emit more than 100 lb of ethylene/day; if they emit more than 100 lb of photochemically reactive hydrocarbons/day in a gas stream that is more than three volume percent; or if they emit more than 250 lb of photochemically reactive hydrocarbons/hr. If they emit more than 100 lb ethylene/day they must take some abatement action to reduce emissions. If they emit more than 100 lb of photochemically reactive hydrocarbons/day in a gas stream with more than three volume percent, or if they emit more than 250 lb of photochemically reactive hydrocarbons/hr, they must control the effluent streams with incineration. Ethylene dichloride-vinyl chloride and polyvinyl chloride plants apparently do not emit sufficient quantities of photochemically reactive hydrocarbons to be covered by these regulations. As a result of the ethylene regulation, however, three ethylene dichloride-vinyl chloride plants will be required to control their oxychlorination reactor emissions. Two of these plants, which plan to use incineration to control emissions from the oxychlorination reactor, will be reducing vinyl chloride as well as ethylene dichloride emissions. The third plant is planning to install an additional reactor which will allow more complete 9-11 COLOR!TE 008835 reaction of ethylene and chlorine to ethylene dichloride. The effect of the additional reactor on vinyl chloride emissions is not known at this time. Louisiana's emission limits for ethylene from the oxychlorination reactor can be achieved by incineration or the installation of an additional reactor. At-this time, it is not certain which control measures will be applied by the plants, but the installation of an additional reactor is expected to be the favored option. 9-12 COLORITE 008836 References 1. "EPA Urges Prompt Steps by Chemical Industry to Reduce Vinyl Chloride Air Emissions,'' Environmental News, ERA, Washington, D. C., June 1 1 , 1 974. 2. Telephone LUMVer bet L i on beli'.eeri Susan Wyatt (ERA) anu Mi. Ton. Lcimaiu, New Jersey Bureau of Air Pollution Control, Division of Environmental Quality, Department of Environmental Protection, Trenton, N. J., March 6, 1975. 3. Telephone conversation between Susan Wyatt (EPA) and Mr. Sam Crowthers, Texas Air Control Board, Austin, Texas, January 7 and February 21, 1975. 4. Telephone conversation between Susan Wyatt (EPA) and Mr. G. Von Bodunger, Air Control Section, Bureau of Environmental Health, LITSRA, New Orleans, Louisiana, January 8, 1975. 5. Telephone conversation between John Davis (EPA) and Mr. Murphy, Division of Air Pollution, Kentucky Department for Natural Resources and Environmental Protection, Frankfort, Kentucky, March 10, 1975. 9-13 COLORITE 008837