Document p2BDOBq0o3EDqVezv3beQnZ7X

INTEROFFICE memorandum R. C. Sander cc: J. Andersen (Escambia) R. Duggan (Escambia) B. Helms (Calvert City) H, Ortega (Calvert City) R. Schenck J. Spata Subject Date 22 November 1983 EPA Review of the VC Standard Plastics {Location. OittnliiliAA, of OlUrlmint> Regulatory Response (Location, O'tantution, or Department) The enclosed Vinyl Institute report describes the recent meeting with EPA at RTP which I missed because of a scheduling conflict. Note that- a new survey is to be conducted by the.VI. If I understand It correctly, I should have enough data In my files, except for the batch number data from Escambia fear the mcntltfslnce the old $PI report was dropped. 0TB: csb Attachment (3201 AP00022925 SUBJECT: MEETING BETWEEN: UEHORAN Presant: Durham, North Carolina November 15, 1963 for EPA - ' Susan Wyatt. Gil Wood, 1. Purpose of Meeting s' : Ms. - Wyatt thanked The Vinyl Institute representatives for coming and Indicated that EPA that the numerical approach is a viable one and naeds to be further explored. Hr. Holbrook Indicated that the meeting had been requested as an exploratory meeting to hear from Radian Corporation concerning the scops of the study that thay ars to carry out for EPA and to help both Radian and EPA thereby helping the member companies of The Vinyl Institute* Be noted thet The Vinyl * Institute has compiled numerical dsts relating to relief valve, rupture disc and ******'! vent valve discharges-which it was willing to share with the Agency. 2. Statue of EPA Program and Timetable Ms. Wyatt noted that Radian la working on developing information to enable the Agency to propose changes in the relief valve discharge standard. There objective, if possible, Is to go to a numerical standard and to remova the "fussy part." The Agency ia concerned that people will be thinking that the Agency Is becking off from Its original standard so that It feels it must get more educated. She noted that an earlier study TRW had received a lot of Information and in addition, the Agency has aecaaa to the 10-day reports on relief valve Incidents. Radian and EPA plan to visit plants that have been the "better performers" to see whet techniques arc being used. They also went to develop e historical pattern so that they are able to prove that the discharge frequency end volumes have bean reduced. Ha. Wyatt noted that they have gotten information from Region VI on e plant-by-plant basic and have also requested elmller dete from Regions II and IV. She also noted that four year data had bees submitted by SPI. AOtotonrf THE SOCIETY Of THE PLASTICS INDUSTRY, INC. 986 LEXINGTON AVENUE NEW YORK, N.Y. 10017 (212) 573-9400 AP00022926 <* v 'page 2 November 17, 1983 The current plan la to put together a package with the information that has been developed by the end of January and meetings would be held during February and Kerch so that e package could be delivered to Naptac by April. At that time, they would formally ask for comments from intersstsd parties. She noted that this la e very tight time schedule in that they are trying to accomplish In six months what normally requires elsven. As far as plant visitation goes, Ks. Wyatt Indicated there current thinking was to visit facilities of Formosa Plastics, Shln-Tech, Georgia Pacific, Tenneco and Goodrich. 3. Vinyl Institute Survey la Discussion on Data Collection The survey conducted by The Vinyl Institute (see Appendix A) was distributed. It was pointed out that the data represent a 12-mouth rolling avarage on pounds of vinyl chloride released per million pounds of PVC production or VCK production and ebat there are significant differences in the reporting plants. Mr. Holbrook noted tbst there is a definite difference between the pounds released from bulk (mass) polymerization plants and other plants which carry out dispersion or suspension polymerization processes. Mr. Holbrook also indicated chst he believed that an "old" or "small" plants can be just as good as a'hed'or "large-scale" reactor plane. Hr. Barton, on the other hand, indicated that ha has found that a difference does exist between releases from small and large planta. During the discussion on the data it was indicated that the Agency wishes to standardize on how a release la determined and there are variations In methods used. What is needed Is a method to measure relief valve discharges and the Agency seeks the input of The Vinyl Institute on how this can best be accomplished. Mr. Holbrook offered the help of The Vinyl Institute members in collecting information on how the individual companies calculate their releases and offered to share this Information with, the Agency to see if a method can be standardized. It was pointed out chat the enforcement group at EPA would vary much Ilka to have a "black-and-white" standard, especially one that state agencies can handle. Hr. Evens suggested thee a numerical approach may still narrow down to the number of discharges if the Agency Is unable to develop a quantitative method Involving the pounds evolved In a given period of time. Ma. Wyatt stated that the numerical approach, la a viable option that they are seriously considering, but she cautioned that there are no guarantees the Agency will adopt It. She noted on the other hand that the work place practice has the same problems as the current standard and they are not leaning towards approach since there are problems of interpretation by the enforcement people. 4. Maw Survey to be Conducted * On Idle basis that The Vinyl Institute wishes to be of assistance to the Agency and cooperate with them in every way, considerable time was spent in developing informa tion that Is required by the Agency in order to survey the current state of relief valve discharges. After considerable discussion, it was agreed that Vinyl Institute members will be surveyed sad asked to respond to information on PVC procssses includ ing suspension, dispersion, mass, and latex polymerization processes and providing information on the number of releases, the pounds of vinyl chloride released on AP00022927 /' 'page 3 November 17, 1983 the beets of both production volume end number of batches. The data will be supplied on monthly basis for the period of August, 1981 through August, 1983. A separata survey on vinyl chloride plants will also be made for the same period and will cover the number of releases and pounds released per month end per million pounds of production. It was Indicated that this survey will taka some time to complete but we will undertake it promptly and report back to the Agency es soon es the data Is svsllsble. 5. EPA/Radian Information Obtained from Region VI The Radian representatives presented a table of data involving vinyl chloride monomer relief valve discharge data suxzmary by year (Appendix B) which Is their summary both on pounds, per million pounds of production, pounds released annually and the number of discharges for various plants in Region VI. Also prsseaced was a breakdown, of relief valve discharges (Appendix. C) which provides a breakdown on the reasons reported for these discharges end recommendations being considered by Radian to eliminate such discharges. After some discussion, it was recommended that since the Shin-Tech and Tenneco plants are sister plants, chat consideration be given to visiting one additional bulk polymerization plant, one additional EDC-beaed vinyl chloride- monomer plant and one plant that contained small reactors. Mr, Barton offered the Agency the opportunity to visit the Borden Illapolls. plant which contalna small and large reactors, this contingent on the Agency signing a suitable confidentiality/ secrecy agreement. 6. Confidentiality Agreement Ms. Wyatt indicated that EPA no longer will allow contractors to sign separate third party confidentiality agreements. She Indicated that the Agency's Office of General Counael has developed a "memorandum of understanding" which protects confidentiality in their view. Their proposed memorandum on confidential treat ment is attached (eee Appendix D). This memorandum should be reviewed by legal counsel of the companies involved. Hr. Barton pointed out that one of the problems without having a confidentiality agreement with the contractor itself is that should an employee leave the contractor's employ, the cooperating company has no recourse on the protection of its information. Ms. Wyatt indicated that inasmuch as contractor's employees were designated ee "authorized representatives" of EPA, the Agency felt that confidentiality was protected. Nevertheless, this should be re viewed by the individual companies involved, 7. Review of Other Parts of the Standard In response to Mr. Holbrook's question es to other points within the vinyl chloride emission standard that the Agency was considering reviewing, Susan Wyatt indicated that generally they vera updating the data base without any idea of really changing the standerd. Mr. Holbrook asked whether EPA would egree to some malfunction pro visions for those Infrequent Instances vhera the 10-parts per million stendard is not mst. Ms. Wyatt said that the Agency thought that making 10-parts per million s continuous compliance ovsr e three hour average period would take care of the Infrequent excursions. She else indicated that ehe Agency was considering AP00022928  page 4 November 17, 1983 requiring reporcing on a quarterly basis to be consistent with other reporting requirements. 8* Puture Program Participants agreed that this vas a useful meeting and once the survey data is available, it was agreed chat the parties would sic down again to review the data obtained and to plan any future cooperative work. RTGtjmd Attachments cc: V. Bailey Barton Robert Oubre Jamas Kaehtick V. C. Holbrook J Barr s'' N. Blackman J. Ledvina J. King S. Kuia J. A. Mullins --~ Pater de la Crus - for your information AP00022929 AP00022930 PVC Plants ** >A B C* D E F G H 1 J _____ *CAL\S**4l-T. L M N 0 P 0 R S Aag- Sept. 0.65 2.4 85 93.7 0 II 84 2 6.1 3.6 1.36 0.03 328.1 2.4 18 0.03 0 40.6 202 0 2.3 84 93.0 0 10 0 0.3 6.5 0 1.36 0.03 289.8 2.1 17 0.03 0 38.1 200 TWLVE MONTH ROILING AVERAGE |N0EX(|* POUNDS VCH RELEASED PER MILLION POUNDS PVC PBOOOCTION ..-..A.... . 1902________ Oct. Nov. Dec. ________ Jen. Fab. Mar. Apr. 1983 May June July Aug. 0 1.0 4.9 177.0 0 10 0 0.2 6.9 0 2.66 0.03 125.5 1.4 15 0.03 0 30.3 199 0 .7 4.0 176.0 0 ID o.ooe 0.2 0 0 3.53 0.03 146.6 1.4 15 0.03 0 37.5 198 0 .7 4.8 191.0 0 8 0.000 0.2 0 0 4.87 0.03 151.4 1.3 14 0.03 0 36.5 115 0 5.0 2.5 225.0 0 8 0.008 0.2 47.7 0 14.5 0.03 150.4 i.4 14 0.03 0 35.5 122 00 4.9 4.9 2.9 2.9 219.0 719.0 0 3.2 07 0.000 0.000 00 47.8 47.4 00 Plant Closed 0.03 0.03 97.7 207.4 1.0 13 1.0 3 0.03 0.03 00 34.9 34.4 117 113 O 4.6 2.9 210.2 3.2 12 0.008 0 40.2 0 - 0.03 284.7 1.7 0 0 0 33.9 110 0 4.5 2.9 156.2 3.1 II o.ooe 0 46.2 0 - 0.03 267.8 1.4 0 0 0 33.5 106 0.5 4.1 2.9 160.9 3.1 16 0.02 0 46.3 0 - 0.03 275.1 1.4 0 0 0 34.1 103 0.5 4.0 2.9 147.3 3.2 10 0.02 0.2 44.6 0 - 0.16 279.9 1.3 0 0 0 39.8 a 0.5 10.3 1.6 146.9 7.4 10 0.02 3.0 44.0 0 - 1.2 255.0 1.4 0.06 0 0 8.2 8 Sept. Ml 11 Ion Pounds Production421 260.6 265.2 265.2 262.5 272.5 279.3 278.6 264.0 280.4 264.2 280.9 295.6 298.2 41 * Each Monthly Index entry The sua of al I relief valve, rupture disc, and Manual vent VCM releases for tie previous 12 eontIs divided by the sue of all PVC production at the plant for the previous 12 Months. 12) Each Monthly entry represents the sun of lie previous 12 Months PVC production for plants A ttrough S divided by 12. Source * Tha Vinyl Institute Noveaber 1963. TWELVE MONTH ROLLING AVERAGE INDEXHI ROUNDS VCM RELEASED PER MILLION POUNDS VCM PRODUCTION VCM Plants A n c D 1. f r, 11 1 Ml 11 Ion Prw>ivl'. Production'71 Auq. 4.8 2 6.6 0.4 ?7.34 173 3,4 7.CO n.40 Sept. 4.7 0.2 6.5 0.13 26.96 124 3.4 2.61 0.37 1962______________________________________ 1983 Oct. Nov. Dec. Jan. Feb. Mon. Apr. 2.3 0.2 6.3 0.13 26.96 123 24.5 2.58 0.35 2.3 0.2 18.8 0.13 26.62 122 73.2 2.71 0.33 2.3 0 18.3 0.13 4.11 58 23.9 2.87 0.31 2.3 0 18.0 0.12 4.03 59 23.4 2.01 0.31 2.3 0 17.8 0.12 4.05 59 23.5 2.90 0.B5 2.5 O 17.8 0.13 6.65 61 23.5 2.94 0.78 2.9 6 16.7 0.12 7.53 64 32.9 0 0.47 May June July Auq. 5.8 6 15.6 0.12 7.37 62 34.0 0 37.92 5.6 6 15.5 0 7,08 0 34.2 0 37.38 3.1 S 15.0 0 6.91 0 34.3 0 36.57 3.1 5 10.6 0 7.50 .04 31.1 0 36.57 355.5 360.8 370.5 374.4 375.3 379.6 375 370.1 364.8 376.6 375.3 382.1 387 Ee*-J .Mll r, 1rfev entry = Tie sw of all relief valve, rupture disc, and Manuel vent VCM releases for tie previous 12 wont Is divided l>y t lo sum ol all VCM production at tie plant for tie previous 12 wonths. ,7> acl ihiI l.ly '"iti y represents tie sum of tie previous 12 Months VCM production for plents A ttroegh f divided by 12. Sourcm - lie Vinyl Institute November 1963. Z6ZZ000dV CQ SL. Af p-t#i.J\yL a REASON OPERATOR ERROR PREMATURE RELEASE INSTRUMENT MALFUNCTION POWER FAILURE EQUIPMENT FAILURE UPSET CONDITIONS INCORRECT SRV SETTING UNKNOWN/NOT AVAILABLE TOTAL OF DISCHARGES BREAKDOWN OF RVDS 1977 - 1982 CONTROL EDC/VCM PLANTS PERCENT PERCENT BY BY NUMBER WEIGHT PVC PLANTS PERCENT PERCENT BY RY NUMBER WEIGHT OPERATOR TRAINING/SOP MAINTENANCE PROGRAM O/A MtNTENANCE/REDUNBANT IHS1R. BACK-UP POWER ) 1 A3.8 6.1 21.5 3.8 6.9 B.5 3.1 6.2 A5.2 A.3 19.6 11.0 10.6 B.2 3.2 1.8 30.5 9.0 26.9 1.2 20.3 6.0 0 6.0 *2.2 32.5 18.5 l.A 1.8 0.6 0 2.9 130 213.000 LBS 167 366.000 IBS AP00022913 f A'pp ewdix ^ MEMORANDUM ON CONFIDENTIAL TREATMENT OF CERTAIN INFORMATION FOR USE WITH SITE VISITS BY EPA AUTHORIZED CONTRACTOR REPRESENTATIVES UNDER AUTHORITY OF SECTION 114 OF THE CLEAN AIR ACT 1. Pursuant to the provisions of Section 114 of the Clean Air Act, as wended, (source) (hereinafter "the source") will provide, or give access to, Information.requested by the Environmental Protection Agency (EPA) In the course of carrying out Its responsibilities* Such information and such access will be provided to EPA and to Its duly authorized repre sentative (contractor) (hereinafter "the contractor") designated by EPA to assist EPA In carrying out such responsibilities pursuant to Contract No. _______ EPA. The information requested may be either documentary (e.g., records, photographs or charts) or non-documentary (e.g., oral communications, taking of photographs, or visual observations). EPA and the contractor recognize that the source nay consider the Informa tion so provided, or some part of It, to be confidential within the meaning of Section 114 and 18 U.S.C. 1905. The source may assert a claim of confidentiality under the procedures established In Part 2 of Title 40 of the Code of Federal Regulations (40 CFR Part 2) by noting such claim on documentary material provided to the contractor or to EPA. The contractor will note such claim when submitting the Information to EPA. The EPA will note such claim when submitting such Information to the contractor. Moreover, the source may notify the contractor or EPA that it considers the non documentary Information provided to EPA or to the contractor to be confidential. The contractor will note said claim of confidentiality In any reports or documents submitted to EPA which utilize such non-documentary Information. The EPA will note said claim of confidentiality In any reports or documents submitted to the contractor which utilizes such non-documentary Information. Any material AP00022934 /2 op Information claimed as confidential .will be treated by the contractor as confidential In accordance with Its contract and will be treated by ERA In accordance with the provisions of 40 CFR Part 2. Any material or Information for which a claim of confidentiality is not made may be made available to the public by EPA without notice to the source. 2. The provisions In the contractor's contract with EPA concerning the use and disclosure of confidential information are included therein for the benefit of, and shall be enforceable by, both EPA and the source. The provisions of Contract Mo. between EPA and the contractor provide: a. The contractor and Its employees will* (1) use the i- Information claimed to be confidential only for purposes of carrying out the work required by the contract; (11) not disclose the Information to anyone other than EPA employees without the prior written approval of the Assistant General Counsel for Contracts and General Administration; and (ill) return to the EPA Contracting officer all copies of the information, and any abstracts or excerpts therefrom, upon request by the Contracting Office, whenever the information Is no longer required by the contractor for the performance of the work or upon completion of the contract. b. The contractor will obtain a written agreement to honor 4 the provisions of paragraph 2(a) from each of Its employees who will have access to the Information, before the employee Is allowed access. AP00022935 3 c. The contractor will not use any Information claimed to be confidential to compete with the source. d. Before entering Into any subcontract that will Involve either the disclosure to a subcontractor by the contractor of Informa tion claimed to be confidential, or the collectlon'of Information by a subcontractor, the contractor will obtain the written consent of the EPA Contracting Officer, after a written determination by the appropriate EPA program office. 3. Any subcontractor who will have access to the Information Is subject' to the restrictions set forth In this memorandum. 4. It is Intended that this memorandum be consistent with and not exceed the provisions of 40 CFR Part 2 and the provisions of Contract No._______ ' This memorandum does not address Information not obtained from the source. Nothing In this memorandum relieves the contractor of any liability ft may Independently have to the source as a matter of statutory or comnon law from Injury to the source arising from the contractor's release of Information In a manner which exceeds Its authority under 40 CFR Part 2 and Its contract with EPA. U.S. Environmental Protection Agency Company By:B*; _____________________________________________________________________________________ Date: ________________ Date: Contractor By: _________________________ Date: _____ AP00022936