Document pJEXa5ZV0ojbJb1Rwb92pJg7
tenneco POLYMERS, INC.
(COMPANY)
TO: OPERATIONS - PASADENA FOR: F. KOSLOSKY FROM: G. E. DISCH RE: EPA: STANDARD ON VINYL CHLORIDE
DATE: JANUARY 17, 1985
I am attaching for your use the latest standard for vinyl chloride issued by the EPA. It was issued on January 9 in the Federal Register.
GED/rs Attachment
cc: H. R. Bowers D. M. Hersh J. W. Kachtick R. R. Neugold
Guy E. Disch
TEN 3874
Wednesday January 9, 1985
Part V
Environmental Protection Agency
40 CFR Part 61 National Emission Standards for Hazardous Air Pollutants; Vinyl Chlorid ; Proposed Rule and Notice of Public Hearing
rEN 3875
1182
Fdnl Registae / Vol, 80. No. 0 / Wedneaday. January >, 1965 / Propoted Ku)w
ENVIRONMENTAL PROTECTION AGENCY
40CFR Hrttl (AD-FRL-27S7-4)
National Emlaalon Standards tor Hazardous Air Poltutanta; Vinyl Chlorid#
AOCHCY: Envoronmental Protection Agency (EPA). action: Proposed rule and notice of public hearing.
Summary: The current emission standard for vinyl chloride [VC) was promulgated under Section 112 of the Clean Air Act in 1976. A review of the technological basis and administrative aspects of the standard has been completed, and the conclusions of the review are presented in this notice The conclusions are the basis for this action which (1) proposes administrative and clarifying revisions to the standard and (2) announces decisions pertaining to other aspects of the current standard. This notice also withdraws proposed revisions to the current standard which were published in the Federal Register on June 2,1977 [42 FR 28154).
If requested, a public hearing will be held to provide interested persons an opportunity for oral presentations of data, views, or arguments concerning the proposed revisions to the current standard.
Oates: Comments. Comments must be received on or before March 25.1965.
Public Hearing. If anyone contacts the EPA requesting to speak at a public hearing by January SO 1965, a public hearing will be held on February 26, 1985 beginning at 9:00 a.m. Persons interested in attending the hearing should call Ms. Shelby Joumigan at (919) 641-5576 to verify that a hearing will
ccur. Request to Speak at Hearing. Persons wishing to present oral testimony must contact EPA by January-30,19B5. Incorporation by Reference. The incorporation by reference of certain publications in these standards will be approved by the Director of the Federal Register as of the date of the final rule.
ADDRESSES: Comments. Comments should be submitted (in duplicate if possible] to: Central Docket Section (A130). Attention Docket Number A-81-21. U.S. Environmental Protection Agency. 401 M Street. S.W.. Washington, D.C. 20460.
Public Hearing. If anyone contacts the EPA requesting to speak at a public hearing by.January 30,1985. the public hearing will be held at EPA Auditorium.
comar of Highway 64 and Alexander Wait for relief valve discharges. (2)
Drive. Retoarch Triangle Paik, North . providing a compliance teat procedure
Carolina. Persons Interested In attending and a specific emission limit for
the bearing should call Ms. Shelby
Operator* who perform stripping
Joumigan at (919} 641-6578 to verify thef operations In reactors, and (3) specifying
a hearing will occur. Persons wishing to requirements for leak detection and
present oral testimony should notify Ms. repair programs for certain equipment in
Shelby Joumigan, Standards
VC service. Additional minor
Development Branch (MD-13), U.6.
administrative changes to the standard
EnviromentBl Protection Agency,
are being proposed end ere explained
Research Triangle Park. North Carolina .later in this preamble.
27711. telephone number (919) 541-657*.
Summary ofHealth. Environmental
Background Information Document
Energy, and Economic Impacts. Since no
The general findings of the review study major revisions to the standard are
are documented in "Vinyl Chloride--A being proposed, the impacts resulting
Review of National EmiBBion
froig the current standard remain
Standards", EPA-450/3-82-003 (NT1S- generally unchanged. In 1975, it was
PB 84-114354), available from die
estimated that emissions of VC from
National Technical Information Service, . plants producing ethylene dichloride
5285 Port Royal Road. Springfield.
(EDC), VC monomer and polyvinyl
Virginia 22161. The major technical-
chloride (PVC) would be reduced from
analysis for the review study is
96.000 Mg/yr to 4.910 Mg/yT under the
contained in a separate document which current standard, representing an
may be obtained from the U.S. B>A
emission reduction of 91,000 Mg/yr of
Library (MD-35). Research Triangle
VC (or 95 percent of VC emissions).
Park. North Carolina 27711, telephone
Emissions of volatile organic compounds
number (919) 641-2777. Please refer to
fVOC) and EDC are also reduced under
"Vinyl Chloride: Relief Valve Discharge file standard.
Standard," EPA-450/3-85-002, for the technical document.
Docket. Docket No. A-81-21,
containing supporting information used in developing the proposed standard is available for public inspection And copying between 8:00 a.m. and 4:00 p.m.. Monday through Friday, at EPA's Central Docket Section. West Tower Lobby. Gallery 1. Waterside Mall, 401M Street, SW\, Washington, D.C. 2D460. A reasonable fee may be charged for copying.
The estimated risks attributed to exposure to VC from EDC/VC and PVC plants in operation prior to the current
standard were 5.5 cases per year for liver angiosarcoma and 11 cases per year for all cancers. The risks attributed to exposure to VC from sources under the current standard have been estimated to be 0.28 caseB per year for liver angiosarcoma and 0.55 cases per year for all cancers.
!n 1975. the estimated capital cost for existing plants to meet the VC standard
FOR FUTHER INFORMATION CONTACT:
was $198 million, of which $15 million
Mr. Robert E. Rosensteel or Mr. Leslie B. was for EDC Bnd VC monomer plants
Evans. (919) 541-5671, concerning
and $183 million was for PVC plants.
technical aspects of the industry and
The EPA estimated that the annualized
control technologies, and Mr. Fred
cost (including capital amortization, etc.)
Dimmick or Mr. Gilbert H. Wood (919) to these plants to maintain the required
541-5578, concerning regulatory
emission levels would be $70 million per
decisions. The address for these
year.
contacts is Emission Standards and Engineering Division (MD-13), U.S.
Background
Environmental Protection Agency,
The VC standard was proposed on
Research Triangle Park. North Carolina December 24.1975 (40 Fr 59532), and
27711.
promulgated on October 21,1976 (41 Fr
SUPPLEMENTARY INFORMATION:
Summary of Revisions to Current Standard
46559). It is applicable to plantB producing EDC by the reaction of oxygen and hydrogen chloride with ethylene, plants producing VC by any
Revisions. Several administrative
process, and plants producting one or
changes are being proposed as a result more polymers containing any fraction
of a review of the national emission
of VC. These plants are subject to
standard for VC. No major revisions are different requirements at numerous VC
being proposed to the standard As with emission points in the manufacturing
the current standard for VC, the
process. These requirements include
revisions are being established under
numerical emission limits, equipment
Section 112 of the Clean Air Act. The
specifications, and work practices.
significant administrative revisions include: (lj Reformatting the emission
The standard was designed to minimize fijNbg$yrisks associated
Federal Register / Vol BO, No. 6 / Wednwday, January 9, 1965, / Propoted Rules
118$
a' with VC by requiring reasonable control V measure*. At stated In the preamble to
the proposed atandard (40 Fr 60532.
December 24.1976), there U no known threahold level of effects for VC.
Therefore, the only approach that would eliminate health rieka araodeted with VC would ban Ha production and uae. Thia approach waa not selected. Rather, an approach waa aelected to minimize the health rieka aaaociated with VC by use of reasonable control measure.
On November 19.1976. the Environmental Defense Fund (EDF) petitioned the United States Court of Appeals for the District of Columbia Circuit to review the standard. On March 24.1977, the EDF and the EPA moved to dismiss the proceedings on the basis of a settlement agreement requiring the EPA to'propose amendments which would require increased efficiency of existing control equipment, require more stringent control of new sources, and prohibit increases in emissions within the vicinity of an existing source due to new construction. The preamble to the proposed amendments was to state that the EPA'a policy for regulating carcinogens under Section 112 of the
ean Air Act would include a general
al of eliminating emissions of carcinogens and that the EPA would initiate a review of the VC standard 3 years after the promulgation of the amendments. On June 2.1977. the amendments were proposed (42 FR 26154). Many comments pertaining to policy, technological feasibility, and procedural aspects of the proposed amendments were received. Review f these comments indicated that additional technical data and cost information were required before the proposed amendments, or revisions of the proposed amendments, could be promulgated.
Meanwhile, the EDF filed a petition with the EPA requesting the establishment of a comprehensive program for regulating airborne carcinogens under Section 112 of the Clean Air Act. The aspects of the EDFs petition concerning the development of standards under Section 112 were similar to those proposed in the June 2, 1977, amendments to the VC standard. Based on the similarity of the proposed amendments and the EDFs requested comprehensive program for regulating airborne carcinogens, the EPA believed tlmWH should not take final action on the p^Bsed VC amendments until after it h^ffeted on the EDFs petition.
On October 10.1979.(44 FR 58642). the EPA proposed "Policy and Procedures for Identifying. Aasessing. and
Regulating Airborne Substances Posing Assessment Group reviewed new health
a Risk of Cancer.*' This proposal
etudies that have become available
addressed several issues which were
since the atandard was promulgated.
central to the proposed VC
This review Included a study of the
amendments. It also articulated the
estimated carcinogenic strength f VC
EPA's conclusion that Section 112 does (the VC unit risk number) and focused
not express an Intent to eliminate totally on whether this number should be
all risks from emissions of airborne
changed to reflect new Informaton.
carcinogens. The EPA's selection of the * Since the current standard was
level of control for a hazardous air
promulgated, new occupational studies
Uutant emission standard would not have confirmed qualitatively that liver
based on a policy that requires zero and brain cancer incidence are
emissions of carcinogen*. This policy is asoriated with population exposure to
consistent with the basis for other
atmospheric VC. However, none of
recent actions under Section 112. For
these new studies have sufficient
example, standards for benzene from
exposure information to warrant a
coke ovens and leaks from equipment
refinement of the quantitative cancer
components in benzene service are not risk estimate.
based an a zero emissions policy but rather on a reasonable level of control, which considers emissions and health
Findings and Conclusions of the Review Study
risks. The EPA believes It is not appropriate
to leave the proposed amendments to the VC standard in effect or to
promulgate amendments based on the proposed amendments. Therefore, the June 2,1977, proposal is withdrawn. Ab described in the following section of this notice, the EPA began a review study to obtain additional technical data and
cost information and to detennie whether other amendments to the standard are needed. New amendments
The findings and conclusions of the VC review study are presented in the following subsections. The first subsection discusses the need and basis for the current standard. The second subsection addresses the level of control required by the current standard. The third aubsectioD identifies source categories not covered by the current standard and evaluates the appropriateness of regulating these sources.
developed as a result of the review
(1) Need and Basis for Current Standard
study are proposed in this notice.
The current VC standard was
Review of VC Standard
established based on judgments
Early in 1960 the EPA began a review
of the VC standard. The primary purpose of the review was to investigate the adequacy and appropriateness of the standard in light of policy decisions, health studies, control technology developments, and enforcement and compliance experience which have occurred since the standard was first promulgated. The review consisted of a screening study of: (1) Existing and new control technologies. (2) sources not regulated by the standard, and (3) enforcement and compliance experience
since promulgation of the standard. Information and data evaluated during this study were obtained through literature searches, plant visits, and interviews with industrial
concerning the costs and benefits of the standard to society. The standard is not designed to eliminate VC exposure risk entirely. Rather, it strikes a balance between public health protection and the cost of that protection. Data (evaluated before the current standard was established) strongly indicate that VC causes or contributes to the development of angiosarcoma, other cancers, and various noncarcinogenic disorders in people with occupational exposure and in animals with experimental exposure to VC. Although no dose-response data are available et the concentrations of VC found in the ambient air, the EPA concluded when the standard was established that any atmospheric concentration of VC poses
representatives and EPA regional personnel involved in enforcement and
some public heath risk. To eliminate the risk of VC exposure entirely, a complete
surveillance of the VC-emitting
prohibition of all VC emissions would
industries. The information and data are be necessary. This would require the
presented in a document that may be
closure of the entire industry and result
obtained as described in the ADDRESSES in serious, adverse economic impacts.
section of this preamble. Decisions
Furthermore, the EPA concluded at the
based on this revjew are summarized in time the current atandard was
the next two section* of this preamble. established that a complete prohibition
As another aspect of the review tof the of all VC emissions would not be
VC standard, the EPA's Carcinogen
^|4^ble or necessary. The EPA
TEN
tm
Factor^ Reftstor /'Vd 60, No. / Wedn--dty, January > WB5 /Proposed Rides
aencVaried lliia Id view of (1) fee beneficial esas of VC product* k whidi desirable *ub*titule* arc not readily
available: (Z) the potential adverse health and environmental impact* associated with VC robstitutes that have not been throughly studied. (3) the number of employee*, particularly to fabrication industries. who would become at least temporarily unemployed; and (4) the availability of control technology that la capable of substantially reducing emissions of VC Into the atmosphere.
Although all EDC, VC and PVC plants have now incorporated VC emission controls, the maintenance of a Federal standard for VC is still considered necessary. The VC standard contains requirements for the proper operation and maintenance of control devices and the proper implementation of work practices. These requirements reflect an appropriate balance between the need to minimise health rids and the avoidance of unreasonable economic and community impacts which would result from standards designed to reduce risks to aero. Relative to the initial control costa, the additional cost of maintaining and implementing the Federal VC standard is small. Nevertheless, if the Federal standard is discontinued, these small costs may be sufficient to provide the industry with an economic incentive for discontinuing the use of proper control measures. Thus, the continued maintenance of Federal standards for the control of VC is necessary to ensure a continuation of the current level of control. Additionally, the standard is important for the control of VC emissions from plants built in the future. The consequence of not maintaining a Federal standard would be to increase the carcinogenic risk to large segments of the population. (In 1675 when the standard was originally proposed, approximately 4jB million people lived within a 5-mile radius of EDC, VC and PVC plants.) Accordingly, the EPA has concluded that die maintenance of the Federal standard for VC, or reasonable revision of the standard, is appropriate.
(21 Review of Technology-Based Level
of Control
This subsection describe* the status of the technology-based level of control for sources covered by the current standard. The present status of emissions from sources covered by the current VC standard is presented in Table 1.
Tabu 1. Rum* or Owwht ttassrei l*s tu Faow bounces Oovcmeo rr ths vsm. Ocowds rcsHAP
fwtoten
*/*>
totoW sv?in IS'
UMaa ta MM SMJMO M*/V IDC/VC to**
Stwy
**-----
w u
Omgfrortf- SJ g/tg EDC t (roduel
maw------ WOtl U&JU9 . kJ qutvrttffl
U4 so m Si
Matototoi_ Sw eews w
to* to*iatoa'
I'
Sntoamna San a modal 6*.000 mg/yt PVC lacto*
Pnrrw> control
fcMCtP Contnd
aonm a/to warn atotom
.....
to -0007 kgMOQ -woduci dCaOupappmw-toon*.
Work pr*efcC* ntJ
tm 07 vis t-d
>7
1^0 W*
Aataia***__
Mndtrdft
Ur
<Tgi ***
* t-t
*|HI on * WA vnMicn Mwa datonpad to*
** 17S VC MMdm tAmrttad by muMl mica pm id pumyinnfl
^Rapraarfe wawK wnmtcm bon EDC/VC aid SC
bt'oDtoum* awaawnig
aatant atandarti ncx cotoeaad on
nW
aatot
*waw
bow
EDC/VC ptoita fma to 1*75
*B*m0 on Va EPA ami*ppm* oMnwtM to' Vpic*
wn. son. Cwawr w>Tai to bus. tow. art
<top*raion ptoto ara not p unto Maa.
10ppmv Standard. Emission sources covered by this standard include EDC purification and VC monomer formation and purification equipment monomer recovery systems and other equipment at PVC plants, and vents from fugitive emission capture systems. The standard is based primarily on the control of these emissions by incineration or other primary control devices and specifies an emission limit of 10 parts per million byvolume (ppmv) of VC averaged over a 3hour period. The 10 ppmv standard applies to control device bypass streams
One of the amendments proposed in 1077 would have required reduction of the emiaskw limit from 10 to 5 ppmv. The goal of the. proposed 5 ppmv limit was to ensure that the standard continued to approach a "zero emission goal" by requiring owners and operators both to maximise the effectiveness of
existing control systems and to design improved new control systems at the time of construction. The 5 ppmv limit was not based on date for control technology different from that analyzed
at fttt time of the promelyetioo of tbs M
ppmv kmh.
-
Comments received on the proposed 1677 amendment* stated that in older to meet a limit of 5 ppmv. a control dbvfos
would have to be capable of control at a level even tower than 5 ppmv to offset emission fluctuations. Commenter* also
stated that a change from 10 to 5 ppmv would result to little reduction in mass emissions Of VC Finely, commentera
questioned the rationale of the "aero emission goal" policy.
Because the proposed 5 ppmv emission limit was not besml on data from a control technology different from that analyzed for the current standard and because 10 ppmv represents the lowest level of control which has been consistently achieved, the EPA withdraws the proposed 5 ppmv limit and affirms the original 10 ppmv limit. If auch a technology had been identified, it could have been the basis of a revised standard. However, during the review study no more advanced technology was
identified, even though additional data on incinerators, carbon adsorbers, and solvent absorption control systems on existing plants were obtained. Although - these data indicate that incinerators are capable of reducing emissions below 10 ppmv. 10 ppmv represents the lowest level of control which has been consistently achieved. Based on this information, the EPA has concluded that there ie no improved or new control technology that has been demonstrated to significantly and consistently reduce missions to a level below that required by the current standard. Therefore, no further technological investigation of the 10 ppmv standard is planned.
Oxychlorination Vent Standard--Q g/kg EDC The current oxychlorinatian vent standard of 0-2 g of VC per kg of EDC does not require an add-on control device. Instead, the bruit can be achieved at most plants by controlling operating conditions and at the remaining plants through process modifications. At the time the original standard was written, incineration of oxychlorination vent emissions was investigated. Because of expected high energy costs associated with supplemental fuel requirements feecombustion. incineration was determined not to be a reasonable
method of control for this source.
The amendments proposed in 1077 specified a level of 6 ppm for the oxychlorination vent. The proposed requirement was baaed on inetaHstion of an oxygen feed system with an incinerator or equipment control deviceThe use of oxygen teed in the IDC oxychlorineton process decreases toe
TEN 3878
r>a--I
1 Vol. 80. Ho. 6 / Wednesday, January
/ Prqpoted.fltdM .........llflB
volunaof Inert substaisoas to toe vent stream and, cooaoqsantly. to* coat for uppUmeoul M required for
Incineration. Comments received on tois proposed amendment focused primarily on the hifb expense and large energy
requirements associated with the production of oxygen.
The review study identified no oontrol
technology for oxychlorinatian vents at EDC/VC plants that bad not been
considered during the development of the original standard. Additionally, the EPA reevaluated the cost of retrofit incinerator controls and reached the same conclusion drawn in the development of the original standard. As before, the high cost associated with incinerating oxychlorination vents at existing EDC/VC plants makesthi* level of control unreasonable. Thus, die
current standard of 0.2 g/kg EDC is considered still to be the moat reasonable level of control for existing oxychlorination vents. In addition, the review study concluded that significant new construction or modification of
EDC/VC plants is not expected- At this time, only one new EDC/VC facility is reportedly planned fBF Goodrich has plans to construct an EDC/VC facility tn
ovent, Louisiana.) Oxychlorination
ents at new EDC/VC plants will be regulated by the proposed standards of performance Tor air oxidation processes (40 CFR Part 60 Subpart HI) or by the BACT or LAER requirements aI new source review regulations applicable in
specific locations to a level comparable to that achievable through the use of incineration. Because the technologically achievable level of control is assured through the current requirements, the EPA concluded that investigation of additional control (i.e,, incineration) was not required for oxychlorination vents.
Reactor Opening--0.02 g/kg PVC Product. The current VC standard restricts emissions during polymerization reactor openings. The standard was based on reactor purging and on a reduction in the frequency of reactor openings. An increased level of control was not proposed in the 1977 amendments. (The level of control
provided by the current standard, 0.02 g/kg of PVC product, reduces VC emissions to about 1.S6 Mg per year for a model PVC plant ) During die review of the standaid. no technology was identified that would provide additional
reductions beyond the level of (he ^Brenl standard. Therefore, the EPA is
investigating further the control of
reactor openings. Combined Sources After Resin
Stripping. The sources of VC emissions covered under (he current standard
Include blend tanks, dtym. centrifuges, processors meeting toe mare stringent
storage ailot, bagging operations, and
limit* proposed previously are stripping
ny aowcet following toe stripper.
theseTtslnsto thlslowkval to fuel
Control of these emissions la based on emissions from those resins which are
either stripping the PVC resin to a
more difficult to strip. Without this
specified (based on resin type) residual ability to average the emissions and
VC level (i*.. 400 ppm for suspension,
reductions among resins, these
bulk, solution, ana latex resins; and
processors might not achieve the current
2,000 ppm for dispersion resins) or controlling the emissions from all sources following the stripper with a
control device. The 1077 proposed
amendments would have required "new resins" to be stripped to lower levels (i.e,, 100 ppm for suspension, bulk, solution, and latex resins; end 600 ppm for dispersion resins). When the amendments were proposed, the EPA believed that some resins could meet the proposed bouts; whereas, for other
resins the manufacturer would have
been required to develop improved tripping technology or not to produce the resin.
Industry comments stated that most dispersion, copolymer, and bulk resins would suffer degradation if more stringent emission limits were imposed. Additionally, the commenters noted the
inherent difficulties in defining e "new reBin." Information submitted by commenter* indicated that minor
adjustments to resin compositions are made routinely, and completely new resins are rarely, if ever. made. As a result of these comment*, the EPA concluded that it is impossible in many cases to distinguish between new and existing resins and still have any resins covered by the proposed amendments.
Further, the proposed amendments did not address what levels of control could be achieved by improved stripping technology. For these reasons, the EPA chose to evaluate whether higher levels of control are achievable lor all resins, or only for some special classes of resins.
The review study found that resin stripping technology has improved since the current standard was promulgated, and that some processors can achieve lower resin residual VC levels than those required in the original standard. In certain cases, some resins can meet the more stringent levels specified in the previously proposed amendments. However, other processors manufacturing resins of differing grades and characteristics can only marginally comply with the original standard. Because of the wide variation in resin grades and characteristic*, it cannot be
standard. Exempting resin grades known to be difficult to strip is not
feasible because these resins cannot readily be defined. For the foregoing reasons, the EPA has concluded that there is no demonstrated level of control which could significantly and consistently reduce residual VC levels in resins to levels below that required by the current standard. Therefore, the EPA it not investigating further the
control of the combined sources after stripping.
Equipment Leaks. Because little was known about leak detection and elimination programs for control of equipment leaks bom components in VC service, specific requirements for these programs were not included in the current standard. Instead, each plant was required to institute and implement a formalized leak detection and
elimination program incorporating both a fixed-point monitor and a portable monitor. Plant-specific programs were subject to approval by the Administrator. Consequently, due to
site-specific differences among plants, as well as variations In leak definitions and monitoring practices, differences in control of equipment leaks among the plants have resulted. Since the standard was promulgated, the EPA has obtained more information pertaining to toe control of equipment leaks from components in VC service. With toe information obtained form the development of other standards, an effective leak detection and repair program based on use of a portable monitor can now be specified for equipment covered by this program. The specific leek detection and repair requirements are discussed in the Administrative Revisions section of this preamble.
Relief Vahe Discharge Standard. Sources of VC emissions covered by this standard include discharges from relief valves on pressure vessels, transfer lines, and other equipment in EDC/VC and PVC plants. The standard la based on emission control by a combination of equipment and process modifications,
concluded that, even though a particular and operational procedures, found In resin made by one company can meet a plants daring development of the
particular level, any other resin or
standard. An exact combination of
similar resins produced by another
modifications and operational
company could alto meet that level.
procedures was not specified. Instead, a
Furthermore, in some catesIheapn^j ^g^perfonnance standard (i.e., an emission
1166
federal Register / VoL 90, No. 6 / Wednwdiy. )nuary 6, 1968 / iTopoaed Rules
tandard) wai established beesuse It waa believed that different comblnationa could ba equsllv affective In controlling relief valve discisrges.
The current format of the atandard prohJbite all relief valve discharges except emergency discharges. Emergency discharges are described aa
tboae which could not have been avoided by taking mearurea to prevent the discharge (i.e., thoae that are **n npreventeble"). Since the atandard waa promulgated, all planta have experienced aome releaaea. Many of theae releaaea are considered preventable by the EPA. Baaed on visits
to plants with good compliance histories, the EPA concluded that a level of performance reflecting compliance with the current format of the standard through the combined effects'of equipment, process modifications and operational procedures remains reasonable, during the review, no technological level of control was found thBt would provide for a more stringent atandard. Therefore, the standard is still considered to reflect the appropriate level of control for these sources. However, as discussed in the Administrative Revisions section of the preamble, the EPA is proposing to revise the standard by setting limits for relief valve discharges in a different format.
Administrative Aspects of the Standard. Even though the EPA decided not to revise the level of control associated with the current VC standard, the EPA identified revisions to several administrative aspects of the standard. These revisions as well as those identified above, are discussed in the Administrative Revisions section of the preamble.
(3) Review ofSources Not Previously Covered
This subsection discusses the status of VC sources not covered by the current standard that were identified in the review study. For these sources, the EPA assessed whether b Federal standard was warranted. TTie EPA's assessment of these sources was based primarily on b quantitative analysis of VC emissions from these sources combined with a qualitative analysis of risks associated with exposure to VC from these sources. The EPA considers these analyses to be adequate in place ' of thorough quantitative risk assessment for purposes of determining whether a Federal standard is warranted for these sources. Because these sources are already relatively well-controlled and the quantity of VC emission, and consequently, the risks associated with exposure to VC bom these sources, are small in comparison
to sources covered by the VC standard, the EPA concluded that non* of tba additional sources identified In the review study warrant a Federal
atandard.
Miscellaneous Sources of VC
Emissions. Miscellaneous sources are plants other than PVC and RDC/VC plants that use VC as a raw pnsteria) or produce VC as an intermediate or by product The EPA bas identified four such plants, two of these plants produce l.l.i-trichloroethane. one produces perchloroethylene and trichloroethylene and the fourth plant produces pestiddes. (An additional 1,1,1-trichloroethane unit
was constructed at a fourth location but has reportedly never operated. There
are no plans to operate in the furture.) Review of VC emission sources at the identified plants showed them to be well controlled. Emissions Df VC bom these plants are primarily from fugitive sources and range from less than 1 Mg/ yr to 14 Mg/yr per plant In general, the VC NESHAP requirements for process vents and equipment in VC service are being met at the miscellaneous sources
due to company policy considerations and State and local regulatory requirements. In addition, many of the equipment components in VOeervice would be covered by standards of performance for new sources and standards for sources in nonattainment areas. Based on the investigation of these sources, the EPA concluded that they are already relatively wellcontrolled and do not contribute significantly to VC exposure. For these reasons, additional requirements for miscellaneous sources of VC ere not being proposed at this time.
PVC Fabrication Plants. There are about 8.000 fabrication plants which take the resin produced by PVC plants and fashion it into intermediate or final products. Emissions from these plants are estimated to be about 0.0035 Mg/yi per plant. In comparison to VC production plants (which typically emit about 92 Mg/yr), FVC fabrication plants are small emitters of VC. If standards were developed for this category they would not result in reduced emissions because the best control for these plants is to reduce the VC levels in the resins being processed by the fabricators. Resin stripping beyond the level that process economics would dictate is already being done as a result of the EPA's current standard and OSHA's'VC standard, based on the EPA's assessment of these sources, the EPA concluded that they do not contribute significantly to VC exposure. Therefore, the EPA believes that the evaluation of .controls fdr PVC fabrication plants is
nneoesaafy and that 6m currant lava) of oontrol resulting from the EPA's standard and OSHA's atandard Is still reasonable.
Landfills! OR-tcpedhcsUan resins
containing VC has been taken to landfills where the gaseous VC can be released. However, the current EPA standard intends that all resins,' including off-specification resins, be stripped to reduce the VC emissions from sources downstream from the tripper. In order to clarify that stripping requirements also apply to the offspecification resins before removal of landfills, these requirements are being restated to explicity address offspecification resins. The EPA believes that the level of control resulting from the stripping requirements is reasonable; thus, VC emission requirements for landfills are not being proposed today. However, the EPA recognizes that VC may be emitted from hazardous waste landfills and is evaluating and may regulate under the Resource Conservation and Recovery Act (RCRA) volatile emissions (including VC) from landfills at hazardous waste disposal facilities. The EPA also recognizes that VC has been detected in municipal landfills. Therefore, in addition to assessing VC emissions from hazardous waste disposal facilities, a (RCRA) Subtitle D TASK FORCE has been formed which will assess all environmental releases including air emissions from Subtitle D facilities (a category which includes municipal landfills).
Administrative Revisions
As discussed in the Findings and Conclusions of the Review Study section of this preamble, the EPA identified several administrative revisions that are appropriate as a result of the review study. The rationale for the proposed administrative revisions is presented in this section of the preamble. These revisions include; (1) Reformatting the emission limit for relief valve discharges, (2) providing a compliance test procedure and a specific emission limit for operators who strip in the reactor*. (3) specifying requirements for leak detection and repair program for equipment components in VC service, and (4) miscellaneous revisions.
Relief Valve Discharges
Background. The current format of the standard for relief valve discharges allows only "emergency'' discharges (he, discharges that could not be avoided by taking preventive measures). The standard applies to all pressure jt^jef devices on pressure vessels.
F4an)
/ 10. No. / Wwhutdiy. )wwiy t W65 / IVopcitd Mw
tranafv Udm. w) adtar
Id
EDQ/VC and PVC plants. The control
technique* considered u the basis of
the stsodard bivalve e combination f
equiptswit modifies Uom. prooeae
modification*, and operational
procedure*. As exact combination of
modifications sod operational
procedure* we* not specified is the
current standard; rather, a performance
standard (i.e., an emission standard)
was established because different
combinations of the modifications and
procedures were expected to be equally
effective in controlling relief valve
discharges.
Based on 6 years of enforcement and
compliance experience, the EPA has
concluded that the relief discharge
standard has resulted in. (1) Significant
reductions in the frequency and quantity
of VC discharges from relief valves. (2)
significant use of agency resources to
evaluate individual discharges for
preventability. and (3) uncertainty on
the part of producers regarding whether
they comply with the atandard
Additionally, the EPA learned some of
VC and PVC believe that this part of the
current atandard applies only to
discharges through safety relief valves
and that discharges through other
pressure relief devices, such as rupture
disks or manual or automatic vent
valves, are not covered. This
interpretation is not compatible with the
intent behind the current standard. To
provide more efheient enforcement by
decreasing the burden of individual
preventability assessments on the EPA.
and to provide a better understanding to
plant operators of the goal of the
standard, the EPA is proposing to
reformat the standard for relief valve
discharges and to define the emission
points covered by this standard to
include appropriately all pressure relief
devices. As discussed more completely
in the following sections, the EPA is
proposing to change the format of the
numerical limits in the standard to
reflect the number of discharges that
occur from those plants complying with
the format of the current standard.
The EPA found in the review study
that efforts by all EDC/VC and PVC
producers to comply with the standard
are reflected in their prefonnance [in
terms of size and frequency of
discharges) since the standard went into
affect. In general, a reduction in the
reported frequency and size of relief
valve discharges by PVC producers has
i occurred since 1074. A further decrease,
in relief valve discharges by the PVC
industry occurred between I960 and
1981. Performance by the EDC/VC
industry exhibited a less marked trend
of decreased discharges near the compliance period. Foliowing Initial drop to rebel eahve discharge* after the
standard went boto eBeci the frequency and quantity of eebef aatve discharges by EDC/VC plants have decreased slightly or remained relatively constant.
Control Boris for Numerical Limits.
In selecting the proposed numerical limits, EPA first evaluated In detail the
recent performance (1081 to 1083) of five PVC plants end one EDC/VC plant These plants were chosen based on discussions with EPA Regional Office
personnel end industry arid were intended to represent plants with good rebef valve discharge records, bi general, die EPA'i evaluation of these plants Indicates that each has adopted the combination of equipment, operational procedures and attitude
toward prevention of relief discharges intended by die ourrent standard, and that their resulting performance is consistent with compliance with the current standard. The EPAT evaluation found that a few discharges may continue to occur from some plants that comply with the standard. This observation is consistent with the expectation held by the EPA when the standard was written. .
In order to revise the standard in terms of numerical limits representing compliance with the current format of the standard, this evaluation separated PVC and EDC/VC plants. For plants, rebef valve discharge performance data were further separated by source (reactor vs. nonreactor} and by resin type The EPA then reviewed the performance of 25 additional PVC plants and 12 additional EDC/VC plants. The EPA reviewed this large ael of plants to ensure that the level of performance demonstrated by the evaluated plants could be achieved by all PVC and EDC/ VC plants.
The numerical limits presented in the Findings section of this preamble are based on an evaluation of the number of discharges representing the demonstrated performance level associated with compliance with the provisions of the existing standard.
Format for NumericalLimits. Ibe EPA visited the five PVC plants evaluated in detail. As expected, the EPA found difference* in the combinations of hardware and operational procedure* associated with control of relief valve discharges of each of the plants. Furthermore, no exact relationship was fouad between the effectiveness of specific hardware items and operational procedure* and prevention atdischarges. In the EPA'* judgment, the various oambnutione at
hardware and operabone) procedures
Implemented by each of (btplants dog with the etbtedes adopted toward preventing relief valve dischargee represent the types of control measures that the standard Intended. In particular, the EPA concluded that die km frequency of discharges by tire visited
plants was Indicative of their degree of
effort to prevent relief veive disdiaiges. Consistent with the goal of this
proposed revision, the EPA decided thst en alternative numerical emission limit bated on performance resulting under the current standard could be revised in a format that would be easier to understand by enforcement and industry personnel.
The EPA investigated two basic ways of expressing relief valve discharge
performance for PVC plants. One format is based on mass emissions, for example, the pounds of VC discharged per minion pounds of PVC produced (lb
VC/MM lb PVC). Based on a review of methods used by industry to determine the amount of VC discharged from relief valves, the EPA was unable to identify a sufficiently accurate method tor measuring discharge quantities from rebef valves. Al present, producer* are required only to estimate discharge
quantities for reporting purposes. Demonstration of compliance with a lb VC/MM lb PVC limit would require
producers to measure the amount of VC discharged during an incident Because a suitable measurement method was not
identified, the EPA decided not to redefine rebef valve discharge performance by PVC plants in e lb VC/ MM lb PVC format
Another format is based on the frequency (Le, number per unit time) of discharge from occurrences. No method for measuring the amount of VC discharged from rebef valves is needed because only the occurrence of a release is required for this format The occurrence of a discharge can be determined by monitoring process parameters as web as inspecting relief valve performance report*. Thus, of the two basis ways of expressing rebef valve performance that were considered, the EPA selected a format baaed on the frequency of discharges.
Based on this decision, die EPA then considered bow the format would be appbed to PVC and EDC/VC plants. At PVC plants, the frequency of discharge* from polymerization reactors and associated process eqoipment may be
related to the fact that a hatch process is used to produce most types of PVC. For batch PVC production processes, the opportunity for discharges is related to the number of tiroes a new
TEN 3881
1148
Fodora) EfUlf / Vol >0, No. 8 / Wednesday, )tnimy . 1866 / ftoposed Rules
Elymerixation batch la initiated. pressing relief valve discharge perf finance for these plants with a di*charge-per-batch format aooounta for
variationa among plants in the number of ba tehee produced The EPA aelected 100 polymerization batcher aa a
convenient baaia for expressing relief valve discharge performance by PVC
plants with batch production proceaaea in a discharge frequency formal
Further, the EPA noted that the ability of batch PVC producer* to limit the discharge frequency may be different for reactor and nonreactor discharges and that reactor diacharge* may vary by resin type at any plant Consequently,
relief valve discharge* by individual PVC planta (except for continuoua solution process plant*} were classified according to type of discharge (i.e,, reactor vs. nonreactor} and die reactor
discharges were separated by resin type. Nonreactor discharge sources at PVC plhnts include blowdown tanks, .transfer lines, and storage vessels. Because usage of this equipment is also
related to some extent to the frequency of batch polymerization operations, the relief valve discharge performance by nonreactor sources in PVC plants with batch production processes was also examined dh the basis of number of discharges/100 batches.
Unlike the batch process used to produce other PVC resin types, the solution PVC process is continuous. Thus relief valve discharge performance for the solution PVC process cannot be expressed on a frequency per batch
basis. Instead, the relief valve discharge performance associated with the solution production process can only be expressed in terms of the total number of discharges (reactor and nonreactor) per year.
Similarly, the EDC/VC production process is not a batch process, but is continuous. Thus, relief valve discharge performance by EDC/VC plants sIbo cannot be expressed on a frequency per batch basis. Moreover, the EPA was
unable to detect a direct relationship between discharge frequency and VC production at EDC/VC plants. Thus, the EPA decided to define releif valve discharge performance for EDC/VC plants on the basis of a total number of annual discharges.
Findings. PVC Reactor Diacharges. Suspension resins account for the highest percentage of total PVC production. The remaining PVC production is in the form of bulk, dispersion and solution resins. (A small amount of latex resin is produced by a process closely related to the dispersion process.) Examination of relief valve discharge performance associated with
production of suspension and bulk resins indicates that react r discharge
frequency generally is aithar lass than 0835 dischaiges/lOO batches or is much
greater. (Recent rssetor discharge frequencies for suspension resin plants
with poorer performance levels ranged between 0.059 and 0.101 discharges/100
batches.) Further examination of relief valve discharge performance by suspension resin producers indicates that only one plant experienced more than 4 discharges per year during the
Eeriod from 1981 to 1083. Performance y this plant also exceeded 0.035 discharges/100 batches. The reactor discharge frequency associated with dispersion and latex
'reduction is typically zero. However,
Sor a typical dispersion or latex resin
process with a low production rate [i.e.. number of polymerization batches per
year), a single emergency reactor discharge in a given year would be equivalent to a discharge frequency of about 0.035 discharges/100 batches.
Nonreactor Discharges. Nonreactor
discharge frequencies by PVC plants typically were either less than 0.025 discharges/100 batches or were much greater. (Recent nonreactor discharge frequencies reflecting poorer performance than the 0.025 level ranged between 0.048 end 0.225 diacharges/lOO batches.) Furthermore, with the exception of two producers, no more than three discharges per year were reported from nonreactor sources in PVC plants during the period from 1881 to 1BB3.
Each of the five PVC plants that the EPA evaluated in detail was among those achieving 0.035 discharges/100 batches or less in each of the reactor discharge categories and 0.025 dischBrges/100 batches or less in the nonreactor discharge category. The EPA examined individual discharge incidents for the PVC producers whose recent performance has exceeded 0.035 dischaiges/100 batches in one or more of the reactor discharge categories or who exceeded 0825 discharges/100 batches and 3 discharges per year from nonreactor sources. In every case, the EPA identified one or more discharges that were preventable. Elimination of these preventable discharges indicates
that these producers should have achieved discharge frequencies comparable to the five PVC plants that the EPA evaluated in detaiL
Solution PVC Process. Discharge frequency from both reactor and nonreactor sources by the single plant
producing PVC by the solution process was zero during die period 1981 to 1983. Previously, this plant experienced as many as two discharges in a 12-m nth
period. Reoent performance suggests that preventable discharges have been eliminated at this plant With the exception of a potential emergency discharge occurrence, future discharges
at this plant are not anticipated.
EDC/VC Discharges. During the review study, the EPA evaluated performance by one EDC/VC plant in detail. This plant experienced about four discharges that could be considered emergencies. Recent (1881 to 1983) relief valve discharge performance data for other EDC/VC producers indicates an industry range of 0 to 7 discharges/yr. Information obtained from plants during the review indicated that, where applicable, similar types of equipment process modifies tions and perational procedures used to control relief valve discharges from PVC plants also are used at EDC/VC pants. The EPA examined discharges by the EDC/VC producers who exceeded four discharges in one or more years since 1981 and found that one or more of the discharges at each plant were preventable. Elimination f the preventable discharges would allow each of these plants to reduce their annual discharge frequency to four or fewer.
Summary ofNumerical Limits. Based on the study of current relief valve discharge performance by PVC and EDC/VC plantB, the EPA is proposing that the following numerical limits for relief valve discharges be added to the standard. Each discharge causing an exceedence of any numerical limit presented below would be considered a violation without regard to whether any individual discharge was preventable.
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(1) Dac*tpgat *o>n SVC
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t*ac*wtp*/(0C
BS faanchaa. no! w<fa( 4
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--Oapwfatoi i*n poo- 0.035
(McftaiyaaMOO
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--tx* Wi E0C4M_____ 0035
pachaipm/IOC
latchti
(B) MowmcKv Kwon____ 0.025
ttadwpaa/IOC
fatM* not aicaaffaip 3
^rnppa 'r (2) CmXpfli faont fVC 1 Oac*wpa/|ir.
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(3) OiacharpM faont EOC/VC 4 *ac*aargaa/jr
ptato.
Compliance Provisions. The EPA recognizes that all plants may experience an unavoidable relief valve discharge incident at some time. Examination of relief valve discharge performance by PVC plants with low
TEN 3882
Fxbmal ftflrtw / Vol. 60. No. * / Wadneiday, January P. 1965 / Proposed Rulci
,
discharge frequencies Indicated that .plant* with tha lowest polymerization batch frequencies typically experience
about ne discharge tat a 12-month
period The EPA concluded that for most plant* a 12-month reporting period (rolling every 6-months) was both
suitable and appropriate for determining
compliance with the proposed numerical limits. For plants producing only a small amount of a particular resin (i.e., low number of polymerization batches), an apparent violation of the atandard may result from a single discharge occurrence during a 12-month
compliance period as described below.
For a PVC plant producing a single resin type to meet the numerical limit for reactor discharges (i.e., 0.035 discharges/100 batches), it must . experience and average of no more than one discharge per 2,658 polymerize tion batches over the preceding 12-month period. An average reactor discharge frequency exceeding one discharge per 2,858 batches would be a violation of the standard. However, if the plant made
less than 2.858 polymerization batches over the 12-month compliance period, a single discharge occurrence would be an apparent violation of the standard (i.e., the discharge frequency per 100 batches
rould exceed 0.035). Because insufficient batches were made, the reported discharge frequency per 100 batches would not correctly reflect the performance by that plant in comparison to other plants complying with the standard. In rectifying the undue compliance burden posed on plants with small numbers of batches by the discharge/100 batch format and the selected 12-month compliance period, the EPA is proposing to add additional provisions affecting the number of batches used to calculate the discharge frequency. For PVC plants producing less than 2,858 batches of a particular resin, the minimum number of 2.858 batches will be used when determining compliance with the numerical limits.
PVC plants producing more than one resin type must demonstrate compliance separately for reactor discharges occurring from different resin production processes. Only the relief valve discharges and polymerization batches specific to each resin type are considered for determining compliance. However, for determining compliance with the standard for nonreactor discharges, the total number of polymerization batches (regardless of
type) are counted,
determine the number of polymerization batches produced for purposes of assessing compliance, the following guidelines apply. A
"polymerization batch" consists of each sequence of charging VC and other materials to the reactor, heating reactor, contents, polymerization of reactor contents, and removal (La., blowdown) of reactor contents. Any batch that ia aborted following charging of VC to the reactor is nonetheless counted as a polymerization batch in assessing compliance. For PVC plants producing bulk resin, a single "polymerization batch" includes both prepolymerization and postpolymerization reactor operation*.
Discharge frequency can be recorded in two ways. Discharge frequency can
be recorded on the basis of discharge events (involving discharges from one or more relief valves) or on individual
relief valve discharges. In most cases, . plants currently report discharges individually when they occur from relief valves on separate equipment However, certain equipment such as
polymerization reactors that are equipped with multiple relief valves may experience discharges simultaneously from more than one relief valve. Most plants currently report such multiple discharges from a single piece of equipment as a single discharge. Thus, the performance levels serving as the basis f6r the numerical limits represent individual discharges and not multiple discharge events except when they occur from a single piece of equipment For determining compliance with the numerical limits, discharge frequency is to be recorded on the basis of individual discharges except when simultaneous discharges occur from relief valves on the same piece Df equipment
A relief valve discharge in considered to be any venting through a pressure relief device to prevent or relieve an overpressure condition from equipment in VC service that results in emissions of VC directly or indirectly to the atmosphere. In determining whether or not a relief valve discharge results in emissions-to the atmosphere, the controlling factor is the ultimate disposition of the gaBes. Venting to a manifold or header system that ultimately discharges to the atomsphere constitutes a relief valve discharge- If the manifold or header discharges gases through a control device meeting the 10 ppmv VC emission limit, the venting does not constitute a relief valve
discharge. For purposes of reporting compliance
status with the limits, plants will be required to calculate their discharge per batch frequencies with sufficient precision to demonstrate that performance is either equal to. below of in excess of the limits. Baaed on
operating history, relief valvt discharge performance by certain plants Is
expected to be much better than the
respective limits. For example, some new suspension resin PVC plants produce about 5,000 batches during a 12-month compliance period. One and two discharges at one of these plant* during * compliance period would result in a discharge performance of 0.02 and 0.05 discharges per 100 batches, respectively. The second discharge during the compliance period would be 'a violation of the proposed 0.035 discharges per 100 batches limit despite the fact that the first discharge would result in performance well below the limit These types of plants were considered in selecting the proposed limits and reporting procedures for relief valve discharges. The result that plants of this type must perform well below the limits in the standard in order to be in compliance is consistent with the proposed limits, which were selected to represent an upper boundary on the number of allowable discharges
intended by the standard. The EPA expects that plants using the best technology and procedures should be able to perform better than the proposed limits.
Reporting Requirements. The current standard for relief valve discharges requires producers to report discharges within 10 days of the incident. The EPA is proposing to eliminate the 10 day reporting requirements and to require reporting of all discharges on a quarterly basis. Although compliance is to be determined on a semiannual basis, quarterly reporting of discharges is appropriate because violations of the standard mBy occur well before the end of the 8-month period. Quarterly reporting notifies enforcement personnel of potential violations and violations that have already occurred prior to the end of the compliance period bo that corrective actions can take place sooner following the end of the compliance period. Information to be included in the semiannual report for individual relief valve discharges is to be reduced to include only the date, time, source, cause and estimated amount of each discharge occurrence. The semiannual report will also inlcude information on compliance status.
In addition, plants will now be required to maintain relief valve discharge records for 3 years, because of the potentially significant increase in the time period between a discharge occurrence hnd reporting of tire discharge.
Effective Date ofRevision. The current standard as written will remain
TEN 3883
UN
Federal Register / Vol. *0. No. / Wtdwtdiy, January >, MW ( Proposed >riw
is effect lor relief velve discharges until the proposed revisions ere promulgated. The proposed administrative revisions do not change the standard's original intent and are intended only to eat limits to facilitate compliance auto enforcement efforts. Thus, the current standard will continue to be enforced until the revisions ere promulgated.
Stripping-in-Reactor Compliance Test
Procedure
The test method for measuring raactor opening losses was developed for resin (ripping operations that take place in vessels separate from the reactor. Some PVC plants, including all bulk resin manufacturers, however, do not use separate strippers to remove residual VC from the resin'produced Instead,, these plants strip VC from the product resin in the reactor (postpolymerization reactor in the case of bulk resin producers). For plants with reactor resin stripping operations, the concentration of VC in the reactoT vapor space, as measured in accordance with the current standard, exceeds the O.Q2g/kg of PVC requirement The high concentrations result form VC monomer diffusing from the resin into the vapor space during the period following completion of the stripping operation (normally occurring under a vacuum that must be broken before the reactor can be emptied) and before the reactor is completely emptied of PVC resin. According to the Federal Register notice of promulgation of the current VC standard (40 FR 46563. October 21,1876). any VC escaping from the resin after it has been stripped to acceptable levels is not intended to be counted as part of the reactor opening loss. However, the current standard did not include in the measurement method an acceptable method for determining what part of the VC in the vapor space has escaped from "the resin after stripping is completed.
The current standard allows bulk resin producers to calculate reactor opening loss emissions from the postpolymerization reactor based on the number of reactor evacuations, the vacuum invloved and the volume of gas in the reactors. For nonbulk resin producers with reactor resin stripping operations, calculation of reactor opening loss emissions!* more complicated due to the presence of water vapor in the reactor VBpor space. Currently, waivers of testing for producers with nonbulk resin stripping operations in the reactor have been granted on a case-by-case basis by the EPA Regions, typically with the provision that residual VC samples are anlayzed on each batch. A variety of
oalculatioo methods are then used to establish the reactor opening toes.
Based eo experience of tha EPA Regional offices, a method for
determining tha reactor opening low that accounts for stripping in the reactor has been developed for use by all nonbulk resin producers with reactor resin stripping operations and Is Included in the proposed revisions to the current VC standard. Limitations for resin residual and reactor opening loss are added together to give a total allowable VC content from these two sources. The measured resin residual VC and the calculated reactor opening loss would then be added together, and averaged over a 24-hour period according to resin type. If the 24-hour average meets the combined standard, the plant would be considered to be in compliance with both the stripping and the reactor opening loss requirements. .
Leak Detection and Repair
Background. The current standard requires implementation of a formalized program for detection of leaks from equipment in VC service and elimination of these leaks. The formalized program includes a multipoint VC detector and a portable volatile organic compound (VOC). analyzer. The fixed-point monitoring system continuously monitors VC concentrations in the work area around equipment in VC service and sounds an alarm when concentrations exceed a prescribed level The portable monitor is used independently to screen individual equipment components for leaks. Rather than specifying the number of points to be monitored, the sensitivities of the multipoint detector, the VC concentration that indicates a leak, and the actions to be taken to repair leaks, the current standard requires each plant owner or operator to prepare a program plan containing these specifications and to submit the plan to the EPA for approval. Plant owners or operators are required to submit data on background concentrations of VC in different areas of the plant to use in determining the VC concentration that should be designated as indicating a leak. Plans, therefore, were tailored by each plant and reviewed by the the EPA Regional Offices.
The EPA found in the review study that differences in leak detection and elimination programs exist among PVC and EDC/VC production plants and miscellaneous sources and that sitespecific differences include variations in leak definitions and monitoring practices. The definition and monitoring practices. akqs with repair predicts, are primary influences on the control
affective**** of leak detection and repair program*. Soma plants Implemented rigorous programs aadother* Implemented programs lacking '
specific procedures or requirements.
Accordingly, the effectiveness of leak detection and elimination programs varies among tha plants.
Since the current standard was promulgated, the EPA has obtained more information pertaining to the control of emission from equipment
leaks. Based on this information and the review of the leak detection and
elimination plans being implemented to control emissions of VC. the EPA
decided to specify leak detection and * repair requirements for certain equipment components in VC service. Although information obtained from development of other standards Indicates that a routine leak detection and repair program with a portable monitor can be an effective emission reduction technique without the requirement of a fixed point monitoring system, the EPA concluded that fixedpoint monitoring systems already in place have uses that justify their retention in the current standard. In particular, fixed-point monitors allow for quick detection of certain large VC leaks that might otherwise go undetected until the next routine portable monitor screening. The EPA recognizes that existing fixed-point monitoring plans wili need to be reviewed in tight of the leak detection and repair requirements being specified at this time. The complexity of existing fixed-point monitoring plans, in terms of number and distribution of monitoring points, varies greatly among plants. Consequently, some plant owners or operators nmy want to alter the number of points that are monitored and the distribution of monitoring locations to better complement the specified portable monitoring requirements. Such changes to existing fixed-point monitoring plans will be allowed providing they do not alter the plant's ability to detect large VC leaks.
The proposed revisions are primarily intended to standardize control of VC emissions from equipment leaks. In doing this, the EPA is concerned that existing effective plans not be inappropriately changed. The proposed revisions include provisions that allow plants with existing effective plans to periodically demonstrate the
ffectiveness f their plans without additional requirements. Accordingly, the EPA requests comments from industry representatives concerning tbe specific effects of specifying leak
TEN 3884
Fwdaral Raster / Vol. BO. No. 6 / Wednesday, January 9, 1985 / Proposed Rules
1191
detection and repair requirement* on effective exitting plana.
Leak Detection and Repair Requirements. The EPA established leak detection and repair requinmenta (40 CFR Part 61 Subpart V) for oerlain
equipment in volatile hazardous air pollutant (VHAP) aervice on June 6,
1984. These requirements were established in conjunction with the final
standard for benzene equipment leaks. The requirements of Subpart V generally
apply to pumps, compressors, pressure relief devices, sampling connection systems, open-ended valves of lines, valveB, flanges and other connectors, and product accumulator vessels. These requirements reflect the level of control that the EPA considers reasonable for -equipment covered by developing standards for VHAP. The EPA is therefore proposing to add VC to the list of substances covered by Subpart V.
Subpart V would substantively affect nly valves and flanges in VC service within this industry. All other equipment in VC service are alrt ady required by the VC standard to comply with equipment and work practice standards consistent with those In Subpart V. For example, pumps and compressors meeting the dual mechanical seal requirements of the current VC standard will be in compliance with the Subpart V requirements. In addition, the sampling connection systems requirements of Subpart V are essentially the same as the current
standard. The use of rupture discs for controlling leaks from pressure relief devices, as required by the VC standard, is consistent with the "no detectable emissions" requirement included in Subpart V. Requirements for controlling leaks from pressure relief devices are described in more detail later in this section. Thus. Subpart V will afTect primarily valves and flanges in VC service by requiring a specific monitoring schedule, leak definition and repair provisions.
Compliance with the provisions of Subpart V will be UBed to determine compliance with the portable monitor leak detection and elimination
requirements in the current VC standard (40 CFR 61.85(b)(8)(ii)), and therefore,
the current standard is being revised to reflect this change. However, process units within VC and PVC plants in which the percentage of leaking valves ri* equal to or less than ZJ3 percent are 'considered by the EPA to be effectively controlling VC emissions from leaking valves. For these process units, the existing leak detection and elimination program will continue to be allowed while the percentage of leaking valves is
X-0 percent or lest. Any process unit In
which the percentage of leaking valves Is found to exceed ZjO percent will be required to comply with the provisions of Subpart V.
The Subpart V requirements for valves ere based on e leak detection end repair program that requires (1) monthly monitoring for valves in gas/ vapor end light liquid aervice, (2) an initial attempt at repairing these valves
within 6 days after detection of a leak, (3) repair of leaking valves within 15 days after detection of the leak unless repair would require a process unit shutdown, and (4] repair of valves during the next process unit shutdown after repair is delayed until a process unit shutdown. Valves found not to leak for 2 successive months can be monitored quarterly until leaks are detected. Monitoring of equipment to detect leaks is conducted in accordance with Method 21 and a leak is defined as a measured organic concentration equal to or greater than 10,000 parts per million by volume (ppvm). For b complete description of the leak
detection and repair requirements, see Subpart V (40 FR 23498, June 8,1984).
In addition, Subpart V contains standards for other types of equipment (e.g., flanges, and open ended valves or lines). Standards for flanges include monitoring with a portable instrument under prescribed procedures within 5 days of observing evidence of a potential leak by visual, audible or other means. Open-ended valves or line^ ere required to be capped, blinded or Titled with a second valve. These provisions are not expected to significantly afreet producers with these types of equipment in VC service. The equipment and procedures employed as normal practice by these producers or as a result of the current VC standard are expected generally to ensure compliance with Subpart V.
Pressure ReliefDevices. The EPA proposed and promulgated the work practices, equipment, design and operational standards in the current standard before explicit legal authority existed in Section 112. These requirements are found in S 81.65(b). In August of 1977, Congress amended Section 112 to allow the use of these requirements. Section 112 of the Clean Air Act requires that an emission standard (i.e.. a performance standard) be established for control of a hazardous air poDutant unless, in the Judgment of the EPA. it is not feasible to prescribe or enforce such a standard. An emission standard allows for some flexibility in complying with the standard, since any control technique
that achieves that standard may be
applied. Section 112(e)(2) defines tike following conditions tinder which It is
not feadible to prescribe or enforce an
emission standard: (1) If, the pollutants ' cannot be emitted through a conveyance designed and constructed to emit or capture the pollutant; or (2) if the application of measurement
methodology is not practicable due to technological or economic limitations. Section 112(e)(1) allows that if an
emission standard is not feasible to prescribe or endorce, then the EPA may tetead promulgate a design, equipment, work practice, or operational standard,
or combination thereof.
The EPA has reviewed the design, equipment, work practice and operational requirements contained in the current VC standard. The only
aources covered by the current standard with one ofthe requirements for which a
performance standard (i.e., an emission standard) is feasible are pressure relief devices. As discussed below, the EPA is setting a "no detectable emissions" limit for these aources. For the other sources, the EPA is reinstating those requirements as set forth in the current standard.
The EPA selected the use of rupture disks as the basis for the current
standard for pressure relief devices. When the integrity of ruptures disks is maintained, equipment leaks through the relief device are eliminated. Rupture disks normally maintain their integrity unless an overpressure occurs. After the occurrence of an overpressure, replacement of the rupture diBk once again eliminates equipment leaks of VC through the pressure relief device.
For emission control techniques that eliminate equipment leaks, such as the UBe of rupture disks, a "no detectable emissions" limit is feasible. An instrument reading of less than 500 parts per million by volume (ppmv) above a background concentration based on Reference Method 21 can be used to indicate whether equipment leaks have been eliminated: that is. that the equipment has "no detectable emissions."
The "no detectable emission" limit would not apply to discharges through the pressure relief device during overpressure relief. (These releases are covered under H 61.64(a) and 61.85(a).)
The standard would specify, however, that the relief device be returned to a state of "no detectable emissions" within 5 days after such a discharge. The standard would further require an annual test to verify the "no detectable emissions" status of the pressure relief devices and a test after each over
TEN'S 885
UK
Fodent b^Mv / Vet. V). No. t / Vadnwdiy, Jemmy I INS / Proposed tod--
pressure relief. This MlministreUvv change implement* the beat* of this
Standard consistent with the
requirement* of Section 113)v).
Miscellaneous Revisions
Based on discussions with the EPA regional personnel regarding their experience in administering the current VC standard, the EPA is proposing several additional administrative revisions that would facilitate compliance and enforcement efforts associated with the current standard. Thf-se revisions represent minor changes to the standard. A brief description of these administrative revisions and the basis for making them follows.
Definition ofLeak, Exhaust Cos and Relief Valve Discharge. Functional definitions of *3eak", "exhaust gas" and "relief valve discharge" are being Bdded to the standard to clarify the applicability of the standard to each of these types of VC emissions. Diming their review of enforcement end compliance experience since the standard was promulgated, the EPA discovered several cases of confusion over the intended meaning of "leak", "exhaust gas" and "relief valve discharge." These three distinct categories of VC emissions are being defined In the revised standard te provide compliance and industry personnel with a clear understanding of which part of the Standard applies to any given discharge of VC emissions to the atomospbere.
Definition of EDC and VC Purification, in the past, acme plants have nusinterfrented which equipment components are included in EDC purification and VC purification processes with the result that emissions from certain equipment intended to be covered by the standard way not have been controlled The definitions of "EDC purification" and "VC purification" ere being revised to clarify that all purification equipment following EDC and VC formation were subject to regulation wider the current standard
10 ppmv Standard. Two clarifying revisions are being made to the 10 ppmv regulations to improve understanding of the applicability of this part of the . standard First, although the test method for determining compliance with the 10 ppmv standard specifies that the average results from three 1-hour
sampling runs be used Qub 3-hour averaging period is not specified in the 10 ppmv requirements. Specifying that emissions may not exceed 10 ppmv over a 3-bour averaging period clarifies that instantaneous compliance with the 10 ppmv standard is not an intended requirement. Moreover, specification af
ths I boo* avettghg period Is intended . to clarify that the K> ppmv standard
ppltes to VC amission* in all exhaust
gas streams covered by ths ID pprev requirements, including any mxitrel device bypass streams. Requirement* for ralndstit^ the VC content in bypassed omissions for purposes of
reporting VC amissions in excess of the 10 ppmv standard are being added to the regulation. The EPA may use these calculation* along with continuous emission monitoring results as indications of noncompliance if they show clearly that emissions In excess of the 10 ppmv requirements occurred
The second clarifying revision Id the 10 ppmv standard fevotves the specification that the 10 ppmv requirements apply to each exhaust gas stream from the covered equipment. The purpose of this revision is to clearly prohibit plants from using dilution with other exhaust gas streams as a technique for meeting the 10 ppmv requirement. This revision i* not intended to prohibit the common practice of combining two or more exhaust gas streams in a common header leading to a control device. According to the revised 10 ppmv requirements, combining an exhaust gas stream containing more than 10 ppmv VC with another exhaust gas stream containing less than 10 ppmv VC is allowed only when the combined stream
is ducted to the control device.
Relief Vahe Definition. The current standard few relief valve discharges was intended to apply not only to safety relief valves bat to all types of pressure relief devices. A definition of "relief valve" is being proposed under the revised standard to clarify that the current relief valve discharge standard also applied to rupture discs, manual vents and other pressure relief devices that vent to the atmosphere to protect process equipment from unsafe overpressure conditions. The definition of rebef valve in the proposed standard is not intended to include pressure control valves used to control flow to an incinerator or other control device. However, the current relief valve discharge standard did cover emissions from pressure control valves. Also not included in the definition of relief valve are pressure control systems such as polymerization reaction shortstop systems or refrigerated water systems which act to reduce pressure by means other than venting.
Reactor Opening Lem Reqairemeats for Bulk PVC Benin Producers. Bulk PVC resin production differs from production of other type* of PVC resin in that the polymerization reaction is
carried oat le two reaction Is Initiated iia tbs "prepolymniMtioa* reactor and the
seeder eontunt* are tbsa traneferred la the "poatpolymeriiatkm" saartor where the reaction is completed. Stripping of
residual VC in bulk main is performed foilOK'ing the poatpolymartmtion step h> the reactor vessel. Tbs postpolymerisation reactor generally ie opened after every batch and mast comply with the reactor opening lose
limits specified in the standard. Because the prepofymerisation reactor is opened less frequently end because determination of gross product (for reactor opening loss estimation) is difficult, the EPA hos allowed plants to meet the equipment opening requirements for minimising VC emissions from polymerization reactor openings. The reactor opening loos requirements are beliqj revised at this, time to specifically exclude prepolymerization reactors. Accordingly, VC emissions from all
opening of prepofymerization reactors will be subject to the equipment opening requirements. This revision is intended to clarify and improve the consistency of the equirements of the revised standard as they spply to balk PVC resin producers in light of actual industry' practice. No redaction in VC emission control stringency will result from the change in requirements far prepolymerization readers.
Inprocess Wastewater Requirements for Gasholder Soak. Under the current standards, the VC content of tnprocess wastewateT mutt be reduced to less than 10 ppm exposure of die wastewater to the atmosphere. In the case of gasholder water seals, the VC content in the exposed water seal may exceed 10 ppm during normal operation f die gasholder. Experience since the standard was promulgated indicates that compliance with the atmospheric exposure limit is not practicable for this particular inprocess wastewater source. Consequently, the definition of inprocess wastewater is being revised to exclude the exposed water seal of gasholders. The inprocess wastewater stripping requirements will continue to apply to wastewater after removal from the gasholder seal.
Elimination of3&Day Limit an Equivalency Requests. The current standard specifies a 30-day limit for existing sources to submit requests far use of equivalent mathode. Because such a fimit pose* a restriction on initiative by industry to develop alternative, and potentially more effective, control measures, the 30-day limitation is being eliminated.
TEN 3886
. feJanJ Register / Vol <0. No. 6 / Wedneedey, Imauy % W66 / IVopowd Rates
103
Other, la addition to the revisions
tacraaae or decrease In tbs overall
dwafl*d above. nviiw af (ha
recosdkeepioi end reporting eumetfy
raoordkasplngaadreportiag
practiced by individual plants
irejoEwnenb of the ouxsnt standard
Tht EPA concluded that Ate currant
was performed to identify ways to mm recordkeeping requirements, as
recordkeeping end reporting burden on specified in 40 CHI fUT ere still
plants end to identify any edditionel
appropriate. However, the H'A is
recordkeeping end/or reporting need*. proposing to extend the current
The EPA identified two areas where the recordkeeping requirements for all
reporting burden on plants could be
reporting activities from 2 to 9 year*.
reduced. The current reporting
The net impact of the revised
requirements for residua! VC monomer recordkeeping and reporting
specifications end reactor opening
' requirements proposed by me EPA is
measurements require that results of all estimated to be a decrease in a
compliance tests be reported in
paperwork burden of about 2.8 person-
semiannual reports. The EPA is
years.
proposing to allow plants to report only
It should be noted that ali
test results that show exceedences of
Comprehensive Environmental
the respective standards. If no exceedences occur, plants will be
required to indicate that fact in the semiannual report This type of exception reporting is currently allowed for demonstration of compliance with the 10 ppmv standard for process vents. The second area is the requirement to report relief valve discharges within 10
days of their occurrence. The EPA is proposing to allow plants to report relief
valve discharge occurrences on a quarterly basis rather than within 10 days f their occurrence. Furthermore, the reporting requirements for relief valve discharges have been streamlined by dropping the need to report actions taken and implemented preventive measures for each discharge. Information on the date, time, source, cause and estimated amount of , individual relief valve discharge will be included with the semiannual reports along with information on compliance status.
Additional semiannual reporting requirements being added for PVC producer* are the number of reactor openings and the design capacity number of polymerization batches for each resin type. This requirement will provide general information to facilitate review of industry-wide compliance
Response, Compensation, and liability Act (CEROA) Section 101(14} . hazardous substances such as vinyl chloride are subject to reporting requirements under Section 103(a) of CERCLA- CERCLA requires that persons
In charge of vessela or facilities from which hazardous substances have been released in quantities (RQs) immediately notify the National Response Center (NRD of the release. The toll-free 24-hour telephone number of the NRC Is 800-424-8802 and in Washington, D.C. metropolitan ares it is (202} 428-2875. (See CERCLA Section 103 and 48 FR 23552, May 25,1963.)
Vinyl chloride was assigned a statutory11 pound reportable quantity under Section 101(14) until adjusted by regulation, and is presently undergoing assessment for berth chronic toxicity and carcinogenicity. Its RQ will be adjusted pending the outcome of these reviews by the Office of Emergency and Remedial Response. Federally permitted releases under CERCLA (See CERCLA Section 101(1} end 48 FR 23552} are not subject to CERLA notification requirements or
liabilities. However, releases of hazardous substances that are not subject to a permit or control regulation must be reported.
Regulatory Flexibility Analysis
status during past reporting periods.
The Regulatory Flexibility Act of 1980
Specific recordkeeping and reporting requires that adverse effects of ail
requirements are included as part of the Federal regulations upon small
revisions to the leak detection and
businesses be identified. According to
repair requirements. The recordkeeping the current guidelines of the Small
requirements include preparation of an Business Administration (SBA), a small
initial log to record equipment
business that produces or processes VC
component identification, physical
is one that has 500 employees or less.
tagging of equipment components which Currently, none of the existing
leak, and maintaining a record of
producers or processors that are
equipment leaks and repair action,
affected by the standard are estimated
hieluded in the reporting requirements
to be small by this, definition- Since none
Mp the number of equipment leaks end of the companies meet* the SBA
Me repair status of leaking components. definition of small business, no
Depending on the particular leak
regulatory flexibility analysis is
detection and repair pregpam fas place, required. Even if an analysis were -
these requirements may represent an
required, the proposed administrative
revision* do not increase tbs ooat of compliance with the stmJsij
Pubbc Hearing
If requested, e public bearing will be held to discuss the proposed revisions to the VC standard tat accordance with sections 212(bXlK6) and 207(d)(5) of the Clean Air Act Person* wishing to make oral presentations on the proposed revisions should contact the EPA at the address givan In the Aooattttt section of this preamble. Ora) presentations will be limited to 15 minutes each. Any member of the public may file a written statement before, during, or within 80 day* after die hearing. Written statements should be addressed to the Central Docket Section address given in the ADMtttsn section of this preamble.
A verbatim transcript of the hearing and written statements will be available for public inspection and copying during normal working hours at the EPA's Centra] Docket Section in Washington, D.C. (see addresses section of this preamble).
Docket
The docket is an organized and complete file of all the information submitted to or otherwise considered by the EPA in the development of this proposed rulemaking. The principal purposes of the docket are: (1) To aUow interested parties to identify and locate documents so that they can affectively participate in the rulemaking process, and (2} to serve as tire record in care or judicial review (except for interagency review materials ({ 307(d)(7(A)j).
Miscellaneous
In accordance with section 117 of the Act publication of this proposal was preceded by consultation with appropriate advisory committees, independent experts, and Federal departments and agencies. The Administrator will welcome comments on all aspects of the proposed regulation, including health, and economic and technological issues.
The information collection requirements in this proposed rule have been submitted for approval to the Office of Management and Budget (OMB) under the Paperwork Reduction Act of 1980.44 U.S.C. 3501 et teg. Comments on these requirements should be submitted to the Office of Information and Regulatory Affairs of OMB. marked "Attention: Desk Officer for EPA". as well as to the EPA docket described above. The final rale will respood t any OMB or public comments oe the information collection requirement*. .
. TEN 3887
11M
Fodaral Kniitir / V 1. 50. No. 6 / WidnwJay, Jinuity 9,1985 / Proposed Rdw
Under Executive Order 12291, die EPA met fudge whether regulation la 'major" end therefore eubject to the requirement of a Regulatory Impact Analysis. Thia regulation ia not major becauee: (1) The national annualized compliance coate, including capital charge* resulting from the atandarda total lea* than f100 million: (2) the atandarda do not cauae a major increaae in prices or production costs; and (3) the standards do not cause significant adverse effects on domestic competition, employment, investment productivity, innovation or competition in foreign markets.
This regulation was submitted to the Office of Management and Budget for review aa required by Executive Order 12291. Any comments from OMB to EPA and any EPA response to those comments are included in Docket Number A-81-21. The docket is available for public inspection at EPA'a Central Docket Section, West Tower Lobby, Gallery 1, Waterside Mall, 401 M Street. SW,, Washington, D.C. 20460.
Pursuant to the provisions of 5 U.S.C. 605(b), 1 hereby certify that this rule, If promulgated, will not have a significant economic impact on a substantial number of small entities because no small entities are affected.
List of Subjects In 40 CFR Part 61
Air pollution control, Asbestos, Beryllium, Hazardous materials, Mercury, Vinyl chloride.
Dated* Dated December 31,1084. Ahrki L. Aim. Acting Administrator.
PART 61--(AMENDED)
It is proposed to emend 40 CFR Part 61 as follows:
1. The proposed changes to 40 CFR Part 61 proposed at 42 FR 26154, June 2, 1977 are withdrawn.
2. By revising the definitions in existing f 61.61 (j). (1). (o) and (p) for "in process wastewater", "in vinyl chloride aervice", "ethylene dichloride purification" and "vinyl chloride purification" and by adding definitions for the terms "relief value", "leak", "exhaust gas", "relief valve discharge and "3-hour period" in new paragraphs (v). (w). (x). (y) and (z).
|4t41 Definitions.
*
(J) "Inprocess wasterwater" means any water which, during manufacturing or processing, comes into direct contact with vinyl chloride or polyvinyl chloride or results from the production or use of any raw material, intermediate product finished product, by-product, or waste
product containing vinyl chloride or polyvinyl chloride but which has not been discharged to a wastewater treatment process or discharged untreated as wastewater. Gas-holder eeal water is not inprocess wastewater until it te removed from the gasholder. I *
(1) Tn vinyl chloride service" means that a piece of equipment either contains or contacts a liquid that is at least 10 percent vinyl chloride by weight or e gas that Is at least 10 percent by volume vinyl chloride as determined according to the provisions of | 6167(h). The provisions of | 61.67(h) also specify how to determine that a piece of equipment la not in vinyl chloride service. This definition must be used in place of the definition of "VHAP aervice" in Subpart V of this part
44*4
(o) "Ethylene dichloride purification" include* any part of the process of ethylene dichloride production which follows ethylene dichloride formation.
(p) "Vinyl chloride purification" includes any part of the process of vinyl chloride production which follows vinyl chloride formation. *Ap*
(v) "Relief valve" means each pressure relief device including pressure relief valves, rupture disks, manual vents and other pressure relief systems used to protect process components from overpressure conditions. "Relief valve" does not include control valves used to control flow to an incinerator or other air pollution control device.
(w) "Leak" means any of several events that indicate interruption of confinement of vinyl chloride within process equipment Leaks include events regulated under Subpart V of this part such as: (1) An instrument reading of 10,000 ppm or greater (2) indications of liquid dripping; (3) a sensor detection of failure of a seal system, failure of a barrier Quid system, or both; and (4) detectable emissions as indicated by an instrument reading of greater than 500 ppm above background. Leaks also include eventB regulated under 161.65[b)(8)(i) of detection of ambient concentrations in excess of background concentration. Emissions of vinyl chloride not regulated under I 61.61 (a) and (b); 161.63(a): | 6164 (a), (b), (c).
(d), (e) and (f): and f 61.65 (a) and (b)(1),
(b)(2), (b)(3). (b)(4). (b)(5), (b)(6), (b)(7) and (b)(6) shall be considered a leak. A relief valve discharge is not a leak.
(x) "Exhaust gas" means any offgas discharged directly r ultimately to the atmosphere that was initially contained in or was in direct contact with the equipment f r which 10 ppm emission
limits art pretencea tn 16162 () and (b); I63(a). 161.64 (aXH (a)(2). (b),
(c) and (d* 16165 (bJUXH). 0X2). (b)(5), (b)(6)(ii) and (b)(9)(U). A teak as defined In paragraph (w) of this section Is not an exhaust gas.
(y) "Relief valve discharge" means any nonleak discharge through a relief valve.
(z) "3-hour period" means any three consecutive 1-hour periods (each hour commencing on the hour).
3. By changing " all exhaust gases" to "each exhaust gas stream" and making other minor clarifying revisions in I 6162(a), | 6163(a), and 16164 (a)(1), (b), (c) and (d) aa follows:
161.42 Emission standard lor attiytena dlehlorids plants.
(a) Ethylene dichloride purification; The concentration of vinyl chloride in each exhaust gas stream from any equipment used in ethylene dichloride purification is not to exceed 10 ppm (average for S-hour period or as determined in accordance with | 6167(g)(1)), except as provided in S 61.65(a). This requirement does not preclude combining of exhaust gas streams provided the combined steam is ducted through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm, or equivalent as provided In 16166. This requirement does not apply to equipment that has been opened, is out of operation, and mel the requirement in 161.65(b)[6)(i) before being opened. *'***
|61.43 Emission standard tor vinyl chloride plants.
An owner or operator of a vinyl chloride plant shall comply with the requirements of this section and { 61.65
(a) Vinyl chloride formation and purification: The concentration of vinyl chloride in each exhaust gas stream from any equipment used in vinyl chloride formation and/or purification is not to exceed 10 ppm (average for 3-hour period or as determined in accordance with { 6167(g)(1)), except aa provided in I 61.65(a). This requirement does not preclude combining of exhaust gas streams provided the combined steam is ducted through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm, or equivalent as
provided in f 61.86. This requirement
does not apply to equipment that has been opened, is out of operation, and met the requirement in i 61.65(b)(6)(i) before being opened. *6 6 ' 6
rEN 3888
**btat / Vot. 90, No. t / Wadnaadny, January 9, 1985 j Proposed Rules_______ lilt
|6144 EISSlBW ***** terstr7to* vnponw punk
An own* r operator of polyvinyl
* (l)Tht reactor opsning lass from each reactor to Mt to tXoaad M2 g vinyl chlaride/k* (000002 lb viny) cfaloride/lb)
chloride plant shall comply with tbs
of poly vfayl chloride product, except as
reqidremsnts of this seedon and | 0146. provided to paragraphs (f)(1) and (f)(2)
(s) Reactor. The following
of diis section, with the predict
requirements apply to reactors:
determined on a dry solids basis. This
(1) The concentration of vinyl chloride requirement doe* not apply to
in each exhaust gas stream from each
prepolymerization reactor* in the bulk
reactor Is not to exceed 10 ppm (avenge process. This requirement does apply to
for St-hour period or as determined In
postpolymerizatiDn reactors to die bulk
accordance with 161.07(g)(1)), except as provided in pangraph (s)(2) of this section and 161.65(e). It*
process, where the product means the gross product of prepolymerization and postpolymerizatioa 66
(b) Stripper. The concentration of viny] chloride in each exhaust gas 'stream from each stripper is not to exceed 10 ppm leverage for 5-hour period or as determined in accordance with | 61.67(g)(1)), except as provided in f 61.65(a). This requirement does not apply to equipment that has been opened, is out of operation, and met the requirement in f 6145[b)(6)(i) before being opened.
(c) Mixing, weighing, and holding containers. The concentration of vinyl chloride in each exhaust gas stream from each mixing, weighing, or holding container in vinyl chloride service which precedes the stripper (or die reactor if the plant has no stripper) in the plant process Sow is not to exceed 10 ppm (average for 5-hour period or as determined in accordance with 161.67(g)(1)), except as provided in f 61.65(a). This requirement does not apply to equipment that has been opened, is out of operation, and met die requirement in i 0l.65(b)(6)(i) before being opened.
(d) Monomerrecovery system. The concentration of vinyl chloride in each exahust gas stream from each monomer recovery system is not to exceed 10 ppm (average for 5-hour period or as determined in accordance with | 61.67(g)(1)). except as provided in I 61.65(a). This requirement does not apply to equipment that has been opened, is out of operation; and met the requirement in 161.65(b)(6)(i) before being opened. **6
4. By revising existing paragraphs S 61.64(a)(2) and by removing (a)(3) as follows;
f 61j64 Emission standard lor potyvtoyt chloride plants.
w An owner or operator of a polyvinyl Bhloride plant shall comply with the Requirements of this section end f 6146.
(e) Reactor. The following requirements apply to reactors:
5. By revising paragraph (e) introductory text and adding paragraph (e)(3) to 161.64 as follows:
| tl.64 Emission standard tor polyvinyl CWorids plants. *0*00
(e) Sources following the etripperfsj.
The following requirements apply to
emissions of vinyl chloride to die
atmosphere from the combination of all
sources following the *tripper(s) (or the
reactor!*) is the plant has no stripper(s)] in the plant process flow including but
not limited to, centrifuges,
concentrators, blend tanks, filters,
dryers, conveyor air discharges, baggers, storage containers, and inprocess
wastewater, except as provided in
paragraph (1) of this section:
S4
*4
t
(3) The provisions of this paragraph apply at all times including when offspecification or other types of resins are made.
6. By adding paragraph (f) to { 61.64 as follows:
16144 Emission standard tor polyvinyl chloride plants
44
44
6
(f) Reactor used as stripper. When a
nonbulk resin reactor is used as a
stripper this paragraph may be applied
in lieu of | 61.64 (a)(2) and (e)(1):
(1) The weighted average emissions of
vinyl chloride from reactor opening loss
and all sources following the reactor
used as a stripper from all grades of
polyvinyl chloride resin stripped in the
reactor on each calendar day may not
exceed:
(i) 202 g/kg (0.00202 Ib/lb) of polyvinyl
chloride product for dispersion polyvinyl
chloride resins, excluding latex resins,
with the product determined on a dry
solids basis.
(ii) 0.42 g/kg (0.00012 Ib/lb) of
polyvinyl chloride product fen- all other
polyvinyl chloride resins, including latex
resins, with toe product determined on s
dry solids basis.
TEN 3889
7. By revising paragraph (a) to 16146 as follows:
16146 Emission standard ter sthylaos wpwonovi Ipiji emonot no fHjnfvijri chloride plants
An owner or operator erf an ethylene dichloride, vinyl chloride, and/or polyvinyl chloride plant shall comply with the requirements of this section.
(a) Relief valve discharges. (1) Polyvinyl chloride plants (suspension, dispersion, latex, and bulk processes).
(1) Reactor. The number of discharges to the atmosphere from relief valves on polyvinyl chloride reactors to vinyl chloride service is not to exceed the following limits except as provided in paragraph (a)(l)(iii) of this section. For all reactors producing suspension resins within a PVC plant, the number of relief valve discharges is not to exceed 0.035 discharges per 100 polymerization batches nor 4 discharges per year. For all reactors producing dispersion and letex resins within a PVC plant, the number of relief valve discharges is not to exceed 0.035 discharges per 100 polymerization batches. For all reactors including prepolymerization and postpolymerization reactors, producing bulk resins within a PVC plant the number of relief valve discharges is not to exceed 0.035 discharges per 100 polymerization batches.
(ii) The number of discharges to the atmosphere from relief valves on equipment (excluding polyvinyl chloride reactors) in vinyl chloride service is not to exceed 0-025 discharges per 100 polymerization batches nor 3 discharges per year except as provided in paragarph (e)(l)(iii) of this section.
(iii) The limits specified in paragraphs (a)(i)(i) and (a)[l)(ii) of this section may be exceeded when only one relief valve discharge to the atmosphere occurs during the 12-month period preceding the close of the 6-month reporting period.
(2) Polyvinyl chloride plants (solution and other continuous PVC production processes). The number of discharges to the atmosphere from relief valves on all equipment in vinyl chloride service is not to exceed 1 discharge per year.
(3) Ethylene dichloride and vinyl chloride plants. The number of discharges to the atmosphere from relief valves on equipment in vinyl chloride service is not to exceed 4 discharges per year.
(4) Each relief valve discharge that contributes to a relief valve discharge frequency to excess of any limit prescribed to paragarphs (a)(1). (a)(2) and (a)(3) of this paragraph constitute*
1116
Federal Register / Vol. 50, No. 6 / Wednesday. January B, 1665 / Proposed Rules
o Individual violation of tha respective limit.
(5) For avery relief valve diecharge to the atmosphere, the owner or operator ahall record the Identity of the source, the date and time of the discharge, the cause of the discharge, the approximate total vinyl chloride loss during the discharge, and the method used for determining the vinyl chloride loss. This information shall be submitted in writing to the Administrator as part of the reporting requirements of paragraph | 61.70. This information shall be retained and made availableior inspection by the Administrator for a minimum of 3 years.
6. By revising paragraphs (b)(3), . (b)(8)[i).(b)(6)(iii). (b)(8)(iv) and
(b)(8)(vi) to i 61.65 as follows;
1S145 Emission standard tor ethylene dicNoride, vtnyt chloric** and potyvinyt chloride plants.
An owner or operator of an ethylene dichloride, vinyl chloride, and/or polyvinyl chloride plant shall comply with the requirements of this section.
(a) * * * (b) Fugitive emission sources (1) * * * (2) * * * (3) Leakage from pump, compressor, and agitator seals; (i) Rotating pumps. Vinyl chloride emissions from seals on all rotating pumps in vinyl chloride service are to be minimized by installing sealless pumps, pumps with double mechanical seals or equivalent as provided in 61.66. If double mechanical seals are used, vinyl chloride emissions from the seals are to be minimized by maintaining the pressure between the two seals so that any leak that occurs is into the pump; by ducting any vinyl chloride between the two seals through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm; or equivalent as provided in { 61.66. (ii) Reciprocating pumps. Vinyl chloride emissions from seals on all reciprocating pumps in vinyl chloride service are to be minimized by installing double outboard seals, or equivalent as provided in S 61.66. If double outboard seals are used, vinyl chloride emissions from the seals are to be minimized by maintaining the pressure between the two seals so that any leak that occurs is Into the pump; by ducting any vinyl chloride between the two seals through a control system from which the concentration of vinyl chloride In the exhaust gases does not exoeed 10 ppm; or equivalent as provided in f 61.66. fiii) Rotating compressor. Vinyl chloride emissions from seals on all
rotating compressors In vinyl chloride servioe are to be minimised by Installing compressors with double mechanical eals, or eauivalent as provided In 16146. If double mechanical Malt ate used, vinyl chloride emissions from the Mils are to be minimised by maintaining the pressure between the two Mali so that any leak that occurs Is into the compressor; by ducting sny vinyl chloride between the two Male through a control system from which die concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm; or equivalent as provided in | 6146.
(iv) Reciprocating compressors. Vinyl chloride emissions from seals on all reciprocating compressors in vinyl chloride service are to be minimized by Installing double outboard teals, or equivalent as provided in | 61.66. If , double outboard teals are used, vinyl chloride emissions from the seals are to be minimized by maintaining the pressure between the two seals ao that any leak that occurs is into the compressor by ducting any vinyl chloride between the two seals through a control system from which the concentration of vinyl chloride in the exhaust gsses does not exceed 10 ppm; or equivalent as provided in | 61.66
(v) Agitator. Vinyl chloride emissions from seals on all agitators in vinyl chloride service are to be minimized by installing agitators with double mechanical seals, or equivalent as provided in 161.66. If double mechanical seals are used, vinyl chloride emissions from the seals are to be minimized by maintaining the pressure between the two seals so that any leak that occurs is into the agitated vessel: by ducting any vinyl chloride between the two seals through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm; or equivalent as provided in $ 61.66. 6*
(8) Leak detection and elimination.
(i) It includes a reliable and accurate vinyl chloride monitoring system for detection of major leaks and identification of the general area of the plant where a leak is located. A vinyl chloride monitoring system means a device which obtains air samples from one or more points on a continuous sequential basis and analyzes the samples with gas chromatography or, if the owner or operator assumes that all hydrocarbons measured are vinyl chloride, with infrared spectrophotometry, flame Ion detection, or an equivalent or alternative method. 4 * *
(Ml) II protldM lor an sooeptabls
calibration and maintenance achedule for the vinyl chloride monitoring eystem and portable hydrocarbon detector. For the vinyl chloride monitoring eystem, daily epan check ie to be conducted with a concentration of vinyl chloride equal to the concentration defined as a leak according to paragraph (b)(8)(vi) of this section. The calibration is to be done with either.
(A) A calibration gas mixture prepared from the gases specified in sections 54.1 and 5.24 of Test Method 106 and in accordance with section 7.1 of test Method 106, or
(B) A calibration gas cylinder standard containing the appropriate concentration of vinyl chloride. The gas composition of the calibration gas cylinder standard is to have been certified by the manufacturer. The manufacturer must have recommended a maximum shelf life for each cylinder to that the concentration does not change greater than 5 percent from the certified value. The date of gas cylinder preparation, certified vinyl chloride concentration and recommended maximum shelf life muBt have been affixed to the cylinder before shipment from the manufacturer to the buyer. If a gaB chromatograph is used as the vinyl chloride monitoring system, these gas mixtures may be directly used to prepare a chromatograph calibration curve as described in section 74 of Test Method 106. The requirements in section 54.3.1 and 5444 of Test Method 106 for certification of cylinder standards and for establishment and verification of calibration standards are to be followed.
(iv) The location and number of points to be monitored and the frequency of monitoring provided for in the program are acceptable when they are compared with the number of pieces of equipment in vinyl chloride service and the size and physical layout of the plant ***
(vi) It contains a definition of leak which is acceptable when compared with the background concentrations of vinyl chloride in the areas of the plant to be monitored by the vinyl chloride monitoring system. Measurements of background concentrations of vinyl chloride in the areas of the plant to be monitored by the vinyl diloride monitoring system are to be induded with the description of the program. The definition of leak for a given plant may vary among the different areas within the plant and is also t change over time as background concentrations in the plant are reduced.
TEN 3*890*
Fftdwl
/ V 1. BO, No. 6 / Wftdnaaday, January 9. MBS / Proposed Rules
1117
By fwltinf paragraph (b)(4) to | 6146 a* follows: *
|*tM tnUaaiuuatanftarftloreftiytana *ortda, vtnyt Mortfta antf potyrtnyt cWortda plants
ft ft
(b) Fugitive emission sources.
* ft ft
(4) Leaks from relief rahes. Vinyl chloride amission* due to leaks from each relief valve on equipment in vinyl chloride service shall comply ivith | 61442-4 of Subpart V of this part. ft ft ft ft ft
10. By revising paragraph (b)(7) of | 61.65 as follows:
|6145 tmtsaton standard tor ethylene (ftcNorWs, vinyl eMorM* and polyvtnyt cmooov puma.
* **
(b) Fugitive emission sources. ft ft ft ft ft
(7) Samples. Unused portions of ' samples containing at least 10 percent by weight vinyl chloride are to be returned to the process or destroyed in a control device from which the ' concentration of vinyl chloride in the exhaust gas does not exceed 10 ppm. Sampling techniques are to be such that sample containers in vinyl chloride are purged into a closed process system.
11. By revising paragraphs (b)(8) introductory text, (b)(8)[ii), and (b)(8)[v) t | 81.85 as follows:
|8145 Emission standard tor ethylene
ftcNortda, vinyl chloride and polyvinyl
chloride plants.
ft ft ft ft
ft
(b) Fugitive emission sources. ft ft ft ft ft
(8) Leak detection and elimination. Vinyl chloride emissions due to leaks from equipment in vinyl chloride service are to be minimized by instituting and implementing a lead detection and repair program consistent with the provisions of Subpart V of this part The program is to be implemented within 90 days of the effective date Of these regulations, unless a waiver of compliance is granted under | 81.11. Approval of a program will be granted by the Administrator provided he finds:
(i) * * * (U) It includes a reliable and accurate portable hydrocarbon detector to be used consistent with the provisions of Subpart V of this part. An owner or operator is exempt from 161442-l(d), || 81442-7 (a), (b) and (c). | 81446 and | 81447 of Subpart V of this part for any process unit in which the percentage of leaking valves is demonstrated to be equal to or less than 2.0 percent, as
determined In accordance with the following:
(A) A performance feat as specified In paragraph (b)(8)(U)(C) of this taction shall be conducted initially within 90 days of die affective data of these regulations, annuity and at requested by the Administrator.
(B) For each performance test a minimum of 200 or 90 percent of the total valve* in VOC service (as defined in 180.481 of Subpart W of Part 80) within the process unit shall be randomly selected and monitored within 1 week by the methods specified In 181445(d) of Subpart V of this part If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. The leak percentage ahall be determined by dividing the number of valves in VOC service for which leaks are detected by the number of tested valves in VOC service.
(C) If a leak is detected, it shall be repaired in accordance with 161442-7 (d) and (e) of Subpart V of this part.
(D) The results of the performance test ahall be submitted in writing to the Administrator in .the first semiannual report following the performance test as part of the reporting requirements of 1614a
() Any process unit in which the percentage of leaking valves is found to be greater than 2JO percent must comply with all provisions of Subpart V of tills part within 90 days. ft ft ft ft ft
(v) It contains a plan of action to be taken when a leak is detected consistent with Subpart V of this part.
12. By revising 16146 as follows:
|6148 Equivalent equipment and
Upon written application from an owner or operator, the Administrator may approve use of equipment or procedures which have been demonstrated to his satisfaction to be equivalent in terms of reducing vinyl chloride emissions to the atmosphere to those prescribed for compliance with a specific paragraph of this subpart
13. By revising paragraph (f) of 161.67 as follows:
18147 Emission tests. ft ft ft ft ft
(f) The owner or operator shall retain
at the plant and make available, upon request for inspection by the Administrator, for e minimum of 3 years, records of emission test results and other data needed to determine
emissions.
rEN 3891
14. By revising paragraphs (g)(3) Introductory taxi tg)(3)(l|. and (g)(3)(iU) of 18147 as follows:
|8147 KmMon lasts. ft ft ft ft ft
(gr * * (3) When a stripping operation Is used to attain the amission limits in 18144 (e) and (f). amissions are to be determined using Test Method 107 as follows:
(1) The number of strippers (or reactors using as strippers) and samples and the types and grades of resin to be sampled are to be determined by the Administrator for each individual plant at the time of the test based on the plant's operation.
tU| * * * (iil) The corresponding quantity of materia] processed by each stripper (or . reactor used as a stripper) is to be determined on a dry solids basis and by a method submitted to and approved by the Administrator.
ft ft ft - ft ft
15. By revising paragraph (g)(5) introductory text and adding paragraph (g)(6) to | 61.67 as follows:
|6147 Emission tssts.
ft ft ft ft ft
(r * * (5) The reactor opening loss for which an emission limit is prescribed in 161.64(a)(2) is to be determined. The number of reactors for which the determination is to be specified by the Administrator for each individual plant at the time of the determination based on the plant's operation. ft ft ft ft ft
(6) For a reactor that is used as a tripper, the emissions of vinyl chloride from reactor opening loss and all sources following the reactor used as a tripper for which an emission limit is prescribed in { 6144(f) are to be determined. The number of reactors for which the determination is to be made is to be specified by the Administrator for each individual plant at the time of the determination based on the plant's operation.
(i) For each batch stripped in the reactor, the following measurements are to be made:
(A) The concentration (ppm) of vinyl chloride in resin after stripping, measured according to paragraph (g)(3) of this section:
(B) The reactor vacuum (mm Hg) at end of strip from plant instrument and
(C) The reactor temperature (*C) at end of strip from plant instrument.
1198
Federal Register / VoL 10. No. 6 / Wednetday, January 9. 1985 / Proposed Rules
(II) For each batch stripped in the reactor, the following Information la to
be determined:
(A) Hie vapor presoure (mm Hg) of water In the reactor at and of atrip from the following table:
In ro
HO
1D8 9*m9UT*
XG
Mecto
pvm ** rp
HO
9mp* tv w. r
HO MOW
9n
XS
40 S6J 41 SSJ 42 14 43 Ml 44 ms 46 n.s 46 res 47 76.6 46 S3 7 46 66.0 60 *2.5
61 972
62 MS.1 13 1073 14 ms 65 11S.0 se 1234 67 126.6 M 1961
0 146.4
1 se . 4
m m
* w
m
70
71 72 71
74 n
76 77 76 76
o
1
16*4 463J 1714 ires 1S7J 1661 ao*o 214J *T3? mi S43.S 654.6 SS6.7
mi
M.1 3014 *14.1 3773 641.0 656.1 SM.7
ar
9 4 SB S7
m
as so si se so 4 K
m
*7 66 SO 100
4J 400.6 S1SS 433*6 460J 4M.V 467.1 6061 sms 6410 S07.O Ml sms *33.1 as74 6621 707J
mi
raoo
(B) The partial pleasure (mm Hg) of vinyl chloride in reactor at end of atrip from the following equation:
PPVA=760- RV - VPW
Where: PPVC-= partial pressure of vinyl chloride, hi
mm Hg *60 X atmospheric pressure at 0*C, hi mm Hg RV-- absolute value of reactor vacuum, in
aim Hg VPW vapor pressure of water, in mm Hg
(C) The reactor vapor apace volume (m1) at end of strip from die following equation:
nvsv-RC-wv-
wcw *33
where:
RVSV -=reactor vapor space volume, in m* PC^reector capacity, in m* WV--volume of water in reactor from recipe,
in m* PVCW --dry weight of polyvinyl chloride in
reactor from recipe, io kg C33--typical density of polyvinyl chloride, in
kg/m*
(iii) For each batch atripped in the reactor, the combined reactor opening loss and emissions from all sources following the reactor used as a stripper la to be determined using the foDowing equation:
(PPVCKRV8V)(1J02) Op7MVCXlir)+
(PVCW)(27+m
*'
where:
C-g vinyl ohlorida/kg polyvinyl chloride product
FPMVC--concentration of vinyl chloride in resin efter stripping, in ppm
10'*--conversion factor for ppm PPVC-partial pressure of vinyl chloride
determined according to paragraph (g)(6)(ii)(B) of this acetic*. to mm Hg RVSV-reactor vapor space volume determined according to paragraph ' (gHBKiiKC) Of this section, in m* 1,002--Idea) get constant in g--``K/mm Hg-- m* for vinyl chloride PVCW-dry weight ef polyvinyl chloride in reactor from recipe. In kg &3--conversion factor for *C to *K RT--reactor temperature, io *C
16. By adding paragraph (h) to f 61.67
as follows:
(h)(1) Bach piece of equipment within a process unit that can reasonably contain equipment in vinyl chloride service is presumed to be in vinyl chloride service unless an owner or operator demonstrates that the piece of equipment la not in vinyl chloride service. For a piece of equipment to be considered not in vinyl chloride service,
it must be determined that the percent vinyl chloride content can be reasonably expected not to exceed 10 percent by weight for liquid streams and 10 percent by volume for gas streams. For purposes of determining the percent vinyl chloride content of the process fluid that is contained in or contacts equipment procedures that conform to the methods described in ASTM Method D-2287 (incorporated by reference as specified
in | 61.16) shall be used.
(2X1) An owner or operator may use engineering Judgment rather than the procedures in paragraph (h)(1) of this section to demonstrate that the percent vinyl chloride content does not exceed 10 percent by weight for liquid streams and 10 percent by volume for gas streams, provided that the engineering Judgment demonstrates that the vinyl chloride content clearly does not exceed 10 percent. When an owner or operator and the Administrator do not agree on whether a piece of equipment is not in vinyl chloride service, however, the procedures in paragraph (h)(1) of this section shall be used to resolve the disagreement
fii) If an owner or operator determines that a piece of equipment is in vinyl chloride service, (he deteff^tkwdian
be revised only after following the procedures in paragraph (h)(1) of this section.
(3) Bernpies used in determining the percent vinyl chloride content shall be representative of the process fluid that is contained in or contacts the equipment
17. By adding paragraphs (d), (e) and (f) to | 61.68 as follows:
I61.M Eirtaslon monfrortnp.
4 *
(d) When exhaust gas(es), having ~ emission limits that are subject to the requirement of paragraph (a) of this section, are emitted to the atmosphere around the control system and required vinyl chloride monitoring system, the vinyl chloride content of the amission shell be calculated (in units of each applicable emission limit) by best practical engineering Judgment baaed on the discharge duration and known VC concentrations in the affected equipment as determined in accordance with 161.87(h) or other acceptable method.
(e) For each 3-hour period, the vinyl chloride content of emissions subject to the requirements of paragraphs (a) and (d) of this section shall be averaged (weighted according to the proportion of time that emissions were continuously monitored and that emissions bypassed the continuous monitor} for purposes of reporting excess emissions under 161.70(c)(1).
(f) For each vinyl chloride emission t the atmosphere determined in accordance with paragraph (e) of this section to be in excess of the applicable emission limits, the owner or operator shall record the identity of the aource(s). the date, time, and duration of the excess emission, the cause of die emission, the approximate total vinyl chloride loss during the excess emission, and the method used for determining the vinyl chloride loss. This tnfdnnstion shall be retained and made available for inspection by the Administrator as required by 161.71(a).
16. By changing the title from "Semiannual report" to "Reporting" and by revising paragraph (a) of f 61-70 as follows:
frdwal Register / V 1. BO. No. > / Wednesday, January 9,1W / Proposed Rules
11M
|61.76 Reporting.
(a)(1) The owner or operator of any source to which thla subperl tpplis* ahall aubmlt to the Administrator on September 15 and March 15 of each year a report in writing containing the information required in paragraphs, (c), (d) and (e) of thii section ana on December 15 and June 15 of each year a report in writing containing the information required in paragraph (e) of this section, except as provided in paragraph (a)(2).
(2) In the case of an existing source that submits semiannual reports on an approved fixed schedule other than September 15 and March 15. the approved semiannual reporting schedule shall be used to report the information required in paragraphs (c), (d) and (e) of this section. In addition, the information required in paragraph (e) of this section will be reported exactly 3 months following the semiannual reporting dates.
(3) The first report is to be submitted following the first full 3 month reporting period after the initial report is submitted.
16. By revisingparagraph (c)(1) of 161.70 as follows:
| S1.70 Reporting.
Stilt
(c) * * * (1) The owner or operator shall include in the report a record of the vinyl chloride content of emissions for each 3-hour period during which average emissions ire in excess of die emission limits in S 61.62 (a) or (b), | 61.63(a). or I 61.64 (a)(1). (b). (c). or (d), or during which average emissions are inexcess of the emission limits specified for any control system to which reactor emissions are required to be ducted in | 61.64(a)(2) or to which fugitive emissions are required to be ducted in t 61.65 (b)(i)(ii). (b)(2). (b)(5), (b)(6)(ii), or (b) (9)(ii). If emissions in excess of the emission limits are not detected, the report shall contain b statement that no excess emissions have been detected. The emissions are to be determined in accordance with 161.68(e). 20. By revising paragraph (c)(2) introductory text removing paragraphs (c) (2)(iv), revising paragraph (c)(2)(iii) and revising (c)(2)(v) and (c)(2)(vi) introductory text to { 61.70 as follows:
f 11.70 Reporting.
t t tt t
(c) * * * (2) In polyvinyl chloride plants for which a stripping operation is used to attain the emission level prescribed in | 61.64(e). the owner or operator shall include in the report a record of the
vinyl chloride coolant In ths polyvinyl chloride resin.
(HP '
(ill) The vinyl chloride content in aach sample is to be determined by Test Method 107 as prescribed in 161.67(g)(3).
(iv) [Reserved] (v) The report to die Administrator by the owner or operator is to include a record of any 24-hour average resin
A,i ----------------5_----------------
where: A = 24-hour avenge concentretlon of type. Ti
resin In ppm (dry weight basis). Total production of type 71 resin over the 24-hour period, in kg. 71=Type of rwin: /-1.2. . , oi where w is total number of resin type* produced during the 24-hour period. M= Concentration of vinyl chloride in one aample of grade Ct resin, in ppm. Production of grade G resin represented by the sample, in kg. C<= Grade of resin: e.gn Ct, C,. and C,. n=ToUl number of grades of resin produced during the 24-hour period.
If no 24-hour average resin vinyl chloride concentrations in excess of the limits prescribed in 161.64(e) are measured, the report ahall state that no excess resin vinyl chloride concentrations were measured.
(vi) The owner or operator shall retain at the source and make available for inspection by the Administrator for a minimum of 3 years records of all data needed to furnish the information required by paragraph (c)(2)(v) of this section. The records are to contain the following information:
(A) * * *
(B)* * *
* *
21. By revising paragraph (c)(3) of 161.70 as follows:
f 61.70 Reporting.
* t 't t t
(C)* * * (3) The owner or operator ahall include in the report a record of any emissions from each reactor opening in excess of the emission limlta.prescribed in 16144(a)(2). Emissions are to be determined in accordance withf 6147(g)(5). except that emissions f r each reactor are to be determined. If emissions in excess of the emission limits are not detected, the report shall
ten:
vinyl chloride concentration, as determined in this paragraph, in exeats of the limits prescribed in 16144(e). The vinyl chloride content found In each' aample required by paragrapha (c|(2)(i) nd (c)(2)(H) of thie section ehellhe averaged aeparately for each type of resin, over each calendar day and weighted according to the quantity of each grade of resin processed by the stripper(s) that calendar day. according to the following equation:
5_
include a statement that excess emissions have not been detected.
4 * *
22. By adding paragraph (c)(4) to 161.70 as follows:
161.70 Reporting
t tt t t
(c)* * * (4) In polyvinyl chloride plants for which stripping in die reactor is used to attain the emission level prescribed in I 6144(f), the owner or operator shall include in the report a record of the vinyl chloride emissions from reactor opening loss and all sources following the reactor used as a stripper. (i) One representative sample of polyvinyl chloride resin is to be taken from each batch of each grade f resin immediately following the completion of the stripping operation, and identified by resin type and grade and the date and time the batch is completed. The corresponding quantity of material processed in each stripper batch is to be recorded and identified by resin type and grade and the dBte and time the batch is completed. (ii) The vinyl chloride content in each sample is to be determined by Test Method 107 as prescribed in | 6147(g)(3). (iii) The combined emission from reactor opening loss and all sources following the reactor used as a stripper are to be determined for each batch stripped in a reactor according to die procedure prescribed in 16147(g)(6). (iv) The report to the Administrator by the owner or operator is to include a record of any 24-hour average combined reactor opening loss and emissions from all source* following the reactor used as a stripper as determined in this paragraph, in excess of the limits prescribed in | 6144(f). The combined reactor opening loss and emissions from
Fadartl RtUtar / Vol <0, Wo. 4 /'Wadnetday, January >, 1065 / Proposed Rules
all tourea* following (be reactor mm) m a tripper associated with each batch
are to be averaged separately for each type of rests, over each calendar day and weighted aooording to die quantity
of each grade of Mein stripped in reacton that calendar day as fdlows:
For each type of resin (suspension.' dispersion. latex, bulk, other), (he following calculation is to be performed:
ft t ,f Cfi
1-1 1
Cc ,
*'I' 6W,1 +
Cf .
, fr Cc
G2 C2 . . . 6b Gn
T
Where:
A - 24-hour average combined reactor opening loss and emiaaiona bom all aourcet following the reactor aaed ai a stripper, in g vinyl chloride/kg product (dry weight-basia).
Q~ Total production of resin in batches for which stripping is completed during the 24-hour period, is kg.
C Average combined reactor opening lots and emissions from all source* fallowing the reactor used as a stripper of all batches of grade G, resin for which stripping is completed during the 24-hour period in g vinyl chloride/kg product (dry weight basis) (determined according to procedure prescribed in | SI.07(g)(6)).
P--Production of grade Gi resin in the batches for which C is determined, in kg.
GtGrade of resin: eg.. Gi. Gi. and U. n=Total number of grades of resin in betches
for which stripping is completed during the 24-hour period.
If no 24-hour average combined reactor opening lots and emissions from all sources following the reactor used a stripper in excess of the limits prescribed In f 61.64(1) are determined, the report shell state that no excess vinyl chloride emissions were determined.
23. By adding paragraphs (d), (e) and (f) to | 61.70 as follows:
161.70 Reporting. 4S4
(d) The owner or operator shaD include In the report a record of relief valve discharges as prescribed in | 61.65(a)(4), and the owner or operator shall report exceedences of the relief valve discharge frequency limits prescribed in | 61.65(b) to be determined as follows:
(1) For polyvinyl chloride plants producing dispersion, latex or bulk resins, the relief valve discharge frequency from polyvinly chloride reactors is to be determined aaiag the following equation. Separate calculations are to be made for each resin type ft) as defined:
N
Where F,=relief velve discharge frequency per 100
polymerisation batches from all reactors producing resing type t N* total number of relief valve discharges during the 12-month period preceding the close of the 6-month reporting period from all reactors producing resin type t Y *= total number of polymerization betches of resin type t during the 12-month period preceding die close of the 6-month reporting period divided by 100 t resin type: dispersion (including latex) or bulk resin type
(2) For polyvinyl chloride plants producing suspension resinB. the relief valve discharge frequency from polyvinyl chloride reactors is to be determined in two ways using the following equations:
F. - --H : end F,, - h
V
where F,,--relief valve discharge frequency per MX)
polymerization batches from all reactors producing suspension resin F^ k relief velve discharge frequency per 12month period from all reactors producing suspension resin Ns total number of relief valve discharges during the 12-month period preceding the dose of the 6-month reporting period from all reactors producing suspension resin Y=total number of polymerization batches of suspension resin during the 12-monih period preceding the dose of the 6-month reporting period divided by 100
(3) For polyvinyl chloride plants producing suspension, dispersl n, latex, or bulk resins, the relief valve discharge frequency from all other equipment (excluding polyvinyl chloride reactors) is to be determined in two ways using the followiiiga^tk)g94
-----t----------------------------------------t----%- -------
ti F, * --: and Fi*N
where
P(--relief valve discharge frequency pm 100 polymerisation batches from all equipment (excluding reactors)
Fi - relief valve discharge frequency per 12month period from all equipment (excluding reactors)
N--total number of relief valve discharges during the 12-month period preceding the dose of die Omonth reporting period from all equipment (excluding reactors)
Y - total number of polymerization batches of all resin types combined divided by 100
(4) For polyvinyl chloride plants using the solution process or any other continuous production process, the relief valve discharge frequency Is the summation of each relief valve - discharge from all equipment types during the 12-month period preceding the close of the 6-month reporting period.
(5) For ethylene dichloride/vinyl chloride plants, the relief valve discharge frequency is the summation of each relief valve discharge from all equipment types during die 12-month period preceding the close of the 6month reporting period.
(6) A polymerization batch consists of each sequence of charging VC and other materials to the reactor, heating reactor contents, polymerization of reactor contents, and removal of reactor contents including any incomplete sequence that is aborted after charging VC to the reactor. For bulk resin production plants, a single "polymerization batch" includes both prepolymerization and postpolymerization reactor operations.
(e) The owner or operator shall include in the report the number of relief valve discharges to the atmosphere during the 6-month period preceding the report from each of the following sources: suspension resin production reactors; dispersion and latex resin production reactors; bulk resin production reactors; all nonreactor equipment in PVC plants; all quipment used in solution process and other continuous process PVC plants: and all equipment to EDC/VC plants: any other source.
(f) The owner or operator shall include in the report the number of reactor openings and the design capacity of the number of polymerization batches for each type of resin to each plant during the 6-roonth period preceding (he report The design capacity of the number of polymerization batches may be defined
Federal Kigbttr / Vol. 80. No. 0 / Wednesday. |intttiy >, 1865 / Proposed Rulea
initially and remain unchanged unlew algnificant change* to the design : capacity occur.
U. By revising paragraph (a) introductory text of 161.71 as follows:
'
(a) The wner or operator of any source to which this subpart applies shall retain the following information at die source'and make it available for
inspection by the Administrator for a
minimum of 3 years: a o
25. By adding the words "vinyl chloride" to the definition of the term "volatile hazardous air pollutants" in | 61.241 of Subpart V as follows:
161.141 Definition*.
*
"Volatile hazardous air pollutant" or "VHAP" means a substance regulated under this part for which a standard for equipment leaks of the substance has been proposed and promulgated. Benzene is a VHAP. Vinyl chloride is a VHAP.
(Sec. 112 Clean Air Act of 1076)
[FR Doc. 85-606 Filed 1-6-85: M5 am)
U01
V
PEN 3895