Document paxgek332EyexjXmy8X4gnOX

V. JACOBS ENGINEERING CO. ENGINEERS CONSTRUCTORS CALIFORNIA ' ILLINOIS * FLORIDA NEW JERSEY * PUERTO RlCO UNITED KINGDOM - IRELAND 8 3 7 SOUTH FAIR OAKS AVENUE PASADENA. CALIFORNIA 91105 (713) 449-7171 TELEX 6 7 - 5 4 S 8 (7 13) 6 8 1- 3781 REPLY TO 172 GLEN ROAD, MOUNTAINSIDE, NEW JERSEY 07094 (201) 233 9500 TELEX 130771 April 8, 1975 Mr. Darwin E. Rhoads, CSP Manager, Safety and Loss Prevention Tenneco Chemicals Park 80 Plaza West-1 Saddle Brook, N. J. 07662 Vinyl Chloride NAPC TAC Arlington, Va. March 25 & 26, 1975 Dear Darwin: As you requested, here is a copy of my report on the National Air Pollution Control Techniques Advisory Committee meeting about vinyl chloride emis sions. Jacobs Engineering Co. is a full service engineering and construction organi zation. We serve the process industries world-wide. A special strength is our Environmental Services Group. This group can determine and imple ment the best approach to managing the environmental problems associated with the storage, handling, and polymerization of vinyl chloride. Darwin, my colleagues and I would like to serve you and Tenneco Chemicals. Please let me know your needs. Sincerely yours. C.S.P Manager, Safety & Health Services GBS:ns Enclosure;. Report on NAPC TAC meeting COLORITE 007959 ivl. VVoLl St- 111 C f: Eiff-'" = l e is f C.lf O < . ? . , /' e ' , y . /' / / , ,' /* C a 1 i o u a 1 i \ i r 1 'o i 1 u 11 Conti- ol '1 vc b w i e :=, Ad v vs o ' \ (" om mi l ` c` e P V. e r .. , ,,, V. 1 1' I ' ` 1 L'! u! i -c i- POw.oi Ar Im gton. Vi rgi m 1 M i rf 1 h 3 5 a. 2 f , ! 11 "A 1. This Committee iidvi.st:s the aw f, la ndu rd s development ngenev of EPA, the Emissions St'inda rds and Engi nee r 1 ng Division (see Agenda). It reviews a ncl mad.ns informal coniiiioUs on. standards as they approach final develop ment, and before KD-\ publishes them as a Proposed Standard in the PR. Industry has been contacted during deailepmnit of the standard both in formally and by requests for i o t o r rna t'h >a published in the FR. Industry and other groups are given time to comment at meetings of this Committee, rhe Committee meets every month or every other month. The next meetings are scheduled, tentatively, for May 5th and May' 6th, 1975 possibly in Puerto Rico and for June 2 5th a ncl June 2 6th, 1975. 2. pew Regulations under Development - see notes for March 2 6, 1975, attao hed. 3. Vinyl Chloride E b'A standard is scheduled to be proposed in June. 'Puis agency prepared a draft document of 6 to /00 pages, nor available to us before the meeting, '1 ne data was revised after publication and before presentation on March 25th. 7 he standards to be prepared are intended to encourage VCM recovery, rather than incineration. The "numbers" are 400 parts VC per million parts PVC leaving the stripper and 10 parts VC per million parts air emitted from driers, hagging and other downstream point sources. Industry representa tives said suspension processes could meet these, especially if the emission j are averaged over batches and products; the proposal is for each batch and product. However, dispersion processes connot meet these standards. The standard proposed for water effluent is 0.0043 lbs VC per 100 lbs PVC. The same 10 ppm standard will apply to the ethylene dichloride vent and the o v y c h) o j i n a lion 'vent in VCM plants (1 ! o' la plants have ov vc h! or in ?. t ion vents' 1 he capital cosls and the operating costs in the. dealt document were- developed r- " contractor, the- Cation.il Air Cleaning, Institute ("), v ho used sub-contrat tors. rhe costs were Challenged vigorously by indust-v. An 5 Pi grcnio will iiieel with agency stiff to review cost data. COLORITE 007960 (_, u it ri )1 ; 1 ` 1 n i < |i.' : an rec i e v, i I i:: 1 > : I m i ' 11' . ; 11; ' , : :. ` i' l'11' 11; r I i r] t i '11' i 111 r t ; 11 , ji r | h o r p i. 11.': ;) v .i 11 'i! rluM, . i'.1! `--'il-if a ' u i r u : . 11 r |; li u: . y I n \ v i'll. . t" iliOU 'aa been Uot d . t .. i'111 \ lur I ,t ry '.I wl 11 `I*-U I! 11' g 11) n i. i >;'' r; i i. rt l o n - iv : 111 o; i:' a 1i1 (! 1.i: of.ir./.i I I. I n; 111 : r' r p ' 1 s e:, ` : l j a s pi i 1 ,.g (li.i.i iu.;l i, a hi b' I ; i lii trow i w inc' 'I'.iti'i ' o' A'lurin- uted 1' . 11 i k a j' !' i-i i '. e f', pa c M'u.u , a:; t ' 11 beat si' t'ulria"'',, ; routing, unot'wr, equolly bad c`m\ i t-ci'inv-Mitu! probb-m. There was e we:: j i v liba iibS.fri ol the prop o,3d 1 to c i) a f r o I emissions trail1 safety I'clu'j valves: iai1 .'('asi-d ! si /.a. rd , w.'i.sta oi foci aw! nione) to upi'i'ali1 a .dare used i a ` r o q a a' n t I v, invite five- ness of iGrc it: oxidiuing a sudden rush nf VC',, the secondary emission ot fICl and its ha/.ard. A few .small exi'-ting plants do not tiuv. strip VC ib'Oitt I1 VC; I'm cost of doing so probably, will form them to close. Envirotirne ntal impact has been assessed in the document using rlii fusion moduli m;. The mode! neglects plume rise and local vtTocity gradients. Field data has been collected to refine model. The model predicts O./.t'i ppm maximum for 24 hour;; under worst conditions with the standard des cribed above. If no standard is adopted, the model predicts 14 ppm. EPA health people have not determined (neither has NIOSli) whether a high shorttime exposure e.g. dist barge from safety' relief valve or low long-time exposure e.g. drier emissions is the cause of disease. Thus, no perfor mance standard based on monitoring, ambient air can be established. 4. Coke Oven Emissions The standard which this agency is developing is to allow a 20-second visible' emission per charge averaged over 18 charges. The United Steel Workers are a.dvocating no visible emissions and will fight for this as the OSilA standard; such a standard is achievable in coice oven batteries designed and operated to this criterion. The many old coke ovens in the IJ. S. can be made to meet the 20-second standard only with major maintenance expenditures and unusually' well-d i s c ip li ned managers and crews. The working conditions a'-e arduous, 120-140" b top-side temperature; this leads to low quality maintenance. Engineering work to bring existing, coke oven batteries into compliance and to design new batteries will be done by the operating companies and their traditional suppliers. GBSrcb enclosures; GLiS' manuscript notes to M. Wolkstein and E. Weis berg 1 k 2 ol 3/2e/75 k'APCT AC Ma te r ia 1 COLORITE 007961 St'; m i ir ot N' IS yulafiu k; m-M-w Dr` w S3 om: `'if A. Phosphate Fertilizer after Comments 1. K c-moved opacity stsndard i,,, Modification.- - !o >- 1 orribin.cn ..! B. Continuous Monitoring for Npw SiurC'-s ati d Existing Sources Standards should be- in EPA Steerin'. Committee in mid-April. C. Dust Emissions from Coal Preparation Plants - tested for the greatest tines applying to new plants. Discussions of volatiles in residual waste piles from coal which emit HgS, SOetc. from slow combustion. D. Developing simpler procedures for States to follow in setting regulations for non-criteria substances under Sec. Ill (d) of the Clean Air Act. E. Electric Steel Furnaces - will go forward in May, F. Non-Ferrous Smelters - American Mining Congress resisting. Plan to promulgate zinc and lead smelters and copper smelters, except those that use impure concentrates. G. Asbestos regulation is to be promulgated this summer - for emissions from manufacturing plants and mines. H. NOx standard about ready for review by committee in May. I. Sulfur from sulfur recovery plants in oil refineries - same as H. J. Kraft Pulp Mills - F.xisting Pulp Mills Lengthy discussion of setting standards and of measuring odors and ox enforceability of these standards. Victor Suss man spoke knowledge ably of measuring odor; he was at N. J. hearing yesterday. K. Primary Aluminum - Section 111(d) different standards for different aluminum cells. COLORITE 007962 NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE AUTHORITY Established by the Surgeon General, U.S. Public Health Service, Department of Health, Education, and Welfare, on March 4, 1968, under section 110(d) of the Clean Mr Act, as amended; reestablished by the Administrator, Consumer Protection and Environmental Health Service, pursuant to the Secretary's Reorganization Order daLed July 1, 19o8; transferred to the U.S. Environmental Protection Agency pursuant to Reorganization Plan No. 3 of 1970; reconstituted by the Administrator on June 8, 1971, pursuant to sections 108(b)(1) and (2), and 117(f) of the CLean Air Act, as amended; rechartered January 5, 1973, to include requirements of section 9(c) of the Federal Advisory Committee Act, P.E. 92-463; revised April 24, 1973,to assign an additional function; and terminating January 4, 1975, unless extension beyond that date is authorized in accordance with section 14 of the Federal Advisory Committee Act. STRUCTURE % Consists of the Deputy Assistant Administrator, Office of Air Quality Planning and Standards, or his designee, as Chairman and 16 members appointed by the Administrator for overlapping terms of one to four years. Members are selected from the chemical, engineering, biomedical, and socioeconomic disciplines resident in universities, State and local governments, research institutions, and industry. Members arc selected also for their technical expertise and/or interest in the development of air pollution control techniques. FUNCTIONS Advises the Deputy Assistant Administrator, Office of Air Quality Planning and Standards on the latest available technology and economic feasibility of alternative methods to prevent and control air contamination to be published in air quality control techniques documents. Also advises on informational documents regarding air pollution control techniques and testing and monitoring methodology for categories of new sources and air pollutants subject to the provisions of sections 111 and 112 of the Clean Air Act, as amended. In addition, the Committee, through a subcommittee, periodically reviews Air Quality Planning and Standards program accomplishment plans and the associated contracts and grants awarded to carry out these plans* ACCOMPLISHMENTS The Cocmittee held two open meetings during 1973. The average non-member attendance at both meetings was between 50-80. In February, the Committee reviewed with EPA staff technical data upon which new source performance standards for the following industries arc to be based: kraft pulp mills; coal preparation plants; ferroalloy plants; sta tionary gas turbines; electric arc furnaces; primary aluminum smelters; and phosphate fertilizer plants including wet process phosphoric acid, super-phosphoric acid, diamoniura phosphate, granular triple superphosphate, granular triple superphosphate storage, and run-of-pile triple superphosphate. In May, EPA had new source performance standards for coal preparation plants, kraft pulp mills, phosphate fertilizer plants, and primary aluminum plants and briefed the Committee on the proposed regulations. Standards for stationary gas turbines, ferroalloy plants, and electric arc furnaces were reviewed in detail with the Committee, including much new data which had recently been collected from the industry and from EPA source tests. They also reviewed the Group ItA nev source performance standards for copper, lead and zinc smelters* EPA's final position on new source performance standards for these sources was approved by the Committee. Regular Lions were reviewed and published by the Committee on (i) National Emission Standards for Hazardous Air Pollutants; (2) The Group II New Source Performance Standards; and (3) Regulations covering emissions during startup* shutdown, and malfunction for all sources covered under standards of performance for new stationary sources. 16 TT COLORITE 007963 COLORITE 007964