EPA450/2-75-009
           STANDARD SUPPORT

                     AND

ENVIRONMENTAL IMPACT STATEMENT:

           EMISSION  STANDARD

                     FOR

             VINYL CHLORIDE
           Emission Standards and Engineering Division
             U. S. ENVIRONMENTAL PROTECTION AGENCY
              Office of Air and Waste Management
           Office of Air Quality Planning and Standards
           Research Triangle Park, North Carolina 27711

                    October 1975

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 This report has been reviewed by the Emission Standards and Engineering
 Division,  Office of Air Quality Planning and Standards,  Office  of Air and
 Waste Management,  Environmental  Protection  Agency,  and  approved for publi-
 cation.  Mention of company  or  product  names  does not constitute  endorsement
 by  EPA.  Copies  are available free of charge  to Federal employees,  current
 contractors and  grantees, and non-profit organizations—as supplies permit--
 from  the Air Pollution Technical Information Center, Environmental Protection
Agency, Research Triangle Park,  North Carolina 27711; or may be  obtained,
for a fee,  from the National  Technical  Information  Service,  5285 Port Royal
Road,  Springfield,  Virginia 22161.
               Publication No. EPA-450/2-75-009
                            11

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                                PREFACE
A. PURPOSE OF THIS DOCUMENT
     This report summarizes the information obtained during the
development of a national emission standard for vinyl chloride
under the authority of section 112 of the Clean Air Act.  It is
being distributed in connection with formal proposal of the
standard in the FEDERAL REGISTER.  Its purpose is to explain the
background, basis, and environmental and economic impacts of the
proposal in greater detail than could be included in the FEDERAL REGISTER
and to facilitate analysis of the proposal by interested persons,
including those who may not be familiar with many of the technical
aspects of ethylene dichloride-vinyl chloride and polyvinyl chloride plants.
     Contained in this document is information on the industrial
sources of vinyl chloride, control technology which can be applied
to these sources, the proposed standard and the rationale for its
selection, alternative approaches for regulating vinyl chloride,
environmental and economic impacts of the proposed standard and
alternative control levels, and other Federal or State regulations
which apply to vinyl chloride or to plants which emit vinyl chloride.
Information on the health effects of vinyl chloride is contained
in a second document prepared by EPA, which is entitled the Scientific
and Technical Assessment Report or^ Vinyl Chloride and Polyvinyl Chloride.
Copies of both documents may be obtained from Mr. Don R. Goodwin,
(MD-13), Director, Emission Standards and Engineering Division, United
States Environmental Protection Agency, Research Triangle Park,
North Carolina 27711  [(919) 688-8146].  Requests for additional
information or for copies of reports (other than published literature)
cited in the background documents, and comments on the
                                  iii

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proposed standard should be forwarded to the same address.
B.  AUTHORITY FOR THE STANDARD
     National emission standards for hazardous air pollutants
are promulgated in accordance with section 112 of the Clean Air
Act (42 U.S.C. 1857c-7), as amended in 1970.  "Hazardous air pollutant"
is defined in the Act as "an air pollutant to which no ambient air
quality standard is applicable and which in the judgment of the
Administrator may cause, or contribute to, an increase in mortality
or an increase in serious irreversible, or incapacitating reversible,
illness."  Emission standards established under the authority of
section 112 are to be set at a level which in the Administrator's
judgment "provides an ample margin of safety to protect the public
health from such hazardous air pollutants."
     To set a standard under section 112 of the Act, a pollutant must
be listed in the FEDERAL REGISTER as a hazardous air pollutant.  Within
180 days of listing, the Administrator must propose a national emission
standard which, in his judgment, adequately protects public health.
Within 30 days of proposal of the standard, the Administrator must
give notice of a public hearing.  The Administrator can withdraw a
pollutant from the hazardous list only if he finds, on the basis of
information presented at the public hearing, that the pollutant
clearly is not hazardous.  Otherwise the Administrator must promulgate
a standard within 180 days of the proposal.  The Act does not require
that the Administrator consider available control technology or
economic impact in establishing the level of the standard.
                               IV

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However, EPA must, from time to time, issue information on control
technology.
C.  CONSIDERATION OF ENVIRONMENTAL IMPACTS
     Section 102(2)(c) of the National Environmental Policy Act (NEPA)
of 1969 (PI-91-190) requires Federal agencies to prepare detailed
environmental impact statements on proposals for legislation and other
major Federal actions significantly affecting the quality of the human
environment.  The objective of NEPA is to build into the decision-
making process of Federal agencies a careful consideration of all
environmental aspects of proposed actions.  The Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements,
According to section 7(c)(l), "No action taken under the Clean Air
Act shall be deemed a major Federal action significantly affecting the
quality of the human environment within the meaning of the National
Environmental Policy Act of 1969."
     EPA has concluded, however, that the preparation of environmental
impact statements could have beneficial effects on certain regulatory
actions.  Consequently, while not legally required to do so as a result
of section 102(2)(c) of NEPA,  EPA will prepare environmental impact
statements for various regulatory actions, including proposed actions
under section 112 of the Clean Air Act.  This voluntary preparation of
environmental impact statements, however, in no way legally subjects EPA
to NEPA requirements.

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     To implement this EPA policy decision, therefore, a separate
section is included in this document which is devoted solely to an
analysis of the potential environmental  impacts associated with
the proposed standard and alternative levels of control.  Both
adverse and beneficial impacts associated with the proposed standard
and alternatives in such areas as air and water pollution, increased
solid waste disposal and increased energy consumption are identified and
discussed.  Generally, standards proposed under section 112 will most
likely have beneficial impacts on ambient air quality and potential
adverse impacts in other areas.
D.  CONSIDERATION OF INFLATIONARY IMPACTS
     Executive Order 11821 (39 FR 41501, November 29, 1974) requires
all Executive agencies to issue inflation impact statements when
enacting major regulations or rules and when submitting proposals for
major legislation.  In accordance with the executive order, a separate
chapter is included in this document which describes in detail the
economic impact of the proposed standard for vinyl chloride and alternative
levels of control.  The economic analysis includes to the extent possible
the impact of other regulations on the industries which would be affected
by the proposed standard.  Figures are given for both the capital and
annual operating costs to the industries of installing and implementing
the necessary control equipment to meet the proposed standard and other
regulations.  The potential plant closures and price increases in
consumer goods which would occur as a result of these costs to the
industries are also estimated.
                                 VI

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  Draft Standard Support and Environmental Impact Statement

     Vinyl Chloride Emissions from Ethylene Dichloride-

        Vinyl Chloride and Polyvinyl Chloride Plants

               Type of Action:  Administrative
                         Prepared by
Director, Emissibn Standards and Engineering Division
Environmental Protection Agency
Research Triangle Park, N. C. 27711
                          pproved by
                 (Date)
Assistant Administrator
Office or Air and Waste Management
Environmental Protection Agency
401 M Street, S. W.
Washington, D. C. 20460

Draft Statement Submitted to Council on Environmental Quality

                             on
                 (Date)
                           (Date)

Additional copies may be obtained or reviewed at:
Emission Standards and Engineering Division
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, fl. C.  27711
Public Information Reference
 Unit
Environmental Protection Agency
Room 2922 (EPA Library)
401 M Street, S. W.
Washington, D. C.  20460
                                 VII

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                              TABLE OF CONTENTS


                                                                        Page


List of Tables	   xvii

List of Maps and Figures 	   XX1'V

Chapter 1.  Summary 	   1-1

    1.1  The Proposed Standard 	   1-1

    1.2  Environmental Impact 	   1-8

        1.2.1  Alternatives to the Proposed Action 	   1-8

        1.2.2  Summary of the Environmental Impacts
               of the Proposed Standard 	   1-23

        1.2.3  Relationship Between Local Short-Term Uses of flan's
               Environment and the Maintenance and Enhancement of
               Long-Term Productivity 	   1-31

        1.2.4  Irreversible and Irretrievable Commitments of Resources
               Which Would Be Involved if the Proposed Action
               Should Be Implemented 	  1-31

    1.3  Economic Impact 	  1-32

Chapter 2.  Rationale for Regulating Vinyl Chloride 	

    2.1  History 	  2-1

    2.2  Alternative Control Strategies Considered 	  2-2

        2.2.1  No Action or Delayed Standards 	  2-2

            2.2.1.1  Summary of Health Findings 	  2-2
                                     vm

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                                                                        Page
            2.2.1.2  Extent of Public Exposure to Vinyl
                     Chloride 	   2-4

            2.2.1.3  Other Regulations and Their Effect on
                     Vinyl Chloride Emissions 	   2-5

            2.2.1.4  Conclusions	   2-7

        2.2.2  Action Under Section 115 - Abatement Conferences 	   2-7

        2.2.3  Action Under Section 303 - Emergency Powers 	   2-8

        2.2.4  Standards Under Section 109 - National Ambient Air
               Quality Standards (NAAQS) 	   2-9

        2.2.5  Standards Under Section 111 - Standards of Performance
               for NevM Stationary Sources (SPNSS) 	   2-11

        2.2.6  Standards Under Section 112 - National Emission
               Standards for Hazardous Air Pollutants (NESHAP) 	   2-14

            2.2.6.1  Vinyl Chloride as a Hazardous Pollutant 	   2-15

    2.3  Setting an Emission Limit 	   2-18

        2.3.1  The Alternative of Prohibiting Vinyl Chloride
               Emissions 	   2-19

        2.3.2  The Alternative of Best Available Control Technology-.   2-25

    2.4  Selection of Source Categories 	   2-27

        2.4.1  Ethylene Dichloride - Vinyl Chloride Plants 	   2-27

        2.4.2  Polyvinyl Chloride Plants	   2-27

        2.4.3  Polyvinyl Chloride Fabricating Plants	   2-27

        2.4.4  Miscellaneous Sources of Vinyl Chloride 	   2-29

    2.5  Conclusions 	   2-31

    References  	   2-33

Chapter 3.  The Ethylene Dichloride - Vinyl Chloride and
            Polyvinyl Chloride Industries 	   3-1

    3.1  General 	   3-1
                                     IX

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                                                                        Page
    3.2  Description of the Process 	   3-3
        3.2.1  Ethylene Dichloride - Vinyl Chloride Production 	   3-3
            3.2.1.1  Acetylene - Hydrogen Chloride Process 	   3-3
            3.2.1.2  Ethylene Dichloride Process 	   3-5
        3.2.2  Polyvinyl Chloride Production 	   3-10
            3.2.2.1  Suspension Polymerization 	   3-11
            3.2.2.2  Dispersion (Emulsion) Polymerization 	   3.79
            3.2.2.3  Bulk Polymerization 	   3-19
            3.2.2.4  Solvent Polymerization 	   3-22
        3.2.3  Summary 	   3.24
    References 	   3-26
Chapter 4.  Control Technology 	   4_]
    4.1  Adsorption 	   4-3
        4.1.1  Carbon Adsorption 	   4-3
        4.1.2  Resin Adsorption 	   4-7
        References 	   4-9
    4.2  Incineration 	   4-10
        References	   4-15
    4.3  Solvent Absorption 	   4_16
        References	   4-20
    4.4  Refrigeration 	   4_2i
        References	   4-23
    4.5  Control of Fugitive Emissions 	   4-24
        References 	   4-29

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                                                                    Page
4.6  Relief Valve Discharge .....................................   4-30
    References ..................................................   4-31
4.7  Gasholder and Purge Water System  ...........................   4-32
    References ..................................................   4-37
4.8  Improved Stripping .........................................   4-38
    References ..................................................   4-45
4. 9  Reactor Openi ng Loss Control s  ..............................   4-46
     R eferences  .................................................   4-49
4.10  Emissions and Control Techniques for Inprocess
      Wastewater  ................................................   4-50
     References  .................................................   4-53
4.11  Parti cul ate Control .......................................   4-54
    4.11.1  Centrifugal Separators  Applied in the  Polyvinyl
            Chloride Industry ...................................   4"55
    4.11.2  Fabric Filters Applied to the Polyvinyl
            Chloride Industry ...................................   4-56
4.12  Data Demonstrating Capability of Selected
      Control Techniques ........................................   4~57
    4.12.1  Stripping ...........................................   4-57
    4.12.2  Carbon Adsorption ...................................   4-61
    4.12.3  Incineration ........................................   4-68
    4.12.4  Solvent Absorption ..................................   4-70
    4.12.5  Purge Water System ..................................   4-71
    4.12.6  Process Equipment Purge .............................   4-72
                                  XI

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                                                                        Page
        4.12.7  Oxychlorination Process Emissions  	   4-72
        4.12.8  Bulk Plant Purge	   4-72
        References 	   4.73
    4.13  Control Techniques Summary 	  4-74
Chapters.  Alternative Control Levels 	   5-1
    5.1  Ethylene Dichloride - Vinyl Chloride Plants  	  5-4
    5.2  Polyvinyl Chloride Plants  	  5-6
Chapter 6.  Environmental Impacts of the Alternative
            Control Levels 	  6-1
    6.1  Secondary Environmental Impacts of Individual
         Control Systems 	  6-2
    6.2  Primary and Secondary Environmental Impacts at
         Model Plants 	  6-8
        6.2.1  Primary Environmental Impacts 	  6-8
        6.2.2  Secondary Environmental Impacts 	  6-25
            6.2.2.1  Air Impact 	*	  6-26
            6.2.2.2  Water Impact	  6-40
            6.2.2.3  Solid Waste	  6-51
            6.2.2.4  Noise and Radiation 	  6-52
            6.2.2.5  Energy Considerations 	  6-52
    References 	  6-61
Chapter 7.  Economic Impact Analysis 	  7-1
    7.1  Industry Economic Profile  	  7-1
        7.1.1  Ethylene Dichloride  	  7-1
        7.1.2  Vinyl  Chloride 	  7-1
                                       xii

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                                                                    Page
    7.1.3  Polyvinyl Chloride 	   7-2
    7.1.4  Vertical Integration and Industry Concentration 	   7-2
    7.1.5  Polymerization of Polyvinyl Chloride
           Resins by Process 	   7-3
    7.1.6  Polyvinyl Chloride Consumption by End Use 	   7-3
    7.1.7  Polyvinyl Chloride Substitutes 	   7-4
    7.1.8  Industry Employment 	   7-5
    7.1.9  Increases in Industry Capacity 	   7-5
    7.1.10  Product Price Histories 	   7-6
7.2  Cost Analysis of Alternative Emission
     Control  Systems 	   7-8
    7.2.1  Introduction 	   7-8
    7.2.2  Cost of Alternative Control Measures 	   7-10
        7.2.2.1  Ethylene Dichloride - Vinyl Chloride
                 Model PI ant 	   7-10
        7.2.2.2  Suspension Polyvinyl Chloride Model Plant 	   7-12
        7.2.2.3  Dispersion Polyvinyl Chloride Model Plant 	   7-15
        7.2.2.4  Bulk Polyvinyl Chloride Model Plant 	   7-16
    7.2.3  Cost-Effectiveness of Vinyl Chloride Controls 	   7-17
7.3  Economic Impact Analysis of Alternative Control
     Systems 	   7-18
    7.3.1  Introduction 	   7-18
    7.3.2  Discussion 	   7-19
    7.3.3  Ethylene Dichloride - Vinyl Chloride Plants - Existing
           PI ant Economi c Impact Analysi s 	   7-22
        7.3.3.1  Existing Ethylene Dichloride Plants 	   7-22
                                  xm

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                                                                        Page
            7.3.3.2  Existing Vinyl Chloride Plants 	   7-28
        7.3.4  Ethylene Dichloride - Vinyl Chloride Plants - New
               Plant Economic Impact Analysis 	   7-35
        7.3.5  Polyvinyl Chloride Plants - Existing Plant
               Economic Impact Analysis 	   7-38
            7.3.5.1  Introduction 	   7-38
            7.3.5.2  Control Scenario #1 	   7-38
            7.3.5.3  Control Scenario #2	   7-42
            7.3.5.4  Control Scenario #3	   7-43
            7.3.5.5  Control Scenario #4	   7-45
        7.3.6  Polyvinyl Chloride Plants - New Plant
               Economic Impact Analysis 	   7-47
            7.3.6.1  Introduction 	   7-47
            7.3.6.2  New Suspension Process Plants 	   7-47
            7.3.6.3  New Dispersion Process Plants 	   7-50
            7.3.6,4  New Bulk Process Plants 	   7-53
        7.3.7  Summary 	   7-54
            7.3.7.1  Ethylene Dichloride - Vinyl
                     Chloride Plants 	   7-54
            7.3.7.2  Polyvinyl Chloride Plants	   7-57
    References 	   7-65
Chapter 8.  Rationale for the Proposed Standard 	   8-1
    8.1  Selection of Emission Sources to be Covered by
         the Proposed Standard 	   8-1
    8.2  Rationale for the Emission Limits 	   8-3
        8.2.1  Oxychlorination Reactor at Ethylene Dichloride -
               Vinyl Chloride Plants 	   8-5
                                     xiv

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                                                                        Page
        8.2.2  Sources Following the Stripper in Dispersion Resin
               Manufacture at Polyvinyl Chloride Plants 	   8-9

        8.2.3  Other Stack Emission Sources	   8-14

        8.2.4  Fugitive Emission Sources 	   8-22

    8.3  Selection of the Format of the Proposed Standard 	   8-32

    8.4  Methods for Determining Compliance With the
         Proposed Standard 	   8-40

        8.4.1  Emission Tests 	   8-40

        8.4.2  Reporting 	   8-41

        8.4.3  Recordkeeping 	   8-45

        8.4.4  Other Methods for Determining Compliance 	   8-45

    8.5  Evaluation of Need to Set Standards for Polyvinyl
         Chi ori de Parti cul ate 	   8^-46

        8.5.1  Polyvinyl Chloride Particulate as a Source of
               Vinyl Chloride Emissions 	   8-46

        8.5.2  Need to Set a Standard for Polyvinyl
               Chloride Particulate 	   8-49

    References  	,	   8-51

Chapter 9.  Other Regulatory Requirements Developed or Being
            Developed for Vinyl  Chloride and Their Relationship to
            the Proposed Standard for Vinyl Chloride 	   9-1

    9.1  Occupational Safety and Health Administration 	   9-1

        9.1.1  The Emergency Temporary Standard 	   9-1

        9.1.2  The Proposed Permanent Standard 	   9-1

        9.1.3  The Promulgated Permanent Standard  	   9-2

        9.1.4  Amendments and Corrections to the
               October 4, 1974 Regulation 	   9-3

        9.1.5  Relationship of the Proposed EPA Standard and
               the OSHA Regulation 	   9-4
                                     xv

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                                                                         Page
    9.2  Environmental Protection Agency  	    9-6
        9.2.1  Water Regulations	    9-6
        9.2.2  Pesticide Regulation  	    9-7
    9.3  Department of Transportation  	    9-7
    9.4  Department of Health, Education, and Welfare  	    9-8
        9.4.1  Food Packages  	    9-8
        9.4.2  Aerosol Products  	    9-9
    9.5  Consumer Product Safety  Commission  	    9-9
    9.6  State Regulations  	    9-10
Appendix A.  Evoluation of the Proposed Standard  	    A-l
Appendix B.  Index to Environmental  Impact Considerations  	    B-l
Appendix C.  Emission Source Test Data 	    C-l
Appendix D.  Emission Monitoring and Compliance Testing
             Techniques and Costs 	    D-l
Abstract and Technical Report Data	    E-l
                                    xvi

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                              LIST OF TABLES

                                                                        Paqe
1-1   Emission Standard  for Ethylene Bichloride - Vinyl
      Chloride Plants 	  1-9

1-2   Emission Standard  for Polyvinyl Chloride Plants 	  1-11

1-3   Matrix of Environmental and Economic Impacts of Alternatives
      for Regulating Vinyl Chloride Emissions from
      Ethylene Dichloride - Vinyl Chloride Plants 	  1-16

1-4   Matrix of Environmental and Economic Impacts of Alternatives
      for Regulating Vinyl Chloride Emissions from Polyvinyl
      Chloride Plants 	  1-17

2-1   Estimated Vinyl Chloride Emissions in the U. S. - 1974 	  2-28

3-1   Producing Companies, Plant Locations, and Capacities -
      Ethylene Dichloride 	  3-28

3-2   Producing Companies, Plant Locations, and Capacities -
      Vinyl Chloride 	  3-30

3-3   Producing Companies, Plant Locations, and Capacities -
      PVC Resins 	  3-32

3-4   PVC Producers by Process 	  3-35

3-5   Vinyl Chloride Emissions for Ethylene Dichloride-Vinyl Chloride
      Producti on 	  3-37
3-6   Vinyl Chloride Emissions for Suspension Polyvinyl
      Chioride Process 	  3-38

3-7   Vinyl Chloride Emissions for Dispersion Polyvinyl
      Chloride Process	 3-39

3-8   Vinyl Chloride Emissions for Bulk Polyvinyl Chloride
      Polymeri zati on 	 3-40

3-9   Vinyl Chloride Emissions for Solvent Polyvinyl Chloride
      Polymeri zati on 	 3-41
                                      xvn

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3-10   Summary of Fugitive Emissions 	   3-42
3-11   Vinyl Chloride Monomer Content in Streams
       Discharging to Sewer 	   3-44
4-1    Source Description for Typical Polyvinyl
       Chloride Plant 	   4-77
4-2    Source Description for Typical Ethyl2110 Die? lorido-Vinyl
       Chloride Plant 	   4-79
4-3    Control Techniques Applicable to Polyvinyl
       Chloride Plants 	'.	   4-80
4-4    Control Techniques Applicable to  Ethylena Dichlon'de-Vinyl
       Chloride Plants 	   4-83
4-5    April 1975 Status of Dispersion Resin Stripping
       with Projection of Future Capabilities  	   4-84
4-6    April 1975 Status of Suspension Resin Stripping 	   4-85
4-7    Adsorption of Recovered Vinyl Chloride Monomer
       on Activated Carbon 	   4-86
4-8    Kilograms Per Year of VCM Emitted during  Equipmpnt
       Purge for Typical 316 MM kg/yr (700 MM  Ib/yr) EDC-VCM Plant •••   4-87
4-9    Kilograms Per Year of VCM Emitted During  Equipment
       Purge from Typical 68 MM kg/yr (150 MM  Ib/yr) PVC Plant 	   4-88
4-10   Oxychlorination Process Vent Description  	   4-89
4-11   Polyvinyl Chloride Particulate Emission Factors 	   4-90
6-1    Secondary Environmental Impacts of Individual
       Control Systerns 	   6-3
6-2    Vinyl Chloride Mass Emission Reduction  	   6-9
6-3    Reductions in Vinyl Chloride Ambient Concentrations -
        Estimated by Diffusion Modeling - 5-Minnte Maxima 	   6-13
6-4    Reductions in Vinyl Chloride Ambient Concentrations -
       Estimated by Diffusion Modeling - 24-Hour Average Maxima 	   6-14
                                    xvi

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                                                                        Paqe
6-5    Reductions in Vinyl Chloride Ambient Concentrations -
       Estimated by Diffusion Modeling - Annual Average Maxima 	  6-15

6-6    Vinyl Chloride Ambient Concentrations - Cluster of Four
       Ethylene Dichloride - Vinyl Chloride and Polyvinyl Chloride
       Plants - 5-Minute, 24-Hour and Annual Average Maxima -
       Unregulated and Regulated 	  6-18

6-7    Emission Factors for Hydrogen Chloride Resulting From
       Incineration of Emission Points in Ethylene Bichloride -
       Vinyl Chloride (EDC-VCM) and Polyvinyl Chloride (PVC) Plants  ..  6-29

6-8    Hydrogen Chloride Mass Emissions from Model Ethylene
       Dichloride - Vinyl Chloride Plants Using Incineration to
       Attain the Alternative Control Levels 	  6-30

6-9    Hydrogen Chloride Mass Emissions from Model Polyvinyl
       Chloride Plants Using Incineration to Control a Maximum
       Number of Emission Points 	  6-31

6-10   Hydrogen Chloride Ambient Concentrations From Incineration
       of Vinyl Chloride Emissions at Ethylene Dichloride - Vinyl
       Chloride Plants - Estimated by Diffusion Modeling 	  6-34

6-11   Hydrogen Chloride Ambient Concentrations From Incineration
       of Vinyl Chloride Emissions at Polyvinyl Chloride Plants -
       Estimated by Diffusion Modeling 	  6-35

6-12   Increased Water Consumption by Model Ethylene Dichloride -
       Vinyl Chloride Plants Using an Incinerator-Scrubber to
       Attain the Alternative Control Levels 	  6-41

6-13   Increased Water Consumption by Model Polyvinyl Chloride Plants
       Using Various Control Systems to Attain the Proposed Standard/
       Alternative II (Dispersion Plants) 	  6-42

6-14   Quantities of Vinyl Chloride Released Into the Plant Inprocess
       Wastewater by Control Systems Which Can Be Used to Meet the
       Proposed Standard/Alternative II (Dispersion Plants) 	  6-44

6-15   Information on Water Effluent From Incinerator-Scrubber
       Systems At Model Ethylene Dichloride - Vinyl Chloride Plants
       Attaining the Alternative Control Levels 	  6-47
                                     xix

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6-16   Information on Water Effluent from Incinerator-Scrubber
       Systems at Model Polyvinyl Chloride Plants Controlling a
       Maximum Number of Emission Points With Incineration 	   6-48

6-17   Increased Energy Consumption - Ethylene Dichloride - Vinyl
       Chloride Plant [318 MM kg VCM/YR (700 MM Ib VCM/YR)]
       Attaining the Alternative Control Levels 	   6-53

6-18   Increased Energy Consumption - Dispersion Polyvinyl
       Chloride Plant [14 MM kg/yr (30 MM lb/yr)] 	   6-54

6-19   Increased Energy Consumption - Suspension Polyvinyl Chloride
       Plant [68 MM kg/yr (150 MM lb/yr)J Meeting the
       Proposed Standard 	   6-56

6-20   Increased Energy Consumption - Bulk Polyvinyl Chloride Plant
       [45 MM kg/yr (100 MM lb/yr)] Meeting the Proposed Standard ..   6-57


6-21   Comparison of Energy Consumption by Model Plants With
       and Wi thout Controls 	   6-58

7-1    Vertical Integration in the EDC/VCM/PVC Industry 	   7-66

7-2    1974 PVC Consumption by End-Use Category 	   7-68

7-3    Possible PVC Substitutes 	   7-69

7-4    Announced PVC Capacity Expansions and Closures 	   7-71

7-5    Prices of Ethylene Dichloride, Vinyl Chloride, and
       Polyvinyl Chloride 	   7-72

7-6    Summary of Algorithms Used For Computing Model Plant
       Costs and Credits 	   7-73

7-7    Control Costs for Model Balanced EDC-VCM Plant 	   7-78

7-8    Control Costs For Model PVC Suspension Plants 	   7-79

7-9    Control Costs For Model PVC Dispersion Plants 	   7-81

7-10   Control Costs For Model PVC Bulk Plants 	   7-83

7-11   Summary of Fugitive Emission Control Costs For Balanced
       Ethylene Dichloride - Vinyl Chloride Model Plant 	   7-84
                                     xx

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                                                                        Page

7-12   Summary of Fugitive Emission Control Costs for Suspension
       Polyvinyl Chloride Model Plant 	   7-86

7-13   Summary of Fugitive Emission Control Costs for Dispersion
       Pol vinyl Chloride Model Plant 	   7-88

7-14   Summary of Fugitive Emission Control Costs For Bulk Polyvinyl
       Chloride Model Plant	   7-90

7-15   Cost-Effectiveness of Alternative Vinyl Chloride Control
       Methods 	   7-92

7-16   EPA Water Effluent Regulations - Compliance Costs for EDC,
       VCM, and PVC Plants to Meet the 1983 (Best Available
       Technology) Requirements 	   7-94

7-17   Existing EDC Plants - Capital Summary, Alternative I
       or Alternative II 	   7-95

7-18   Existing EDC Plants - Annualized Cost Summary,
       Alternative I or Alternative II 	   7-96

7-19   Existing EDC Plant Profitability Calculations and
       Assumptions (Before Control) 	   7-97

7-20   Existing EDC Plants - Profitability Summary, Alternative I
       or Alternative II 	   7-98

7-21   Existing EDC Plants - Capital Summary, Alternative III	   7-99

7-22   Existing EDC Plants - Annualized Cost Summary,
       Alternative III 	   7-100

7-23   Existing EDC Plants - Profitability Summary,
       Alternative III 	   7-101

7-24   Existing VCM Plants - Capital Summary, Alternative I 	   7-102

7-25   Existing VCM Plants - Annualized Cost Summary,
       Alternative I 	  7-103

7-26   Existing VCM Plants - Profitability Summary,
       Al ternati ve I 	  7-104

7-27   Existing VCM Plants - Capital Summary, Alternative II 	  7-105
                                    xxi

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                                                                        Page

7-28   Existing VCM Plants - Annualized Cost Summary,
       Alternative II 	   7-106

7-29   Existing VCM Plants - Profitability Summary,
       Alternative II 	   7-107

7-30   Existing VCM Plants - Capital  Summary,
       Alternative III 	   7-108

7-31   Existing VCM Plants - Annualized Cost Summary,
       Alternative III 	   7-109

7-32   Existing VCM Plants - Profitability Summary,
       Alternative III 	   7-110

7-33   Financial Impact of Alternative-  Control  Levels on
       New EDC-VCM Plants 	   7-111

7-34   Existing PVC Plants - Capital  Summary,
       Control Scenario #1 	   7-112

7-35   Existing PVC Plants - Annualized Cost Summary,
       Control Scenario #1 	   7-114

7-36   Existing PVC Plants - Profitability Summary,
       Control Scenario #1 	   7-116

7-37   Existing PVC Plants - Capital  Summary,
       Control Scenario #2 	   7-118

7-38   Existing PVC Plants - Annualized Cost Summary,
       Control Scenario #2 	   7-120

7-39   Existing PVC Plants - Profitability Summary,
       Control Scenario #2 	   7-122

7-40   Existing PVC Plants - Capital  Summary,
       Control Scenario #3 	   7-124

7-41   Existing PVC Plants - Annualized Cost Summary,
       Control Scenario #3 	   7-126

7-42   Existing PVC Plants - Profitability Summary,
       Control Scenario #3 	   7-128
                                     xxi i

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                                                                        Page

7-43   Existing PVC Plants - Capital Summary,
       Control Scenario #4 	   7-130

7-44   Existing PVC Plants - Annualized Cost Summary,
       Control Scenario #4 	'	   7-132

7-45   Existing PVC Plants - Profitability Summary,
       Control Scenario #4 	   7-134

7-46   Financial Impact of Various Control Systems at New
       Suspension Process PVC Plants 	   7-136

7-47   Financial Impact of Various Control Systems at New Dispersion
       Process PVC PI ants 	   7-138

7-48   Effect of Economies of Scale on New Dispersion Process
       PVC Plants 	   7-139

7-49   Financial Impact of Various Control Systems at New Bulk
       Process PVC Plants 	   7-140

8-1    Alternative Control Levels for a Typical  [318 Million
       Kilograms (700  Million Pounds) a Year] Ethylene Dichloride -
       Vinyl Chloride  Plant 	   8-6

8-2    Alternative Control Levels for a Typical  14 Million
       Kilograms (30 Million Pounds) a Year PVC Dispersion Plant 	   8-11
                                    xxm

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                          LIST OF MAPS AND FIGURES
                                                                        Page
Figure 3-1  Acetylene Process For Vinyl Chloride Production              3-4
Figure 3-2  Vinyl Chloride by the Balanced Process                       3-6
Figure 3-3  Dichloroethane Cracking Process for Vinyl
            Chloride Production                                          3-7
Figure 3-4  The Oxychlorination Process                                  3-8
Figure 3-5  Polyvinyl Chloride Plant - Suspension Process                3-12
Figure 3-6  Polyvinyl Chloride Plant - Dispersion Process                3-20
Figure 3-7  Polyvinyl Chloride Plant - Bulk Process                      3-21
Figure 3-8  Polyvinyl Chloride Plant - Solvent Process                   3-23
Map 3-1     Ethylene Dichloride Plant Locations                          3-29
Map 3-2     VCM Plant Locations                                          3-31
Map 3-3     PVC Plant Locations                                          3-34
Figure 4-1  Countercurrent Stripping Column                              4-43
Figure 4-2  American Chemical Incinerator Test                           4-69
Figure 6-1  Map of Four Plant Cluster  -  Case A                           6-19
Figure 6-2  Map of Four Plant Cluster  -  Case B                           6-19
                                     xxiv

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1.   SUMMARY
     1.1  The Proposed Standard
     A national emission standard for vinyl  chloride emissions
from ethylene dichloride-vinyl chloride and polyvinyl chloride
plants is being proposed under the authority of section 112 of the
Clean Air Act.  Section 112 is intended for the regulation of
hazardous air pollutants.  "Hazardous air pollutant" is defined
in section 112 as "an air pollutant to which no ambient air quality
standard is applicable and which in the judgment of the Administrator
may cause, or contribute to, an increase in mortality or an increase
in serious irreversible, or incapacitating reversible, illness."
     Vinyl chloride has been implicated as the causal agent of
angiosarcoma (a rare form of liver cancer),  other cancers, and
serious noncarcinogenic disorders in people with occupational
exposure and in animals with experimental exposure to vinyl chloride.
Reasonable extrapolations from these findings cause concern that
vinyl chloride may cause or contribute to the same or similar
disorders at present ambient air levels.  Therefore, vinyl chloride
meets the specifications of a "hazardous air pollutant" as defined
in the Clean Air Act.
     Section 112 requires that emission standards be established
at a level which provides an ample margin of safety to protect public
health.  As applied to threshold pollutants, this requires that emission
standards be established below the threshold level of effects.  This
cannot be done for vinyl chloride because no dose-response data are
                               1-1

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available for the concentrations of vinyl chloride found in the ambient
air.  Moreover, for carcinogens there may be no atmospheric concen-
tration which poses absolutely no public health risk.  Therefore, the
purpose of the proposed standard is to minimize vinyl chloride emissions
from ethylene dichloride-vinyl chloride and polyvinyl chloride plants to
the level attainable with best available control technology. This would
have the effect of furthering the protection of public health by minimizing
the health risks to the people living in the vicinity of these plants
and to any additional people who are exposed as a result of new construction.
     The stationary source categories of vinyl chloride emissions
include 41 polyvinyl chloride plants which are responsible for
approximately 85 percent of the total nationwide emissions, 17 ethylene
dichloride-vinyl chloride plants which are responsible for approximately
11 percent of the total emissions and approximately 8000 fabricating
plants and several miscellaneous sources which are responsible for the
remaining emissions.  The proposed standard is applicable to only
ethylene dichloride-vinyl chloride and polyvinyl chloride plants
which are the largest sources of emissions.  (It should be noted that
throughout this document the term "ethylene dichloride-vinyl chloride
plants" is used.  This is because ethylene dichloride and vinyl chloride
are typically produced at the same plant location.  However, this
is not necessarily the case.  The proposed standard applies to plants
which produce ethylene dichloride or vinyl chloride as well as to
plants which produce both).  Standards for the fabricating plants are

                               1-2

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not being proposed at this time because available ambient monitoring
data indicate that vinyl chloride concentrations in the vicinity of
these plants are negligible.  Also, vinyl chloride emissions from these
plants will be minimized indirectly as polyvinyl chloride plants reduce
the residual vinyl chloride in the raw materials going to the fabri-
cating plants in response to the proposed standard and OSHA's standard
for vinyl chloride which was promulgated October 4, 1974.  A decision on
whether standards for the miscellaneous sources will be proposed will be
made after on-going studies on them are completed.
     The proposed standard for ethylene dichloride-vinyl chloride
and polyvinyl chloride plants would impact primarily on southeastern
Texas, southern Louisiana, and the Northeastern States, where most of
the plants are located.   Fourteen of the 17 ethylene dichloride-vinyl
chloride plants are located in southeastern Texas and southern Louisiana.
Other States in which ethylene dichloride-vinyl chloride or polyvinyl
chloride plants are located include Kentucky, California, Illinois,
Massachusetts, Mississippi, Oklahoma, Delaware, Maryland, Pennsylvania,
Ohio, New Jersey, New York, West Virginia, Georgia, and Michigan.
There is also an ethylene dichloride-vinyl chloride plant in Puerto
Rico.  Additional States may be affected by the proposed standard as new
plants are constructed.   The proposed standard is a national emission
standard which will be enforced by the Federal EPA and by States which
request and are delegated the authority to enforce the standard.
     In order to minimize vinyl chloride emissions to the atmosphere,
the proposed standard covers all known point and fugitive emission
                               1-3

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sources in both ethylene dichloride-vinyl  chloride and polyvinyl
chloride plants.  The point sources in ethylene dichloride-vinyl
chloride plants include ethylene dichloride purification, vinyl
chloride formation and purification, and the oxychlorination reactor.
The point sources in polyvinyl  chloride plants include reactors;
strippers; mixing, weighing and holding containers; monomer recovery
systems; slurry blend tanks; centrifuges;  concentrators; dryers; baggers;
and storage silos.  Fugitive emission sources in both kinds of plants
include loading (or unloading)  vinyl chloride from storage vessels
into transfer equipment, slip gauges, leakage from equipment
(including pump, compressor, and agitator seals and relief valves),
opening of equipment for cleaning and maintenance, manual venting of
gases to reduce pressure in equipment, obtaining samples of vinyl
chloride product, and inprocess wastewater.  Relief discharges from
equipment in both ethylene dichloride-vinyl chloride and polyvinyl
chloride plants cause short-term peak emissions.
     The proposed standard would reduce emissions from a typical
ethylene dichloride-vinyl chloride plant by  approximately 94 percent
and from a typical polyvinyl chloride plant by approximately 95 percent.
(These emission reductions are based on emission levels which were
reported to exist in the spring of 1974.  The reductions in fugitive
emissions as a result of the proposed standard cannot be quantified,
but are included in these percentages based on best judgment.)  The
                              1-4

-------
emission limitations included in the proposed standard for ethylene
dichloride-vinyl chloride and polyvinyl chloride plants are summarized
in the following paragraphs.
Ethylene Pi chloride-Vinyl Chloride Plants
     The proposed standard would apply to any plant where ethylene
dichloride is produced by reaction of oxygen and hydrogen chloride
with ethylene.  It would also apply to any plant where vinyl chloride
is made by one or more processes including, but not limited to, the
addition of hydrogen chloride to acetylene and dehydrochlorination of
ethylene dichloride.  Ethylene dichloride and vinyl chloride are
typically produced at the same plant location, although this is not
necessarily the case.  The individual emission points in ethylene
dichloride-vinyl chloride plants would be regulated as follows:
     1.  Emissions from equipment used in the purification process for
ethylene dichloride and in the formation and purification processes
for vinyl chloride would be reduced to 10 ppm by volume.  This
can be accomplished by add-on control devices, such as an incinerator.
     2.  Emissions from the oxychlorination reactor would be
reduced to 0.02 kg/100 kg ethylene dichloride product from the
oxychlorination process.  This can be accomplished by controlling
process parameters or by add-on control devices, such as an
incinerator.
     3.  Preventable relief valve discharges would not be permitted.

                                1-5

-------
     4.  Fugitive emissions would be minimized primarily by
equipment and procedural specifications requiring enclosure of
the emission sources and capture of the emissions.  For example, before
opening equipment to the atmosphere, vinyl chloride contained in the
equipment would have to be removed and transferred to a recovery
system or a control device.  Leakage from pump seals would be prevented
by installing pumps with no seals or with double mechanical seals.
A formal program would be instituted and implemented for leak detection
and elimination.  Vinyl chloride emissions from the more highly
concentrated inprocess wastewater streams would be reduced by
removing the vinyl chloride from the water before the water is
exposed to the atmosphere; the vinyl chloride removed would be
collected and ducted to a recovery system or control device.
Polyvinyl Chloride Plants
     The proposed standard would apply to any plant which polymerizes
vinyl chloride.  Production of homopolymers, copolymers, terpolymers,
or other polymers containing any fraction of polymerized vinyl chloride
would be covered.  The standard would be applicable to all manufacturing
processes, including suspension, dispersion, emulsion, latex, bulk,
and any other processes developed in the future.  The individual
emission points in polyvinyl chloride plants would be regulated as
follows:
     1.  Emissions from major process equipment preceding and
including the stripping operation in the flow of materials through the
plant (e.g. reactors, strippers, and monomer recovery systems) would
                               1-6

-------
be reduced to 10 ppm by volume.  This can be accomplished by add-on
control devices, such as carbon adsorption.
     2.  Emissions from major process equipment following the
stripping operation in the flow of materials through the plant
(e.g. slurry blend tanks, centrifuges, dryers and storage silos)
would be reduced by removing the residual vinyl chloride from
the polyvinyl chloride resin during the stripping operation
before the polyvinyl chloride resin is processed in equipment
following the stripper.  Dispersion resins would contain no more than
2000 ppm residual vinyl chloride as they completed the stripping
operation and all other resins would contain no more than 400 ppm
residual vinyl chloride.  Add-on control devices, such as
incinerators, could also be employed to attain comparable emission
levels.
     3.  Emissions from opening of reactors would be reduced to
0.001 kg/100 kg of reactor product.  Except for postpolymerization
reactors in the manufacture of bulk resins, one way in which this
can be accomplished is by using water to displace the vinyl
chloride in the reactor to a recovery system before opening the reactor
and reducing the number of reactor openings by solvent cleaning.
For postpolymerization reactors in the manufacture of bulk resins,
the proposed standard could be attained by evacuating the reactor
several times and breaking the vacuum with nitrogen.  The number of
evacuations would depend on the volume of gas in the reactor and
the vacuum involved.
     4.  Preventable relief discharges would not be permitted.
For example, relief discharges from reactors can be prevented by
                                1-7

-------
several measures, including injecting chemicals to stop the
polymerization reaction, instrumentation of the reactor to
detect upset condition, or venting the contents of the reactor to
a gasholder and ultimately to a monomer recovery system.
     5.  As in ethylene dichloride-vinyl chloride plants, fugitive
emissions would be minimized primarily by equipment and procedural
specifications requiring enclosure of the emission sources and
capture of the emissions. A formal program would be instituted and
implemented for leak detection and elimination.  Vinyl chloride
emissions from the more highly concentrated inprocess wastewater
streams would be reduced by removing the vinyl chloride from the
water before the water is exposed to the atmosphere; the vinyl chloride
removed would be collected and ducted to a recovery system or control
device.
     A more detailed summary of the proposed emission limits and
testing, reporting, and recordkeeping requirements for ethylene
dichloride-vinyl chloride and polyvinyl chloride plants can be
found in Tables 1-1 and 1-2, respectively.
     1.2  Environmental Impact
     1.2.1  Alternatives to the Proposed Action
     Several different sets of alternatives were considered in
developing the proposed standard for vinyl chloride.  These different
sets of alternatives are listed as follows:
     A.  Alternative regulatory strategies
     The first step in evaluating the vinyl chloride problem
was to determine whether standards for atmospheric emissions of vinyl
                             1-8

-------
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chloride are needed, and if so, which section of the Clean Air
Act should be used to regulate the emissions.  Therefore, the
following alternatives were considered:
     1.  No proposal of standards.
     2.  Delay proposal of standards until more data are available.
     3.  Section 115 of the Clean Air Act (Abatement Conferences).
     4,  Section 303 of the Clean Air Act (Emergency Powers).
     5.  Section 109 of the Clean Air Act (National Ambient Air
Quality Standards for Vinyl Chloride).
     6.  Section 109 of the Clean Air Act (National Ambient Air
Quality Standards for Non-Methane Hydrocarbons).
     7.  Section 111 of the Clean Air Act (Standards of Performance
for New Sources).
     8.  Section 112 of the Clean Air Act (National Emission
Standards for Hazardous Air Pollutants).
     After a thorough evaluation of the above alternatives, EPA
concluded that a standard is needed for vinyl chloride now and
that it should be developed under the authority of section 112 of
the Act.  Since a standard for vinyl chloride could not be based on a
threshold level of effects, consideration was given to the following
alternative regulatory strategies under section 112.
     1.  Prohibit all emissions from the manufacture and processing
of vinyl chloride.
     2.  Minimize emissions by setting a standard which would
require emission reduction to the lowest level achievable by use of best
available control technology.
                                1-13

-------
     A decision also had to be made regarding which source
categories of vinyl chloride emissions should be regulated.  The
source categories considered include:
     1.   Ethylene dichloride-vinyl  chloride plants
     2.   Polyvinyl chloride plants
     3.   Polyvinyl chloride fabricating plants
     4.   Miscellaneous sources
     The alternative regulatory strategy selected is to propose a
standard based on the application of best available control technology.
The source categories selected for regulation at this time are ethylene
dichloride-vinyl chloride and polyvinyl chloride plants.  The rationale
for selecting this regulatory strategy and a discussion of the alternative
strategies considered are contained in Chapter 2.
     B.   Alternative control levels
     Once EPA decided that the standard for vinyl chloride would be
based on the application of best available control technology, a second
set of alternatives was examined.  This second set of alternatives
concerned the level of control which should be required.   In Chapter 4
are discussed the alternative control  systems which are available for
application to the vinyl chloride industries.  In Chapter  5 are outlined
alternative levels of control which can be achieved with the control
systems described in Chapter 4.  These alternative control levels
include:
     1.   The proposed standard
     2.   A more stringent standard
                               1-14

-------
     3.  A less stringent standard
     The environmental impacts of these alternative control  levels are
discussed in Chapter 6 and the economic and socioeconomic impacts
of these alternatives are discussed in Chapter 7.
     Other alternatives were considered, such as for the units of the
proposed standard and the methods for determining  compliance with
the proposed standard.  These alternatives are discussed in  Chapter 8.
     The matrices in Tables 1-3 and 1-4 summarize  the environmental,
health, economic, and social impacts of the proposed standard and
alternative control levels.  Some of the alternative regulatory
strategies, such as setting no standards and prohibiting all emissions,
are also presented in the matrix.  Although health impacts are not
specifically listed, they can be assumed to be directly related to the
primary air impacts.  The +'s and -'s in the squares indicate whether
the impacts are positive or negative and the numbers beside  the +'s
and -'s represent a subjective estimate of the degree of the positive or
negative impact on a scale of 1 to 5.  The point-of-reference is the
current situation, with no standard in effect.
     The impacts for the proposed standard and alternative actions
for ethylene dichloride-vinyl chloride plants are  summarized in
Table 1-3.  Basically, the alternative control levels for ethylene
dichloride-vinyl chloride plants differ only in the level of control
required for one of several emission points in a typical plant (the
oxychlorination reactor).  The oxychlorination reactor was selected
to present alternatives for because it is a relatively small emission source
in the average plant and relatively large quantities of energy would be
                               1-15

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necessitated if the emissions from it were required to be controlled
with incineration, the most effective current method of control which could be
applied to it.   The alternative labeled in the matrix as "a more stringent
standard" would require a level of control equivalent to incineration of
the emissions from the oxychlorination reactor.   The alternative labeled
as "a less stringent standard" represents no control of the emissions
from the oxychlorination reactor.   The proposed standard represents
a level of control in-between, which can be attained by control of
process variables.
     The less stringent standard would result in only a 90 percent
emission reduction from the entire plant, compared with a 94 percent
emission reduction with the proposed standard and a 97 percent emission
reduction with the more stringent standard.  The greater reduction in
vinyl chloride emissions achievable with the more stringent standard
would also result in greater secondary impacts.   Incineration of the
emissions from the oxychlorination reactor and control of emissions from
the incinerator with a scrubber would result in more water consumption,
greater emissions of hydrogen chloride to the air and water, and minute
amounts of additional vinyl chloride released into the inprocess waste-
water.  One of the more significant secondary impacts of the more
stringent standard would be the increase in energy consumption required
for combustion.  The more stringent standard would result in a 7 percent
increase in energy consumption at an average plant.  The proposed
standard would require less than a 1 percent increase.  The negative
economic and social (inflation) impacts assigned to the more stringent
standard are slightly higher than those assigned to the proposed and
                          1-18

-------
less stringent standards, because the increased cost of the control
equipment to achieve the more stringent standard would add somewhat to
the increased price of polyvinyl chloride products to the consumer.  The
secondary impacts of the proposed standard and the less stringent
standard are essentially the same, because they do not require combustion
of emissions from the oxychlorination reactor at a typical plant.  There
is one plant which may have to use incineration for the oxychlorination
reactor to attain the level of the proposed standard.  This plant would
then incur the impacts indicated for the more stringent standard.
     The alternative control levels for polyvinyl chloride plants also
differ only in the degree of control required for one of several
emission points, i.e., emissions from sources following the stripper.
The alternatives apply to the manufacture of only one type of polyvinyl
chloride resin (dispersion resin), which constitutes 13 percent of the
total polyvinyl chloride production.  This emission point in the manu-
facture of dispersion resin was selected as the one to present altern-
atives for because it can be controlled in two ways:  (1)  installation
of control devices such as incinerators or (2) stripping the vinyl
chloride from the polyvinyl chloride resin before the resin is processed.
Under proper conditions, stripping can achieve the same degree of
emission reduction as add-on control devices and is much less energy
consuming.  For several reasons explained in more detail in Chapters 4,
5, and 8, the technology for stripping has not been developed to the
same extent for dispersion resins as for other resins.  There are
three alternative control levels for polyvinyl chloride dispersion
plants.  The less stringent standard represents essentially no
                               1-19

-------
control of the sources following the stripper.   The proposed standard
represents a level of control which is judged to be generally available
within the maximum time allowed for compliance under section 112 of the
Act.  This level of control has been achieved by one plant for all resin
grades and two plants for some resin grades.   It can be achieved by all
plants with the more energy-consuming add-on control technology.  The
more stringent standard represents the degree of stripping which is
required for other polyvinyl chloride resins.
     In regard to primary impact, the less stringent standard would
achieve only a 52 percent reduction in emissions compared with a
95 percent emission reduction with the proposed standard and a 97
percent emission reduction with the more stringent standard.  There
are no significant secondary environmental impacts indicated for
the three levels of control.  A small economic impact is indicated
for the less stringent standard and a moderate economic impact is
indicated for the proposed standard.  A large economic impact is
indicated for the more stringent standard because EPA judged that
if that degree of control were imposed, the majority of the dispersion
resin manufacturers would close, at least temporarily until technology
could be developed to achieve that degree of control.  For this reason,
no environmental or energy impacts are indicated for the more stringent
standard.  The inflation impacts or the price increases in consumer
products due to the less stringent standard and the proposed standard
are both indicated as small.  A small to moderate impact is indicated
for the alternative of prohibiting emissions because, in general,
substitutes for polyvinyl chloride resins would be more expensive
                                1-20

-------
than the resins.  Since the more stringent standard would be expected
to also close down dispersion resin manufacture, at least temporarily,
the same inflation impact is indicated for the more stringent
standard as for prohibiting emissions.
     There would be more significant secondary environmental, energy,
and economic impacts than indicated in the matrix if a plant elected
to meet the proposed standard with add-on control devices rather than
improved stripping.  Since these two types of control under proper
conditions achieve the same level of control, they represent alternatives
for the industry, rather than for EPA to choose between.  Therefore, the
impacts from using add-on controls are not indicated in the matrix.
     For the alternative regulatory strategy "no standard," for both
ethylene dichloride-vinyl chloride and polyvinyl chloride plants,
the only impact listed is a negative primary air impact.  Even
though unregulated plants do have an impact on other environmental
media, the secondary impacts listed in the matrices represent only
those effects on the environment caused by implementing controls.
The primary air impact of "no standard" is negative because not
only would this alternative result in a continuance of present
ambient air concentrations of vinyl chloride and their associated
health risks, but it would result in an increase in ambient air
concentrations of vinyl chloride in some locations due to growth
in the industries.  As discussed in Chapter 7, the annual growth
rate in the industries was approximately 10 percent between 1969 and
1974.  Future growth in the industries is expected to continue at
approximately this same rate, although it is possible that the rate
                                 1-21

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will decrease somewhat.  Growth in production would obviously result in
higher ambient air concentrations of vinyl chloride and more increased
health risk with no standard in effect than with the proposed standard
in effect, both in communities in the vicinity of expanding plants and
in presently unaffected communities where new plants will be constructed.
     The secondary environmental impacts for the alternative regulatory
strategy "delayed standard" for both the ethylene dichloride-vinyl
chloride and polyvinyl chloride plants are the same as for the
"proposed standard," except that they would obviously be delayed in
time.  The primary impact of the delayed standard would be the same as
the proposed standard once it went into effect.  However, the primary
impact is not rated as highly for "delayed standard" as for the "proposed
standard," because the primary impact represents health impact, and the
"delayed standard" would allow for a longer period of continued exposure
to current ambient concentrations of vinyl chloride and the associated
risk of adverse health effects.  The secondary economic impact of a
delayed standard might be less than that of the proposed standard,
although this is not indicated in the matrix, because this would
give the affected industries more time for research and development
of more cost-effective control equipment.
     The alternative regulatory strategy of prohibiting all emissions
of vinyl chloride could not be attained with available control technology
and would in effect ban vinyl chloride and polyvinyl chloride production.
Since no control devices would be used, there would be no secondary
environmental impacts.  The primary impact of banning vinyl chloride
                                1-22

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them would be insignificant.
Increased Atmospheric Emissions of_ Hydrogen Chloride
     Atmospheric emissions of hydrogen chloride are expected to be
a potential problem only at ethylene dichloride-vinyl chloride plants.
This is primarily because incineration, the source of hydrogen chloride
emissions, is more likely to be selected as a control method to meet
the proposed standard at ethylene dichloride-vinyl chloride plants
than at polyvinyl chloride plants.  Polyvinyl chloride plants are
expected to meet the proposed standard with control measures other
than incineration.
     Hydrogen chloride emissions to the atmosphere can be minimized
by utilizing a scrubber after the incinerator.  Due to corrosion
problems which would be caused by uncontrolled hydrogen chloride
emissions both on plant property and in the community, ethylene
dichloride-vinyl chloride plants are not expected to use incinerat"
to control vinyl chloride emissions without using scrubbers to c
the hydrogen chloride emissions.  However, there is no assuranc
that scrubbers would be used since there are no EPA regulation:
requiring the plants to use them.  If a typical, average-sized
ethylene dichloride-vinyl chloride plant did use an incinerator
to meet the proposed standard and did not control the hydrogen
chloride emissions, diffusion model results indicate that the
maximum 24-hour average ambient concentrations would be approximately
equivalent to the American Conference of Governmental Industrial
Hygienists (ACGIH) 8-hour average ceiling level for occupational
                   o
exposure (7000  vg/m ) and would exceed all the existing foreign
                                1-25

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standards and the National Academy of Sciences (NAS) recommended
guidelines identified in Chapter 6 for public exposure to hydrogen
chloride.  [It should be noted that EPA has no standard or guideline
limit for public exposure to ambient concentrations of hydrogen
chloride, and thus no "yardstick" with which these diffusion
model estimates can be compared.  The NAS guidelines and foreign
standards are the only "yardsticks" available; they have limited
value because they have varying averaging times that do not necessarily
correspond with the averaging times used for the diffusion modeling.]
     However, as already stated, it is expected that a plant would
control the hydrogen chloride emissions.  A large typical ethylene
dichloride-vinyl chloride plant using a 98 percent efficient
scrubber to control the hydrogen chloride emissions from the incinerator
would emit 10.2 kg/hr (22.6 Ib/hr) hydrogen chloride.  Diffusion model
results indicate that the maximum 24-hour average concentrations of
                                                                       3
hydrogen chloride in the vicinity of this large plant would be 430  i^/m
or about 6 percent of the ACGIH's 8-hour average ceiling level
for occupational exposure ard below the NAS guidelines and West
Germany's standard.  The diffusion model results would exceed the
Russian and Czechoslovakian standards, which are substantially
lower than the other guidelines and standards.  The Russian
standard is based on concentrations which might cause reflexive
reaction of the sensory organs.
     In addition, ethylene dichloride-vinyl chloride plants typically
already emit hydrogen chloride from process equipment.  When the hydrogen
chloride emissions from both the process equipment and the incinerator-
                               1-26

-------
scrubber system are considered together in computing maximum ambient
concentrations, the projected maximum 24-hour average ambient concentration
at the large plant would be in the same range or somewhat higher than
the existing foreign standards and the NAS recommended guidelines for
public exposure. However, it should be noted that the emissions from the
incinerator-scrubber would represent only about 25 percent of the total
emissions from the two sources.  In other words, the projected maximum
ambient hydrogen chloride concentrations in the vicinity of the plants
would already be relatively high due to emissions from the process
equipment, and the incinerator-scrubber would increase these levels.
Lowered |>H_ of_ Inprocess Wastewater Due tp_ Hydrogen Chloride
     Hydrogen chloride absorbed in an incinerator-scrubber control
system would cause the water leaving the scrubber to have a low pH.
At ethylene dichloride-vinyl chloride plants, where incinerator-scrubber
systems are most likely to be used to meet the proposed standard, the
pH could be less than 1.  This acidic effluent could cause the total
plant effluent to have a low pH since the scrubber effluent would
be a sizeable portion of the total effluent stream.  In order to
meet the EPA effluent guidelines, the pH of the total plant effluent
would have to be adjusted to 6.0 - 9.0 by recovering the hydrogen
chloride to be used as a raw material by the plant or by adding
caustic either to the scrubber water or to the effluent leaving the
scrubber.  Therefore, no additional steps to minimize the impact
of this pollutant are needed.
Increased Water Consumption
     Ethylene dichloride-vinyl chloride plants using incinerator-
scrubbers to meet the proposed standard would increase their water
consumption by less than 1 percent.  Polyvinyl chloride plants
                          1-27

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meeting the proposed standard with improved stripping for the sources
following the stripper, a water purge system to control emissions from
reactor opening, carbon adsorption for the monomer recovery system,and
steam stripping for the inprocess wastewater, would increase their water
consumption by 6 to 38 percent, depending on the manufacturing process.
EPA's Office of Water and Hazardous Materials is currently investigating
whether these increases in water consumption to meet the proposed
standard for atmospheric emissions of vinyl chloride would require a
change in EPA's Effluent Guidelines and Standards for ethylene dichloride-
vinyl chloride and polyvinyl chloride plants (39 FR 12506 and 39 FR
14678).  After the investigation is completed, appropriate changes will
be made in the guidelines and standards as needed.
Increases jm the Quantity of Vinyl Chloride jn_ Inprocess Wastewater
     Incinerator-scrubbers used at ethylene dichloride-vinyl chloride
plants to meet the proposed standard would increase the quantities
of vinyl chloride released into the wastewater by less than 0.1 percent.
The increase in vinyl chloride released into wastewater at polyvinyl
chloride plants meeting the proposed standard could be more significant
if the plants used steam for inproved stripping, steam to desorb vinyl
chloride from a carbon adsorption unit, or a water purge system to
remove vinyl chloride from reactors before opening them to the
atmosphere.  However, any increases in vinyl chloride released into
the wastewater from these sources at polyvinyl chloride plants are
expected to be minimized by the proposed standard, which would require
that vinyl chloride emissions to the atmosphere from the more
highly concentrated inprocess wastewater streams be controlled by
removing the vinyl chloride from the wastewater.  Therefore, no addi-
                              1-28

-------
tional steps need to be taken to minimize this potential adverse impact.
Increased Solid Waste Disposal Due tu Carbon Used for Adsorption
     Although carbon used in adsorption is continuously desorbed
and recycled, it is expected that it may have to be replaced every
1 to 3 years.  Since there has been very limited experience with
carbon adsorption in the ethylene dichloride-vinyl chloride or
polyvinyl chloride industries, it is not known for certain at this
time what the carbon bed-life would be or whether the damaged carbon
could be regenerated.  If polymerization occurred on the carbon,
it could be regenerated by oxidizing the polymer.  If the structural
characteristics which make carbon desirable, however, were damaged,
it could not be regenerated.  In meeting the proposed standard, the most
likely emission point to be controlled by carbon adsorption is the
monomer recovery system in polyvinyl chloride plants.  For an average-
sized plant an adsorption unit used for this purpose would require 3450
kg of carbon (7,600 Ib  of carbon).  If this were thrown away every
year, it would represent 3 percent of the total solid waste generated by
an average-sized plant.  This appears to be an insignificant impact.  In
addition to the problem of bulk, however, there may be problems in
disposal of the carbon associated with residual vinyl chloride or other
materials collected on the carbon.  The significance of any such problems
is not known at this time.  The carbon could also be burned in a boiler
as a low sulfur fuel, but may cause air pollution problems associated
with conversion of chlorinated hydrocarbons to hydrogen chloride.
Increased Energy Consumption
     Typical ethylene dichloride-vinyl chloride plants using incineration
to meet the proposed standard would require less than a 1 percent
                              1-29

-------
increase in energy consumption.   This is because only the emissions from
the ethylene dichloride purification and vinyl  chloride formation and
purification processes would be  required to be  incinerated,  and little
if any supplemental  fuel  would be required for  their combustion.
     Polyvinyl  chloride plants using incineration to meet the proposed
standard would  increase thei> energy consumption very significantly
("typical" suspension plants, 223 percent; "typical" dispersion plants,
836 percent; and "typical"  bulk  plants,  166 percent) primarily due to
the supplemental fuel which would be required for control
technology to reduce emissions from dryers, storage, and transfer
operations.  Improved stripping  would require a much smaller percent
increase in energy consumption ("typical" suspension plants, 15 percent;
"typical" dispersion plants, 81  percent; and "typical" bulk  plants,
50 percent).
Summary
     Based on the above discussion, the  potential secondary  or
adverse environmental impacts of the proposed standard are either
insignificant or will be minimized without additional action, except for
two.  First, EPA may find it necessary,  as a result of current investi-
gations, to make some changes in the water effluent guidelines and
standards, particularly for polyvinyl chloride plants.  Second, hydrogen
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chloride is already emitted by process equipment at ethylene dichloride-
vinyl chloride plants and by other petrochemical plants in the complexes
where ethylene dichloride-vinyl chloride plants are typically located.
An incinerator used to attain the proposed standard at an ethylene
dichloride-vinyl chloride plant could increase its hydrogen chloride
emissions by several fold.   Typically, however, due to the corrosion
problems which would otherwise occur both on plant property and in the
community, plants use scrubbers to control already existing hydrogen
chloride emissions.  Hydrogen chloride emissions resulting from control
of vinyl chloride emissions are expected to also be controlled for the
same reason.  If even a moderately efficient scrubber (98 percent control)
were used to control the hydrogen chloride emissions resulting from
incineration of vinyl chloride emissions, the increase in hydrogen
chloride emissions from a typical ethylene dichloride-vinyl chloride
plant due to the proposed standard would be reduced to 35 percent.
However, since diffusion model results indicate that under "worst-case"
meteorological conditions, the hydrogen chloride emissions from the
process equipment and the incinerator combined would cause maximum
ambient concentrations of hydrogen chloride in the vicinity of ethylene
dichloride-vinyl chloride plants to be in the same range or somewhat
higher than existing foreign standards and National Academy of Sciences
(NAS) guidelines for public exposure, EPA plans to further evaluate the
need to control hydrogen chloride emissions.  NAS is currently preparing
a report on the health effects of hydrogen chloride for EPA.  A
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final  draft of that report is scheduled for completion by the end of
1975.   At that time, EPA will assess the hydrogen chloride problem.
     1.2.3  Relationship Between Local  Short-Term Uses of Man's
            Environment and the Maintenance and Enhancement of Long-
            Term Productivity
     By taking steps now to establish standards based on best available
control technology to minimize vinyl chloride emissions, EPA will
be able to minimize exposure and prevent severe illnesses and deaths
which may have occurred in future years as a result of prolonged community
exposure to vinyl chloride.  Therefore, the proposed standard may
curtail industrial expansion on a short-term basis, as a result of
funds being diverted from support of industrial expansion to support of
installation of process changes and control systems to attain the
standard; but it will enhance the long-term productivity of man and
his environment.
     1.2.4  Irreversible and Irretrievable Commitments of Resources
            Which Would Be Involved if the Proposed Action Should
            Be Implemented
     Irreversible and irretrievable resources which would be committed
to reduce ambient concentrations of vinyl chloride include energy
and the materials to construct incinerators, boilers, monitoring
equipment, carbon adsorption units, etc.  If incineration were used
to meet the standard, additional energy and materials would be
needed for operation of an absorption unit to abate hydrogen
chloride emissions.
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     1.3  Economic Impact
     In accordance with Executive Order 11821 and OMB circular
A-107, EPA has carefully evaluated the economic and inflationary
impacts of the proposed standard.  This economic analysis is
contained in Chapter 7, and includes the costs of control systems
which can be used to attain the proposed standard and alternative
control levels, and the impact of these costs on the vinyl chloride
industries and the public consumer.  The total estimated capital cost
for existing plants to meet the proposed standard is $198 million,
of which $15 million is for ethylene dichloride-vinyl chloride plants
and $183 million is for polyvinyl chloride plants.  The total
annualized costs for attainment of the proposed standard are
estimated to be $70 million, of which $12 million is for ethylene
dichloride-vinyl chloride plants and $58 million is for polyvinyl
chloride plants.
     Also, included in the economic analysis were the costs of
the OSHA standard which the plants are subject to and the EPA
water effluent guideline limitations which the plants will be
subject to in 1983 (best available control technology economically
achievable).  The total capital cost for existing plants to meet
the EPA water effluent guideline limitations is $83 million, of which
$35 million is for ethylene dichloride-vinyl chloride plants and
$48 million is for polyvinyl chloride plants.  The total annualized
cost to meet the effluent guideline limitations is $17 million, of
which $7 million is for ethylene dichloride-vinyl chloride plants and
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$10 million is for polyvinyl  chloride plants.   The costs to the
industry of meeting the OSHA standard cannot be quantified at this
time, but they are expected to overlap to some degree with the
costs to meet the fugitive emission regulations in the proposed
standard.  The capital cost to meet the fugitive emission regulations is
$37 million and the annualized cost is $25 million.
     The proposed standard would not deter construction of new
ethylene dichloride-vinyl  chloride plants or new polyvinyl chloride
suspension or bulk plants.  For polyvinyl chloride dispersion
plants (which constitute 13 percent of the industry production), the
proposed standard would significantly deter the construction of
new plants that have capacities of less than 45 million kg/yr
(100 million Ib/yr) but would not deter construction of plants
larger than 45 million kg/y\  Total costs for attainment of the
proposed standard and the effluent guideline limitations are estimated
to result in the closing of no ethylene dichloride-vinyl chloride
plants and four small polyvinyl chloride plants.  These four plants
are estimated to employ 30 people and account for approximately
0.5 percent of existing industry capacity.  It is estimated that
the four plant closures resulting from imposition of the proposed
standard would have occurred if only the costs of fugitive emission
controls were incurred.
     It is estimated that the price of polyvinyl chloride resins
would rise by approximately 7.3 percent in order to maintain
precontrol profitability and also to recover the total annualized
control costs necessitated by the proposed standard at ethylene
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dichloride-vinyl chloride plants and polyvinyl chloride plants
This increase is estimated to translate into a maximum consumer price
increase in goods fabricated from polyvinyl chloride resins of approximately
3.5 percent.  Recovery of effluent annualized costs plus maintenance of
precontrol profitability is estimated to add approximately 2 percent to
polyvinyl chloride resin prices and result in an additional maximum
consumer price increase of 1 percent.
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2.  RATIONALE FOR REGULATING VINYL CHLORIDE
     2.1  History
     In January 1974, the B. F. Goodrich Chemical Company reported
to the National Institute of Occupational Safety and Health (NIOSH)
that several of its employees had died from angiosarcoma of the liver
(a rare form of cancer) and that those deaths may have been related
to occupational exposure to vinyl chloride gas.  This report resulted
in growing concern over the potential health effects of vinyl chloride
and spurred efforts by various government agencies to take steps
to obtain data needed to assess in more detail the impact of vinyl
chloride on human health and to reduce vinyl chloride exposure both
to the worker and to the general population.  EPA established a Task
Force on vinyl chloride in February 1974, to identify the environmental
problems resulting from the manufacture and use of vinyl chloride and
polyvinyl chloride.  While air, water, and solid waste disposal are all
possible routes for entry of vinyl chloride into the environment in the
vicinity of manufacturing facilities, the Task Force concluded that,
based upon current information, the air route poses the most significant
environmental problem to the population located there.   Potential
sources of exposure to the general population due to the use (as opposed
to the manufacture) of vinyl chloride include aerosol containers,
plastics used for containing or wrapping food products, and drinking
water.
     On April 26, 1974, EPA published in the FEDERAL REGISTER an
emergency suspension order for specific indoor aerosol pesticides
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containing vinyl  chloride.   In May 1974,  EPA initiated a study to
determine whether Federal  regulation of atmospheric emissions  of vinyl
chloride from manufacturing facilities is needed and,  if so, which of
the regulatory alternatives under the Clean Air Act would be most
appropriate.  For the purpose of the study, data were  gathered
on health effects, air quality concentrations,  control techniques,
and costs.
     2.2  Alternative Control Strategies  Considered
     The Administrator of  EPA considered  several approaches to
dealing with air emissions  of vinyl  chloride.   The main alternatives
were taking no action, delaying action until more data on health
effects at lower concentrations of vinyl  chloride are  available,
taking action under section 115 or 303 of the Clean Air Act, or
setting standards under section 109, 111, or 112 of the Clean
Air Act.
     2.2.1  No Action or Delayed Standards
     Factors considered in  determining whether Federal regulatory
action is needed for vinyl  chloride emissions and, if  so, whether it
is needed at this time, included the health effects of vinyl  chloride,
the extent of public exposure to vinyl chloride, and the degree to
which other regulations are reducing vinyl chloride emissions.
                                        2
     2.2.1.1  Summary of Health Findings
     Vinyl chloride has been shown to cause cancer in  both sexes
of three species of rodents by the inhalation route, the primary
route by which humans who live in the vicinity of plants manufacturing
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or processing vinyl chloride are exposed.  Angiosarcoma of the liver has
been observed in rats, hamsters, and mice exposed to vinyl chloride.  In
two of these species, rats and mice, liver angiosarcoma has been produced
at exposure levels as low as 50 parts per million (ppm), which is the
lowest level for which studies have been completed thus far.   In one
experiment, exposure levels as low as 50 ppm for four hours per day,
five days per week for a 12 month period produced nephroblastomas and
liver angiosarcoma after 135 weeks.  In a second experiment,  angiosarcoma
in mice has been produced by exposures as low as 50 ppm for a 26 week
duration.  Furthermore, these animal studies showed a multiple cancer
risk from vinyl  chloride, i.e., tumors in organs other than the liver
such as the brain, lungs, kidneys, and mammary glands.
     As of June 1975, the National Cancer Institute had confirmed
27 cases of liver angiosarcoma among workers with a history of
exposure to vinyl chloride, 15 in the United States and 12 in
Europe and Canada.  Additionally 11 cases had been reported and
not yet confirmed.  Most, but not all, of these confirmed cases
have been among  workers involved directly in polyvinyl chloride
production.  Cases of liver angiosarcoma have been reported in one
U. S.  and three  European workers exposed to vinyl chloride, but not
directly involved in polyvinyl chloride production.   These cases suggest
that exposure to vinyl chloride at lower levels than usually  encountered
in polyvinyl chloride production plants is capable of causing liver
angiosarcoma.
     To date,  angiosarcoma of the liver has been considered an
extremely rare disease among the general  population.   In a survey
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by the American Cancer Society, only one case of liver angiosarcoma
was recorded per 78,000 deaths.  Compared with this record, the data
indicating the frequency of liver angiosarcoma among workers
exposed to vinyl chloride show that the relative risk to these
workers of developing this disease is approximately 3,000 times
greater than that to the general population.  Such a relative
risk represents a statistically significant difference ( p <0.001)
in the frequency of liver angiosarcoma among those exposed to high
levels of vinyl chloride compared with those in the general population.
     Occupational exposure studies have strongly implicated
vinyl chloride as a human chemical carcinogen which causes
tumors in many different sites, only one of which is angiosarcoma
of the liver.  Other manifestations in humans include acroosteolysis
and liver dysfunction.  Sitrilar toxicology studies have verified
the occurrence of tumors in other body organs such as the brain
and lungs.  Bioassay studies have shown the potential of vinyl
chloride to be a chemical rrutagen and teratogen.  (More details on
these animal and occupational studies may be found in the
                                                                    o
Scientific Technical Report on Vinyl Chloride and Polyvinyl Chloride .)
     2.2.1.2  Extent of Public Exposure to Vinyl Chloride
     Generally, the population exposed to vinyl chloride emissions
is composed of those people living within the vicinity of the
approximately 17 ethylene dichloride-vinyl chloride plants, 41 polyvinyl
chloride plants, 8000 fabricating plants, and 8 identified
miscellaneous sources.
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     Results from a preliminary ambient monitoring program conducted by
EPA in the spring of 1974 indicate that people living in the immediate
vicinity of ethylene dichloride-vinyl chloride and polyvinyl chloride
plants are generally exposed to average daily concentrations of less
than 1 ppm with some 24-hour average excursions of 1 to 3 ppm and with
                                              3
occasional peak exposures of as high as 33 ppm .   Results from a
more extensive ambient monitoring program conducted by EPA from
November 1974 to June 1975 are not discussed in detail here because
they are still being analyzed.  The results are generally in the
same range as reported here for the preliminary ambient monitoring
program except there are no concentrations as high as 33 ppm.
     If ethylene dichloride-vinyl chloride and polyvinyl chloride
industries are not regulated, community exposure to vinyl chloride
may increase as the industries expand.  The growth rate in
consumption of vinyl chloride and polyvinyl chloride between 1969
and 1974 averaged approximately 10 percent per year.  Future
growth in consumption is expected to continue at approximately this
same rate, although it is possible that the rate will decrease
somewhat.  Assuming that the growth rate in capacity would be the
same as for consumption, at a 10 percent growth rate, current
capacity would double in approximately 7 years.
     2.2.1.3  Other Regulations and Their Effect on Vinyl Chloride Emissions
     At least some reduction of vinyl chloride emissions may be expected
as the result of the standard promulgated by the Occupational Safety
and Health Administration (OSHA) on October 4, 1974, and some State
regulations for new construction and for hydrocarbon emissions.  These
regulations are described in Chapter 9.
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     In response to the OSHA regulation which became effective
April 1, 1975, the ethylene dichloride-vinyl chloride and polyvinyl
chloride industries have adopted some measures which not only reduce
employee exposure, but also reduce emissions to the atmosphere.  However,
other methods of reducing employee exposure to vinyl chloride, such as
respiratory protection, ventilation of the workplace, opening
sides of buildings, and installing tall stacks do not reduce
the emissions to the atmosphere.  Although the OSHA standard
requires all employers to institute feasible controls to the
fullest extent possible and to continue to improve and apply
engineering controls until full compliance is achieved, it does
not establish any deadlines for compliance through engineering
controls.  Written plans demonstrating how plants will achieve
this goal must be drawn up and made available, upon request, to
representatives of OSHA and NIOSH; however, for submittal of
formal plans, there is also no deadline.  For these reasons, it
is difficult at this time to evaluate the degree to which the
OSHA regulation will reduce vinyl chloride emissions to the
atmosphere.  It is assumed, however, that the plants will respond
to the OSHA regulation with a combination of ventilation techniques,
emission reduction, and respiratory protection and that this
response will not be uniform.
     As the result of some State regulations for new sources and
for hydrocarbon emissions, some newly constructed polyvinyl chloride
plants and the oxychlorination process at some existing ethylene
dichloride-vinyl chloride plants are required to be controlled.
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The State regulations, however, do not necessarily cover all emission
points, nor do they require the same degree of emission reduction as
the proposed standard.  Additionally, the State regulations are not
expected to be uniform in the degree of control they require.
     2.2.1.4  Conclusions
     Based on the analysis summarized above, EPA concluded that
vinyl chloride is a carcinogen, that ambient concentrations of the
gas pose a public health risk, and that the alternative of taking
no action to regulate it is unacceptable.  The alternative of
delaying the standard setting would allow acquisition of additional
information, but it is likely that gaps in the relevant information
would still remain.  Due to the expected long latency period between
initial exposure to vinyl chloride and occurrence of disease, it will
be many years before useful epidemiological data will be available
on the effects of lowered occupational exposure resulting from the
OSHA regulation.   Therefore, EPA has further concluded that ambient
concentrations of vinyl chloride should not be allowed to persist until
all information gaps are filled.  If EPA were to wait until all
needed data were available to establish precise dose-response
relationships, a standard could be long delayed, and the public
might be exposed to substantial and irreversible harm in the interim.
Moreover, the risks to the public could increase as the industry
expands.
     2.2.2  Action under Section 115 - Abatement Conferences
     Section 115 of the Act gives EPA the authority to call abatement
conferences in cases where an air pollutant endangers the health
or welfare of persons.   Such conferences may be requested by a
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State or city when the pollutant originates within their
jurisdiction or when the problem originates elsewhere but poses
a problem within their area.  EPA may initiate conferences if the
pollutant problem exceeds State boundary lines.   An abatement
conference covers many subjects, including information on occurrence of
the air pollutant, adequacy of abatement actions, and the
amount of delay that may be encountered in abating the pollution.
     For vinyl chloride, abatement conferences would have to be
initiated by at least 16 States and Puerto Rico where all of the
ethylene dichloride-vinyl chloride and polyvinyl chloride plants are
located.  Generally, EPA would not be able to call abatement conferences
since vinyl chloride problems are localized and not interstate, but EPA
could encourage the States to call such conferences.  Once appropriate
abatement actions were determined during the conferences, the States
involved would have to initiate such actions.  If abatement actions
were not initiated, EPA would have six months to hold hearings and
request that abatement action be taken within a reasonable time
not to exceed six months.  If the States or industry failed to act,
EPA would have to file suit in the appropriate U. S. District Court
to enforce the abatement action.
     In general, this procedure is unwieldy, requires a significant
amount of manpower, and based on past experience, may not bring
about the required abatement measures.  Abatement conferences, therefore,
are not considered an effective approach to controlling vinyl chloride.
     2.2.3  Action under Section 303--Emergency Powers
     Section 303 of the Act allows the Administrator to bring suit, in
the appropriate U. S. District Court, to restrain any person causing or
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contributing to air pollution that presents an "immiment and substantial
endangerment to the health of persons."  The Administrator may seek to
stop pollutant emissions or take other action as may be necessary.
This mechanism has been used once by EPA.  In 1971, court injunctions
were obtained against plants in Birmingham, Alabama during an air
pollution episode to reduce concentrations of particulate matter below
dangerous levels.
     EPA has concluded that in the case of vinyl chloride where
permanent regulatory control of a continuing problem is possible,
that control is preferable to Section 303.  Additionally, using Section
303 could be cumbersome since injunctions may have to be obtained in
each U. S. District Court that has a source of vinyl chloride within its
jurisdiction.
     2.2.4  Standards under Section 109--National Ambient Air Quality
            Standards (NAAQS)
     The purpose of air quality standards is to control air pollutants
which have an adverse effect on public health and welfare and which
are present in the ambient air due to numerous or diverse stationary
or mobile sources.  Primary standards are set at levels requisite
to protect the public health, allowing an adequate margin of safety.
Secondary standards are set at levels requisite to protect the public
welfare from any known or anticipated adverse effects.
     Section 109 is usually used to control a pollutant whose presence
in the ambient air is ubiquitous.   Vinyl  chloride is emitted from
ethylene dichloride-vinyl chloride plants, polyvinyl chloride plants,
polyvinyl chloride fabricating plants, and a few miscellaneous sources.
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Detectable concentrations of vinyl  chloride have not yet been found in
the ambient air except in the vicinity of these sources.
     Establishing a national ambient air quality standard (NAAQS)
for vinyl chloride would set into motion preparation of State implementation
plans (SIP) for each of the 247 air quality control regions (AQCR's) to
demonstrate attainment and maintenance of the standard.  This is a
complex process and is not generally considered the optimum regulatory
approach for situations involving a limited number of source categories.
The time required to implement the NAAQS/SIP process is estimated to be
6 months for setting a standard plus 13 months to develop and approve
the SIP's.  Compliance with the standards must be within 3 to 5 years
after the SIP's are approved.
     EPA concluded that Section 109 is not the most suitable
alternative for controlling vinyl chloride because vinyl chloride
is a localized problem and because the NAAQS/SIP process is time-consuming
and complex, and requires considerable State and Federal resources.
Furthermore, Section 109 does not provide the expedited means of control
which Congress meant to be used for a hazardous air pollutant.
     2.2.4.1  Section 109--Existing National Ambient Air Quality
              Standard for Nonmethane Hydrocarbons
     There exists a NAAQS for nonmethane hydrocarbons which possibly
could be used as an indirect regulatory mechanism for controlling vinyl
chloride.  However, the hydrocarbon standard is clearly intended as a
guide to achieving the NAAQS for photochemical oxidants.  40 CFR
51.14(c)(4) provides that the degree of total hydrocarbon emission
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reduction necessary for attainment and maintenance of the NAAQS for
photochemical oxidants will also be adequate for the attainment of the
NAAQS for hydrocarbons.  States now have approved control strategies for
hydrocarbon/oxidants and are progressing toward fulfilling the require-
ments of their respective strategies.  To change the SIP's, EPA would
have to present findings that the plans are inadequate and would have to
require resubmittal of the plans.  This would reopen a full review of
the hydrocarbon/oxidant control strategies, including the transportation
control plans.  Hydrocarbon/oxidant strategies have focused on area-wide
hydrocarbon emissions and it would be difficult to justify singling out
vinyl chloride sources for control.  Vinyl chloride is less photochemically
reactive than many other petrochemicals and does not contribute signi-
ficantly to total urban hydrocarbon emissions.
     Moreover, the hydrocarbon standard regulates only the
6-9 a.m. concentrations of nonmethane hydrocarbons.  During the
remaining 21 hours of the day, control of vinyl chloride emissions
could not be required under existing SIP's.  Since the NAAQS is for
hydrocarbons in general, there is no way to require States to regulate
vinyl chloride in particular.   For the above reasons, control of vinyl
chloride under the existing NAAQS for hydrocarbons would not be appropriate
or effective.
     2.2.5  Standards under Section Ill—Standards of Performance for
            New Stationary Sources (SPNSS)
     Standards of performance  for new stationary sources apply to
categories of sources that emit pollutants which may cause or contribute
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to the endangerment of public health or welfare.   New sources  are



controlled under Section lll(b)  and existing sources, under Section



lll(d).  [Section lll(b) standards can be established for pollutants



already regulated under the authority of sections  109 or 112,  whereas



section lll(d) standards cannot.]  Such standards  reflect the  use of the



best system of emission reduction (considering cost)  which has been



adequately demonstrated for the  affected source.   The level of control



set by EPA need not be related directly to the adverse effects of the



air pollutant.



     The standard setting process begins by listing in the FEDERAL



REGISTER categories of sources for which the Agency intends to set



standards of performance.  Within 120 days after listing, standards



for these sources must be proposed and public comments solicited.



Within the next 90 days the Administrator must consider the public



comments and promulgate the standards.  Any new source which



commences construction after the proposal of the standard must comply.



     To control existing sources emitting health-related pollutants



under Section lll(d), the Agency proposes and promulgates emission



guidelines that describe the degree of emission control achievable with



best demonstrated control systems, considering costs.  Also, proposed



and promulgated is the time within which EPA believes that compliance



with such emission guidelines can be achieved.  Within 9 months after



promulgation of the emission guidelines, the individual States must



submit a plan for implementing emission standards  for existing sources



of the pollutant (in this case,  vinyl chloride).  After the plans are



received, EPA has 4 months to approve or disapprove the plans and, if





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a State plan is unacceptable, two months more to promulgate EPA regulations.
To be approved, State plans must contain emission standards at least as
stringent as the EPA emission guideline.  However, in cases where
existing sources would incur severe economic hardship or would risk
closure if forced to comply with the emission guidelines, less stringent
State standards could be approved.  Furthermore, a State could issue a
variance allowing the source to continue operations without full  compliance
with a standard.
     As noted above, the use of section 111 would require the use
of best demonstrated control technology, taking cost into account.
The best available systems for controlling vinyl chloride emissions
have been used within existing ethylene dichloride-vinyl chloride and
polyvinyl chloride plants.  Since those control systems appear to be
economically feasible, emission standards reflecting the use of best
available control technology would be required under section 111  and
would achieve considerable emission reduction at both ethylene dichloride-
vinyl chloride and polyvinyl chloride plants.  However, consideration of
costs could result in lower levels of emission reduction being required
at some individual existing plants.
     After very close examination, EPA concluded that section 111 is not
the best mechanism for controlling vinyl chloride.  Specifically, the
length of time required under section lll(d), the possibility of
differing levels of control from State to State, State-granted
variances that may be based only on cost considerations, and standard
development as a State rather than a Federal process were all features
that made section 111 unacceptable for vinyl chloride.
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     2.2.6  Standards under Section 112—National  Emission Standards
            for Hazardous Air Pollutants (NESHAP)
     Section 112 was incorporated in the Clean Air Act to control
pollutants which, in the Administrator's judgment, may cause,  or contribute
to, an increase in mortality or an increase in serious irreversible,  or
incapacitating reversible, illness.  Emission standards should be set
at levels that provide an ample margin of safety to protect the public
health from the atmospheric emissions of the pollutant.  Emission
standards under section 112 apply to all new and existing sources
of the pollutant.
     To set a standard under section 112, EPA must list vinyl  chloride
as a hazardous pollutant in the FEDERAL REGISTER.   Within 180  days
of the listing, the Administrator must propose a national emission
standard which, in his judgment, adequately protects public health.
Within 30 days, the Administrator must give notice of a public
hearing to be held to examine his judgment that the pollutant  is
hazardous.  Allowance must also be made for comments on the proposed
standard from the public and scientific and industrial communities.   The
Administrator can withdraw a pollutant from the hazardous list only
if he finds, on the basis of information presented at the public
hearing, that the pollutant clearly is not hazardous.  Otherwise, the
Administrator must promulgate a standard within 180 days of the
proposal.  Section 112 does not require that in setting a standard the
Administrator consider available control technology or economic
impact.  However, EPA must, from time to time, issue information
on control technology.
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     2.2.6.1  Vinyl Chloride as a Hazardous Pollutant
     In deciding whether section 112 would be an appropriate regulatory
strategy for vinyl chloride, it had to be determined whether vinyl chloride
meets the specifications of a hazardous air pollutant as defined in the
Act.  "Hazardous air pollutant" is defined in section 112 as "an air
pollutant ... which in the judgment of the Administrator may cause, or
contribute to, an increase in mortality or an increase in serious
irreversible, or incapacitating reversible, illness."
     Vinyl chloride appears to be such a hazardous air pollutant.
As noted earlier in this chapter (section 2.2.1.1), data taken from
animal  experiments and occupational exposure studies have strongly
indicated that vinyl chloride causes or contributes to angiosarcoma,
other cancers, and noncarcinogenic disorders in people with occupational
exposure and in animals with experimental exposure to vinyl chloride.
Reasonable extrapolations from these findings cause concern that present
ambient levels of vinyl chloride may cause or contribute to the same or
similar disorders.  Data obtained in the spring of 1974 from plants that
produce or process vinyl chloride indicate that approximately 100
million kg of vinyl chloride are emitted to the atmosphere annually.
The majority of these emissions are from ethylene dichloride-vinyl
chloride and polyvinyl chloride plants.  Approximately 4.6 million
people live within a five mile radius of where these plants are
        4
located.   There are no dose-response data, and thus no absolute
proof of adverse effects, at the concentrations of vinyl chloride found
in the ambient air.  However, for carcinogens there may be no atmospheric
concentration which poses absolutely no public health risk.  Also,
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data from studies of occupational exposure indicate that there is
a latency period as long as 20 years between initial exposure to
vinyl chloride and occurrence of disease.  This latency period could
possibly be longer for low levels of exposure.   Production of
polyvinyl chloride did not begin to operate on a large scale until
relatively recently.  Only about 10 of the approximately 40 polyvinyl
chloride plants are 20 years, old or older, and the oldest one is
40 years old.   These considerations led to the conclusion that EPA
should take action now to reduce exposure levels to vinyl chloride
before retrospective evidence of risk is allowed to show itself.  By
taking steps now to reduce emissions, EPA will  be able to reduce
substantially the risk that severe illness and death will occur in the
future as a result of present and prolonged community exposure to
vinyl chloride.
     EPA's conclusions are supported by The Evaluation of Environmental
Carcinogens which was completed on April 22, 1970, by the Ad Hoc
Committee on the Evaluation of Low Levels of Environmental Chemical
Carcinogens.  The Ad Hoc Committee was formed in response to a request
by the Deputy Assistant Secretary for Health and Scientific Affairs of
the Department of Health, Education, and Welfare (HEW).  The Committee
was to review the problems relating to the evaluation of low levels of
environmental  chemical carcinogens, to consider the scientific bases on
which such evaluations can be made, and to advise the Department of HEW
on the implications of such evaluations.  The report to HEW includes the
                                          4
following conclusions and recommendations:
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     (1)  "Any substance which is shown conclusively to cause tumors
in animals should be considered carcinogenic and therefore a potential
cancer hazard for man."
     (2)  "Because the latent period in human carcinogenesis is so long,
epidemiologic evidence develops only over periods of 15 to 20 years.
Timely decisions to exclude materials from uses involving exposure
to man, therefore, must be based solely on adequately conducted animal
bioassays.  Retrospective human evidence of risk must not be allowed
to show itself before controlling action is taken.  Chemicals should
be subjected to scientific scrutiny rather than given individual
rights; they must be considered potentially guilty unless and until
proven innocent."
     (3)  "No chemical substance should be assumed safe for human
consumption without proper negative lifetime biological assays of
adequate size.   The minimum requirements for carcinogenesis bioassays
should provide for adequate number of animals of at least two species
and both sexes with adequate controls, subjected for their lifetime
to the administration of a suitable dose range, including the
highest tolerated dose, of the test material by rates of administration
that include those by which man is exposed."
     (4)  "No level of exposure to a chemical carcinogen should be
considered toxicologically insignificant for man.   For carcinogenic
agents a safe level for man cannot be established by application of our
present knowledge.   The concept of 'socially acceptable risk1  represents
a more realistic notion."
                               2-17

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     Several court decisions also support EPA's decision.  In
Environmental Defense Fund, Inc. v. Environmental Protection Agency, 510
F.2d 1292 (D. C. Cir. 1975), which questioned the protection of the
manufacture and sale of aldrin and dieldrin, Judge Leventhal recognized
(1) consideration of the long latency period in cancer, (2) the finding
that the concept of threshold level has no practical significance for
carcinogens, and (3) the extrapolation to humans from animal test data,
as valid grounds for EPA's decision-making. See also Environmental
Defense Fund, _Inc_._ v. Ruckelshaus, 142 U. S. App. D. C. 74, 439 F. 2d
584 (1971) on animal test data.  Furthermore, in the preamble to the
October 1974 OSHA regulation for vinyl chloride, The Evaluation of
Environmental Carcinogens was cited as partial support for the level of
the standard.  This regulation was upheld by the U. S. Court of Appeals
for the Second Circuit in the case of Society of the Plastics Industry
v. Occupational Safety and Health Administration, 509 F. 2d 1309 (1975),
cert,  den, sub nom. Firestone Plastics Co. v. U_. S_. Department of_ Labor,
43 U.  S. L. W. 3623 (1975).  In its decision, the Court of Appeals
stated that much of OSHA's evidence for the regulation was based on
animal exposure to vinyl chloride, with only indirect human evidence,
but that
     ...nevertheless, it remains the duty of OSHA to protect
     the working man, and to act even in circumstances where
     existing methodology or research is deficient.
     The panel also stated that the evidence on vinyl chloride's
dangers was "quite sufficient" to merit OSHA's regulations.
     2.3  Setting an Emission Limit
     A concurrent issue before EPA was what level of emission control
could or should be required under section 112.  Section 112 provides
                              2-18

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that the Administrator shall set an emission standard "at the level
which in his judgment provides an ample margin of safety to protect the
public health from such hazardous air pollutants."  The problem presented
was how this provision should be interpreted when dealing with an
apparent non-threshold pollutant that is hazardous at some level.  The
term "non-threshold pollutant" refers to a substance which creates a
risk of adverse health effects at all ambient levels (other than zero).
An "apparent non-threshold pollutant" is, quite simply, a substance
which, on the basis of available information, appears to be a non-
threshold pollutant.   An apparent non-threshold pollutant may be known
to be "hazardous" within the definition of section 112 at some levels,
and create a risk to public health at all levels.  Vinyl chloride is
such a pollutant.  It clearly causes angiosarcoma, other cancers, and
noncarcinogenic disorders in animals which have been experimentally
exposed to vinyl chloride and in people with occupational exposure.
However, an emission standard for vinyl chloride cannot be established
below a threshold level of effects because, as noted above, no dose-
response data are available for the concentrations of vinyl chloride
found in the ambient air.  Further, it is EPA's position that for a
carcinogen it should be assumed, in the absence of strong evidence to
the contrary, that there is no ambient concentration that poses absolutely
no public health risk.   The issue is how far the level  of such pollutants
should be reduced to provide "an ample margin of safety."
     2.3.1   The Alternative of Prohibiting Vinyl Chloride Emissions
     EPA considered that sectionl!2 might be interpreted to require a
                             2-19

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complete prohibition of emissions of any apparent non-threshold pollutant.
This zero emission limitation would be the only emission standard which
would offer absolute safety from ambient exposure.  Establishing zero
emission limits would in effect ban domestic vinyl chloride and polyvinyl
chloride production because ethylene dichloride-vinyl chloride and
polyvinyl chloride plants could not comply with zero emission limits
using currently feasible control technology.
     2.3.1.1  Direct Impact.
     The direct impact of banning vinyl chloride and polyvinyl
chloride production would be on the producing companies and their
employees and in the regions in which these companies are located.
Twenty-eight companies would be directly impacted.  However, the lack
of detailed financial information for privately-held companies and of
 profit  data about vinyl  chloride and  polyvinyl  chloride output for
 publicly-held  companies  make an assessment of  probable  company
 failure difficult.
      For 27 companies,  however, EPA approximated dependency on vinyl
 chloride and polyvinyl  chloride production by  comparing estimated
 vinyl  chloride and polyvinyl chloride sales to total  sales.   In
 doing  this, EPA recognized that the estimated  percentage of vinyl
 chloride and polyvinyl  chloride sales is  not necessarily the same as the
 estimated percentage of profits.   Based on sales information, three of
 the 27 companies  are judged to be highly  dependent upon vinyl chloride
 and polyvinyl  chloride  production.   The three  companies are all
 polyvinyl  chloride fabricators as well  as producers.   With a ban on
 vinyl  chloride and polyvinyl chloride production, all  three would
 probably fail.  For the one firm for which sales data are unavailable,
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no estimation of probable company failure is possible.
     Prohibiting vinyl chloride emissions and, therefore, banning
production would have grave effects on employment.  Direct employment
impacts on a per plant basis are not known, but estimates of total
employment are available.  According to these estimates, there are
approximately  940 people employed in vinyl chloride production and 5600
people in polyvinyl chloride production.  Thus, over 6500 people would lose
their jobs as a result of prohibiting vinyl chloride emissions.
Although many skills used in vinyl chloride and polyvinyl chloride
production are readily transferrable to other industries, the extent
that this transfer would occur is not known.  At any rate, transfer
would not be immediate.
     For ethylene dichloride-vinyl chloride plants, immediate regional
impacts of a ban would be felt primarily in the areas of southeastern
Texas and southern Louisiana where 14 of the 17 plants are located.  In
certain instances, vinyl chloride output goes to other regions as well.
For polyvinyl chloride plants, the immediate impacts would be more
dispersed geographically.  Although some polyvinyl chloride plants are
located in the southeastern Texas-southern Louisiana area, most
are located in Delaware, New Jersey, New York, and Massachusetts.  In
all of these areas, multiplier impacts in terms of decreased output,
unemployment, and lowered income could be expected.
     2.3.1.2  Indirect Impacts
     The indirect impacts of prohibiting emissions (and thereby
banning vinyl chloride and polyvinyl chloride production) would be felt
                             2-21

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primarily by raw material suppliers (ethylene dichloride producers) and
by product output receivers (polyvinyl chloride fabricators).   There are
11 firms producing ethylene dichloride at 17 plants.   About 80 percent
of their ethylene dichloride output goes to vinyl chloride and polyvinyl
chloride plants.  With one exception (Vulcan Materials), all  companies
also produce either vinyl chloride or polyvinyl chloride or both.
Because much ethylene dichloride output appears captive, the impact of
lost ethylene dichloride revenues has probably been counted in terms of
lost vinyl chloride and polyvinyl chloride sales.  Vulcan Materials
would not be expected to fail  in the event of a ban,  because it does not
rely heavily on ethylene dichloride sales.
     The Chemical Economics Handbook estimates the number of polyvinyl
chloride fabricating plants to be 8,000.   It is not known how many of
the 8,000 are independent or how many are affiliated with larger com-
panies.  The economic viability of the fabricator has not been analyzed.
However, the more dependent these companies are upon vinyl chloride and
polyvinyl chloride input, the more likely is the possibility of failure.
     There are no estimates of domestic ethylene dichloride employment
and, therefore, no determination of potential impact.  For polyvinyl
chloride fabrication, total direct and indirect employment loss with
no transfer of jobs or raw material substitutes is estimated by
Arthur D. Little, Inc. to be 1.7 to 2.2 million jobs.   This estimate
includes not only persons employed by fabricating plants, but also persons
employed in utilization of the fabricated products, such as auto and
construction workers.  The estimate amounts to over 1 percent of the
1972 labor force.
                              2-22

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     Nearly all ethylene dichloride production occurs in southeastern
Texas and southern Louisiana.  Since most vinyl chloride production
occurs here and some polyvinyl chloride production occurs here as well,
this area could conceivably be hard hit.  This is especially true if the
affected resources could not be transferred to other uses in the area.
     Although no location maps for fabricating plants have been developed,
the number of, and the wide variety of outputs from, polyvinyl chloride
fabricators suggests no geographic concentration.  If there are any
clusters of plants, they are probably in metropolitan areas.
     2.3.1.3  Substitutes for Polyvinyl Chloride
     According to one estimate, substitutes for polyvinyl chloride exist
for approximately 85 percent (by weight) of present polyvinyl chloride
     o
uses.    It is believed that prices of substitutes would generally be
higher than polyvinyl chloride prices and would result in higher
consumer prices for finished goods.  Industry representatives have indicated
that,  although known substitutes exist for most polyvinyl chloride uses,
they do not feel that substitutes exist in sufficient quantities to fill
immediately the void which would be created by banning vinyl chloride
and polyvinyl chloride production.  In effect, they say that there would
not be sufficient substitutes for polyvinyl chloride products for approx-
imately two years.
     Even if substitutes for polyvinyl chloride were readily available,
they would not necessarily have some of the desirable characteristics
of polyvinyl chloride.   For example, one of the desirable properties
of polyvinyl chloride fabricated products is nonflammability; most of
the proposed substitutes do not have this property and would require
                              2-23

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additional processing to achieve it.   Furthermore, the potentially
adverse health and environmental impacts from substitutes have not
been thoroughly studied, and, therefore, it is not known whether
they would pose an even greater environmental hazard than vinyl
chloride.
     As an alternative to substitution, there exists the possibility
of importing polyvinyl chloride resins for final fabrication by U. S.
industry.   Although the U.  S. has imported very little polyvinyl
chloride in the past [18 million kilograms (4 million pounds) in
1972], imports in 1973 increased significantly to 28.8 million
kilograms  (64 million pounds).    Excess foreign polyvinyl chloride
capacity remained.  At the end of 1973, excess polyvinyl chloride resin
capacity outside the United States was about 1237.5 million kilograms
per year.   But there is no assurance that raw materials would be available
so that foreign producers could operate at 100 percent capacity in the
future.  Nor would there be any assurance that U. S. polyvinyl chloride
resin users would receive the additional supplies.
     2.3.1.4  Conclusions
     Complete prohibition of all vinyl chloride emissions would
require closure of vinyl chloride and polyvinyl chloride production
because there is no technology to achieve a zero emission limitation and
development of such technology is not foreseen.  Banning production
of vinyl chloride and polyvinyl chloride would have a negative impact on
the producing companies, especially on the three or four companies
which according to EPA's evaluation are highly dependent on sales of

                             2-24

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vinyl chloride and polyvinyl chloride and might therefore be expected to
fail if vinyl chloride and polyvinyl chloride production were banned.
There would be an even greater impact on unemployment at the approxi-
mately 8,000 fabrication plants which depend at least partially on
polyvinyl chloride as a raw material.  This impact would persist
unless and until these plants could adapt their equipment to
manufacturing substitutes.  With regard to the consumer, there are
substitutes for about 85 percent by weight of the uses of polyvinyl
chloride, but these substitutes would generally not be available for at
least two years, would generally be more expensive than polyvinyl
chloride products, and would not necessarily have some of the desirable
characteristics, such as nonflammability, of polyvinyl chloride.  In
view of (1) the beneficial uses of vinyl chloride products for which
desirable substitutes are not readily available, (2) the potential
adverse health and environmental impacts from substitutes which have not
been thoroughly studied, (3) the number of employees (particularly
in fabrication industries) who would become at least temporarily
unemployed, and (4) the availability of control technology which is
capable of substantially reducing emissions of vinyl chloride into the
atmosphere, EPA concluded that setting zero emission limits would be
neither desirable nor necessary.
     2.3.2  The Alternative of Best Available Control Technology
     An alternative interpretation of section 112 is that it authorizes
setting emission standards that require emission reduction to the
lowest level achievable by use of the best available control technology
in cases involving apparent non-threshold pollutants, where complete
                                2-25

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emission prohibition would result in widespread industry closure and
EPA has determined that the cost of such closure would be grossly
disproportionate to the benefits of removing the risk that would remain
after imposition of the best available control  technology.  EPA
recognizes that consideration of technology in  standard setting
is not explicitly provided for under section 112.  Congress never
discussed the particular problem associated with apparent non-
threshold pollutants.  The Administrator, however, believes that
Congress did not intend to impose the costs associated with complete
emission prohibition in every case involving such a pollutant.  The
best available control  technology approach will produce the most
stringent regulation of hazardous air pollutants short of requiring a
complete prohibition in all cases.  This interpretation of section 112
has been adopted for vinyl chloride.  This approach was used in the
case of asbestos, but has never been judicially tested.  The
purpose of the proposed standard is thus to minimize risk to public
health by establishing  an emission standard which will reduce emissions
to the level attainable with best available control systems.  An emis-
sion standard based on  best available control technology will result in
different total emission levels and different ambient air concentrations
at different plants due to variations in plant  sizes and configurations.
However, it will further the protection of public health by minimizing
the health risks to the people living in the vicinity of these plants
and to any additional people who are exposed as a result of new construction.
                             2-26

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     2.4  Selection of Source Categories
     There are four source categories of vinyl chloride emissions:
ethylene dichloride-vinyl chloride plants, polyvinyl chloride plants,
polyvinyl chloride fabricating plants, and miscellaneous sources.
In developing the proposed standard, EPA evaluated or is evaluating
                 Q
all four sources.
     2.4.1  Ethylene Dichloride-Vinyl Chloride Plants
     According to EPA estimates, 17 ethylene dichloride-vinyl chloride
plants were responsible for about 11 million kg (24.2 million pounds) of
vinyl chloride emissions in 1974.  This constituted 11 percent of total
emissions from all sources.  (See Table 2-1.)  These plants are
second to polyvinyl chloride plants as being the largest source
category of emissions.
     2.4.2  Polyvinyl Chloride Plants
     There are about 41 existing polyvinyl chloride plants which are
responsible for approximately 85 percent of the total nationwide emissions
of vinyl chloride.  In 1974, these emissions were 85 million kg  (187
million pounds).   (See Table 2-1.)  Information on the source categories
of vinyl chloride covered by the proposed standard, including polyvinyl
chloride plants,  is presented in more detail in the remainder of this
document.
     2.4.3  Polyvinyl Chloride Fabricating Plants
     There are about 8,000 polyvinyl chloride fabricating plants
emitting (in 1974) approximately 0.6 million kg/yr (1.3 million Ib/yr)
of vinyl chloride.  (See Table 2-1.)  A monitoring program conducted by
EPA at five fabricating plants indicated that ambient concentrations
                                2-27

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                              Table 2-1

        Estimated Vinyl Chloride Emissions in the U. S.-1974


                                   Estimated Vinyl Chloride  Percent of Total
                                      Emissions - 1974       Estimated Emissions
Source	Number of Plants    (1,000 Kg/yr)	1974	

Ethylene Dichloride-
Vinyl Chloride           17             11,000                        11
Plants

Polyvinyl Chloride
 Plants                  41             85,000                        85

Polyvinyl Chloride
 Fabricating Plants     ^8,000             600                         1

Miscellaneous Sources    8                ^3,000                       3


 Total                                  99,600                       100
                                 2-28

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around the perimeter of these plants are almost negligible.  At three of
the plants, no vinyl chloride was detected, and, where it was found, the
highest concentration was 6 parts per billion (ppb).
     According to an Arthur D. Little report,   the major emphasis
in 1974 on limiting vinyl chloride emissions at fabricating plants
was concentrated on reduction of vinyl chloride monomer content in
plant air in order to minimize risk to plant workers.  Manufacturers
believed that the most practical way to limit emissions both inside and
outside the plant was to reduce the monomer content in the incoming
resin.  As far as can be determined, all vinyl chloride emissions from
the fabricating plants are due to residual vinyl chloride in the
raw materials coming from the polyvinyl chloride plants.   Consequently,
vinyl chloride emissions from fabricating plants will be minimized
indirectly as polyvinyl chloride plants, in response to the proposed
standard, reduce vinyl chloride in these raw materials from as high as
1000 ppm to less than 10 ppm.  For the foregoing reasons, EPA has
concluded that no standard for fabricating plants is necessary at
the present time.
     2.4.4  Miscellaneous Sources of Vinyl Chloride
     For purposes of EPA action, sources of vinyl chloride emissions,
other than ethylene dichloride-vinyl chloride plants, polyvinyl
chloride plants, and polyvinyl chloride fabricating plants, are
classified as miscellaneous sources.  Of a number of miscellaneous
sources of vinyl chloride emissions, two major categories have been
identified.   The first category includes those plants that use vinyl
chloride as a chemical intermediate for the production of 1,1,1-
Trichloroethane (1,1,1-TCE) and 1,1,2-Trichloroethane (1,1,2-TCE)
                              2-29

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and for the production of other special  chemicals, e.g.  certain
pesticides, including endrin.   The percent of total  emissions of
vinyl chloride attributable to those plants is not known.   Some
emission controls have been reported by  1,1,1-TCE and 1,1,2-TCE
production plants integrated with ethylene dichloride-vinyl chloride
plants.   The extent and effectiveness of these controls, however, is
unknown at the present time.  Of the two plants manufacturing special
chemicals, one already vents gases to a  thermal oxidizer;  information on
the emission controls of the other is not yet available.
     The second category of miscellaneous sources includes those
plants that produce vinyl chloride as a  by-product.   Known to be in
this category are three plants manufacturing ethylene amines from
ethylene dichloride and one plant manufacturing ethylene inline from
ethylene dichloride.  An ADL study,   however, notes the possibility
that some industrial processes involving by-product vinyl  chloride
emissions have not been identified.  Total emissions from the sources
in this category are not known.
     Information on the use of emission  controls was unavailable for two
of the plants.  Of the other two, one reported the burning of vinyl
chloride in a flare tower as well as the current construction of
an incineration facility with a scrubber.  The remaining plant reported
current construction for incineration as an interim control and plans
for a solvent adsorption system as the permanent control.   The
reduction in vinyl chloride emissions that will be achieved by these
controls is unknown.
                               2-30

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     According to the EPA data, miscellaneous sources of vinyl
chloride emissions accounted for about 3 percent of the total estimated
1974 emissions from all sources.  (See Table 2-1.)  EPA is continuing
its research on vinyl chloride emissions from miscellaneous sources.
Although the proposed standard does not include these sources, there is
a possibility that EPA will conclude that regulations for them should
be proposed at a later date.
     2.5  Conclusions
     Based on the findings of health studies (section 2.2.1.1), EPA
has concluded that vinyl chloride, a carcinogen, is a hazardous pollutant
and that, as such, it must be regulated now.  A careful study of regulatory
options (section 2.2) indicated that section 112 of the Clean Air Act--
National Emission Standards for Hazardous Air Pollutants (NESHAP)-- is
the most effective mechanism for regulating vinyl chloride.
     EPA determined that the use of best available control technology
is the proper interpretation of section 112 for regulating an apparent
non-threshold pollutant, such as vinyl chloride, where complete
emission prohibition would result in widespread industry closure and
where the Administrator has determined that the cost of such closure
would be grossly disproportionate to the benefits to be achieved by
completely prohibiting emissions.
     Based on data available on emission levels, process equipment,
control technology, and costs of control technology, EPA concluded
that the proposed standard should cover ethylene dichloride-vinyl
chloride and polyvinyl chloride plants.  As noted above, future
action by EPA to control vinyl chloride emissions from miscellaneous
sources may be found necessary.
                              2-31

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     The proposed standard for polyvinyl chloride plants covers
any plant where vinyl chloride alone or in combination with other
materials is polymerized into polyvinyl chloride.  Thus, the
proposed standard includes plants which produce homopolymers in which
vinyl chloride is the only polymerized constituent and/or copolymers,
terpolymers, or any other polymers in which other raw materials in
addition to vinyl chloride are polymerized.  EPA considered exempting
from the proposed standard plants (six of the approximately 41 existing
plants) which produce a polymer in which vinyl chloride is less than
50 percent of the raw material polymerized.  EPA decided not to exempt
these plants from the proposed standard because the total vinyl
chloride emissions from a plant are more a function of the total quantity
of vinyl chloride processed in the plant than the percent vinyl chloride
contained in the resin.  Furthermore, available data indicate that the
processing equipment in these six plants is the same as in the plants
producing resins with higher percentages of vinyl chloride, so that the
same control technology can be applied and separate standards are not
required.
     Ethylene dichloride and vinyl chloride are typically produced at
one plant.  However, the proposed standard covers plants that produce
one and not the other as well as  plants  that  produce  hoth.   The
definition of ethylene dichloride plants contained in the proposed
standard limits the applicability of the proposed standard to the
production of ethylene dichloride by oxychlorination of ethylene.
Available data indicate that there are no vinyl chloride emissions from
direct chlorination of ethylene.
                               2-32

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                         References

1.   Preliminary Assessment of the Environmental Problems Associated
    with Vinyl Chloride and Polyvinyl Chloride, Report on the Activities
    and Findings of the Vinyl Chloride Task Force, compiled by the Office
    of Toxic Substances, Environmental Protection Agency, Washington, D. C.,
    September 1974.

2.   Scientific and Technical Assessment Report on Vinyl Chloride and
    Polyvinyl Chloride, compiled by Office of Research and Development,
    Environmental Protection Agency, Washington, D. C., June 1975.

3.   Preliminary Assessment of the Environmental Problems Associated with
    Vinyl Chloride and Polyvinyl Chloride, ibid., p. 2.

4.   Population Residing Near Plants Producing Vinyl Chloride, Prepared
    by the Environmental Health Hazards Project—American Public Health
    Association for the Office of Toxic Substances--U. S. Environmental
    Protection Agency, Washington, D. C., August 1975.

5.   Evaluation of Environmental Carcinogens.  Report by Ad Hoc Committee on
    the Evaluation of Low Levels of Environmental Chemical Carcinogens
    to the Surgeon General, USPHS, HEW, Washington, D. C., April 22, 1974,
    pp. 1,8.

6.   "Polyvinyl Chloride Resins,"  Chemical Economics Handbook, Stanford
    Research Institute, September 1973.

7.   Cited from "Economic Impact of a Shutdown of the Polyvinyl Chloride
    Industry," a study done for the Society of the Plastics Industry,
    Inc. by Arthur D.  Little, Inc., May 1974.

8.   Calculated from Modern Plastics, January  1974.

9.   Two studies by Arthur D. Little, Inc. (see footnotes 10 and 11) are
    currently being conducted for the U.  S.  Environmental Protection
    Agency.

10.  Vinyl Chloride Monomer Emissions from the Polyvinyl Chloride Processing
    Industries, Draft Report to U. S. Environmental Protection Agency by
    Arthur D. Little,  Inc., May 1975.

11.  Industrial Sources, Process, and Quantities of Vinyl Chloride Emissions
    in the U. S.  Other Than Those Connected  With The Manufacture of
    Vinyl Chloride or Polyvinyl Chloride, Draft Final Report to U. S.
    Environmental Protection Agency by Arthur D. Little, Inc., July 1975.
                               2-33

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 3.  THE ETHYLENE  DICHLORIDE-VINYL  CHLORIDE AND  POLYVINYL  CHLORIDE  INDUSTRIES

3.1  GENERAL
     This chapter will discuss the production of vinyl  chloride monomer
and the associated industries, ethylene dichloride and polyvinyl  chloride
production.  Ethylene dichloride is an important segment of the vinyl
chloride monomer industry in that, in 1974,  92  percent  of vinyl  chloride  monomer
production capacity was based on the pyrolysis  of ethylene dichloride.  The
other 8 percent was based on the addition of hydrogen chloride to  acetylene.
The 1974 production amounted to 2.6 billion  kilograms of vinyl chloride.
     In 1975 polyvinyl chloride resins were  produced by 23 companies at
41 plants by one or more of four processes—suspension, emulsion,  bulk,
and solution.
     Tables 3-1, 3-2, and 3-3 list the producing companies and indicate
the locations and the capacities of the three industries discussed.
Associated maps 3-1, 3-2, and 3-3 show the location of each of the plants.
Table 3-4 shows the producers of each type of polyvinyl chloride resin.
     The near term (i.e. next 2 to 3 years)  outlook for the vinyl  chloride
and polyvinyl chloride industry is uncertain.  There has been a dramatic
turnaround in the vital statistics of the total thermoplastic/thermoset
sector of the plastics industry of which polyvinyl chloride is a part.   In
1973 resin sales increased 12 percent over the  1972 level; production was
              14
up 10 percent.    Future demand and capacity assumptions at that time
yielded forecasts of improved operating rates and higher profits.   However,
                                 3-1

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at the end of 1974,  Society cf Plastics  Industry  data  revealed  total resin
production up 4 percent but sales  were up  only  1.7  percent.   Such data  are
not consistent with  projections of improved  operating  rates  and higher
profits.  It is difficult to make  an  assessment of  the near  term vinyl
chloride outlook with data specific to a much broader  industry  class.
     Chapter 7, Economic Impact, contains  an in-depth  look at the  industry
structure and projects the impact  of  various market influences  on  the
industry.
                                 3-2

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 3.2   DESCRIPTION  OF THE  PROCESS
      The purpose  of this section is  to  provide  a  orocess  description  and
 to identify each  source  of emission  in  different  types  of oolvvinvl chloride,
 vinyl  chloride, and ethylene  dichloride  plants.   The emission  sources  are
 described in  terms  of  stream  volumes  and  composition,   In  addition, a  discussion
 of the cause  of emission is presented.
 3.2.1   Ethylene Dichloride-Vinyl  Chloride  Production
      Vinyl  chloride is oroduced  in the United States by two methods, which  are
 distinguished by  the starting materials.   The first, accounting  for 8  percent
 of the total  vinyl  chloride  capacity is  the acetylene-hydrogen chloride
method.   The  second method, accounting for 92 percent of the total, is the
ethylene  dichloride  (dichloroethane)  process.  For a discussion of the chemical
and physical  properties of vinyl  chloride, see Scientific and Technical
Assessment Report of Vinyl Chloride and Polyvinyl  Chloride, a document prepared  by
 RPA's  Office  of Research and  Development.
3.2.1.1   Acetylene-Hydrogen Chloride  Process -
     Only two plants in the United States use this method  of producing vinyl
chloride which consists of the addition of hydrogen chloride to acetylene in a
reactor.  The acetylene path to vinyl chloride can be described as follows:
                        CH = CH + HC1 -> CH2 = CHC1
     The  reaction  is catalyzed in a large reactor  by mercuric chloride on an
activated carbon base at  85-141°C (185-285°F).   Figure  3-1  shows  a simplified
flow diagram for the acetylene process.   Vinyl  chloride  is produced in the
reactor and purified in subsequent columns.   The  purification is accomplished
by scrubbing with  water or solvent to remove unreacted  hydrogen chloride  and
acetylene.  The vinyl chloride is transferred to storage and the  material  scrubbed
from the process is  incinerated or otherwise treated.  As  of August 1,  1975,
neither of these plants were operating.
                                     3-3

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3.2.1.2  Ethylene Dichloride_Process -
     The principal process currently used to produce vinyl  chloride is
dehydrochlorination (removal of hydrogen chloride) of dry ethylene dichloride.
The ethylene dichloride path can be described as follows:
                      CH2C1CH2C1 + CH2 = CHC1 + HC1
     Typically, vinyl  chloride producers will return the hydrogen chloride
by-product of this process back to a system which makes more ethylene
dichloride.  This process is called the oxychlorination process and with
vinyl chloride production via ethylene dichloride "cracking", the two are
known  as the balanced process  (see  figures 3-2  and 3-4).  All  plants  differ
in their exact configurations  but the  process can be described generally
as follows:
     Ethylene is  directly chlorinated  with chlorine in a catalytic reactor
to produce ethylene dichloride.  The material is  transferred to  a finishing
column after being cooled by water  and brine condensers.  Noncondensable gases
are separated in  the finishing column  and vented  to the  atmosphere after
being  scrubbed with water or aromatic  solvent to  recover ethylene dichloride
and remove hydrogen chloride.
     The organic  liquid oroduct from the reactor  is ourified in  a finishing
column to produce pure ethylene dichloride.  Impurities, including other
chlorinated hydrocarbons, are  sent  to  disposal.
     No emissions of vinyl chloride have been reported from the  direct
chlorination process.
     The ethylene dichloride is transferred to a  cracking furnace operating
at approximately  510°C (950°F), where  vinyl chloride is produced.  The furnace
is packed with a  catalyst such as pumice, or charcoal.  The yield to vinyl
                                     3-5

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 chloride  is 94 to 97 percent.  The hot effluent gases are quenched and
 partially condensed by direct contact with cold ethylene dichloride in a
 quench tower  (see figure  3-3).
     The  separation of hydrogen chloride and product purification are
 generally accomplished in additional operations described below.  Each
 producer  has  minor modifications, in this process, but typically the following
 would be  included.  Hydrogen chloride is recovered and recycled to an oxychlorination
 plant which chlorinates ethylene with the chlorine in the hydrogen chloride.
 Because of the entrainment of some vinyl chloride in the hydrogen chloride
 recycle process, and the  generation of vinyl chloride in the nrocess, some
 vinyl chloride emissions  occur from the oxychlorination reactor.
     The ethylene dichloride produced from the oxychlorination process is
transferred to finishing  columns  for purification  as  described above  in
the direct chlorination step.  As there is still  some vinyl  chloride  in  the
system, some emissions  of vinyl  chloride occur from the ethylene dichloride
finishing columns.   The purified  ethylene dichloride  is used to produce-
more vinyl chloride in  the cracking plant.
     Vinyl chloride is  purified in finishing columns  which  vent some  vinyl
chloride.   The product  is transferred to a product storage  facility (usually
large spheres) before shipment by pineline or tank car.
     The ethylene dichloride and  vinyl  chloride finishing column vents
are sometimes  referred  to in this document as the  purification processes.
Typically, the total  vinyl chloride emissions from these  vents are 0.29  kg/100 kg
 (Ib VCM/100 Ib VCM)  produced.  The oxychlorination vent has  reported  vinyl
chloride emissions  of 0.0364 kg/100 kg  (Ib VCM/100 Ib VCM)  produced.8
                                     3-9

-------
     Ethylene dichloride - vinyl  chloride plants  also have fugitive  emissions
which include pump and valve emissions,  transfer  losses,  inprocess wastewater
losses, loading operation losses,  and sample flask losses.
     There are  special  problems involved with using  a material balance
 to  determine  the  fugitive  loss of vinyl chloride  from a vinyl chloride plant.
 The percentage  fugitive  loss f^om a  vinyl chloride olant  is smaller than the
 percentage fugitive loss from a oolyvinyl chloride plant.  For this reason
 it  is  necessary to measure  all streams more carefully to  determine the
 exact  amount  of fugitive emission.   However, there are several gas streams
 into and out  of these plants which are not measured  as accurately as the
 liquid and solid  streams into and out of a  oolyvinyl chloride nlant.  These
 streams include the gaseous chlorine and ethylene feedstocks.  For this reason
 material balance  values  for fugitive emissions from  vinyl  chloride olants
 are less accurate than  material balances values for  fugitive emissions from
 polyvinyl chloride plants.
     The total fugitive emissions, reported in table 3-1C  were estimated by
                                                              9
individual  vinyl chloride operating  companies in  June of 1974.    These
estimates  are based on material  balance  or emission values (found in the
literature)  for various sources.
3.2.2  Polyvinyl Chloride Proauction
     Polvvinyl  chloride is produced  by four types of processes in the United
States.  Three  of these are batch processes:  suspension polymerization, which
accounts for  78 percent of 1973 plant capacity; dispersion or emulsion
polymerization  accounting for 13 percent; and bulk (mass) oolymerization which
accounts for  6  percent.  The solution or solvent polymerization nrocess is
a continuous  process used by one company and accounts for 3 percent of United
States oolyvinyl  chloride capacity.
                                     3-10

-------
3.2.2.1   Suspension  Polymerization  -
      Figure 3-5  presents a  simplified  flow diagram for the suspension
process.  This is  by far the most common  nrocess used to manufacture oolyvinyl
chloride  resins  (78  percent of the  total  U. S. capacity).  The nrocess  involves
the  mixing of a  weighed amount of vinyl chloride in a metered amount of
water,  catalyst  and  suspending agents.  The ingredients are mixed in a
clean,  glass or  stainless steel lined, reactor.  A steam jet or vacuum pump
is used to remove  some of the air filling the reactor.  The amount of air
left depends on  the  absolute pressure  after evacuation.  The reactor is
jacketed  to provide  steam heat or water cooling as necessary to control
the  reaction which takes place.  The catalyst initiates the reaction and
the  suspending agent is used to keep vinyl chloride droplets small and dispersed.
Agitation is supplied to the "slurrv"  beino formed in the reactor by an agitator
located in the  bottom of  the vessel.  The  polymerization  reaction  continues
in the slurry droplets to  85 to  90  percent completion  which  requires
approximately six hours.   The 10 to  15 percent unreacted  vinyl  chloride
is present in  the vapor  space of the reactor,  is  dissolved  in  the  water,
or is dissolved  (or trapped  in)  the  polyvinyl  granule  itself.   The reactors
are generally 11,340  to  22,680  liters  (3000  to 6000  gallon)  kettles and the
tyoical  plant may have from  12  to 18 reactors.  Reactors  built within  the
last  three years  in new  plants  are  generally much  larger  (56,660 to 103,200
liters or  15,000  to 35,000  gallons)  and fewer  in  number  (4 to 8)  than the
older existing  reactors.
     Some  of the  unreacted  vinyl  chloride  in the  reactor  is  removed from
the batch  by vacuum and  transferred  to a monomer  recovery  system consisting
of compressors  and condensers.   The  vinyl  chloride  is  recovered to a  holdina
tank  for recycling.  Noncondensable  gases  (  such  as  the  reactor air described
above) accumulate in  the  recovery system  and must  be  vented.   The  venting
                                     3-11

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may be manual or automatic and periodic or continuous deoendina on the
system design and pressure.  With the venting of these gases, some vinyl
chloride is released.  This is referred to as Source Area D in figure 3-5
(Suspension Flow Diagram) and in table 3-6  (Summary of Emissions).
     Each  reactor is equipped with a "manhole", which is a hatch allowing
entry into the vessel.  The entry is necessary to clean the scale that is
left on the walls of the reactors after the slurry batch has been transferred
(usually pumped to another holding tank).  The scale must be removed to
insure the duality of the resin subsequently produced will be maintained.
The removal is done by high pressure water spray, by personnel who enter
the vessel and chip the scale away, or by a combination of these two methods.
     When  the hatch is opened the monomer which has not been removed by
the vacuum recovery system and which is still  in the gas phase is released
by purging the reactor with steam or air.   This is referred to as the "Reactor
Opening Loss" and  is  Source Area  B  in  table  3-6 and  figure  3-5.
The cleaning of the reactors typically takes place every two to six batches
(one to three days)  for about three hours.   The completion of this cleaning
and the closing of the reactor marks the completion  of the reactor cycle.
     The polymerization of vinyl  chloride usually  takes  place  at  a
pressure of about  5.1  to 6.8 atmospheres ana the polyvinyl  chloride
reactors  are  protected  from overpressure and catastrophic  rupture
by safety valves  or a combination of rupture discs and safety valves.   Because
of equipment failure,  power failure, or operator error,  run-away  reactions
occasionally occur in the reactors.   These  excursions  are  generally stopped
by releasing the  pressure and venting to stacks by either  automatic pressure
relief valves or  manual  venting.   The reason for the venting is  to protect
the vessel  from overpressure.   This  vent contains  a  large  amount  and  a high
                                     3-13
-------
 concentration of vinyl chloride  (typically 2270 kg or 5000 nounds) but only
 lasts 5  to  15 minutes.  Thirty-six plants report emission factors of 0.04-0.40
 kq/lOOkg (lb/100 Ibs)  of PVC produced from this source.1  Source Area B  in
 figure 3-5  and  table 3-6  describes this emission.
      From the reactor, the batch can be transferred into a second vessel  for
 further  processing.  In several  plants, the  slurry leaving the reactor
 is  Dumped to a  stripper.  A stripper is a kettle similar to  the reactor  in
 which vinyl chloride is  "stripped" from the  slurry by applying heat and/or
 vacuum to the reactor  contents for a period  of time.  Some plants perform
 this  step in the reactor, but nost producers do not wish to  "tie UD" the
 reactors with the  time consuming process (1-4 hours) since it can
reduce the production rate.   Heat is  applied by steam jacketing or  by direct
introduction of steam into the slurry.   The  vent gases  from the stripper are
transferred  to  the  monomer recovery system as described  above.
     In  some plants, the  stripper is  opened  to the  atmosphere following  the
vacuum step  of  stripping  in  order to  vent  the vessel  and transfer the  batch
to a tank where  the various  batches can  be blended  (the  slurry blend  tank).
This results in  some vinyl  chloride emissions.  In  other plants the  vinyl
chloride  which was  stripped  from  the  polymer is  released to  the atmosphere.
Seventeen plants reported vinyl  chloride emissions  associated with  the  stripping
operation varied between  zero  and 0.5 kg/100 kg  (lbs/100 Ibs) of PVC  produced.2
Source Area  C  describes this  emission point  on figure  3-5  and table 3-6.
     When stripping is  complete,  the  batch is transferred  to  the  slurry  blend
tanks  where  various batches  are  blended  together  to  form a  more uniform
product.   These  large tanks  (rthich typically  hold three  to  four batches)  are
generally open  to  the atmosphere. As  the  slurry  is mixed,  residual monomer
in the slurry  is released.   This  emission  (Source Area  E)  varies widely  from
                                     3-14
-------
 plant to  plant  depending  on  the  effectiveness of  stripping.  Thirty  plants
 reported  losses  of  between  0.01  and 0.7  kg/100 kg  (lbs/100  Ibs) of  PVC
 produced  (see table  3-6   and figure 3-5.)3
      From the blend  tank  the slurry is usually pumped to a centrifuge where
 as much water as possible is removed (source Area F).  Emissions of  vinyl chloride
 can take  place  from  the centrifuge casing.  The water is generally transferred
 to a  treatment  area  before being  disposed of or recycled (see section 4-10 of
 chapter 4).  Vinyl chloride  emissions occur from this water  and water from
 other  sources within the  plantt  e.g., reactor cleaning, floor cleaning,  etc.  It
 is reported that the concentration of vinyl chloride monomer from typical
 suspension polyvinyl chloride plant water streams before treatment ranges from
less  than 1 ppm to nearly 2000 ppm.    The wet  polyvinyl  chloride cake from the
centrifuge is dropped to a hot air dryer, usually  a  rotary  dryer,  where  the
remaining water is removed.   In the  dryer most of  the vinyl  chloride  remaining
in the resin is released.   This vinyl  chloride is  exhausted  from the  dryer
baghouses or cyclones and is  represented by Source Area  G  in table 3-5   and
figure 3-5.  The dried, solid, polyvinyl  chloride  particles  (resin)  are
collected by bag collectors  or cyclones.   From this  point  the resin  is  transferred
to storage or lagging ^reas   (Source  Area G).   The  residual  vinyl  chloride monomer
in the resin is released in  all  sources  downstream of the  stripping  operation.
These sources are the slurry  blend tanks, centrifuges, dryers,  and the  bulk
polyvinyl  chloride resin storage areas.   The  sum of  the  emissions  from  all these
sources is due entirely to the vinyl  chloride  content of the polyvinyl  chloride
resin leaving the strippers.
     The dryers, storage bins and silos,  bulkloading operations, bagging machines
and resin transfer operations are all  potential  sources  of  particulate  polyvinyl
chloride emissions.  When the product resin is transferred  by air to  any of the

                                     3-15
-------
above areas, its separation from the carrier air stream creates a source of
participate emissions.
     Finally, there are emissions which are unaccounted for in all other source
estimates.  These losses are called fugitive emissions and are the most difficult
to quantify.  Fugitive emissions as discussed here include emissions from (1)
the loading, unloading, sampling and storage of vinyl chloride, (Source Area A)
(2) pumps, compressor, and agitator seals, (3) pipe and equipment flanges and
manhole cover seals, (4) the opening of equipment for inspection and maintenance,
(5) leaking pressure relief valves, (6) sampling for laboratory analysis,
(7) vinyl chloride dissolved in process water exposed to the atmosphere, and
(8) manual venting of equipment.  The data presently available do not
permit an estimate to be made of the magnitude of the vinyl chloride
emission attributable to most of these categories individually.  Emissions
from source area 4 are estimated and presented in Tables 4-8
and 4-9 .  Emissions from source area 7 are detailed in table  3-11.   The
fugitive emission factor reported in table 3-11  was determined by averaging
                                                    4
individual operating company data from June of 1974.   The specific  emission
factors given in tables 4-8 and 4-9 were derived from data given to  EPA in
                        12 13
telephone conversations.  '    Table 3-11  was given to EPA in  a plant visit.
     An instantaneous value for the magnitude of the fugitive  emissions at any
one time is virtually impossible to determine.  Average values over  a period of
time can most accurately be determined by conducting material  balances.  In a
polyvinyl chloride plant, if the amount of vinyl chloride in the product is
deducted from the amount of vinyl chloride fed, the difference will  be the total
gas and solid loss from the system.  Some amount of this total loss  can be
measured accurately.  Waste polyvinyl chloride solid can be collected and weighed
and the vinyl chloride in the gas vent streams to the atmosphere and the waste
                                      3-16
-------
water streams can be measured.  If the known (or accountable) loss is deducted
from the total loss, the difference is the fugitive (or unaccountable) loss.
While it is possible that appreciable amounts of the losses reported here represent
solid losses, solid loss is more easily detected and measured than vinyl chloride
loss.  Most polyvinyl chloride producers assume that the unaccounted for loss in
polyvinyl  chloride plants consists primarily of vinyl chloride vapor emitted to
the atmosphere.
     The use of material balance to determine fugitive losses has several dis-
advantages.  The accuracy of the loss determination depends on the accuracy of the
measurements made.  If the vinyl chloride raw material and the polyvinyl chloride
product are weighed with an accuracy of +_ 1/2 percent then the calculated fugitive
loss may be as much as 1 percent high or 1 percent low (the loss would be 1 percent
higher than actual if the raw material measurement were 1/2 percent higher than
actual and the product measurement were 1/2 percent lower than actual).  An
accuracy of 1/2 percent  is about the best that can be expected using existing
measurement techniques.   Over a period of time high and low readings tend to
balance each other, and the accuracy of loss determination increases as the
time period over which the balance is made and as the number of readings
increases.   It is therefore difficult to make accurate balances over short
periods.   As  an example,  if an operational  upset  in a polyvinyl  chloride plant
causes an instantaneous  emission of two  thousand  pounds  of vinyl  chloride it
would not be  possible to  determine the  time  of the  emission  or the amount of
the emission  using this  method.   There  is  also an accounting problem associated
with using  material  balances  to  determine  loss.   All  waste polyvinyl  chloride
must be  collected  and weighed accurately and  the  vinyl  chloride  and  polyvinyl
chloride  in all  vents  from  the plant  must  be  determined.

                                     3-17
-------
     The total fugitive emissions reported in table 3-10  were determined
                                                                     5
by individual  polyvinyl chloride operating companies in June of 1974.
Because these emissions were determined using different procedures they
are not all exactly comparable.   In many cases the material  balances were
based on engineering estimates because the necessary plant data had not been
collected.  In those plants where the major emission sources had been
identified and measured, the reported unaccountable loss  would be less than
in those plants where these sources had not been measured.  Some plants that
had not measured the amount of scrap polyvinyl chloride produced estimated
the amount.
     Not all polyvinyl chloride plants weigh all vinyl chloride cars into
and out of the plant.  Some plants receive vinyl chloride by pipe line and
the amount received is calculated by tank level or integrated flow measurements.
Other polyvinyl chloride plants weigh all vinyl chloride received but operate
several processes from one viny"! chloride storage area.  Although the total
amount of  vinyl chloride used can be determined accurately the amount used by each
process can only be estimated.  This limitation is  important in plants
which produce two types of resin (dispersion and suspension, for  instance).
The storage area may be common to the two plants and accurate data on the
monomer received by each plant ~s difficult to obtain.
     The production of polyyinyl chloride conolymers, which are oolymers
derived from two monomers such as vinyl chloride and vinyl acetate, differs
from polyvinyl chloride homopolymer production in two resoects.  At least one
producer by-passes the recovery system in vinyl acetate-vinyl chloride copolymer
production because the vinyl  acetate can form acetic acid in the system and
corrosion  problems.  Other producers recycle both back to the process.  One
producer indicates that stripping is more difficult in conolymer production.
                                     3-18
-------
3-2.2.2  Dispersion (Emulsion) Polymerization -
     A simplified flow diagram for a typical dispersion oolymerization
plant is presented in figure 3-6.  This process is basically very similar
to the suspension process in that the batch reactor processes liauid
vinyl chloride dispersed in a water svstem.  The difference is that more soap
is added to the slurry to stabilize the monomer droplets and form agglomerates.
Emulsion resins can be polvmerized at lower temperatures and faster than
suspension resins.  The eguipment used to produce emulsion resins is almost
identical to suspension resin equipment.
     Emulsion resins are more sensitive to heat and shear stresses than
suspension resins and the resin particle if subjected to heat and shear may
be changed in ways that make it unsuitable for use.
     The main equipment difference between the two resins is the tyoe
dryer used.  Since the particle sizes obtained by dispersion polymerization
are much smaller than those obtained by suspension, spray dryers, which
ensure the maintenance of the small  particle size, are generally used.  These
dryers have much higher air volumes than the rotary, flash and fluidized
bed dryers used for suspension resin production.
     Latex resins are produced by the dispersion process.  The production
of these resins is similar to dispersion resins except that more soap
is added to the recipe and the product is sold without drying.
     Emissions from the sources within the dispersion plant are outlined
in table 3-7  which lists all sources within the plant and characterizes
emissions on a ka/100 kg (Ib VCM/100 Ib) PVC produced basis.
3.2.2.3  Bulk Polymerization -
     A bulk process flow sheet is shown in figure 3-7.  The process consists
of making "seed" polyvinyl  chloride  from liquid vinyl  chloride in a reactor
similar to that described in the suspension process.   Conversion of vinyl
                                     3-19
-------
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