United States Office of Air Quality
Environmental Protection Planning and Standards
Agency Research Triangle Park NC 27711
EPA-450/3-85-00£
January 1985
Air
Vinyl Chloride:
Relief Valve
Standard
SIS?
U
-------
EPA-450/3-85-002
Vinyl Chloride:
Relief Valve Standard
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
January 1985
-------
This report has been reviewed by the Emission Standards and Engineering Division of the Office of Air Quality Plar
and Standards, EPA, and approved for publication. Mention of trade names or commercial products is not intend
constitute endorsement or recommendation for use. Copies of this report are available through the Library Ser
Office (MD-35), U.S. Environmental Protection Agency, Research Triangle Park, N.C. 27711, or from National Tech
Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.
-------
TABLE OF CONTENTS
Section Page
Chapter 1 - INTRODUCTION 1-1
Chapter 2 - DATA BASE DESCRIPTION 2-1
2.1 VINYL INSTITUTE DATA 2-1
2.2 REGIONAL COMPLIANCE DATA 2-2
2.3 COMPARISON OF THE VINYL INSTITUTE AND REGIONAL COMPLIANCE
DATA BASES 2-2
Chapter 3 - SUMMARIES OF RELIEF VALVE DISCHARGE PERFORMANCE DATA . . 3-1
3.1 RELIEF VALVE DISCHARGE PERFORMANCE BY PVC PLANTS .... 3-1
3.2 RELIEF VALVE DISCHARGE PERFORMANCE BY EDC/VC PLANTS . . 3-2
Chapter 4 - CONTROL OF RELIEF VALVE DISCHARGES 4-1
4.1 CONTROL MEASURES AT PVC PLANTS 4-1
4.2 RVD CONTROLS AT PLANTS VISITED 4-9
4.3 CONTROL MEASURES AT EDC/VC PLANTS 4-10
Chapter 5 - CAUSES OF RELIEF VALVE DISCHARGES 5-1
Chapter 6 - BASIS OF SUMMARY TABLES 6-1
6.1 SUMMARIES OF VI DATA 6-1
6.2 SUMMARIES OF REGIONAL DATA 6-2
APPENDIX A - MEMORANDUM: VINYL CHLORIDE STANDARD - NUMERICAL
LIMITS FOR RELIEF VALVE DISCHARGES A-l
-------
LIST OF TABLES
Table Page
3-1 SUMMARY OF VINYL INSTITUTE DATA FOR PVC PLANTS 3-4
*
3-2 SUMMARY OF REGIONAL COMPLIANCE DATA FOR PVC PLANTS
(Number of Discharges/100 Batches) 3-6
3-3 SUMMARY OF REGIONAL COMPLIANCE DATA FOR PVC PLANTS
(Number of Discharges) 3-8
3-4 SUMMARY OF REGIONAL COMPLIANCE DATA FOR PVC PLANTS
(Lbs of Discharge/MM Lbs PVC) 3-10
3-5 SUMMARY OF REGIONAL COMPLIANCE DATA FOR PVC PLANTS
(Lbs of Discharge) 3-11
3-6 SUMMARY OF VINYL INSTITUTE DATA FOR EDC/VC PLANTS. . . . 3-12
3-7 SUMMARY OF REGIONAL COMPLIANCE DATA FOR EDC/VC PLANTS
(Number of Discharges/MM Lbs VC) 3-13
3-8 SUMMARY OF REGIONAL COMPLIANCE DATA FOR EDC/VC PLANTS
(Number of Discharges) 3-14
3-9 SUMMARY OF REGIONAL COMPLIANCE DATA FOR EDC/VC PLANTS
(Lbs of Discharge/MM Lbs VC) 3-15
3-10 SUMMARY OF REGIONAL COMPLIANCE DATA FOR EDC/VC PLANTS
(Lbs of Discharge) 3-16
4-1 RVD CONTROLS OBSERVED AT PVC PLANTS VISITED 4-2
4-2 RELIEF VALVE DISCHARGE CONTROLS AT FIVE PVC PLANTS ... 4-3
6-1 SUMMARY OF VINYL INSTITUTE RAW DATA FOR PVC PLANTS ... 6-5
6-2 SUMMARY OF VINYL INSTITUTE RAW DATA FOR EDC/VC PLANTS. . 6-8
6-3 SUMMARY OF 10-DAY REPORTS FOR PVC PLANTS 6-10
6-4 AVERAGE CAPACITY UTILIZATION RATES FOR VC AND PVC. . . . 6-23
6-5 ESTIMATED TYPICAL NUMBER OF BATCHES 'PER REACTOR 6-24
6-6 PRODUCTION CAPACITY OF PVC PLANTS 6-25
IV
-------
LIST OF TABLES (Continued)
Table Page
6-7 SUMMARY OF 10-DAY REPORTS FOR EDC/VC PLANTS 6-27
6-8 PRODUCTION CAPACITY OF EDC/VC PLANTS 6-32
-------
LIST OF FIGURES
Figure
5-1 Rupture Disc/Safety Relief Valve Assembly 5-3
vi
-------
1.0 INTRODUCTION
National emission standards for hazardous air pollutants (NESHAP) are
developed under the authority of Section 112 of the Clean Air Act. The
national emission standard for vinyl chloride (VC) was proposed on
December 24, 1975 (40 FR 59532) and promulgated on October 21, 1976
(41 FR 46559). The standard covers emissions of VC from sources in plants
producing ethylene dichloride (EDC), VC, and polyvinyl chloride (PVC). This
report presents an analysis of one currently regulated source of VC
emissions at EDC/VC and PVC plants—relief valve discharges. The purpose of
the analysis presented here is to characterize relief valve discharge
performance by plants under the current standard. The analysis was
performed to investigate the feasibility of restructuring the relief valve
discharge standard based on redefined numerical limits.
Information on relief valve discharge performance was obtained both
from EPA Regional Offices and industry. Section 2.0 describes the data
sources used in the analysis. Relief valve discharge performance by the
industry is summarized in Section 3.0. The techniques used by industry to
control relief valve discharges are described in Section 4.0. Causes and
preventability of relief valve discharges are discussed in Section 5.0.
Finally, Section 6.0 presents the methodology used to characterize relief
valve discharge performance from collected data.
1-1
-------
2.0 DATA BASE DESCRIPTION
Data from 44 of the 49 plants in the vinyl chloride industry were used
to analyze relief valve discharge performance under the current standard.
Included in the data base are 30 of 35 PVC plants representing 92 percent of
PVC production and all 14 EDC/VC plants. Relief valve discharge data were
obtained from two primary sources: EPA Regional Offices and the Vinyl
Institute. Descriptions of these two data sources follow
2.1 VINYL INSTITUTE DATA
Relief valve discharge performance data were supplied by the Vinyl
Institute (VI) for 29 of their member plants (19 PVC plants and 10 EDC/VC
plants). Data were supplied for a 25 month period from 8/81 to 8/83.
Information available in the VI data were:
- number of discharges/100 batches of resin produced (PVC plants only)
- number of discharges/MM Ib product
- number of discharges
- Ibs of VC discharged/100 batches of resin produced (PVC plants only)
- Ibs of VC discharged/MM Ib production
- Ibs of VC discharged
All data supplied were on a monthly basis (i.e., discrete totals for each of
the 25 months).
The data were divided into discharges from PVC plants and discharges
from EDC/VC plants. Data for PVC plants were separated into reactor and
nonreactor discharges. Reactor discharges were further separated by resin
type (i.e., suspension, dispersion, latex, bulk) and reactor size, large or
small. Reactors with a volume of greater than 10,000 gallons are defined as
large for the purposes of this study.
2-1
-------
2.2 REGIONAL COMPLIANCE DATA
Relief valve discharge compliance data representing 23 PVC plants and
13 EDC/VC plants were obtained from EPA Regional Offices (Regions II, V, and
VI) and one state agency (Texas). Data were obtained in the form of either
10-day reports or summaries of 10-day reports. Ten-day reports are
compliance reports that plants are required under the current VC standard to
submit within ten days of a relief valve discharge incident. Information
typically included in the 10-day reports are:
-. date of discharge
- estimated quantity of VC discharged
- source of discharge
- cause of discharge
- measures taken to prevent the discharge
- measures taken to prevent recurrence
Ten-day reports were obtained for the period 1978-1983. This represents the
entire compliance period since 1978. In total, data were compiled for 458
discharges from PVC plants and 142 discharges from EDC/VC plants. The total
amount of VC emissions associated with these discharges are 1.1 MM Ibs and
0.3 MM Ibs for PVC and EDC/VC plants, respectively.
2.3 COMPARISON OF THE VINYL INSTITUTE AND REGIONAL COMPLIANCE DATA BASES
Exclusive use of either one of the two primary data sources would have
omitted key information needed in the analysis of relief valve discharge
performance. For instance, the regional compliance data included
information on causes and estimated Ibs of VC discharged for individual
discharges. This information was not made available by the VI in their
data. Regional data was also available for a five and one-half year period
versus 25 months of data supplied by the Vinyl Institute. However, the VI
provided data on actual monthly production and batch frequencies by plants
for months when discharges occurred. Furthermore, they classified the
relief valve discharge data by source (i.e., reactor vs. nonreactor) and
2-2
-------
resin type for PVC plants. The regional compliance data for PVC plants did
not always include information on source and resin type for individual
discharges.
In general, where data were obtained for the same plants and period
from both sources, there appears to be general agreement. For instance,
comparison of the numbers and estimated pounds of discharges reported in
each data base indicate close agreement.
2-3
-------
3.0 SUMMARIES OF RELIEF VALVE DISCHARGE PERFORMANCE DATA
This section presents the relief valve discharge performance data for
PVC and EDC/VC plants that were compiled from the data sources described in
Section 2. Several formats were selected for expressing relief valve
discharge performance. Where appropriate, different data formats were used
for PVC plants and EDC/VC plants. For each of the selected formats, data
were compiled on an annual basis. Because limits based on rolling averages
may be selected for incorporation into the VC standard, the tabulated data
in some tables are compiled on an annual basis but with overlap between the
successive periods. In these tables, each new one-year period picks up the
next 6 calendar months and drops the preceding 6 calendar months so that the
tabulated values represent annual plant performance rolling every six
months. Other tables present data in a straight year by year format.
Tabulated summaries of relief valve discharge performance data are presented
for PVC and EDC/VC plants in the following sections. The basis for each of
the summary tables is discussed in Section 6.
3.1 RELIEF VALVE DISCHARGE PERFORMANCE BY PVC PLANTS
The study of relief valve discharge performance by PVC plants with
batch production processes was separated into two categories: reactor
discharges and nonreactor discharges. Reactor discharges were further
separated by resin type (i.e., suspension, dispersion, latex, and bulk) and
by reactor size, large or small. (Reactors larger than 10,000 gallons were
defined as large.) Relief valve discharge performance associated with the
continuous solution process for PVC was not separated according to reactor
and nonreactor discharges. Four formats were used to express relief valve
discharge performance by PVC plants. The four formats are:
- number of discharges
- number of discharges/100 polymerization batches
- Ibs of VC discharged
- , Ibs of VC discharged/MM Ibs of PVC production
3-1
-------
As discussed in Section 2, relief valve discharge data from two independent
sources were studied.
3.1.1 Vinyl Institute Data Summaries
A summary of the relief valve discharge performance data collected by
the Vinyl Institute from member companies is given in Table 3-1. For each
of the PVC producers surveyed, relief valve discharge performance data are
summarized in each of the four formats for three 12-month periods between
8/81 and 7/83. The Vinyl Institute data for individual plants were
initially separated for large and small reactors. However, preliminary
studies indicated no significant difference in the frequency and size of
discharges between large and small reactors. Thus, discharges from large
and small reactors are combined in Table 3-1.
3.1.2 Regional Compliance Data Summaries
Summaries of regional compliance data for PVC plants are given in
Tables 3-2 through 3-5 for each of the four formats. Regional compliance
data are summarized in each of the tables for 12-month periods between 1978
and 1983, where 10-day reports are available.
Preliminary studies of the regional compliance data indicated no
significant difference for large reactor performance versus small reactor
performance in the number of releases/100 batches format. Therefore, large
and small reactor discharges are combined in Table 3-2.
Data were unavailable to accurately estimate PVC production by resin
type at individual plants. Therefore, regional compliance data (in the
format of Ibs of VC discharged/MM Ibs PVC) are not presented by resin type.
3.2 RELIEF VALVE DISCHARGE PERFORMANCE BY EDC/VC PLANTS
Relief valve discharge performance for EDC/VC plants was studied
separately from PVC plants. The following formats were selected to express
relief valve discharge performance by EDC/VC plants:
3-2
-------
- number of discharges
- number of discharges/MM Ibs of VC production
- Ibs of VC discharged
- Ibs of VC discharged/MM Ibs of VC production
As" in the case of PVC plants, relief valve discharge data from the two data
sources described in Section 2 were studied.
3.2.1 Vinyl Institute Data Summaries
Table 3-6 presents a summary of the Vinyl Institute data for relief
valve discharge performance by EDC/VC plants. Performance by the VI-member
EDC/VC plants is summarized in each of the four selected formats for three
12-month periods between 8/81 and 7/83.
3.2.2 Regional Compliance Data Summaries
Summaries of regional compliance data are given in Tables 3-7 through
3-10 for each of the selected formats. Regional compliance data are
summarized in each of the tables for 12-month periods between 1978 and 1983,
where ten-day reports are available.
3-3
-------
TABLE 3-1. SUMMARY OF VINYL INSTITUTE DATA FOR PVC PLANTS
CO
I
Plant Number of Discharges/ 100 Batches
Code 8/81-7/82 2/82-1/83 8/82-7/82
Number of Discharges
8/81-7/82 2/82-1/83 8/82-7/83
Lbs DIscharged/MM
8/81-7/82 2/82-1/83
Lbs PVC
8/82-7/83
Lbs Discharged
8/81-7/82 2/82-1/83 8/82-7/83
Suspension Reactor Discharges
S-l 0.000625
S-2 0.0083
S-3* 0.032
S-4 0.0042
S-5 0
S-6 0.00017
S-7 0.0083
S-8 0
S-9* 0.018
S-10 0
S-ll 0
S-12 0
S-13 0.067
S-14 0.033
S-15 0
S-16* 0.0083
S-17 0.017
0
0.033
0.032
0.0042
0
0.00017
0
0
0
0
0
0
0.101
0,033
0
0.017
0
Plant Down
0.025
0.025
0
0
0.00025
0
0
0.012
0
0.0109
0
0.059
0
0
0.034
0
1
0
1
0
0
0
7
1
0
1
3
0
3
1
1
0
1
0
0
0
0
0
0
10
1
0
2
0
Plant Down
2
1
0
0
1
0
0
1
0
3
0
6
0
0
4
0
28.0
0.4
2.3
0.025
0
0.02
142
0
0.68
0
0
0
109
14.6
0
0.66
86
0
4.7
2.3 '
0.025
0
0.02
0
0
0
0
0
0
277
14.6
0
43
0
Plant Down
4.3
5.5
0
0
0.2
0
0
0.43
0
13.7
0
187
0
0
54
0
2,350
146
326
4
0
2
12.8
0
100
0
0
0
14,175
2.000
0
155
21.000
0
1,530
326
4
0
2
0
0
0
0
0
0
35,852
2,000
0
8,718
0
Plant Down
1,384
1,009
0
0
11
0
0
100
0
1,000
0
24,361
0
0
10,818
0
Dispersion Reactor Discharges
D-l 0
D-2* 0
D-3* 0
D-4 0
0-5 0.0225
D-6 0
0
0
0
0
0.035
0
0
0
0
0
0.035
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
13.2
0
0
0
0
0
153
0
0
0
0
0
153
0
0
0
0
0
585
0
0
0
0
0
3.830
0
0
0
0
0
3,830
0
Latex Reactor Discharges
L-l 0
L-2 0
L-3 0
Bulk Reactor Discharges
M-l* 0
H-2 0.125
M-3 0.116
Nonreactor Discharges
N-l 0.225
N-2* 0.025
N-3 0.168
N-4 0.10
N-5* 0
N-6 0.005
0
0
0
0
0.033
0.052
0.117
0.025
0.275
0.0017
0
0
0
0
0.033
0.03
0
0.125
0.0833
0.0083
Plant Down
0
0
0
0
0
0
0
2
8
12
2
2
5
0
1
0
0
0
0
1
3
7
2
1
1
0
1
0
0
1
1
0
8
6
1
Plant Down
0
0
1
0
0
0
0
405
336
2.5
10
1.1
2.7
0
3.5
0
0
0
0
158
82
1.0
7.9
3.6
0.17
0
9.6
0
0
0.16
30.7
0
267
1.4
0.0025
Plant Down
5.6
0
9.6
0
0
0
0
14,940
26,940
1,150
1,391
87
527
0
511
0
0
0
0
9,090
5,555
550
1,188
77
57
0
0
0
0
4
1,192
0
19,665
400
0.4
Plant Down
0
0
0
-------
TABLE 3-1. (Continued)
Plant
Code
N-7
N-8
N-9
N-10
M-ll*
N-12
N-13
N-14
N-15
N-16
N-17
H-18
N-19
Number of
8/81-7/82
0
" 0.0092
0.005B
0.126
0.014
0.025
0
0
0
0.020
0
0
0.0067
Discharges/ 100 Batches
2/82-1/83 8/82-7/82
0
0.0092
0.0083
0.054
0.014
0.025
0
0
0
0.020
0
0.017
0.010B
0
0
0.0083
0.0433
0
0
0
0
0.0056
0
0
0.017
0.0158
Number of Discharges
8/81-7/82 2/82-1/83 8/82-7/83
0
1
1
2
1
1
0
0
0
1
0
0
1
0
1
1
1
1
1
0
0
0
1
0
1
2
0
0
1
1
0
0
0
0
1
0
0
1
3
Lbs DIscharged/MM Lbs PVC
8/81-7/82 2/82-1/83 8/82-7/83
0
8.5
0.1
2.7
0.79
3.0
0
0
0
17
0
0
2.6
0
8.5
0.0083
0.26
0.79
3.0
0
0
0
17
0
9.6
2.3
0
0
0.0083
0.23
0
0
0
0
0.064
0
0
9.6
2.7
Lbs Discharged
8/81-7/82 2/82-1/83 8/82-7/83
0
1.200
27
341
100
605
0
0
0
1,000
0
0
379
0
1,200
2
41
100
605
0
0
0
1,000
0
810
408
0
0
2
42
0
0
0
0
10
0
0
810
482
*Plants visited.
CO
en
-------
TABLE 3-2. SUMMARY OF REGIONAL COMPLIANCE DATA FOR PVC PLANTS
(Number of Discharges/100 Batches)
CO
en
Plant
Code
Suspension
R-l
R-2
R-3
R-4
R-5,
R-6a
R-7a
R-8a
R-9
R-10
R-ll
R-12
R-13
R-14
R-15
R-17
R-18
R-19
Dispersion
R-ll
R-13
R-18
R-19
R-8?
R-6a
2/78-1/79 8/78-7/79
2/79-1/80
8/79-7/80
2/80-1/81
8/80-7/81
2/81-1/82
8/81-7/82
2/82-1/03
8/82-7/83
Reactor Discharges
0.04
0.017
0.011
(Plant
0.02
0.016
0
0.01
0
0.015
0.0083
0
0.053
0.013
0.013
0.010
0.0078
0.32
0.059
0.016
0.011
start up
0.02
0.026
0
ID
0
0.044
0
0
0.059
ID
ID
ID
0.0077
0.21
0.039
0
0.022
10/79)
0.058
0.046
0
ID
0.032
0.043
0
0
0.051
ID
ID
ID
0.0075
0.064
0.043
0
0.059
0.062
0.039
0
ID
0.036
0.055
0
0
0.014
ID
ID
ID
0.042
0.094
'0.024
0
0.079
0
0.013
0.019
0
ID
0
0.062
0.020
0
O.OOB
ID
0
0.012
0.042
0.12
0
0
0.026
0
0.084
0.019
0
ID
0
0.027
0.020
0
0
ID
0.04
0.012
0.005
0.080
0
0
0
0
0.070
0.013
0.021
0
0
0.036
0.020
0
0
ID
0.056
0.012
0.005
0.11
0
0.031
0.011
0
0.011
0.0083
0.018
0
0
0.028
0.021
0
0
ID
0.026
0.013
0.006
0.085
0
0.031
0.024
0
0.024
0.017
0
0
0
0.020
0
0
0
0.018
0.0091
0.014
0.015
0.015
0
0
0.01
0 0
0.02
0.032
0.012
0.025
0.01
ND
ND
0
0
0.016
0
0.012
0.0066
ND
Reactor Discharges
0.027
0.014
0
0.19
0.028
0
0.022
0.014
0
0.16
0.028
0
0.013
0.014
0
0.054
0
0
0.0095
0.030
0
0
0
0
0.016
0.033
0.022
0
0
0
0.005
0
0.022
0.033
0.20
0
0
0
0
0.034
0.20
0
0
0
0
0
0
0
0
0
0
0.039
0
0
ND
0
0
ND
0
0
Latex Reactor Discharges
R-ll
0.067
0
0
0
0
0
0
0
0
0
Bulk Reactor Discharges
R-8a
R-20a
R-21a
R-22
0
0.18
0
0.052
ID
0.077
0
0.12
ID
0.076
0
ID
ID
0.083
0
ID
ID
0.030
0
ID
ID
0.077
0.041
ID
0
0.078
0.042
ID
0.041
NO
0
ID
0.041
ND
0
0.051
0.030
ND
o
0.094
-------
TABLE 3-2. (Continued)
CO
i
Plant
Code
/
Noneeactor
R-l
R-2
R-3
R-4
R-5a
R-6"
R-7a
R-8a
R-9a
R-10
R-ll
R-12
R-13
R-140
R-15
R-17
R-18
R-19
R-20
R-21a
R-22
2/78-1/79
Discharges
0
0
0.011
(Plant
0.080
0
0
0.012
0
0
0.014
0
0.036
ID
0
0.039
0.026
0.079
0
0
0.010
8/78-7/79
0
0.016
0.011
start up
0.059
0
0
ID
0
0
0.016 •
M).013
0
ID
ID
ID
0.019
0.047
0
0
ID
2/79-1/80
0.019
0.016
0.011
10/79)
0.078
0
0
ID
0
0.007
0.019
MJ.013
0.004
ID
ID
ID
0.009
0.008
0
0
ID
8/79-7/80
0.021
0
0.012
0.35
0.11
0
0
ID
0
0.008
0.018
0
0.024
ID
ID
ID
0.007
0
0
0
ID
2/80-1/81
0
0
0.053
0.68
0.17
0
0
ID
0
0
0.013
0
0.021
ID
0
ID
0.004
0
0
0
ID
8/80-7/81
0
0
0.034
0.57
0.16
0
0.021
ID
0
0.009
0.013
0
0
ID
0
ID
0.004
0.028
0
0
ID
2/81-1/82
0
0.020
0.013
0.21
0.070
0
0.021
0
0
0.018
0.0082
0
0
ID
0
0
0.012
0.029
NO
0
ID
8/81-7/82
0
0.062
0.022
0.12
0.055
0.0075
0
0
0
0.009
0.003
0
0.0042
0
0
0
0.009
0
ND
0
ID
2/82-1/83
0
0.031
0.016
0.054
0.074
0.0075
0
0.012
0
0
0.003
0
0.0042
0
0
0
0.018
0
ND
0
0.017
8/82-7/83
0
0
0.007
0
0.030
0
0
0.0097
0
ND
0.003
0
0
0
0
0.005
0
ND
0
0
ND • No Data; neither 10-day reports nor summaries of 10-day reports available.
ID = Incomplete Data; 10-day report not available for all discharges.
aP1ants visited.
-------
TABLE 3-3. SUMMARY OF REGIONAL COMPLIANCE DATA FOR PVC PLANTS
(Number of Discharges)
CO
i
00
Plant
Code 2/78-1/79 8/78-7/79
Suspension
R-l
R-2
R-3
R-4
R-5.,
R-6a
R'7»
R-8"
R-9a
R-10
R-ll
R-12
R-13
R-14
R-15
R-17
R-18
R-19
Dispersion
R-ll
R-13
R-18
R-19
R-8j
R-6a
2/79-1/BO
8/79-7/80
2/80-1/81
8/80-7/81
2/81-1/82
8/81-7/82
2/82-1/83
8/82-7/83
Reactor Discharges
2
1
1
(Plant
1
3
0
1
0
2
1
0
8
1
2
1
2
29
3
0
1
startup
1
5
0
ID
0
6
0
0
9
ID
ID
ID
2
19
2
0
2
10/79)
3
9
0
ID
2
6
0
0
8
ID
ID
ID
2
6
2
0
5
0
4
7
0
ID
2
7
0
0
2
ID
ID
ID
10
8
1
0
6
0
1
3
0
ID
0
7
2
0
1
ID
0
1
9
9
0
0
3
0
7
3
0
ID
0
3
2
0
0
ID
5
1
1
6
0
0
0 '
0
7
2
1
0
0
4
2
0
0
ID
7
1
1
8
0
1
1
0
1
1
1
0
0
3
2
0
0
ID
3
1
1
6
0
1
2
0
2
2
0
0
0
2
0
0
0
1
1
1
2
1
0
0
1
0
1
4
1
1
1
ND
ND
0
0
1
0
1
1
ND
Reactor Discharges
6
1
0
7
1
0
5
1
0
6
1
0
3
1
0
2
0
0
2
2
0
0
0
0
3
2
1
0
0
0
1
0
1
1
6
0
0
0
0
1
6
0
0
0
0
0
0
0
ND
0
0
1
0
0
ND
0
0
ND
0
0
Latex Reactor Discharges
R-ll
1
0
0
0
0
0
0
0
0
0
Bulk Reactor Discharges
R-8a
R-20
R-21a
R-22
0
14
0
5
ID
6
0
ID
ID
6
0
ID
ID
6
0
ID
ID
2
0
ID
ID
5
1
ID
0
5
1
ID
1
ND
0
ID
1
ND
0
3
1
ND
0
6
-------
Table 3-3. (Continued)
CJ
i
CO
Plant
Code
2/78-1/79 8/78-7/79
2/79-1/80
8/79-7/80
2/80-1/81
8/80-7/81
2/81-1/82
8/81-7/82
2/82-1/83
8/82-7/83
Monreactor Discharges
4
R-l
R-2
R-3
R-4
R-5a
R-6»
R'7a
R-8»
R-9"
R-10
R-ll
R-12
R-13
R-14
R-15
R-17
R-18
R-19
R-20
R-21
R-22
Solution
R-23
0
0
1
4
0
0
2
0
0
5
0
8
0
0
5
8
10
0
0
1
Process
1
0
1
1
(Plant Startup
3
0
0
ID
0
0
6
I
0
ID
ID
ID
6
6
0
0
ID
Discharges
2
1
1
1
10/79)
4
0
0
ID
0
1
7
1
1
ID
ID
ID
3
1
0
0
ID
2
1
0
1
11
7
0
0
ID
0
1
6
0
5
ID
ID
ID
2
0
0
0
ID
1
0
0
4
23
13
0
0
ID
0
0
4
0
4
ID
0
ID
1
0
0
0
ID
0
0
0
4
19
15
0
1
ID
0
1
4
0
0
ID
0
10
1
3
0
0
ID
0
0
1
2
7
7
0
1
0
0
2
3
0
1
ID
0
0
3
3
ND
0
ID
0
0
2
3
2
5
1
0
0
0
1
1
0
1
ID
0
0
2
0
ND
0
ID
0
0
1
2
1
6
1
0
1
0
0
1
0
0
0
0
0
3
0
ND
0
1
0
0
0
1
0
3
0
0
1
0
ND
0
0
1
0
3
0
1
0
ND
0
0
0
ND = No Data; Neither 10-day reports nor summaries of 10-day reports available.
ID » Incomplete Data; 10-day reports not available for all discharges.
"Plants visited.
-------
TABLE 3-4. SUMMARY OF REGIONAL COMPLIANCE DATA FOR PVC PLANTS
(Lbs Discharged/MM Lbs PVC)
Plant
Code
R-l
R-2
R-3
R-4
R-5
R-6b
R-7b
R-8b
R-9b
R-10
R-ll
R-12
R-13
R-H
R-15
R-16
R-17
R-18
R-19
R-20
R-21
R-22
R-23
Resin
Type(s)
Produced
S
S
S
S
S
S.D
S
S.D.B
S
S
S.D.L
S
S,D
S,D
S
S
S
S,D
S,D
B
B
B
So
1978
470
46
10
(Startup
10/79)
19
18
0
105
0
28
170
0
490
1C
38
ND
14C
35
520
16
0
100
27
1979
400
1
26
0
6
120
0
56
0
27
45
1
150
23
25
6
77
11
160
21
0
340
80
1980
67
0
150
31
13
23
0
56
5
85
21
0
210
9
0
276
15
340
290
34
0
205
0
1981
0
1
1
14
6
11
4
200
0
106
100
0
4
1
380
74
5
4
90
100
1
300
0
1982
0
19
28
1
1
41
0
5
0
47C
2C
0C
Oc
1
12
0
0
52
140
ND
0
140
0
1983C
0
ND
ID
ND
ID
10
1
11
1
ND
ND
ID
ND
1
0
0
38
ND
ND
ND
0
150
0
ND = No data; 10-day reports not available.
ID = Incomplete data; 10-day reports not available for all discharges.
aResin type code: S = suspension; D = dispersion; L = latex; B = bulk;
So = solution.
bPlants visited.
cData may be incomplete.
3-10
-------
TABLE 3-5. SUMMARY.OF REGIONAL COMPLIANCE DATA FOR PVC PLANTS
(Lbs Discharged)
CO
I
Plant
Code
R-l
R-2
R-3
R-4
R-5.
R"6b
R~7b
R'8b
R-9D
R-10
R-ll
R-12
R-13
R-14
R-15
R-16
R-17
R-18
R-19
R-20b
R-21D
R-22
R-23
Resin
Types
Produced
S
S
S
S
S
S.D
S
S.D.B
S
S
S,D,L
S
S,D
S,D
S
S
S
S,D
S,D
B
B
B
So
1978
80,000
10,249
3,000
(Startup
10/79)
4,297
6,000
0
13,710
0
2,937
44,860
0
84,144
25
1,925
ND
1,840
6,356
77,500
2,690
0
15,405
4,586
1979
71,500
120
7,760
0
1,450
41,740
0
7,331
0
2,891
11,664
60
25,506
1,640
1,250
366
10,345
1,989
25,600
3,700
0
53,800
12,961
1980
10,000
0
37,934
5,030
4,350
5,510
0
6,164
1,213
7,658
4,553
0
30,161
511
0
13,809
1,724
51,705
37,300
4,700
0
28,677
0
1981
0
167
484
2,170
2,150
2,550
600
48,865
0
9,515
21,860
0
511
81
15,315
3,718
585
552
11,700
13,100
105
39,097
0
1982
0
2,605
12,546
41
650
8,818
0
1,188
0
3,784
596
0
0
2
412
0
0
4,153
16,000
ND
0
10,055
0
1983C
0
ND
19
ND
400
2,100
100
2,393
100
ND
ND
0
ND
11
0
0
3,830
ND
ND
ND
0
10,880
0
ND = No Data; 10-day reports not available.
aResin type code: S = suspension; D = dispersion; L = latex; B = bulk; So = solution,
Plants visited.
Data may be incomplete.
-------
TABLE 3-6. SUMMARY OF VINYL INSTITUTE DATA FOR EDC/VC PLANTS
CO
I
t—«
ro
Plant
Code
E-l
E-2
E-3
E-4
E-5
E-6
E-7
E-B
E-9
E-10
Number of DIscharges/MM Lbs of
VC Production
8/81-7/82 2/82-1/83 8/82-7/83
0.0085
0.0042
0.0086
0
0.0012
0.020
0.016
0.0017
0.0075
0.0025
0.0085
0.013
0.0087
0
0.0012
0.0082
0.019
0.0017
0.0083
0.0083
0.028
0.018
0.0067
0.0025
0
0.0064
0.020
0
0.0067
0
Number of Discharges
8/81-7/83 2/82-1/83 8/82-7/83
1
1
5
0
1
4
3
1
4
2
1
5
6
0
1
4
3
1
5
1
5
7
5
3
0
3
3
0
5
0
Lbs Discharged/MM Lbs VC Lbs Discharged
0/81-7/82 2/82-1/83 8/82-7/83 8/81-7/8? 2/82-1/33 8/82-7/83
0.6
0.2
25
0
0.1
11
17
2
1
140
0.6
22
26
0
0.1
2.4
4.5
2
17
52
51
30
8
4
0
3
7
0
16
0
71
54
15,905
0
80
2,049
3,805
1,150
506
89,798
71
10,434
16,203
0
80
1,113
640
1,150
12,540
43,209
12,659
14,264
5,585
4,351
0
1,360
972
0
12,214
0
-------
TABLE 3-7. SUMMARY OF REGIONAL COMPLIANCE DATA FOR EDC/VC PLANTS
(Number of DIscharges/MM Lbs of VC Production)
Plant
Code
RE-1-
RE-2
RE-3
RE-4
RE-5
RE-6
RE-7
RE-8
RE-9
u> RE"10
C RE-ll
RE-12
RE-13
2/78-1/79
0.0090
0
8/78-7/79
0.0055
0
2/79-1/80
0.0032
0
8/79-7/80
0
0.0016
2/80-1/81
0.0025
0.0033
8/80-7/81
0.0068
0.0036
2/81-1/82
0.0061
0.002
8/81-7/82
0.0016
0.0019
2/82-1/83
0
0.0067
(Plant startup 11/82)
0
0
0.0038
0
0.0032
0.0057
0.0040
0.0045
ND
0.018
0
0.011
0
0.0031
0.0028
0.0039
0.0053
ND
0.018
0.0015
0.018
0
0.0031
0
0.0038
0.0034
(Plant
0.0011
0.025
0.0033
0.015
0
0.0016
0
0.0027
0.0009
startup late
0.0063
0.027
0.0054
0.0083
0
0
0
0
0.0020
1980)
0.0087
0.0033
0.0039
0.018
0
0
0.031
0.0016
0.0033
0.0031
0.0041
ND
0.0087
0.020
0.025
0
Oa028
0.0018
0.0012
0.0030
0.0076
ND
0.025
0.016
0.042
0.0017
0.0081
0.0012
ND
0.0031
0.016
ND
0.0082
ND
0.026
0.0017
0.0044
0.0012
ND
0
0.0097
8/82-7/83
ND
ND
0.012
ND
0.0064
ND
0.010
0
ND
0
ND
0.0016
0
ND * No Data; 10-day reports not available.
-------
TABLE 3-8. SUMMARY OF REGIONAL COMPLIANCE DATA FOR EDC/VC PLANTS
(Number of Discharges)
Plant
Code
RE-1
RE-2
RE-3
RE -4
RE-5
RE-6
RE-7
RE -8
RE -9
RE- 10
RE-11
RE-12
RE-13
2/78-1/79
8
0
0
0
1
0
2
2
3
5
ND
8/78-7/79
5
0
5
0
3
0
2
1
3
6
ND
2/79-1/80
3
0
5
1
5
0
2
0
3
4
(Plant
1
8/79-7/80
0
1
7
2
4
0
1
0
2
1
startup late
5
2/80- 1/81
2
2
B
3
2
0
0
0
0
2
1980)
7
8/80-7/61
5
2
1
2
4
0
0
15
1
3
2
3
2/81-1/82
4
1
(Plant startup
ND
4
4
5
0
17
1
1
2
5
8/81-7/82
1
1
11/82)
ND
5
3
8
1
5
1
ND
2
10
2/82-1/83
0
4
ND
4
ND
5
1
3
1
ND
0
6
8/82-7/83
ND
ND
4
ND
3
ND
2
0
ND
0
ND
1
0
ND * No Data; 10-day reports not available.
-------
TABLE 3-9. SUMMARY OF REGIONAL COMPLIANCE DATA FOR EDC/VC PLANTS
(Lbs Discharged/MM Lbs of VC Production)
Plant
Code
RE-1
RE-2
RE-3
RE-4
RE-5
RE-6
RE-7
RE-8
RE-9
RE-10
RE- 11
RE-12
RE-13
1978
1
0
4
0
0
0
1
1
10
21
1
ND
1979
3
0
24
2
2
0
9
0
23
5
(Plant
ND
1980
2
1
(Plant start up
10
8
14
0
0
0
0
1
start up late 1980)
1
1981
5
1
11/82)
0
6
2
1
0
21
1
1
5
71
1982
0
20
1
ND
2
58
70
2
23
1
ND
0
70
a
1983
0
0
16
ND
3
ND
0
ND
ND
0
ND
1
ND
ND = No Data; 10-day reports not available.
aData may be incomplete.
3-15
-------
TABLE 3-10. SUMMARY OF REGIONAL COMPLIANCE DATA FOR EDC/VC PLANTS
(Lbs Discharged)
Plant
Code
RE-1
RE-2
RE-3
RE-4
RE-5
RE-6
RE-7
RE-8
RE-9
RE-10
RE-11
RE-12
RE-13
1978
638
0
1,170
0
0
0
24
109
7,500
23,200
(Plant start
ND
1979
2,638
0
6,870
1,530
660
0
6,000
0
17,700
6,280
up late
ND
1980
1,967
485
(Plant start
3,220
4,490
3,300
0
0
0
0
450
1980) 1,670
565
1981
2,961
9
up 11/82)
0
2,740
320
108
0
12,700
1
1,030
5,123
46,722
1982
0
12,240
40
ND
1,110
11,000
13,270
1,150
15,900
80
ND
0
43,291
1983a
0
0
5,160
ND
1,230
ND
0
ND
ND
0
ND
84
ND
ND = No Data; 10-day reports not available.
Data may be incomplete.
3-16
-------
4.0 CONTROL OF RELIEF VALVE DISCHARGES
This section documents the experience and information about control of
relief valve discharges obtained in the various phases of the review study
for the VC standard. The original standards support document (EPA-450/2-75-
009) and the review study (EPA-450/3-82-003) identified some methods
employed to prevent relief valve discharges. The 10-day compliance reports
obtained from EPA Regional Offices also provided information on preventive
measures. Finally, information obtained during five plant visits is
included in Tables 4-1 and 4-2. Reports documenting these visits are
contained in Docket Number A-81-21.
A variety of methods are used by PVC and EDC/VC producers to prevent
relief valve discharges. In general, these methods involved implementation
of equipment modifications, process modifications, or operational practices.
The exact combination of modifications and operational practices implemented
varies plant by plant. Effectiveness of individual measures intended to
prevent relief valve discharges is difficult to discern and consequently,
emission reductions can not be assigned to individual control measures.
Because no specific combination of RVD control measures were required by
EPA, individual producers have implemented the combination of control
measures they judged to be needed to comply with the standard.
4.1 CONTROL MEASURES AT PVC PLANTS
Descriptions of the control measures used by various PVC plants to
prevent relief valve discharges follow.
Shortstop Systems
A shortstop system can be used to stop the polymerization reaction when
upset conditions develop. A shortstop system injects a chemical agent into
the reactor which terminates the reaction by inhibiting the action of the
initiator. The system is either manual, automated, or a combination of the
4-1
-------
TABLE 4-1. RVD CONTROLS OBSERVED AT PVC PLANTS
Control Measure Number of Plants (of 5 Total)
Hardware
Computer Control 3
Backup Power 4
Supplemental Reactor Cooling 4
Gasholder 3
Shortstop System 4
Redundant Instrumentation 4
Preventive Maintenance
Rupture Disc Maintenance 4
Relief Valve Maintenance 4
Other (Specific to RVD Prevention) 2*
Operating Training
Initial Training - Classroom 4
- On-The-Job 5
- Formal Progress Review 3*
Continuing Training - Routine Safety Meetings 5
- Other 2
Review of RVD (or "Near Miss") Incident With
Operators(s) 5
*It is unknown whether the other plants that were visited have implemented
these measures.
4-2
-------
TABLE 4-2. RELIEF VALVE DISCHARGE CONTROLS AT FIVE PVC PLANTS
-F*
I
CO
Control Measure
i
Shortstop System
- automatic/computer activated
- automatic/operator activated
- portable/manual
- backup
Redundant Instrumentation
- reactor process sensors
- reactor charging operations
- estimated degree of redundancy
Computer Control
- redundant (computer) backup
- manual (panel) backup
- operations controlled
Backup Power
- agitators/support equipment
- computer/ Instruments
- pumps/compressors/seal oil
circulation
- refrigeration
R-6
No
Yes - large suspension
reactors only
Yes - small reactors
Unknown
No
Yes - large suspension
reactors only
Low
No
No
None
Yes
No
Yes
No
R-8
No
Yes - suspension
Yes
Yes - portable
Yes
Yes
High
Yes
Yes - large sus-
pension reactors
only
All
Yes
Yes
Yes
No
Plant Code
R-9
Yes
Yes
No
Unknown
Yes
Yes
High
Yes
No
All
No
No
No
No
R-7
No
Yes
No
Yes - Manual
activation
Yes
Yes
High
Yes
Yes
Reactor charging,
polymerization and
blowdown sequence
No
Yes
Yes
Yes
R-25
No
No
No
No
Yes
Yes
Very High
No
No
None
Yes
Unknown
Yes
Unknown
-------
TABLE 4-2. (Continued)
-P*
i
Control Measure
Supplemental Reactor Cooling
- standby cooling water pump
- excess refrigeration capacity
- re lux condenser
Gasholder
- VCH recovery/Incinerator surge
- non-reactor RVDs vented
- reactor RVDs vented
Operator Training
- Initial training (new operators)
- classroom
- on-the-job
- progress review
- continuing (qualified operators)
- routine safety meetings
- other
- RVD incident review
Preventive Maintenance
- rupture disc
- relief valve
- other
backup power generator
shortstop system
R-6
Unknown
No
Yes - large suspension
reactors only
Yes
No
No
Yes - 13 1-hr sessions
Yes - 21 days with
skilled operator
Unknown
Yes - Ihr/month
None
Yes
Replaced annually
Tested before Installa-
tion and annually
Yes
Yes
R-8
Unknown
No
Yes - bulk
reactors only
No
No
No
Yes 3 months
Yes total
Written;
performance
Yes - 2 hr/month
Emergency
response training;
shift assignments
Yes
Replaced annually
or sooner, if
needed
Shop tested every
two years
Yes
Unknown
Plant Code
R-9
Unknown
Yes
Yes
Yes
Yes
No
Yes
Yes
Unknown
Yes - monthly
shift briefings
Yes
Replaced annually
Unknown
Unknown
R-7
Unknown
Yes
Yes - large reactors
only
Yes
Yes
No
No
Yes - 6 to 12 months
Certification
Yes
None
Yes
Replaced annually
Tested annually
Unknown
Unknown
R-25
Yes
No
Yes
No
No
No
Yes - 1 week
Yes - 30 days with experience
operator
Written; oral
Yes - monthly
None
Yes
Replaced as needed
Inspected annually
Unknown
Unknown
-------
two. The success of a shortstop system at preventing relief valve
discharges is dependent on several factors including (1) having sufficient
agitation within the reactor for complete dispersion of the shortstop
throughout the reactor contents, (2) the charge manifold (i.e., the manifold
used to charge ingredients to the reactor) being clear, and (3) the timing
of personnel or control systems in initiating the shortstop.
Two primary variations of automated shortstop systems exist. Some
computer-controlled plants have built-in programs that recognize the upset
condition by monitoring operating parameters and that automatically inject
the shortstop agent when needed. Other computer-controlled plants monitor
operating parameters and automatically alert operators when shortstop is
needed. Actual activation of shortstop injection, however, is performed by
the operator.
At some older plants, only manual shortstop systems are available.
Operators are responsible for deciding when shortstop is required and for
manually injecting the shortstop agent. Manual shortstop systems are also
maintained as backup to automatic systems in some plants. Both manual and
automatic shortstop systems have been found to be capable of effectively
preventing relief valve discharges.
Redundant Instrumentation
The degree of instrumentation can be important in preventing relief
valve discharges and varies greatly among plants. For example, instrumenta-
tion monitoring reactor operating parameters (e.g., pressure, temperature)
warns operators of an emergency condition so that immediate action can be
taken. If the primary sensor fails, an emergency condition may go
undetected and a relief valve discharge may result if a secondary sensor is
not present.
Other instruments, in addition to those monitoring actual reaction
conditions, contribute to the prevention of an upset condition. For
example, overcharging a reactor is a common cause of relief valve
discharges. A metering system for charging exact amounts of liquid VC and
t
other ingredients in combination with accurate weigh tanks can prevent over-
4-5
-------
charging and the subsequent hydroful condition. Dual metering in series for
both VC and water is also used by some plants to prevent overcharging.
Sophisticated metering systems are not necessarily required. One plant has
successfully implemented a simple manual procedure to physically measure the
liquid level in the reactors as a check on the charge meter readings.
Computer Control
Many of the newer PVC plants have included computer control as part of
the original equipment and process design. In addition, several older
plants have added computers, or are planning to add computers, to control
their production operations. The primary use of these computers is in
operating and monitoring the batch polymerization process. In most cases,
the computer performs and monitors all reactor charging operations
(including the proper sequence of valve opening and closing and pump
operation), and monitors reaction conditions. The reactor blowdown sequence
is also performed by the computer in most cases.
Computer control at the various plants differs in the degree of
"decision making." As discussed previously, some computers not only alert
operators to emergency reactor conditions but also automatically inject
shortstop. The point at which shortstop is injected depends on programmed
limits for key monitored parameters. The selection of these limits reflects
a plant's judgment on the appropriate margin of safety. Other computers
alert operators of emergency conditions but allow operators to make the
final decision on the appropriate corrective actions.
Another factor that affects the effectiveness of computer control is
the quality of the programming in the system. Although subjective, several
plants have expressed varying opinions on degrees of confidence in this
aspect of the system. As a result, at least one plant continually searches
for and makes improvements in their system software.
Backup Power
Auxiliary sources of power are used by some plants to maintain
agitation, cooling, and instrumentation in the event of losing the main
4-6
-------
power source to a plant. No auxiliary power systems currently found in PVC
plants are designed to operate the entire plant; rather, power is usually
only available to safely shut down the plant by allowing those polymeriza-
tion reactions in progress to be terminated or finished. Most plants have
dual power lines into the plant to provide primary power. The dual lines
keep power constant and prevent sudden surges and dips in power or a
complete loss of power. Emergency back-up power is usually supplied by
diesel-driven generators. DC batteries may be available to operate instru-
ments and computers.
Backup power generation capacity varies from plant to plant.
Typically, sufficient backup power generation capacity is available to
maintain agitation in reactors until shortstop can be effectively dispersed.
However, shortstop systems used at some plants do not require agitation for
effective dispersement, and these plants may have no backup power
generators.
Supplemental Reactor Cooling
In the event that reaction temperature exceeds normal conditions, some
plants have available methods for providing supplemental reactor cooling.
For example, additional cooling water may be supplied by a standby cooling
water pump. In some cases, plants using refrigerated cooling water have
excess refrigeration capacity to provide additional chilled water if needed.
Other sources maintain a reserve capacity of chilled water for use in the
event of cooling tower or refrigeration system failure. Reflux condensers
are operated on some reactors. Although the primary purpose of the reflux
condensers is to maintain constant reactor conditions and to improve product
quality, they also provide an additional means for cooling reactor contents.
Gasholders
A gasholder is a cylindrical, variable-volume vessel. The most common
type of gasholder is a vessel with a floating roof with either a water seal
or a double inner synthetic seal that expands to accommodate the influx of
«
gas. The operating principle of a gasholder is based on piston
4-7
-------
displacement. A free moving piston floats on the confined gas, rising and
falling with changes in the volume of stored gas. As gas enters and builds
up to the designed operating pressure, the piston rises and floats on the
gas.
Gasholders are currently being used at some plants as part of the
recovery system to contain and store VC gas collected from various emission
sources in the plant. The gases stored can be fed to the recovery system,
or the gasholder can serve as a surge vessel feeding the primary control
device. (Incinerators must receive a near constant flow and concentration
of combustibles for proper operation.)
At present, a few plants are venting small nonreactor relief valve
discharges to gasholders. However, no plant has connected a reactor relief
valve directly to a gasholder or uses a gasholder only for relief valve
discharges. Some plants manually relieve reactor pressure to gasholders
serving as part of the VC recovery,.system.
Enhanced Operator Training
A staff of qualified operators able to recognize a potential emergency
situation and take appropriate measures to prevent a discharge are a key
element in minimizing relief valve discharges. The different levels of the
previously described hardware controls help to eliminate common operator
errors and aid the operator in detecting potential problems, but the
hardware controls including computers do not provide the decision-making
capabilities that are only found in experienced operations personnel. The
right combination of operator experience and hardware control is an
important preventive measure against relief valve discharges.
Operator training programs vary from company to company. Initial
training programs range from several weeks to over a month with routine
retraining and refresher programs required for all operations. Typically,
operators responsible for relief valve discharge incidents or "near misses"
are counseled and at some plants displinary actions may be taken. The
importance of effective training in preventing relief valve discharges was
verified in plant visit discussions. Every plant with a successful relief
4-8
-------
valve discharge performance record that was visited attributed a large part
to their success to the concern of management in preventing relief valve
discharges and their commitment toward transmitting this concern through
effective training of operators.
Preventive Maintenance
Routine maintenance of relief devices, rupture discs and other hardware
associated with relief valve discharge prevention is an effective method of
reducing discharges due to premature rupture disc failure and other
equipment and instrument failure. Plants generally inspect and/or dismantle
and shop test relief valves on a routine basis (i.e., once per year)
following installation. Rupture discs are typically replaced on an annual
basis. Some plants also replace rupture discs on an "as needed" basis. An
example would be when they are subjected to pressures exceeding set
tolerances.
Different maintenance programs are practiced by plants for other
hardware associated with relief valve discharge prevention. For instance,
backup power generators may be started on a regular basis and shortstop
systems may be inspected periodically to ensure problem-free operation if
needed.
4.2 RVD CONTROLS AT PLANTS VISITED
Five PVC plants that have successfully reduced or eliminated relief
valve discharges were visited to find out what relief valve discharge
control measures had been implemented. It was found that different
combinations of control measures are used at the five plants. As indicated
in Table 4-1, each of the control measures described in Section 4.1 have
been implemented by at least one of the five plants.
According to plant personnel at each of the five plants, an exact
relationship does not exist between specific control measures and prevention
of discharges. Further, many of the identified relief valve discharge
control measures were implemented .primarily for reasons other than relief
valve discharge control, with prevention of discharges a secondary benefit.
Plant personnel indicated in most instances that the relief valve discharge
4-9
-------
controls in place would be retained even in the absence of a relief valve
discharge standard because of their role in improving the production process
and reducing product loss.
Table 4-2 presents a summary of the specific relief valve discharge
controls at the five visited plants.
4.3 CONTROL MEASURES AT EDC/VC PLANTS
Information obtained during the review study indicate that many of the
same hardware and operational practices associated with prevention of relief
valve discharges at PVC plants have been implemented by EDC/VC producers.
Specifically, the backup power, supplemental cooling (for product columns),
and redundant instrumentation are applicable hardware controls that are
available at at least some EDC/VC plants. Enhanced operator training
programs are equally important for relief valve discharge prevention at
EDC/VC plants.
4-10
-------
5.0 CAUSES OF RELIEF VALVE DISCHARGES
A wide variety of causes for relief valve dishcarges are reported by
PVC and VC producers. Each relief valve discharge incident has its own set
of unique circumstances. Also, discharges often result from a combination
of causes. Consequently, it is difficult to classify the causes of
individual discharges into distinct categories. However, several general
categories of relief valve discharge causes were identified for the purpose
of this analysis and are discussed below.
Based on regional compliance data, discussions with EPA Regional Office
representatives and plant visits, the following general categories of relief
valve discharge causes were identified.
Operator Error. The most frequently reported cause of relief valve
discharges is operator error or failure to follow applicable standard
operating procedures (SOPs). A number of factors may contribute to operator
error-caused discharges. For example, failure by an operator to follow SOPs
may be due to inadequate training or failure on the part of management to
properly define the appropriate SOP. In other cases, operator negligence is
the primary reason for not following the SOP. Some operator-caused
discharges are simply due to the inevitable element of human error. A few
examples of discharges attributed to operator error are given below.
A reactor was overcharged with VC resulting in a hydroful
condition when the operator failed to close the VC charge
valve. Also, the operator failed to set high pressure alarm
prior to the reactor charging sequence.
A reactor overpressured due to erratic reaction kinetics and
the operator did not react according to the standard operating
procedure for controlling the reaction.
5-1
-------
An operator failed to switch reactor control instruments from
manual to automatic control and the reactor overheated and
consequently overpressured.
Identifications of two.valves were mislabeled during
instrument panel modifications for expansion. An operational
error occurred during manual control, causing the recovery
system to overpressure.
Premature Releases. Premature releases from relief devices are another
frequently reported cause of relief valve discharges. A premature release
occurs when a pressure relief device relieves to the atmosphere at a
pressure lower than the minimum rated pressure. The most widely used relief
devices in PVC and EDC/VC plants are rupture disc/safety relief valve
(RD/SRV) assemblies (see Figure 5-1). Usually, premature releases are
caused by premature failure of rupture discs. Premature failure of the
rupture disc results in a surge of pressure which causes the SRV to lift.
Both the size and the duration of this type of discharge are normally small.
However, if polymer or some other material prevents the valve from
reseating, the discharge may be much larger.
Some premature rupture disc failures are the result of improper
installation. Others are the result of exceeding the recommended service of
the rupture disc. The recommended service life of a rupture disc is
normally one year. Failure to replace rupture discs on an annual basis can
result in premature failure. In addition, a rupture disc can be damaged if
the operating ratio is exceeded. The operating ratio is the ratio of
operating pressure to the stamped burst pressure that the disc can
withstand. The operating ratio for most rupture discs is 70 percent.
Consequently, a rupture disc rated at 200 psig with a 70 percent operating
ratio would likely be damaged at pressures exceeding 140 psig. Once the
operating ratio is exceeded, rupture disc manufacturers recommend that the
disc be replaced to avoid the possibility of premature failure.
5-2
-------
en
CO
ADJUSTING lOtf
JMHNG
SMNDlf
lONNEt
CUtDC GASKff *
IPINDLf GUIDE
•BLOWS flOTECTOt
IBIOWS
DISC INSHT
RUPTURE DISC
TOP OF VESSEL
FLOW ROUTE
Figure 5-1. Rupture Disc/Safety Relief Valve Assembly
-------
Equipment Failure. Relief valve discharge can occur due to the failure
of process equipment. Failure of reactor cooling and agitation equipment
are two common causes of relief valve discharges. When the reactor cooling
system equipment malfunctions, the reactor contents may heat-up resulting in
overpressuring due to thermal expansion. Upon failure of reactor agitation
equipment, reactor contents cannot be adequately cooled and the reactor may
overpressure. If the shortstop used requires agitation for effective
dispersement, it is possible that a relief valve discharge will occur. At
EDC/VC plants, loss of cooling system equipment may allow contents of
process vessels (i.e. VC) to heat-up resulting in overpressuring due to
thermal expansion.
Instrument Malfunction. Another frequently reported cause of relief
valve discharges is instrument malfunction. Instrument malfunction includes
failure or malfunction of temperature indicators, pressure sensors and
transmitters, level indicators and controllers. Instrument malfunction may
result in erroneous control of the process or overfilling of tanks and
vessels. Instrument malfunction can often be attributed to insufficient or
improper maintenance.
Power Failure. A less frequent but nonetheless significant cause of
relief valve discharges is power failure. Relief valve discharges resulting
from power failure are generally larger (in terms of amount of VC
discharged) than discharges from other causes. Once power is lost, reactor
cooling and agitation are normally interrupted unless backup power is
available. The potential for discharge from multiple reactors exists in the
absence of reactor cooling and agitation. However, an established procedure
for safe plant shutdown can be effective in preventing relief valve
discharges when a power failure occurs and no backup power is available.
5-4
-------
6.0 BASIS OF SUMMARY TABLES
6.1 SUMMARIES OF VI DATA
Relief valve discharge data for 19 PVC and 10 EDC/VC plants were
supplied by the Vinyl Institute (VI). A summary of the raw data provided by
the VI are given in Tables 6-1 and 6-2. Table 6-1 is a summary of PVC data.
Table 6-2 is a summary of EDC/VC data. All data were given on a monthly
basis for the period 8/81 through 8/83. Months with no discharges are not
presented in Tables 6-1 and 6-2.
The data supplied by the VI are summarized on an annual basis for
selected formats in Table 3-1 for PVC plants and in Table 3-6 for EDC/VC
plants. The formats presented in Table 3-1 are number of discharges per
100 polymerization batches, number of discharges, Ibs of VC discharged per
MM Ibs of PVC production, and Ibs of VC discharged. Note that the
difference between data in Table 6-1 and Table 3-1 is the period of time,
one month versus one year. To calculate the number of discharges per
100 batches for a one year period, the number of discharges per 100 batches
were summed for the 12-month period and divided by 12 to estimate the
average monthly batch rate. This method assumes that the number of batches
produced in months when a discharge occurred are representative of the
actual average number of batches per month throughout the year.* Values for
numbers of discharges presented in Table 3-1 are simply the sum of
discharges shown in Table 6-1 for the respective one-year periods. The Ibs
of VC discharged per MM Ibs of PVC production values presented in Table 3-1
were calculated in the same way as the number of discharges per 100 batches.
The monthly Ibs of VC discharged per MM Ibs of PVC production values were
summed for a 12-month period and divided by 12. Again, this method assumes
*This assumption was verified as reasonable with the originators of the data
on the ba^is that releases occur randomly and that the average of a number
of randomly selected months is a reasonable approximation of the actual
average monthly batch rate.
6-1
-------
that monthly production in the months that discharges occurred is represen-
tative of the actual monthly average production rate over the year. Pounds
of VC discharged values presented in Table 3-1 are the Ibs of VC discharged
values in Table 6-1 summed for the 12-month period.
Values presented in Table 3-6 for EDC/VC plants were generated the same
way as for PVC plants with one exception. For EDC/VC plants, the numbers of
discharges per MM Ibs VC of production are presented in place of the number
of discharges per 100 batches. Number of discharges per MM Ib of VC
production values were calculated by summing the number of discharges per MM
Ibs of VC production values in Table 6-2 for the respective 12-month periods
and dividing by 12.
6.2 SUMMARIES OF REGIONAL DATA
Summaries of regional data for PVC plants are presented in Tables 3-2
through 3-5. Table 3-3 presents the regional compliance data for PVC plants
in the format of number of discharges per one-year period. Values presented
in this table are based on the summary of 10-day reports presented in
Table 6-3. The number of discharges within each one-year period were summed
to obtain the values in Table 3-3. Pounds of VC discharged values in
Table 3-5 were developed in the same way, by summing the reported Ibs of
discharge in Table 6-3 for each one-year period.
The number of discharges per 100 batches presented in Table 3-4 were
developed by dividing the annual number of discharges in Table 3-3 by an
estimated number of batches for the particular plant and year. Estimating
the number of batches was based on data from several sources including trip
reports, EPA Regional Office contacts, and the VI. It was possible to
estimate typical numbers of batches produced per month per reactor for
different resin types and for large and small suspension reactor sizes for
the years 1981, 1982, and 1983 using data from the VI. These typical
monthly reactor batch rates were multiplied by 12 to approximate typical
yearly reactor batch rates for each resin type for 1981, 1982, and 1983.
These factors are shown in Table 6-5. To estimate similar yearly reactor
batch rates for 1978, 1979, and 1980 the 1982-1983 rates were scaled with
6-2
-------
the industry capacity utilization rates shown in Table 6-4. Based on the
information presented in Table 6-5 and information on the number of reactors
at individual plants, the number of batches produced at each plant were
estimated for each one-year period. The estimates of the number of annual
batches produced at each plant may be sensitive to the plants. For this
reason, neither the estimated number of batches for each plant nor the
numbers of reactors at each plant are presented here. The number of
discharges per 100 batches values presented in Table 3-2 were obtained by
dividing the number of discharges presented in Table 3-3 for each time
period by the estimated number of batches obtained by the methods outlined
above. As a supplement to this approach, it was possible to use data from
the Vinyl Institute to make more accurate estimates of the number of batches
for some plants.
Regional PVC data are presented in the format of Ibs of VC discharged/
MM Ibs of PVC production in Table 3-4. Estimated values of MM Ibs PVC
production were required to calculate Ibs of VC discharged/MM Ibs of PVC
production. Annual production for each plant was estimated using published
PVC production capacities shown in Table 6-6 and the capacity utilization
factors shown in Table 6-4. The Ibs of VC discharged values for each year
in Table 3-5 were divided by the estimated annual PVC production to obtain
the values in Table 3-4.
Summaries of regional compliance data for EDC/VC plants are presented
in Tables 3-7 through 3-10. Table 3-8 presents regional compliance data for
EDC/VC plants in a format of number of discharges per one-year period.
Values presented in the table are based on the summary of 10-day reports
given in Table 6-7. The number of discharges within a one-year period were
summed to obtain the values in Table 3-8. The Ibs of VC discharged values
presented in Table 3-10 also were developed from Table 6-7, by summing the
reported amount of individual discharges for each one-year period.
Tables 3-7 and 3-9 which summarize relief valve discharge performance
by EDC/VC plants in the remaining two formats (i.e., number of discharges/MM
Ib VC and Ibs of discharge per MM Ib VC), required the estimation of VC
6-3
-------
production. Annual VC production of each plant was estimated using
Tables 6-8 and 6-4. Table 6-8 presents the published VC production
capacities of individual plants. These production capacities were used with
capacity utilization factors in Table 6-4 to estimate the annual production
at each plant for the years 1978 through 1983. As a supplement to this
approach, it was possible to use the actual production data from the Vinyl
Institute along with data from other nonproprietary sources to make more
accurate production estimates for some plants. Although these data are not
listed because they may be considered confidential to the respective plant
operators, they were used in producing the summary tables in Section 3.
The number of discharges presented in Table 3-8 were divided by the
estimated annual VC production rates for the respective plants to produce
the number of discharges per MM Ibs of VC production values in Table 3-7.
Similarly, the Ibs of VC discharged values presented in Table 3-10 were
divided by estimated VC production rates to produce the Ibs of VC discharged
per MM Ibs of VC production values in Table 3-9.
6-4
-------
TABLE 6-1. VINYL INSTITUTE RAW DATA FOR PVC PLANTS"
art
en
Plant
Code
Suspension
S-lb
S-2
S-3
S-4
S-5
S-6
S-7
S-B
S-9
S-10
S-ll
S-12
S-13
S-14
S-15
S-16
S-17
Month
Reactor Discharges
8/81
4/82
1/83
5/82
4/83
4/82
No
3/82
6/83
10/81
No
9/81
7/83
No
2/83
8/83
No
8/81
2/82
5/82
7/82
10/82
12/82
1/83
2/83
3/82
8/83
No
9/81
8/82
10/82
6/83
7/83
9/81
Nunber of Discharges
Per MM Lbs of PVC
Produced
0.095
0.032
0.074
0.09
0.07
0.08
Discharges
0.125
0.197
0.10
Discharges
0.08
0.05
Discharges
0.172
0.316
Discharges
0.16
0.08
0.25
0.14
0.18
0.06
0.24
0.08
0.09
0.07
Discharges
0.05
0.06
0.05
0.04
0.07
0.1
Lbs Discharged
Per MM Lbs of PVC
Produced
223.8
4.7
51.3
27.93
66.41
0.3
0.25
2.17
1,706.4
8.2
5.2
69.1
95.0
73.5
245.5
690.9
300.7
1,144.8
230.0
714.2
150.4
175.0
0.8
7.9
506.9
8.2
11.3
126.0
1,028.9
Number of
Discharges
1
1
2
1
1
1
1 1
1
1
1
1
1
2
2
1
3
1
2
1
2
3
Lbs
Discharged
2,350
146
1,384
326
1,009
4
2
11
12.8
100
100
400
600
909
3,000
8,170
2,096
12.850
3,680
6,056
1,775
2,000
12
155
8,560
158
300
1,800
21,000
Number of
Discharges Per
100 Batches
0.005
0.1
0.3
0.38
0.30
0.05
0.002
0.003
0.1
0.21
0.15
0.131
0.251
0.19
0.11
0.32
0.18
0.22
0.08
0.30
0.11
0.4
0.3
0.10
0.10
0.10
0.07
0.14
0.2
Lbs Discharged
Per 100 Batches
1.250
20.9
230.7
123.95
298.52
0.2
0.004
0.034
1,621.4
21.1
15.6
52.2
75.4
88.5
315.5
859.0
376.3
1,435.8
290.9
916.6
189.6
743.5
3.5
15.1
877.9
15.6
22.0
244.2
1.548.7
Dispersion Reactor Discharges
D-l
D-2
D-3
D-4
D-5
D-6
11/81
1/83
No
No
No
No
No
Discharges
Discharges
Discharges
Discharges
0.273 159
0.479 1,836
Discharges
1 565
1 3,830
0.27
0.4?
159
1,609
-------
TABLE 6-1. (Continued)
a\
i
Plant
Code Month
Number of Discharges Lbs Discharged
Per MM Lbs of PVC Per MM Lbs of PVC Number of Lbs
Produced Produced Discharges Discharged
Number of
Discharges Per
100 Batches
Lbs Discharged
Per 100 Batches
Latex Reactor Discharges
L-l No Discharges
L-2
L-3
Mass
M-l
M-2
M-3
No Discharges
6/B3
Reactor Discharges
6/83
12/81
7/82
8/81
9/81
10/81
12/81
1/82
6/82
10/82
11/82
3/83
4/83
7/83
0.5
0.3
0.5
0.2
0.122
0.327
0.231
0.143
0.168
0.204
0.169
0.142
0.357
0.413
0.165
1.9 1 4
369.1 1 1,192
2,968.0 1 5,850
1,894.1 1 9,090
449 1 3,690
1,948 2 11,900
686 2 5.950
57 1 400
587 1 3,500
307 1 1,500
616 1 3,655
57 1 400
1,292 2 7,250
715 3 5,200
521 1 3,160
0.4
0.36
1.1
0.4
0.137
0.387
0.264
0.166
0.198
0.235
0.206
0.179
0.425
0.515
0.179
1.8
422.7
6,290.3
3,969.4
504
2,302
785
66
693
352
754
72
1,539
892
566
Non-Reactor Sources
N-I
N-2
H-3b
8/81
9/81
10/81
11/81
1/82
3/82
4/82
6/82
10/82
11/82
12/82
1/83
3/83
7/83
12/81
7/82
11/82
9/81
3/82
0.03
0.09
0.02
0.03
0.07
0.02
0.02
0.02
0.02
0.02
0.03
0.02
0.02
0.02
0.13
0.08
0.07
0.12
0.095
3.13 1 100
8.86 3 300
2.46
3.10
7.08
1.95
2.28
1.00
1.07
2.33
1.41
2.01
8.29
1.74
25.9
94.6
0.03
1.2
7.3
100
100
300
100
100
50
50
100
50
100
500
100
203
1.188
0.4
10
77
0.3
0.7
0.2
0.3
0.6
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.1
0. 1
0.1
0.2
0.1
0.79
0.55
25.5
69.8
20.2
25.6
58.6
17.8
19.2
8.4
8.5
19.0
11.6
17.2
70.3
14*0
i *t » y
29.6
235!2
0.06
7 Q
/ . j
43.3
-------
TABLE 6-1. (Continued)
Plant
Code
N-4 *
N-5
N-6
N-7
N-8
N-9
N-10
N-ll
N-12
N-13
N-14
N-15
H-16
M-17
N-18
N-19
Month
9/81
10/81
11/81
1/82
6/82
8/83
9/81
1/83
4/82
9/81
11/82
9/81
2/82
7/83
8/83
7/82
4/82
4/83
6/82
1/83
1/82
8/82
10/82
2/83
Number of Discharges
Per MM Lbs of PVC
Produced
0.047
0.068
0.058
0.048
0.034
0.030
No Discharges
0.08
0.10
No Discharges
0.085
0.05
0.06
0.09
0.08
0.06
0.11
0.095
0.06
No Discharges
No Discharges
0.08
0.204
No Discharges
0.1
0.08
0.06
0.08
0.06
Lbs Discharged
Per MM Lbs of PVC
Produced
0.9
24.3
5.1
0.2
2.0
67.8
41.9
115.8
102.1
1.2
0.1
29.7
3.13
2.73
49.5
9.5
36.0
0.77
204
115.8
31.4
12.9
15.2
4.7
Number of
Discharges
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
I
Lbs
Discharged
20
357
89
4
57
2,252
511
1,200
27
2
300
41
42
443
100
605
10
1,000
810
378
213
195
74
Number of
Discharges Per
100 Batches
0.2
0.3
0.3
0.2
0.2
0.1
0.06
0.11
0.07
0.1
0.86
0.65
0.52
0.91
0.17
0.3
0.067
0.235
0.2
0.08
0.06
0.07
0.06
Lbs Discharged
Per 100 Batches
4.2
109.2
23.2
0.9
8.8
305.2
30.6
135.9
1.8
0.2
259.0
26.4
21.9
403.0
17.1
152.8
0.674
235
179.2
29.8
12.2
14.3
4.4
aData Includes releases from relief valves, rupture discs and manual vents In VC service. Data are for the period 8/81
no discharges are not Included In the table.
Plant production ceased 4/82.
cPlant shut down undeflnltely on 6/83.
- 8/83; data for months with
-------
TABLE 6-2. VINYL INSTITUTE RAW DATA FOR EDC/VC PLANTS1
CO
Plant
Code
E-l
E-2
E-3
E-4
E-5
E-6
Month
4/82
2/83
5/83
7/83
12/81
8/82
10/82
12/82
4/83
8/83
9/81
2/82
3/82
4/82
8/82
9/82
5/83
4/83
5/83
6/82
8/81
10/81
6/82
8/82
11/82
5/83
8/83
Number of Discharges
Per MM Lbs of VC
Production
0.102
0.253
0.040
0.046
0.05
0.09
0.02
0.05
0.05
0.02
0.047
0.022
0.019
0.015
0.032
0.016
0.032
0.02
0.01
0.014
0.087
0.105
0.052
0.025
0.021
0.031
0.027
Lbs Discharged
Per MM Lbs of VC
Production
7.26
203.45
410.92
2.13
2.6
37.9
209.5
16.0
99.7
3.6
0.84
1.56
271.10
28.10
5.65
0.81
83.82
47.9
2.9
1.1
6.7
104.5
25.4
3.3
0.02
38.6
0.05
Number of
Discharges
1
3
1
1
1
3
1
1
2
1
2
1
1
1
2
1
2
2
1
1
1
1
2
1
1
1
1
Lbs
Discharged
71
2,413
10,200
46
54
1,209
8,925
300
3,830
145
35
72
13,878
1,920
354
51
5,181
4,095
256
80
77
993
979
133
1
1,226
2
-------
TABLE 6-2. (Continued)
i
10
Plant
Code
E-7
K
E-8b
E-9
E-10
Month
12/81
3/82
7/82
9/82
3/83
7/83
8/83
4/82
8/81
10/81
2/82
5/82
8/82
9/82
11/82
2/83
3/83
12/81
6/82
Number of Discharges
Per MM Lbs of VC
Production
0.053
0.043
0.096
0.087
0.088
0.072
0.074
0.02
0.02
0.02
0.02
0.03
0.02
0.01
0.02
0.02
0.01
0.02
0.01
Lbs Discharged
Per MM Lbs of VC
Production
191.59
2.11
11.03
41.26
33.39
8.36
8.76
23
2.2
0.02
1.7
8.7
61.7
0.6
129.0
0.8
0.3
1,047.1
627.8
Number of
Discharges
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Lbs
Discharged
3,641
49
115
476
380
116
119
1,150
105
1.3
100
300
3,600
40
8,500
50
24
46,589
43,209
Data includes releases from relief valves, rupture discs and manual vents in VCM service. Data are for the
period 8/81 - 8/83; data for months with no discharges are not included in the table.
Plant shut down undefinitely on 6/83.
-------
TABLE 6-3. SUMMARY OF 10-DAY REPORTS0
Plant
Code
Large
R-l
R-2
R-3
Date
Reactor RVDS
8/13/78
11/26/78
• 10/20/79
7/22/79
10/31/79
3/23/80
6/21/78
10/23/81
3/20/82
4/21/82
4/20/79
7/20/78
1/2/79
5/25/79
11/6/79
11/26/79
3/13/80
5/5/80
5/14/80
6/4/80
8/1/80
8/15/80
8/19/80
8/20/80
9/9/80
5/15/81
9/22/81
4/20/82
5/22/82
6/6/82
10/5/82
4/21/83
Resin
Type
S
S
S
S
S
S
S
S
S
S
S
S
S
S
S
S
S
Reported
Lbs of
Discharge
50,000
30,000
38,000
33,000
450
10,000
10,249
167
2,000
605
120
3,000
2,100
3,900
200
1,560
4,000
6,500
2,350
4,560
371
48
2,083
96
17,926
104
5
19
12,090
201
210
19
Source
Reactor
Reactor
Reactor
Reactor
Non-reactor (VC Knockout Drum)
Reactor
Reactor
Non-reactor
Reactor
Non-reactor
Non-reactor
Non-reactor (Vacuum Header)
Reactor
Non-reactor (VCM Filter)
Reactor (Hydroful)
Reactor
Reactor
Reactor
Reactor
Non-reactor (Stripper)
Hydroful
Non-reactor (Charge Filter)
Non-reactor (VCM Sphere)
Non-reactor (Charge System)
Reactor
Non-reactor (Tank)
Non-reactor (Separator)
Non-reactor (Charge System)
Reactor
Non-reactor (VCM Line)
Reactor (Hydroful)
Non-reactor (VCM Recovery)
6-10
-------
TABLE 6-3. (Continued)
Plant
Code
R-4
R-5
Date
l/NA/80
3/28/80
3/30/80
5/30/80
6/8/80
6/30/80
7/16/80
7/30/80
8/7/80
8/10/80
9/9/80
9/29/80
3/20/80
10/13/80
10/13/80
6/4/80
6/10/80
8/11/80
10/7/80
8/25/80
9/22/80
10/2/80
10/10/80
1/29/81
2/22/81
3/5/81
4/2/81
4/28/81
7/28/81
7/31/81
9/2/81
2/2/82
4/12/78
10/21/78
10/25/78
11/1/78
12/2/78
9/11/79
' 9/17/79
9/18/79
Reported
Resin Lbs of
Type Discharge
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
160
640
194
1,800
1,800
33
33
12
12
124
188
160
3
48
320
160
2
1,175
300
41
3,000
7
100
70
S 1,100
100
300
S 50
Source
Non-reactor (VC Strainer)
Non-reactor (VC Strainer)
Non-reactor (VC Strainer)
Non-reactor (VC Strainer)
Non-reactor (VC Strainer)
Non-reactor (VC Strainer)
Non-reactor (VC Strainer)
Non-reactor (VC Strainer)
Non-reactor (VC Strainer)
Non-reactor (VC Strainer)
Non-reactor (VC Strainer)
Non-reactor (VC Strainer)
Non-reactor (VC Recovery)
Non-reactor (VC Recovery)
Non-reactor (VC Recovery)
Non-reactor (VC Tank)
Non-reactor (VC Tank)
Non-reactor (Gas Holder)
Non-reactor (Gas Holder)
Non-reactor (Drain Tank)
Non-reactor (Drain Tank)
Non-reactor (VCM Line)
Non-reactor (Charge Line)
Non-reactor (Recovery System)
Non-reactor (Strainer)
Non-reactor (Recovery System)
Non-reactor (Reflux Tank)
Non-reactor (VC Column)
Non-reactor (Charge Filter)
Non-reactor (Reflux Tank)
Non-reactor (VC Measure Tank)
Non-reactor (VC Line)
Non-reactor (VCM sphere)
Non-reactor (Separator)
Non-reactor (Filter)
Non-reactor (Separator)
Reactor
Non-reactor (VCM Column)
Non-reactor (VCM Column)
Reactor (Hydroful)
6-11
-------
TABLE 6-3. (Continued)
Plant
Code
R-5
(cont'd)
Date
10/7/79
10/10/79
11/17/79
11/17/79
• 2/14/80
5/10/80
7/16/80
7/22/80
8/2/80
8/4/80
8/13/80
8/27/80
9/16/80
9/10/80
9/12/80
9/18/80
10/1/80
1/29/81
2/7/81
2/19/81
3/19/81
3/29/81
3/30/81
4/1/81
4/10/81
5/8/81
5/8/81
5/18/81
5/26/81
6/8/81
8/17/81
1/14/82
2/11/82
3/11/82
4/27/82
6/29/82
10/14/82
12/11/82
1/25/83
1/26/83
9/5/83
Res i n
Type
S
S
S
S
S
S
S
S
S
S
S
S
S
Reported
Lbs of
Discharge
100
300
500
100
100
100
100
500
300
200
50
500
500
500
500
500
500
500
100
100
100
200
100
100
200
200
100
200
50
100
100
100
100
100
100
50
50
50
100
100
200
Source
Reactor (Hydroful)
Non-reactor (VCM Filter)
Non-reactor (VCM Storage)
Reactor
Non-reactor (VCM Filter)
Non-reactor (VCM Filter)
Reactor (Hydroful)
Non-reactor (Compressors)
Non-reactor (Separator)
Non-reactor (Compressors)
Non-reactor (Filter)
Non-reactor (VCM Tank)
Non-reactor (Compressor)
Non-reactor (VCM Tank)
Non-reactor (VCM Tank)
Non-reactor (VCM Tank)
Non-reactor (VCM Tank)
Non-reactor (VCM Line)
Reactor
Reactor
Non-reactor (VCM Column)
Reactor (Hydroful)
Non-reactor (VCM Tank)
Reactor
Reactor
Reactor
Non-reactor (VCM Tank)
Reactor
Non-reactor (Exchanger)
Non-reactor (VCM Tank)
Non-reactor (VCM Tank)
Non-reactor (Compressor)
Reactor
Non-reactor (Compressor)
Non-reactor (VCM Column)
Non-reactor (VCM Tank)
Non-reactor (Compressor)
Non-reactor (Compressor)
Non-reactor (Pump)
Reactor
Reactor
6-12
-------
TABLE 6-3. (Continued)
Plant
Code
R-6
R-7
R-8
Date
3/24/78
1/5/79
7/26/79
11/10/79
11/17/79
1/2/80
8/10/80
1/14/81
5/20/81
8/15/82
1/15/79
2/2/79
4/3/79
9/13/79
10/19/79
4/13/80
9/8/81
7/6/82
10/22/82
6/1/83
7/19/83
NA/NA/81
8/NA/81
7/NA/83
4/28/83
9/28/78
10/12/78
12/3/78
1/27/79
3/20/79
5/17/79
9/3/79
6/NA/81
11/16/82
7/22/82
. 6/12/83
Res 1 n
Type
S
S
S
S
S
S
S
S
S
S
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
S
S
S
D
S
B
D
B
B
Reported
Lbs of
Discharge
6,000
10,000
3,600
4,100
12,000
4,000
650
1,680
715
8,560
500
4,860
2,500
1,700
2,480
860
155
100
158
300
1,800
500
100
100
1,009
8,710
1
5,000
290
850
20
3,090
41,866
0.35
1,188
1,192
Source
Reactor
Reactor (Hydroful)
Reactor
Reactor (Hydroful)
Reactors (2)
Reactor
Reactor (Hydroful)
Reactor
Reactor
Reactor
Reactor
Reactor (Hydroful)
Reactor
Reactor
Reactor
Reactor
Reactor
Non-reactor (Weigh Tank)
Reactor (Hydroful)
Reactor
Reactor
Non-reactor (Charge Pot)
Reactor (Hydroful)
Reactor (Hydroful)
Reactor
Reactor
Non-reactor (Separator)
Reactor (Hydroful)
Non-reactor (Stripper)
Non-reactor (Stripper)
Non-reactor (Recirculation
Line)
Pre-polymerization Reactor
Reactor (6)
Non-reactor (Compressor)
Pre-polymerization Reactor
Post-polymerization Reactor
6-13
-------
TABLE 6-3. (Continued)
Plant
Code
R-9
R-10
R-ll
Date
1/4/80
7/17/83
. 7/28/78
9/25/78
6/17/79
7/19/79
9/11/79
10/15/79
2/10/80
5/24/80
11/29/80
4/24/81
5/5/81
6/23/81
9/24/81
10/4/81
10/23/81
5/28/82
9/8/82
1/20/78
3/29/78
4/18/78
4/26/78
5/2/78
5/4/78
5/22/78
6/5/78
7/3/78
8/25/78
9/30/78
1/1/79
1/11/79
1/31/79
2/6/79
3/4/79
4/12/79
4/29/79
Resin
Type
S
S
S
S
S
S
S
S
S
S
S
S
S
S
S
S
D
D
D
D
D
L
S
D
D
D
D
D
Reported
Lbs of
Discharge
1,213
100
2,774
163
570
1,850
225
246
7,356
252
50
1,000
750
2,060
1,880
1,300
2,525
44
3,740
575
8,000
6,750
1,890
1,375
2,830
1,360
320
12,600
1,660
7,500
700
4,973
334
619
500
464
650
Source
Reactor
Reactor (Hydroful)
Reactor
Reactor
Reactor
Reactors (4)
Reactor
Non-reactor (Receiver Tank)
Reactors (5)
Reactor
Reactor
Non-reactor (Vapor Break Tank)
Reactor
Reactor
Non-reactor (Vapor Break Tank)
Reactor
Reactor
Reactor
Reactor
Reactor
Non-reactor (Slowdown Tank)
Non-reactor (Slowdown Tank)
Reactor
Reactor
Reactor
Reactor (Slowdown Tank)
Reactor
Reactor
Reactor
Non-reactor (Slowdown Tank)
Non-reactor (Slowdown Tank)
Non-reactor (Decanter Tank)
Reactor
Reactor
Non-reactor (Slowdown Tank)
Reactor
Reactor
6-14
-------
TABLE 6-3. (Continued)
Plant
Code
R-ll
(cont'd)
R-12
R-13
Date
5/12/79
6/19/79
10/11/79
11/19/79
12/12/79
12/14/79
2/4/80
2/1/80
5/7/80
5/8/80
8/19/80
10/21/80
12/10/80
1/5/81
1/5/81
4/5/81
5/19/81
8/12/81
10/10/81
1/21/82
8/6/82
7/30/79
1/1/78
1/27/78
2/16/78
3/11/78
3/14/78
3/24/78
3/29/78
4/15/78
4/17/78
4/19/78
" 5/23/78
5/27/78
Res i n
Type
D
D
S
D
S
S
S
S
S
D
S
S
S
S
Reported
Lbs of
Discharge
805
312
300
207
1,000
800
364
996
117
117
665
1,999
295
160
780
365
10
7,720
12,825
378
218
60
11,300
17
68
10,300
1,312
9,540
48
13,200
114
5,040
1,302
1,064
Source
Non-reactor (Recovered VCM
Tank)
Non-reactor (Slowdown Tank)
Non-reactor (Slowdown Tank)
Non-reactor (Vent Gas
Absorber)
Non-reactor (Slowdown Tank)
Non-reactor (Recovered VCM
Tank)
Reactor
Reactor
Non-reactor (Storage Sphere)
Non-reactor (Storage Sphere)
Reactor
Non-reactor (Foam Knock-Out
Tank)
Reactor (Hydroful)
Non-reactor (Slowdown Tank)
Reactor
Non-reactor (Slowdown Tank)
Non-reactor (Recovery System)
Reactor
Reactor
Non-reactor (Slowdown Tank)
Non-reactor (Premix Tank)
Non-reactor (Storage Tank)
Reactor (Hydroful)
Non-reactor (Transfer
Strainer)
Non-reactor (Slowdown Tank)
Reactor
Reactor
Reactor (Hydroful)
Non-reactor (Seed Tank)
Reactor (Hydroful)
Non-reactor (Knock-Out Tank)
Reactor
Non-reactor (Stripping Column)
Reactor
6-15
-------
TABLE 6-3. (Continued)
Plant
Code
R-13
(cont'd)
R-14
R-15
Date
6/9/78
7/18/78
7/22/78
.
8/21/78
12/20/78
1/20/78
3/8/78
5/11/79
6/5/79
6/13/79
11/19/79
12/5/79
2/9/80
2/24/80
4/10/80
6/15/80
6/28/80
7/9/80
7/28/80
9/10/81
4/3/78
2/12/79
3/20/82
6/4/83
8/30/78
10/22/78
3/22/79
3/13/81
5/8/81
5/21/81
5/29/81
6/25/81
10/19/81
12/5/81
5/12/82
Resin
Type
S
S
S
S
D
S
S
D
D
S
S
S
S
S
S
S
S
S
S
S
S
S
S
S
S
Reported
Lbs of
Discharge
9,900
2,694
8,383
9,450
36
338
38
4,188
9,817
1 ,922
9,500
79
8,600
8,200
284
10,092
110
2,775
100
511
25
500
2
11
725
1,200
1,100
2,275
425
83
3,425
4,383
2,499
2,225
418
Source
Reactor
Non-reactor (Seed Tanks)
Non-reactor (Slowdown & Strip
Column)
Reactor
Reactor
Non-reactor (Wastewater
Stripper Tank)
Non-reactor
Reactors (6)
Reactor (Hydroful)
Reactor
Reactor
Non-reactor (Seed Tank)
Reactor (Hydroful)
Reactor (Hydroful)
Non-reactor (Seed Tank)
Non-reactor (Seed Tank)
Non-reactor (Rail Car)
Reactor
Non-reactor (Rail Car)
Non-reactor ("Burp" Tank &
Slowdown Tank)
Reactor
Reactor
Reactor
Reactor (Hydroful)
Reactor
Reactor
Reactor
Reactor
Reactor
Reactor
Reactor
Reactor
Reactor
Reactor (Hydroful)
Reactor
6-16
-------
TABLE 6-3. (Continued)
Plant
Code
R-16
R-17
R-18
Date
9/17/78
12/19/78
4/15/79
4/8/79
4/5/79
4/2/79
3/29/79
3/18/79
2/21/79
2/12/79
1/24/79
1/21/79
1/11/79
1/5/79
9/29/80
11/9/81
1/20/83
1/28/78
3/2/78
3/6/78
6/14/78
6/18/78
7/31/78
8/5/78
8/26/78
9/21/78
11/19/78
11/22/78
11/30/78
3/30/79
4/20/79
5/26/79
8/28/79
1/14/80
3/2/80
3/6/80
Resin
Type
No
S
S
S
S
NA
NA
NA
NA
NA
S
NA
Reported
Lbs of
Discharge
10-day reports
1,240
600
350
525
595
280
525
350
525
350
525
560
510
525
3,480
585
3,830
2,929
741
164
98
98
58
53
16
286
207
1,500
206
309
120
1,260
420
25
- , 8,220
41,866
Source
Reactor
Non-reactor (Recovery Comp.)
Non-reactor (Recovery Comp.)
Non-reactor (Recovery Comp.)
Non-reactor (Recovery Comp.)
Non-reactor (Recovery Comp.)
Non-reactor (Recovery Comp.)
Non-reactor (Recovery Comp.)
Non-reactor (Recovery Comp.)
Non-reactor (Recovery Comp.)
Non-reactor (Recovery Comp.)
Non-reactor (Recovery Comp.)
Non-reactor (Recovery Comp.)
Non-reactor (Recovery Comp.)
Reactor
Reactor
Reactor
Reactor
Non-reactor (Slowdown Tank)
Non-reactor (Slowdown Tank)
Non-reactor (Slowdown Tank)
Reactor (Hydroful)
Non-reactor (Slowdown Tank)
Non-reactor (Hydroful)
Non-reactor (Slowdown Tank)
Non-reactor (Storage Tank)
Non-reactor (Slowdown Tank)
Reactor
Non-reactor (Slowdown Tank)
Non-reactor (Slowdown Tank)
Non-reactor (Low-Pressure
Steam Line)
Reactor (Hydroful)
Non-reactor (VCM Tank)
Reactor (Hydroful)
Reactor
Reactors (6)
6-17
-------
TABLE 6-3. (Continued)
Plant
Code
R-18
(cont'd)
R-19
Date
7/11/80
10/18/80
2/NA/81
5/30/81
10/8/81
10/23/81
7/2/82
8/15/82
9/10/82
10/7/82
10/7/82
3/7/80
3/7/80
1/8/78
1/5/78
1/7/78
1/10/78
1/11/78
1/11/78
1/13/78
1/19/78
1/20/78
1/28/78
2/9/78
2/12/78
2/13/78
2/14/78
2/16/78
2/28/78
2/28/78
3/10/78
3/13/78
3/13/78
3/17/78
3/30/78
4/6/78
4/19/78
4/24/78
5/1/78
Resin
Type
D
NA
NA
NA
NA
NA
S
S
S
S
S
S
S
S
S
S
S
S
S
S
S
S
D
S
S
S
Reported
Lbs of
Discharge
997
580
17
346
206
167
170
3,146
817
6
14
1,329
44
1,840
856
85
3,982
993
136
331
5,800
39
1,074
438
585
331
321
1,954
692
3,196
8,390
585
5,997
1,990
59
68
73
3,840
265
Source
Non-reactor (Wastewater
Stripper Tank)
Reactor
Non-reactor (Slowdown Tank)
Reactor
Non-reactor (Slowdown Tank)
Non-reactor (Slowdown Tank)
Reactor (Hydroful)
Non-reactor (Surge Tank)
Non-reactor (Surge Tank)
Reactor (Hydroful)
Non-reactor (Sump)
Reactor (Hydroful )
Reactor (Hydroful)
Reactor
Non-reactor (Degasser)
Reactor
Reactor
Reactor
Reactor
Reactor
Reactor
Non-reactor (Vacuum System)
Reactor
Non-reactor (Degasser)
Reactor (Hydroful)
Reactor
Reactor
Reactor
Non-reactor (Degasser)
Reactor (Hydroful)
Reactors (2)
Non-reactor (Vacuum System)
Reactor
Reactor
Non-reactor (Knock-Out Drum)
Reactor
Reactor
Reactor
Reactor (Hydroful)
6-18
-------
TABLE 6-3. (Continued)
Plant
Code
R-19
(cont'd)
Date
5/2/78
5/16/78
6/1/78
6/7/78
7/14/78
8/3/78
8/10/78
8/16/78
9/25/78
9/24/78
9/2/78
9/2/78
9/24/78
9/24/78
9/22/78
10/6/78
10/19/78
10/18/78
10/28/78
11/7/78
11/7/78
11/13/78
12/9/78
3/30/78
3/12/78
1/2/79
1/11/79
1/15/79
1/23/79
1/29/79
2/7/79
2/10/79
2/13/79
3/25/79
4/10/79
4/12/79
4/20/79
4/29/79
8/10/79
3/6/80
4/12/80
Resin
Type
S
S
S
S
S
S
S
S
S
S
S
S
D
D
D
S
S
S
S
D
D
D
S
S
S
S
S
S
S
D
D
S
NA
NA
Reported
Lbs of
Discharge
9,551
146
208
159
52
880
28
600
300
60
28
52
40
106
53
640
23
25
20
11,130
260
6,240
2,790
58
150
9,850
320
1,305
2,560
20
20
530
40
200
60
9,540
40
53
1,060
315
10,870
Source
Reactor
Non-reactor (Degasser)
Reactor (Hydroful)
Reactor
Reactor (Hydroful)
Reactor
Reactor
Non-reactor (Vacuum System)
Non-reactor (Vacuum System)
Reactor (Hydroful)
Reactor (Hydroful )
Reactor (Hydroful)
Non-reactor (Vacuum System)
Reactor (Hydroful)
Reactor (Hydroful )
Reactor
Reactor
Reactor
Reactor
Reactor
Reactor
Reactor
Reactor (Hydroful)
Reactor
Reactor
Reactor
Reactor
Non-reactor (Degasser)
Reactor (Hydroful)
Non-reactor (Vacuum System)
Non-reactor (Vacuum System)
Reactor (Hydroful)
Reactor
Reactor
Reactor
Reactor
Reactor (Hydroful)
Reactor (Hydroful)
Reactor
Reactor
Reactor
6-19
-------
TABLE 6-3. (Continued)
Plant
Code
R-19
(cont'd)
R-20
Date
4/20/80
4/16/80
5/12/80
7/5/80
7/27/80
9/17/80
10/28780
2/13/81
3/17/81
4/7/81
4/10/81
4/10/81
4/15/81
5/20/81
7/8/81
10/2/81
1/11/82
1/11/82
1/11/82
4/30/82
8/14/82
1/24/78
2/4/78
4/14/78
4/15/78
4/28/78
4/30/78
5/30/78
6/1/78
6/7/78
6/11/78
7/28/78
9/21/78
11/21/78
12/15/78
12/30/78
4/27/79
6/29/79
9/9/79
10/12/79
Resin
Type
NA
NA
NA
NA
NA
NA
NA
S
S
S
S
D
S
S
S
S
S
D
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
Reported
Lbs of
Discharge
8,300
2,400
410
555
72
13,200
1,140
1,575
51
105
220
3,420
20
6,300
20
36
2,880
5,760
2,880
1,070
3,210
750
900
1,500
1,750
700
650
1,200
3,000
1,200
8,000
1,000
2,500
1,200
1,500
1,000
- 3,200
2,800
1,000
3,500
Source
Reactor
Reactor
Reactor
Reactor
Reactor
Reactor
Reactor
Reactor
Non-reactor (Degasser)
Reactor
Reactor
Reactor
Non-reactor (Vacuum System)
Reactor
Non-reactor (Vacuum System)
Reactor
Reactor
Reactor
Reactor
Reactor
Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Pre-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
6-20
-------
TABLE 6-3. (Continued)
Plant
Code
R-20
(cont'd)
R-21
R-22
Date
11/6/79
12/26/79
3/3/80
7/17/80
2/17/81
2/26/81
4/25/81
4/28/81
6/14/81
3/31/81
12/11/78
8/16/78
8/16/78
5/29/78
5/4/78
1/31/79
2/14/79
3/14/79
4/5/79
5/1/79
6/15/79
6/16/79
6/24/79
8/6/79
8/9/79
1/27/80
2/1/80
1/21/80
7/7/80
7/9/80
7/10/80
8/6/80
9/6/80
10/26/80
11/19/80
12/18/80
. 1/4/82
6/16/82
Resin
Type
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
Reported
Lbs of
Discharge
600
500
2,000
2,700
700
1,750
1,500
1,100
8,000
105
5
4,500
4,000
900
6,000
3,000
13,000
7,000
800
500
1,000
4,000
3,000
700
2,250
300
4,940
3,000
500
25
3,500
100
5,360
560
35
600
3,500
1,500
Source
Post-polymerization Reactor
Post-polymerization Reactor
Pre-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Pre-polymerization Reactor
Non-reactor (Incinerator
Surge Tank)
Post-polymerization Reactor
Post-polymerization Reactor
Pre-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Pre-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Non-reactor (VC Filter)
Post-polymerization Reactor
Non-reactor (VC Filter)
Post-polymerization Reactor
Post-polymerization Reactor
Non-reactor (VC Filter)
Post-polymerization Reactor
Post-polymerization Reactor
Pre-polymerization Reactor
6-21
-------
TABLE 6-3. (Continued)
Plant
Code
R-22
(cont'd)
R-23
Date
6/30/82
10/25/82
11/16/82
3/21/83
3/28/83
4/29/83
5/30/83
10/6/78
6/3/79
8/6/79
Resin
Type
B
B
B
B
B
B
So
So
So
Reported
Lbs of
Discharge
1,000
3,655
400
4,000
3,250
250
3,380
4,586
5,123
7,838
Source
Non-reactor (Booster Pump)
Post-polymerization Reactor
Post-polymerization Reactor
Pre-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Post-polymerization Reactor
Reactor
Reactor
Reactor and Stripper
NA = Not available.
Compliance reports required within ten days of a relief valve discharge
occurrence.
Resin type code: S = suspension
D = dispersion
L = 1atex
B = bulk
So = solution
Resin type listed for reactor discharges only.
6-22
-------
TABLE 6-4. AVERAGE CAPACITY UTILIZATION RATES FOR VC AND PVC PRODUCTION3
Capacity Utilization Rates
Year
1983
1982
1981
1980
1979
1978
VC
62.0%b
62.0
66.2
80.4
93.2
88.5
PVC
62.2%b
62.2
70.7
71.9
87.4
85.4
Source: ChemicalMarketing Reporter. July 5, 1982.
Assumed to be the same as in 1982.
6-23
-------
TABLE 6-5. ESTIMATED TYPICAL NUMBER OF BATCHES PER REACTOR
Suspension
1978
1979
1980
1981
1982
1983
Large
Reactor
1,000
1,030
840-
830
680
1,000
Small
Reactor
750
780
630
620
550
720
Dispersion
450
460
380
370
320
420
Latex
300
310
250
250
220
290
Bulk
480
490
410
400
350
500
6-24
-------
TABLE 6-6. PRODUCTION CAPACITY OF PVC PLANTS'
Annual Capacity
Millions of Lbs
Air Products
Borden, Inc
CertainTeed
Conoco
cr»
i
ro
Ethyl
Formosa Plastics
General Tire & Rubber
Georgia-Pacific Corp.
BF Goodrich
Location
Calvert, KY
Pensacola, FL
Illiopolis, IL
Leominster, MA
Lake Charles, LA
Aberdeen MI
Oklahoma City, OK
Baton Rouge, LA
Delaware City, DL
Delware City, DL
Point Comfort, TX
Ashtabula, OH
Plaquemine, LA
Avon Lake, OH
Deer Park, TX
Henry, IL
Long Beach, CA
Louisville, KY
Pedricktown, NJ
Plaquemine, LA
83
200
200
320
200
190
455
260
180
150
280
530
125
700
400
260
200
150
375
400
190
82
200
200
320
200
190
455
260
180
280
125
700
400
260
200
150
375
350
190
81
200
200
340
185
190
335
215
180
125
700
300
200
150
375
350
190
80
220
200
340
185
190
335
215
180
125
350
300
200
150
375
150
190
79b
120
150
400
145
200
195
200
180
125
350
300
200
150
500
150
200
78
128
150
400
145
200
195
200
180
125
350
300
200
150
500
150
200
-------
TABLE 6-6. (Continued)
Annual Capacity
Millions of Lbs
Goodyear Tire & Rubber
Keysor Corp.
Occidental
Pantasote
en
rij Shintech, Inc.
en
Talleyrand
Tenneco
Union Carbide
Diamond Shamrock
a
Location
Niagara Falls, NY
Saugus, CA
Addis, LA
Burlington, NJ
Pottstown, PA
Passaic, NJ
Freeport, TX
New Bedford, MA
Burlington, NJ
Flemington, NJ
Pasadena, TX
South Charleston, WV
Texas City, TX
Deer Park, TX
83
70
50
220
190
240
55
680
78
160
105
700
50
125
130
82
70
50
220
190
240
55
680
78
160
105
700
50
125
400
81
70
50
220
190
240
55
330
78
160
105
480
50
125
470
80
70
50
190
55
330
160
80
480
50
125
470
79b
70
35
180
60
220
155
80
270
55
200
470
78
70
35
180
60
220
155
80
270
55
200
470
Source: SRI Directory of Chemical Producers.
j
Capacities were not available for 1979 and were assumed to be the same as 1978 capacities.
-------
TABLE 6-7. SUMMARY OF 10-DAY REPORTS3 FOR EDC/VC PLANTS
Plant
Code
RE-1
RE-2
RE-3
RE-4
Date Of
Discharge
6-1-78
6-16-78
7-3-78
7-14-78
7-25-78
11-15-78
4-21-79
5-14-79
5-24-79
6-27-79
8-6-79
9-25-79
3-17-80
1-4-81
2-26-81
5-11-81
7-8-81
8-11-81
5-12-78
8-12-78
1-23-78
2-28-80
12-1-80
2-9-81
2-17-82
8-5-82
11-2-82
12-12-82
12-20-82
1-5-83
1-27-83
7-21-83
8-1-80
7-16-80
5-15-80
5-4-80
• 3-10-80
3-8-80
Amount Of
Discharge
(Lbs)
400
125
31.7
7.6
14.0
56
453
257
257
292
169
1,210
594
17
86
418
25
2,415
3.7
0.2
NA
10
475
9
<100
3,600
8,500
40
40
3,700
650
810
107
2,600
18
300
27
23
Source of Discharge
VCM Check Tank
VCM Dryer
Incineration Knock-Out Drum
Fuel -Rich Seal Pot
02 Rich Vent Gas Seal Drum
Incinerator
VCM Check Tank
Preheater
Stripper Column
Quench Column
VCM Storage Tank
VCM Transfer Line
HC1 Column
VCM Rework Pump
Vinyl Chloride Column
VCM Dryer
Wet Vent Header System
VCM Dryer
Quench Tower
02-Lean Seal Pot
Storage Spheres
Oxchlorination Prereactors
Column (Unspecified)
VC Line
Filter
Transfer Line
Vinyl Furnace
Vinyl Sphere
Transfer Line
VCM Caustic Mixer
VCM Purification Column
VCM Surge Tank
VCM Tank
Check Tank
Check Tank
NA
VCM Storage Tank
VCM Storage Tank
6-27
-------
TABLE 6-7. (Continued)
Plant
Code
RE-4
(cont'd)
RE-5
RE-6
Date Of
- Discharge
2-23-80
3-22-80
5-23-79
5-23-79
5-18-79
5-16-79
5-10-79
1-4-78
8-26-83
5-16-83
11-13-81
11-13-81
11-3-81
8-25-81
10-26-80
10-24-80
7-16-80
10-3-79
11-8-82
8-5-82
6-8-82
6-20-82
2-8-82
2-9-82
12-4-81
7-31-81
6-5-81
3-26-81
12-5-80
4-14-80
1-23-80
12-20-79
12-19-79
3-1-79
4-9-79
1-24-79
Amount Of
Discharge
(Lbs)
7.5
140
160
4,000
110
600
2,000
1,170
2.2
1,226
609
384
1,671
77
1,990
2,500
4
1,534
0.6
133
885
94
1
11,000
200
NA
100
15 - 20
1
2,949
347
92
400
11
158
3.1
Source of Discharge
VCM Check Tank
VCM Column
VCM Column
VCM Check Tank
VCM Check Tank
VCM Column
VCM Check Tank
NA
VCM Check Tank
VCM Column
VCM Column
Caustic Decanter
NA
Caustic Decanter
Quench Column
Caustic Decanter
HC1 Column
Drying Beds
VCM Product Filter
Caustic Decanter
Caustic Decanter
Caustic Decanter & Caustic Dryer
HC1 Column
VC Column
Rework Stripper
HC1 and VC Columns
VC Bullet
VC Filtering System
Loading Line
VCM Relux Column
VC Column
VC Bullets
HC1 Column
Lights & VCM Column
HC1 Stripper
HC1 Column
6-28
-------
TABLE 6-7. (Continued)
Plant
Code
RE-7
RE-8
RE-9
Date Of
Discharge
12/20/81
12/22/81
12/22/81
1/18/82
1/24/82
2/20/82
5/6/82
5/6/82
10/30/82
10/31/82
4-16-82
8-10-79
3-19-79
11-2-78
3-30-78
4-27-82
3-25-82
2-17-82
9-29-81
9-18-81
7-20-81
7-19-81
7-5-81
7-7-81
6-24-81
6-30-81
6-4-81
6-3-81
6-5-81
5-28-81
5-23-81
6-2-81
6-3-81
5-7-81
4-15-81
10-13-78
7-25-78
*
Amount Of
Discharge
(Lbs)
103
1.9
3
2,700
350
4
2,670
620
9,600
620
1,150
3,400
2,600
12
12
1,920
13,878
72
30
5
29
NA
NA
10
4
72
4,400
700
45
1,700
1,700
1,100
2,400
20
500
9
100
Source of Discharge
Vent Gas Knockout Drum
Liquid Knockout Drum
Liquid Knockout Drum
VCM Sphere
Liquid Knockout Drum
Liquid Knockout Drum
EDC Furnace
Quench Column
Light Ends Column
Overhead Storage Drum
Finishing Column Condenser
VCM Tank Car
Storage Vessel
Tank Car Loading Line
Tank Car Loading Line
Transfer Line
Product Storage Vessel
Not Available
Transfer Line
Product Transfer Line
Product Transfer Line
NA
Fill Line
VC Transfer Line
Transfer Line
Storage Sphere
Storage Sphere
Loading Line
Transfer Line
Transfer Line
Transfer Line
Transfer Line
Transfer Line
Unloading Line
Transfer Line
Transfer Line
6-29
-------
TABLE 6-7. (Continued)
Plant
Code
RE-10
RE-11
RE-12
RE-13
Date Of
Discharge
3-28-81
9-8-79
9-1-79
6-1-79
1-30-79
1-14-79
4-30-78
6-19-82
5-11-81
8-27-80
9-9-80
1-2-80
7-28-79
5-27-79
5-8-79
10-20-78
9-16-78
8-31-78
5-23-78
2-18-78
11/12/80
10/8/81
1/5/81
9/29/81
5/6/83
1/6/80
3/7/80
5/31/80
7/29/80
7/30/80
7/30/80
12/10/80
12/20/80
2/1/81
12/8/81
12/22/81
Amount Of
Discharge
Ubs) .
1.2
7,000
700
5,000 -
10,000
22
10
7,500
80
1,027
4
65
378
6,000
209
73
185
1,700
6,000
12,000
3,300
1,670
53
4,620
450
84
10
128
34.4
129.9
53.7
206.8
0.5
1.5
133
33.3
46,556
Source of Discharge
Light Ends Storage Vessel
Quench Column
HC1 Stripping Column
VCM Rundwon Sphere
Filter Valve
HC1 Stripper Column
VCM Column
Accumulator Vessel
NA
NA
Knock Out Drum
Vessel (Unspecified)
Vessel (Unspecified)
Vinyl Transfer Line
Quench Area
Process Compressors
Vessel
Compressors
Tank
Compressor
VCM Sphere
VCM Humidifier Vessel
VCM Sphere
Neutral izer Vessel
Reflux Drum on Product Still
Incinerator Vent Line
Vapor Header
NA
Wet VC Header
EDC Stripout Tank
Wet VC1 Header
Wet VC1 Header
Wet VC1 Header
VCM Sphere
Vent Header
(SRVDs) Dry VC1 Header
VC1 Column (2)
6-30
-------
TABLE 6-7. (Continued)
Plant
Code
Date Of
Discharge
4/30/82
6/2/82
Amount Of
Discharge
(Lbs)
81.6
43,209
Source of Discharge
Wet VC1 Header
(5 RVDs) VC1 Column (3)
VC1 Reboiler
VC1 Reflux Drum
NA = not available.
Compliance reports required within ten days of a relief valve discharge
occurrence.
6-31
-------
TABLE 6-8. PRODUCTION CAPACITY OF EDC/VC PLANTS0
Annual Capacity
Millions of Lbs VC
Borden Inc.
Dow
Conoco
Ethyl
oj Formosa Plastics
ro
Georgia Pacific
BF Goodrich
PPG Industries
Shell Chemical
Location
Geismar, LA
Freeport, TX
Oyster Creek, TX
Plaquemine, TX
Lake Charles
Baton Rouge, LA
Baton Rouge, LA
Point Comfort, TX
Plaquemine, LA,
Calvert City, KY
Lake Porte, TX
Lake Charles, LA
Deer Park, TX
Norco, LA
83
610
150
750
1,250
700
300
300
530
1,000
1,000
1,000
900
840
700
82
610
150
750
1,250
700
300
300
1,000
1,000
1,000
900
840
700
81
380
150
750
1,250
700
300
1,000
1,000
1,000
400
840
700
80
380
150
750
1,250
700
300
1,000
1,000
400
840
700
79b
300
200
700
1,250
300
1,000
1,000
400
840
7QO
78
300
200
700
1,250
330
1,000
1,000
400
840
700
77
300
200
700
1,250
330
1,000
1,000
400
840
700
Source: SRI Directory of Chemical Producers.
Capacities were not available for 1979 and were assumed to be the same as 1978 capacities.
-------
APPENDIX A
MEMORANDUM: VINYL CHLORIDE STANDARD -
NUMERICAL LIMITS FOR RELIEF VALVE DISCHARGES
-------
RADIAN
CORPORATION
MEMORANDUM
DATE: April 16, 1984
TO: File
FROM: Reese H. Howie, Karen K. Fidler
SUBJECT: Vinyl Chloride Standard - Numerical Limits for Relief Valve
Discharges
SUMMARY
Relief valve discharge performance by polyvinyl chloride (PVC) and
ethylene dichloride/vinyl chloride (EDC/VC) plants was analyzed to determine
numerical limits that would reflect an upper limit (i.e., never-to-be
exceeded) performance level that is representative of compliance with the
current format of the VC standard for relief valve discharges. The analysis
resulted in selection of the following 12-month limits:
(1) Discharges from PVC reactors
(suspension, dispersion, latex, bulk processes)
- Reactors
- suspension resin process 0.035 discharges/100 batches
- dispersion resin process 0.035 discharges/100 batches
(including latex resin)
- bulk resin process 0.035 discharges/100 batches
- Nonreactor sources 0.025 discharges/100 batches,
not exceeding 3 discharges/yr
(2) Discharges from PVC plants 1 discharge/yr
(solution and other continuous processes)
(3) Discharges from EDC/VC plants 4 discharges/yr
This memo describes the approach for determining these limits.
BACKGROUND
The current national emission standard for VC was promulgated under
Section 112 of the Clean Air Act in 1976. A review of the standard was
performed to investigate the adequacy and appropriateness of the standard in
light of policy decisions, health studies, control technology developments,
and enforcement and compliance experience which occurred since the standard
was promulgated. As written, the standard prohibits all but "emergency"
relief valve discharges. One finding of the review was that considerable
Progress Center/3200 E. Chapel Hill Rd./Nelson Hwy./P.O. Box 13000/Research Triangle Park. N.C. 27709/(919)541-9100
-------
enforcement resources are being expended by the EPA to assess the preventa-
bility of individual discharges. Second, industry has expressed continual
uncertainty regarding whether they are in compliance with the standard. In
response to these problems, an investigation was performed to identify ways
to reformat the standard with alternative numerical limits representative of
compliance with the current format of the standard.
Data on relief valve discharge performance by the VC industry was
obtained from three sources. First, the Vinyl Institute (VI) provided
relief valve discharge performance data obtained through a survey of their
member companies (19 PVC plants and 10 EDC/VC plants). Second, regional
compliance data on relief valve discharges was gathered for 23 PVC plants
and 13 EDC/VC plants. Third, trip reports documenting visits to five PVC
plants provided information on control techniques used to prevent relief
valve discharges. An analysis of the collected performance data was
undertaken to determine an upper limit performance level that represents
compliance with the current standard format. Based on the analysis, a
series of numerical limits for relief valve discharges are recommended for
incorporation in the standard. The approach for determining these numerical
limits is described below.
APPROACH FOR DETERMINING LIMITS
The approach for determining numerical limits was based on examination
of recent relief valve discharge performance of PVC and EDC/VC plants within
the industry. Recent performance best reflects efforts by the VC industry
to comply with the current standard as evidenced by the general improvement
in relief valve discharge performance by plants since the standard went into
effect. Attached Table 1 illustrates this trend toward improved relief
valve discharge performance. The performance data in Table 1 is based on
10-day compliance reports submitted to EPA regional offices. Attached
Table 2 presents recent relief valve discharge performance data derived from
the VI survey of their member companies. Because we were unable to obtain
all of the relief valve discharge data from EPA regional offices, the VI
data were generally more complete for the recent periods covered; further,
the discharge per 100 batches figures presented in the VI data are based on
actual production data. For these reasons, they were used as the basis for
selecting the numerical limits. The regional compliance data includes
reasons why each discharge occurred. Consequently, the regional compliance
data were used to verify achievability of the limits determined using the VI
data. The two data bases represented in Tables 1 and 2 are described in
more detail in the Radian report, "Relief Valve Discharge Performance Under
Current Vinyl Chloride Standard." In both data sets presented here,
performance is expressed for twelve month periods rolling every six months.
Two basic formats were considered for expressing relief valve discharge
performance by PVC and EDC/VC plants to serve as the basis for determining
numerical limits. The selected format is based on discharge frequency
rather than mass of discharge since a sufficiently accurate method for
A-2
-------
measuring discharge quantities has not been identified. For PVC plants with
batch production processes (i.e., suspension, dispersion, latex, and bulk
processes), the opportunity for discharges appears to be related to the
number of times a new polymerization batch is initiated. For PVC plants
with continuous production processes (i.e., solution process) and EDC/VC
plants, discharge frequency is not related to any batch sequence. For
purposes of evaluating discharge performance to determine numerical limits
for relief valve discharges, performance by batch process PVC producers is
expressed in terms of discharge frequency per batch. Relief valve discharge
performance by continuous process PVC producers and EDC/VC producers is
expressed in terms of annual discharge frequency.
As indicated in Table 2, recent relief valve discharge performance of
PVC plants ranges from 0 to 0.225 discharges per 100 batches. Relief valve
discharge performance of EDC/VC plants in Table 2 ranges from 0 to 7
discharges per year. The performance level representative of compliance
with the current standard is somewhere within these ranges of performance.
The current standard does not prohibit all discharges but rather all
"nonemergency" discharges. Consequently, it was anticipated that plants
could continue to have some discharges without being in violation of the
standard. As expected, recent performance data indicate that relief valve
discharges continue to occur at most plants. However, some plants are
performing better than others. The analysis for determining the upper limit
performance level representative of compliance with the current standard
format was performed separately for PVC and EDC/VC plants.
PVC Plants
The first step in determining what performance level is representative
of compliance with the current relief valve discharge standard format for
PVC plants was to perform a detailed evaluation of plants with good
compliance histories. Five PVC plants were selected which have been
successful in preventing or reducing the frequency of relief valve discharge
occurrences. Based on information obtained during visits to the five
plants, it was judged that hardware and operational practices at each of the
visited plants represent reasonable relief valve discharge control measures
consistent with the intent of the current standard. Although the
combination of controls used at each plant varies, each has been effective
in reducing the frequency of relief valve discharges. The resulting relief
valve discharge performance by the five plants varies. These variations in
performance can be partly attributed to varying levels of sophistication in
hardware controls. For example, some of the visited plants were equipped
with computer control and relatively high levels of instrument redundancy,
both of which are associated with control of relief valve discharges. In
comparison, one plant had no computer control and only minimal redundant
instrumentation. Performance by the plants with more sophisticated hardware
controls was typically better than the less sophisticated plant. However,
hardware items such as computer control and high levels of instrument
redundancy*were not required by EPA to comply with the current standard.
A-3
-------
Instead, an effective combination of operational practices, hardware
controls, and attitude toward prevention of discharges are required to meet
the standard. The less sophisticated plant described above has successfully
reduced relief valve discharge occurences by an effective combination of
attitude, operational practices and minimal hardware.
Four of the five plants evaluated in detail produce suspension resins.
As seen in Table 2, the performance of three of the four plants ranges from
0.018 to 0.034 discharges per 100 batches for reactor discharges. The
fourth suspension plant is not included in Table 2 (i.e., not a VI member
company). Performance of this plant did not exceed 0.010 discharges per
100 batches for the same period (8/81-7/83). Based on the upper level of
performance (i.e., largest number of discharges per 100 batches) of the four
plants that produce'suspension resins, a numerical limit of 0.035 discharges
per 100 batches was selected as an upper limit on performance representative
of compliance with the current standard format.
Two of the five PVC plants produce dispersion resins along with other
resin types. Neither had a dispersion reactor discharge during the period
represented in Table 2. In fact, only one plant included in the VI survey
experienced any relief valve discharges from a dispersion reactor. Likewise,
only one plant producing latex resins experienced any relief valve discharges
from latex reactors. Since the dispersion and latex resin production
processes are based on nearly identical technology, they were combined for
purposes of selecting a numerical limit for relief valve discharges.
Because the potential for an emergency discharge always exists, a limit for
discharges from dispersion and latex reactors was selected on the basis of a
single emergency discharge occurrence. Based on the relief valve discharge
performance data in Table 2, a limit of 0.035 discharges per 100 batches
represents a single discharge from a plant producing a typical number of
dispersion or latex resin batches. Therefore, a limit of 0.035 discharges
per 100 batches for dispersion and latex reactors was selected as an appro-
priate upper limit on performance representative of compliance with the
current standard format for these sources.
Bulk resins are produced at two of the five plants. Relief valve
discharge performance by one of these two bulk plants is presented in the VI
data in Table 2. The other bulk plant, not represented in Table 2,
experienced no discharges during the period 8/81-7/83. Of the remaining two
producers of bulk resins presented in Table 2, relief valve discharge
performance by one is much higher. Performance by the second plant demon-
strates considerable improvement to a level comparable to the visited
plants. Based on recent performance of the two visited bulk plants and the
third recently improved bulk plant, a limit of 0.035 discharges per 100
batches also seems to be the appropriate upper limit on performance repre-
sentative of compliance with the current standard format.
A-4
-------
A limit for nonreactor discharges at PVC plants that produce
suspension, dispersion (including latex) and bulk resins was also selected
on the basis of a detailed evaluation of performance by the five plants.
From Table 2, the range of recent nonreactor relief valve discharge perform-
ance for three of the five plants was 0 to 0.024 discharges per 100 batches.
Two of the five plants are not included in the VI data in Table 2. Neither
of these two plants had a nonreactor discharge during the period covered.
As before, the upper level of nonreactor relief valve discharge performance
by the visited plants was judged to be representative of compliance with the
current standard format. Based on the recent performance by the five plants,
a limit for PVC nonreactor discharges of 0.025 discharges per 100 batches
was selected. Because of the wide variation in the annual number of poly-
merization batches produced at different plants, a limit of 0.025 discharges
per 100 batches would allow some plants only one discharge per year and
other plants as many as 5 discharges per year. Further examination of the
nonreactor relief valve discharge performance data for all PVC plants in
Table 2 revealed that only two plants had more than 3 discharges in one
year. Batch production by these two plants were small to average relative
to other plants. A higher number of allowable discharges does not appear to
be warranted for plants with larger production. Therefore, a limit of 3
discharges per year is specified for PVC nonreactor discharges (in addition
to the limit of 0.025 discharges per 100 batches) as representative of
compliance with the current standard format.
The solution process is currently used by one plant to produce PVC.
Unlike the batch production processes used for other resin types, the
solution process is continuous. Consequently, no separation was made
between reactor and nonreactor discharges in expressing relief valve
discharge performance by this plant. As indicated in Table 1, relief valve
discharge frequency by this plant has been zero for each of the 12-month
periods after 1980. Previously, as many as 2 discharges were reported
during the indicated 12-month periods. Although recent performance suggests
that relief valve discharges have been eliminated by this plant, a limit of
one discharge per year was selected to allow for the potential unanticipated
emergency discharge.
Relief valve discharge performance in Table 2 was reviewed to see how
PVC plants are performing relative to the recommended numerical limits.
Based on the recent performance shown in Table 2, 16 of the 17 (94 percent)
suspension plants in Table 2 are performing within the recommended limit for
suspension reactor discharges (i.e., 0.035 discharges per 100 batches). All
of the dispersion and latex plants in Table 2 are performing within the
recommended limit of 0.035 discharges per 100 batches for dispersion and
latex reactor discharges. One of 3 (33 percent) bulk plants are performing
within the recommended limit of 0.035 discharges per 100 batches for bulk
reactor discharges. Fifteen of 19 (79 percent) PVC plants represented in
Table 2 are performing within the recommended limit of 0.025 discharges per
100 batches for nonreactor discharges. All together, 12 of 19 (63 percent)
PVC plants represented by the VI data are performing within the recommended
A-5
-------
limits for all source and resin type categories. In addition, the single
solution process PVC plant (not represented in the VI data) is performing
within the recommended limit of one discharge per year. Review of the
performance data in Table 2 also shows the bimodal nature of the relief
valve discharge performance for the various plants. In general, either the
plants are achieving the recommended limits or they are exceeding them by a
wide margin (i.e., 0.035 vs. 0.059 to 0.125 discharges per 100 batches for
reactor discharges; 0.025 vs. 0.043 to 0.225 discharges per 100 batches for
nonreactor discharges).
To verify that the recommended numerical limits for relief valve
discharges at PVC plants reflect compliance with the current standard
format, reasons for plant performance worse than that of visited plants were
examined. For each -case where individual plant performance was worse than
the recommended numerical limits, the performance was calculated after
identification and elimination of "preventable" discharges. The criteria
for identifying "preventable" discharges is described below.
Based on information gathered from plant visits, contacts with regional
offices, 10-day compliance reports, and vendors, it was judged that certain
types of discharges can be prevented by reasonable measures. For example,
discharges caused by operator error, due to operator negligence or failure
to follow standard operating procedures (SOP), were considered clearly
"preventable." In addition, operator errors resulting from insufficient
training or lack of established SOP were judged clearly "preventable."
Based on information obtained from visited plants, effective operator
training programs can minimize operator error related relief valve
discharges. Another example of "preventable" discharges is discharges due
to premature releases from relief devices. Premature releases occur when a
relief device releases at a pressure lower than the rated pressure of the
relief device. This occurs most frequently from the premature bursting of
the rupture disc. According to plant visit discussions, plants with routine
maintenance for rupture discs and safety relief valves have been able to
eliminate premature releases. Finally, discharges recurring for the same
reasons as previous discharge incidents were considered "preventable." Such
recurring discharges indicate failure to adopt appropriate preventive
measures in response to the initial discharge occurrence.
Although other causes for specific discharge occurrences may be
preventable, this assessment would need to be done on a case-by-case basis
and would require, in many cases, more information than is available in the
10-day compliance reports. Thus, a more refined preventability assessment
can not be made with the available data. For purposes of this analysis,
only the general discharge categories described above are identified as
clearly "preventable."
Assessment of performance worse than the determined limits can not be
done using the VI relief valve discharge performance data since reasons for
discharges were not obtained in their survey. Instead, assessment of
A-6
-------
performance was done using regional compliance data where causes of
discharges are available. However, there is a considerable overlap of
plants represented in the VI survey and the regional compliance data. The
attached Table 3 presents calculated plant performance for plants with
relief valve discharge performance exceeding the recommended limits.
Included in Table 3 are the actual plant relief valve discharge performance
for the 12-month period in-terms of number of discharges per 100 batches and
number of discharges, number of discharges identified as preventable, causes
of preventable discharges, and performance after elimination of clearly
preventable discharges in terms of number of discharges per 100 batches.
As seen in Table 3, all of the plants for which causes of discharges
are available can improve their performance to a level comparable to the
recommended numerical limits by eliminating all identified preventable
discharges.
EDC/VC Plants
Selection of the numerical limit for relief valve discharges at EDC/VC
plants was based on a detailed evaluation of performance by one EDC/VC plant
and on data in Table 2. As indicated in Table 2, recent relief valve
discharge performance by the 10 Vl-member EDC/VC plants ranges from 0 to
7 discharges per year. Performance by the remaining four plants not
represented in Table 1 (i.e., not VI member companies) range from 0 to
5 discharges per year. Performance by the evaluated plant did not exceed
3 discharges in any recent 12-month compliance period. First, a numerical
limit of 3 discharges per year was considered. For each plant with recent
performance exceeding 3 discharges per year, reasons for poor plant
performance (i.e., performance exceeding 3 discharges per year) were
evaluated. As in the case of PVC plants, individual plant performance was
calculated after identification and elimination of "preventable" discharges.
The same criteria were used for identifying "preventable" discharges at
EDC/VC plants as for PVC plants. Assessment of discharge reasons for plants
with worse performance was done using regional compliance data on individual
discharge reasons. Table 3 summarizes the calculated performance by plants
after elimination of "preventable" discharges. Based on this analysis, it
was judged that all plants could achieve a performance level slightly higher
than the evaluated plant by eliminating "preventable" discharges. Thus, a
numerical limit of 4 discharges per year was selected as an upper limit
performance level representative of compliance with the current standard
format for EDC/VC plants. Seven of the total 14 EDC/VC plants (50 percent)
have achieved a performance level of 4 annual discharges or less since 1981.
A-7
-------
TABLE 1. SUMMARY OF REGIONAL COMPLIANCE DATA
oo
Plant
Code
Suspension
R-l
R-2
R-3
R-4
R-5,
R-6?
«-'?
R-8?
R-9fl
R-10
R-ll
R-1Z
R-13
R-14
R-15
R-17
R-1B
R-19
Dispersion
R-ll
R-13
R-18
R-19
R-«J
R-6*
2/78-1/79 8/78-7/79
Reactor
0.04
0.017
0.011
0.02
0.016
0
0.01
0
0.01S
Discharges (Number
0.059
0.016
0.011
2/79-1/80
8/79-7/80
2/80-1/81
8/80-7/81
2/81-1/82
8/81-7/82
2/82-1/83
8/82-7/83
of Discharges/100 Batches)
0.039
0
0.022
0.043
0
0.059
(Plant start up 10/79)
0.02
0.026
0
ID
0
0.022
0.0083 0
0
0.053
0.013
0.013
0.008
0.0087
0.32
Reactor
0.027
0.014
0
0.19
0.028
0
0
0.026
ID
ID
0.008
0.0085
0.21
Discharges (Number
0.022
0.014
0
0.22
0.028
0
0.058
0.046
0
ID
0.032
0.021
0
0
0.019
ID
ID
ID
0.006
0.064
0.062
0.039
0
ID
0.036
0.024
0
0
0.014
ID
ID
ID
0.015'
0.094
0.024
0
0.079
0
0.013
0.019
0
ID
0
0.026
0.020
0
0.008
ID
0
ID
0.017
0.12
0
0
0.026
0
0.084
0.019
0
ID
0
0.027
0.020
0
0
ID
0.04
0.0094
0.010
0.080
0
0
0
0
0.070
0.013
0.021
0
0
0.036
0.030
0
0
ID
0.056
0.0095
0.004
0.11
0
0.031
0.011
0
O.OII
0.0083
0.018
0
0
0.028
0.021
0
0
ID
0.026
0.010
0.005
0.085
0
0.031
0.024
0
0.024
0.017
0
0
0
0.020
0
0
0
0.018
0.0091
0.011
0.015
0.015
0
0
0.01
0 0
0.02
0.032
0.012
0.025
0.01
NO
NO
0
0
0.016
0
0.010
0.0066
NO
of Discharges/100 Batches)
0.013
0.014
0
0.054
0
0
0.0095
0.030
0
0
0
0
0.021
0.033
0.022
0
0
0
0.009
0
0..022
0.033
0.20
0
0
0
0
0.033
0.20
0
0
0
0
0
0
0
0
0
0
0.039
0
0
NO
0
0
NO
0
0
Latex Reactor Discharges (Number of Discharges/100 Batches)
R-ll 0.067 000
Bulk Reactor Discharges (Number of Discharges/100 Batches)
R-8"
R-20a
R-21
R-22
0
0.20
0
0.052
ID
0.076
0
0.12
ID
0.076
0
ID
ID
0.083
0
ID
ID
0.030
0
ID
ID
0.092
0.041
ID
0
0.078
0.042
ID
0.041 0.041 0.030
NO NO NO
000
ID 0.057 0.094
-------
TABLE 1. (Continued)
Plant
Code
2/78-1/79 8/78-7/79 2/79-1/80 8/79-7/80 2/80-1/81 8/80-7/81 2/81-1/82 B/81-7/82 2/82-1/83
8/82-7/83
Nonreactor Discharges (Number of Discharges/100 Batches)
R-l
R-2
R-3
R-4
R-5
R-6!
R-7t
R-B*
R-9*
K-10
R-ll
R-12
R-13
R-M
R-15
R-17
R-18
R-19
R-20
R-21*
R-22
0
0
0.011
(
0.080
0
0
0.017
0
0
O.OH
0
0.027
ID
0
ID
0.026
0.071
0
0
0.010
(Plant
0
0.016
0.022
start up
0.059
0
0
0.033
0
0
0.017
tO.013
0
ID
ID
ID
0.019
0.039
0
0
0.010
10/79)
0.02
0.016
0.011
0.078
0
0
0.016
0
0.007
0.017
tO.013
0.004
ID
ID
ID
0.009
0
0
0
0
0.021
0
0.012
0.21
0.15
0
0
0
0
0.007
0.015
0
0.024
ID
ID
ID
0.007
0
0
0
0.010
0
0
0.053
0.68
0.17
0
0
0
0
0
0.014
0
0.021
ID
0
ID
0.004
0
0
0
0.036
0
0
0.034
0.66
0.16
0
0.021
0
0
0
0.014
0
0
ID
0
ID
0.004
0.0095
0
0
0.022
0
0.020
0.013
0.21
0.070
0
0.021
0
0
0
0.0086
0
0
ID
0
0
0.012
0.0096
0
0
0
0
0.062
0.022
0.12
0.055
0.0075
0
0
0
0
0.003
0
0.0042
0
0
0
0.014
0
NO
0
0.014
0
0.031
0.016
0.054
0.074
0.0075
0
0.012
0
0
0.003
0
0.0042
0
0
0
0.023
0
NO
0
0.017
Solution PVC Process Discharges (Number of Discharges)
R-23 1221
EOC/VC Plants (Number of Discharges)
0
0
0.007
0
0.030
0
0
0.0096
0
ND
0.003
0
0
0
0
0
0
ND
ND
0
0
RE-1
RE- 2
RE-3
RE-4
RE-5
RE-6
RE- 7
RE-8
RE-9
RE-10
RE- 11
RE- 12
RE- 13
8
0
0
0
1
0
2
2
3
5
ND
5
0
5
0
3
0
2
I
3
6
ND
3
0
5
1
5
0
2
0
3
4
1
0
1
7
2
4
0
1
0
2
1
(Plant startup late
5
2
2
8
3
2
0
0
0
0
2
1980)
7
5
2
1
2
4
0
0
15
1
3
2
3
4
1
(Plant startup
ND
4
4
5
0
17
1
2
5
1
r
1
11/82)
ND
5
3
e
1
5
1
NO
2
10
0
4
ND
4
ND
5
i
I
3
ND
0
6
ND
ND
4
ND
3
ND
urt
11 U
ND
1
0
ND • No Data; 10-day reports not available.
"Plants visited.
-------
TABLE 2. SUMMARY OF VINYL INSTITUTE DATA
Plant Number of Discharges/100 Batches Number of Discharges
Code 8/81-7/82 2/82-1/83 8/82-7/83 8/81-7/82 2/82-1/83 8/82-7/83
PVC Suspension Reactor Discharges
S-l 0.000625 0 Plant Down
S-2 0.0083
S-3* 0.032
S-4 0.0042
S-5 0
S-6 0.00017
S-7 0.0083
S-8 0
S-9* 0.018
S-10 0
S-ll 0
S-12 0
S-13 0.067
S-14 0.033
S-15 0
S-16* 0.0083
S-17 0.017
0.033
0.032
0.0042
• o
0.00017
0
0
0
0
0
0
0.101
0.033
0
0.017
0
0.025
0.025
0
0
0.00025
0
0
0.012
0
0.0109
0
0.059
0
0
0.034
0
1
1
1
1
0
1
1
0
1
0
0
0
7
1
0
1
3
0
3
1
1
0
1
0
0
0
0
0
0
10
1
0
2
0
Plant Down
2
1
0
0
1
0
0
1
0
3
0
6
0
0
4
0
PVC Dispersion Reactor Discharges
0-1 0
D-2* 0
D-3* 0
D-4 0
D-5 0.0225
D-6 0
PVC Latex Reactor
L-l 0
L-2 0
L-3 0
PVC Bulk Reactor
M-l* 0
M-2 0.125
M-3 0.116
0
0
0
0
0.035
0
Discharges
0
0
0
Discharges
0
0.033
0.052
0
0
0
0
0.035
0
0
0
0.033
0.030
0
0.125
0
0
0
0
1
0
0
0
0
0
2
8
0
0
0
0
1
0
0
0
0
0
1
3
0
0
0
0
1
0
0
0
1
1
0
8
A-10
-------
TABLE 2. (Continued)
Plant Number of Discharges/100 Batches
Code 8/81-7/82 2/82-1/83 8/82-7/83
Number of Discharges
8/81-7/82 2/82-1/83 8/82-7/83
PVC Nonreactor Discharges
N-l
N-2*
N-3
N-4
N-5*
N-6
N-7
N-8
N-9
N-10
N-ll*
N-12
N-13
N-14
N-15
N-16
N-17
N-18
N-19
0.225
0.025
0.168
0.10
0
0.005
0
0.0092
0.0058
0.126
0.014
0.025
0
0
0
0.020
0
0
0.0067
EDC/VC Discharges
0.117 0.0833 12
0.025 0.0083 2
0.275 Plant Down 2
0.0017 0 5
000
0 0 1
000
0.0092 0 1
0.0083 0.0083 1
0.054 0.0433 2
0 1
0 1
0 0
0 0
0.0056 0
0 1
0 0
0.017 0
0.0158 1
.0092
.0083
.054
0.014
0.025
0
0
0
0.020
0
0.017
0.0108
7 6
2 1
1 Plant Down
1 0
0 0
1 1
0 0
1 0
1 1
1 1
1 0
1 0
0 0
0 0
0 1
1 0
0 0
1 1
2 3
E-l
E-2
E-3
E-4
E-5
E-6
E-7
E-8
E-9
E-10
1
1
5
0
1
4
3
1
4
2
1
5
6
0
1
4
3
1
5
1
5
7
5
3
0
3
3
0
5
0
*PUnts visited.
A-ll
-------
TABLE 3. ASSESSMENT OF PERFORMANCE WORSE THAN RECOMMENDED NUMERICAL LIMITS
Plant No.
Code Period
PVC Reactor Discharges
R-19 B/8 1-7/82
R-22 2/82-1/83
R-22 8/82-7/83
PVC Nonreactor Discharges
R-2 8/81-7/82
> R-4 8/81-7/82
i— «
ro
R-4 2/82-1/83
R-S 8/81-7/62
R-S 2/82-1/83
R-5 8/82-1/83
EDC/VC Discharges
RE-5 8/81-7/82
RE-7 8/81-7/82
RE-9 6/81-7/82
RE-13 8/81-7/82
RE-13 2/82-1/63
of Discharges
100 Batches
0.085
0.057
0.094
0.062
0.12
0.06
0.055
0.074
0.030
-
-
-
-
-
No. of
Discharges
6
3
6
2
2
1
5
6
3
5
8
5
10
6
No. of Clearly
Preventable
Discharges
4
2
4-6
1
1
1
2
3
1
2
4
4
6
6
Causes of Clearly
Preventable Discharges
1-operator error; 1-premature
release; 2-recurrence
1-premature failure; 1 -recurrence
Representative of this company
Indicated that most of the discharges
were due to design problems.
Appropriate modifications have been
made.
1-operator error
1-operator error
1-operator error
1-operator error; 1-recurrence
2-operator error; 1-recurrence
1-operator error
2-operator error
4-operator error
4-operator error
5-recurrence; 1-operator error
5-recurrence; 1-operator error
Performance After
Elimination of Clearly
Preventable Discharges
0.028 discharges
100 batchTs
0.019 discharges
100 batches
<0.035 discharges
"TOO bate fie s
0.031 discharges
100 batches
0.06 discharges
100 batches
0 discharges
lOO batcFes
0.033a discharges
100 batches
0.037a discharges
100 batcfies
0.020 discharges
100 bat elves
3 dlscharges/yr
4 dlscharges/yr
1 dtscharge/yr
4 dtscharges/yr
0 discharge/yr
'Level does not correctly reflect actual relief valve discharge performance by this plant since most relief valve discharges are flared. Flare
destruction efficiency of VC Is unknown. Typical flare destruction efficiency of other VOCs Is at least 98 percent.
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-85-002
3. RECIPIENT'S ACCESSION NO.
*. TITLE AND SUBTITLE
Vinyl Chloride: Relief Valve Standard
S. REPORT DATE
January 1985
6. PERFORMING ORGANIZATION CODE
7. AUTHGR(S)
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Emission Standards and Engineering Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3056
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Air and Radiation
U.S. Environmental Protection Agency
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
IS. SUPPLEMENTARY NOTES
IO. AB5THAGT
This document presents information on relief valve discharge performance by industries
subject to the vinyl chloride (VC) NESHAP regulations. Information on relief valve
discharge performance was collected as part of the review of the technological basis and
administrative aspects of the current VC standard. The report includes relief valve
discharge performance data for the entire compliance period following promulgation of
the VC standard (i.e., 1978-1983). The information presented was based on Regional
compliance reports, industry survey and plant visit.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air Pollution Control
National Emission Standards for Hazardous
Air Pollutants
Vinyl Chloride
Polyvinyl Chloride. .
Hazardous Air Pollutants
Air Pollution Control
13B
•EMEN1
19. SECURITY CLASS iTIiis Report/
Unclassified
Unlimited
£?A Form 2220-1 (P«». 4-77) f»«*viOua
20. SECURITY CLASS {This page I
Unclassified
21. NO. OF PAGES
74
22. PRICE
is OSSOU«Tt
------- |