ENVIRONMENTAL
               EVALUATION
                    OF
       VINYL CHLORIDE  EMISSIONS
                   IN THE
    LONG BEACH AREA  CALIFORNIA
FEDERAL FIELD INVESTIGATIONS CENTER-DENVER
            DENVER .  COLORADO
                    AND
  REGION  IX - SAN FRANCISCO  CALIFORNIA
                 MAY 1974

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           PREFACE TO REGIONAL MONITORING REPORTS
                      ON VINYL CHLORIDE
     This is a preliminary report and should not be construed
to represent Agency policy.  When reading this document it
should be recognized that this information was obtained in a
very short period of time using sampling and analysis methods
that have received only a limited amount of pretesting.  The
methods utilized were based on the Agency's best scientific
judgement and represent, in the Agency's opinion, the best
methods available.  However, they have not been thoroughly
tested for accuracy and precision under field conditions.  The
actual sampling and analysis methods were based on previous
analytical studies in which similar chemicals were evaluated.

     Prior to and during the actual vinyl chloride sampling and
measurement only limited quality control and standardization of
procedures could be applied in the time available.  It is impor-
tant to recognize that the methods utilized are interim proce-
dures which are subject to further modification.  In addition,
the methods should not be construed as EPA recommended methods.

     The nature of the PVC manufacturing process results in the
escape of vinyl chloride in pulses; therefore, high levels may
appear in grab samples taken at the time of these releases, and
very low levels may be present at intervening times.  So, too,
changes in air movement may influence concentrations at a given
station at any one time.  Therefore, it is important to recognize
that the vinyl chloride data reported in this document are prelimi-
nary in nature and are subject to change as additional monitoring
is performed under more representative and standardized conditions,

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       ENVIRONMENTAL PROTECTION AGENCY
   EVALUATION OF VINYL CHLORIDE EMISSIONS
                   IN THE
        LONG BEACH AREA,  CALIFORNIA
NATIONAL FIELD INVESTIGATIONS CENTER - DENVER
              DENVER, COLORADO
                     AND
    REGION IX - SAN FRANCISCO, CALIFORNIA

                  MAY 1974

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                             CONTENTS


                                                                 Page

I.      SUMMARY	       1

II.     INTRODUCTION 	       3

III.    PLANT EVALUATION 	       7
          American Chemical Corporation	       7
          B.F. Goodrich Chemical Company 	      11

IV.     SAMPLING PROGRAM	      15
          Wastewater	      IS
          Air	      17

V.      RESULTS AND DISCUSSION	      20

APPENDICES:

        A - TEST PROCEDURES

        B - PLANT EVALUATION - KEYSOR-CENTURY CORPORATION

        C - PERSONS CONTACTED

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              EVALUATION OF VINYL CHLORIDE EMISSIONS
                IN THE LONG BEACH AREA,  CALIFORNIA
                            I.   SUMMARY

     A survey of vinyl chloride emissions from the American Chemical

Corporation and B.F. Goodrich Chemical Company showed that vinyl

chloride monomer was leaving the plants via water, sludge, and air as

well as in the final produce, polyvinyl chloride.

     It is estimated that about 2.3 kg (5 lb)/day  of PVC leave the

B.F. Goodrich plant, and 10 kg (22 lb)/day leave the American Chemical

plant in the wastewater effluents.  Smaller quantitied were found in

the sludge.

     Vinyl chloride monomer was released to the air during venting,

cleaning, or by accident.  One on-site release monitored by infrared

spectrometer reached approximately 75 ppm at the point of measurement

in-plant.  The mean value of all grab samples collected was about 0.1

ppm; the maximum value measured was 3.4 ppm, 4.8 km (3 mi) north of the

plants.  To maintain the 0.1 ppm level over the area of the study

(4.8 km radius) would require about 910 kg (2,000  Ib) of VCM.  Each

exchange in the basin must be renewed by this quantity to maintain

the 0.1 ppm level.  Thus, if the exchange of air in the area occurred

four times a day, a minimum of 4 tons of VCM would have been discharged

from these plants.

     The survey also indicated that the plants will routinely be in

violation of the standard proposed by the Occupational Safety and

Health Administration which requires the level of  employee exposure to

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vinyl chloride to be undctectable.  About 5 percent of the ambient air




samples exceeded 1 ppm VCM and in-plant releases from 20 to 75 ppm were




measured.

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                         II.   INTRODUCTION






     Vinyl chloride is used primarily  in  the  production  of  polyvinyl




chloride for floor tile,  records,  pipe, containers  and other  plastic




products.  It is also used as aerosol  propellent  in consumer  products




such as pesticide and hairspray.




     Potential environmental and  health hazards are associated with




the vinyl chloride industry-   Vinyl chloride  has  been implicated  in




both worker and nonworker deaths  from  a rare  but  fatal form of cancer,




angiosarcoma of the liver.  A recent study  in animals has  tentatively




indicated that exposures  to this  chemical in  concentrations as low as




50 mg/1 tends to produce  carcinogens.  These  data have led  the Occupa-




tional Safety and Health  Administration  (OSHA) to propose  a standard




for employee exposure to  vinyl chloride at  no detectable level




(39 FR 16896, 10 May 1974).




     The Administrator of the Environmental Protection Agency (EPA),




Russell Train, established a task force under the chairmanship of the




Director, Office of Toxic Substances,  to  determine  what  action EPA




should take to preclude or reduce the  hazards caused by  vinyl chloride.




A major task force objective was  to collect monitoring data for  the




kinds and levels of air emissions, wastewater effluents, and sludges




from vinyl chloride and polyvinyl chloride  plants and ambient data on




the pollutants from these plants.




     On 10 April 1974 the Director, Office  of Toxic Substances,  asked




the Region IX Administrator to assist  in  assessing  the extent to  which




vinyl chloride in process wastes  is being introduced into  the environment.

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The requirement for analytical results by 20 May prompted a 24 April

request by Region IX for assistance from the National Field Investi-

gations Center - Denver in conducting the analysis of effluent and

sludge samples and ambient air monitoring in the vicinity of two

plants, the American Chemical Company and B.F. Goodrich Chemical

Company plants in Long Beach, California.*

     The B.F. Goodrich and American Chemical plants are next to each

other in a highly industrialized area of Long Beach.  General land use

in the area is shown in Figure 1, and the plot plan of the plant prop-

erty is in Figure 2.  Both plants operate around-the-clock, 7 days a

week.  Residential areas lie within half a mile of the plant.

     The "1974 Directory of Chemical Products, USA" indicates that the

B.F. Goodrich plant has an annual capacity of 73-million kg (160-million

Ib) of polyvinyl chloride resins.  The American Chemical plant has an

annual capacity of 68-million kg (150-million Ib) of polyvinyl chloride

in addition to a 79-million kg (175-million Ib) capacity for vinyl

chloride monomer.

     On 6 May, Region IX and NFIC-D staff members met representatives

of each of the plants (App. C) to discuss industrial processes, and

to determine possible points for sampling to be conducted 7-10 May.
* There are three vinyl chloride plants in Region IX.   The Keysor-Cen-
  tury Corporation at Saugus, Cal. was visited on 30 May 1974, but it
  was not sampled; the plant evaluation is in Appendix B, and Plant
  personnel contacted are given in Appendix C.

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                                                                          d.
                                                                             01
-fl-
                                 AMERICAN  CHEMICAL
                                    CORPORATION
                              B.F.GOODRIGH
                           CHEMICAL  COMPANY
                         Figure 2 •   Properly Layout

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                      III.   PLANT EVALUATION






AMERICAN CHEMICAL CORPORATION






Manufacturing Process and Sources of Waste




     The American Chemical Corporation plant  manufactures  four  products:




ethyl chloride, ethylene dichloride (EDC)  by  two methods,  vinyl chloride




monomer, and polyvinyl chloride by suspension polymerization [Fig.  3].




     In the manufacture of ethyl chloride, the raw materials are ethy-




lene, hydrochloric acid and aluminum chloride as the catalyst.   Only




non-contact cooling water is used in the process.  Unreacted hydro-




carbons and hydrochloric acid are vented through a scrubber.  Off-gases




from the scrubber go to the incinerator.




     In the manufacture of EDC by direct chlorination,  the raw  materials




are crude ethylene and chlorine.  In this process, the  water from the




oxychlorination process is used to wash the feed to the reactor.  This




wastewater is then neutralized and sent to the sewer system. The vent




gases from this unit go to the oxychlorination system and  through an




incinerator.  The carbon steel vessels act as a catalyst in this process.




     The manufacture of EDC by the oxychlorination process uses ethylene,




hydrochloric acid and air as raw materials, and cupric  chloride as a




catalyst.  As in direct chlorination, the acid water from  the oxychlor-




ination reactor is used to wash the ethylene dichloride in an inter-




mediate purification step.  All of this water is neutralized and sent




to the sewer system.  The combined water from both units currently




contains about 200 mg/1 EDC.  By July, steam stripping  will be  installed

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'«.•... C.-s
  Fr^_
Sef: -er
              Etf-ylene
             (CcW Bex)
                                       Ethyl Chloride Unit
                                                      Direct Chlorination
                                           Chlorine
                                                                    Reactor
                                                         Ethylene Oichloride Units
                                                       Oxychlorination
Wastewster to
Sanitary
L                                                                                     Acidic Uater              !
                                                                          — — —— — — — —— __ 	—_ __ ^   -_ _ __ _J


                                                                              EDC  For Vinyl Feedstock
                                                                    Wastewater to
                                                                    Sanitary Seuer £ Ground Drains
              to
    Sanitary Sewer
                                                                                                            Wasteviater  to
                                                                                                            Sanitary  Sewer
                                                                       vinyl Chloride for »/C Feed Stock
                                                                  Figure 3  -flnencan Cieraical Corporation  Process Flow

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to lower the EDC to 25 mg/1.   All  vent  gases  from  this unit go  through




the incinerator.




     There arc three vinyl chloride monomer units  on  the  plant  site,




but only one was operating during  the visit.   Production  capacity  of




this unit is approximately 45-miilion kg (100-million Ib)  of  vinyl




chloride per year.  The VCM production  rate during sampling was esti-




mated at 90 percent of this capacity.  The VCM units  use  EDC  as the




raw material.  For drying, the vinyl chloride monomer passes  through a




caustic system which is blown down once per shift  and discharges 38 to




57 liters (10 to 15 gal.) of caustic to waste for  neutralization.




     The plant has three PVC suspension units, three  centrifuges,  and




three dryers.  The two horaopolymer units use  VCM as the raw material,




tertiary butyl peroxide as catalyst-, and methyl cellulose and carboxy-




methyl cellulose as disperring agents (CMC is used once-through).   The




copolymer unit uses VCM and vinyl  acetates a  mineral  spirits  catalyst,




and trichloroethylene as a modifier. The three PVC dryers produce dry




polymer at a total rate of about 6,800  kg (15,000  lb)/hr.  The dryers are




the limiting factor in PVC production.




     After polymerization, the PVC slurry is  discharged  into  a blowdown




tank where the unreacted momoner is stripped  by vacuum  and recycled to




thePVC reaction vessel.  An incinerator and  scrubber  prevent  escape of




vented VCM to the atmosphere.  The PVC  is separated from  the  water by




centrifuging, dried in rotary steam-heated dryers, and  stored for  sales.




     The vent gas from the rotary dryer goes  to the bag house for




separation.  The air from the bag  house and  storage area  goes through  a

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                                                                    10
particulate filter at a flow rate about 57 m3/min (2,000 cfra).  All

PVC units have VCM recovery units.  When the PVC reactors are to be

opened, the vinyl chloride left in the reactor is discharged through

steam jets to the atmosphere.

     Sources of process wastewater are the caustic blowdown from the

vinyl chloride process, acid washwater used to remove ferric chloride

from the EDO before its distillation, effluent from the PVC slurry

centrifuging units, surface drainage (washwater) from the VCM recovery

units, the PVC plants and the chlorination units, and effluent from

the VCM incinerator flue gas scrubber.

     The plant uses water at a rate of 38 to 41 I/sec (600 to 650 gpm).

The total wastewater flow* is about 19 I/sec (300 gpm), of which 6 to

8 I/sec (100 to 130 gpm) results from the centrifuge units cited

above.  The remaining water is lost through cooling tower evaporation.


Treatment System

     The plant is equipped with separate industrial, storm, and sani-

tary sewer systems.  Three separate basins are used to neutralize

wastewater from the different processes.  One of these, the Dominguez

Channel pumping basin, receives rain and outdoor plant runoff water

in addition to surface drainage from the PVC and chlorination units.

Overflow into Dominguez Channel does not usually occur except during

heavy rains or periods of excessive plant washdown.   The effluent from

the three basins is collected in the West Sanitary Sewer interceptor
* The only flow measurement available in the facility was the total
  flow at the pll check basin.

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                                                                  11
basin, and the pH is again adjusted before the effluent  is  discharged




to the Los Angeles County Sanitation District  for primary  treatment.




The wastewater effluent has a COD of 600-800 mg/1 and a  TSS of  about




1,000 mg/1.  The majority of these suspended solids are  from the sus-




pension polymerization of PVC.




     All off-gases from ACC go through the single stage  incinerator




which operates in the 760to870°C (1,400 to 1,600°F) range and  has an




after scrubber to remove hydrochloric acid.




     Solid waste from plant operations is trucked by contract disposal




to approved landfills.  The sludge and liquid  removal rate is about




32 m3 (8,400 gal.)/week of combined sludge and water; the water con-




tent ranges from 50 to 80 percent.






B.F. GOODRICH CHEMICAL COMPANY






Manufacturing Process and Sources of Waste




     The B.F. Goodrich Chemical Company plant, on a 12-acre site,




manufactures polyvinyl chloride resins and compounds.  PVC is made




using batch suspension polymerization; VCM (purchased) reacts with




water, emulsifiers and initiators, under controlled conditions  of




temperature and pressure [Fig. 4].  The raw materials used in the




reaction are an organic peroxide catalyst, a polyvinyl alcohol  dis-




persing agent, and phthalate plasticizers.




     After the reaction is complete, the unreacted vinyl chloride is




stripped,  condensed,  and recovered for recycle.  The stripped resin




is  then transferred to tanks  for blending of the resins from numerous




reaction vessels.  To this point the process is batch.  The remaining

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        Raw
     Materials
   VCM
   H20
Catalyst
    Reactor
     Washwater
   To Sev;er
             VCM
           Recovery
                  Reactor
 24
Each
      To ATM
                  Refrig.
                   Vent
                Condenser
               Recycle
                 VCM
Reactor
                                               •*»-  ATM
                 Vent
                           Sanitary Sewer
                                                                                     To ATM
                                                 To ATM
To ATM
Blend
Tank
Wash water
To
Sewer
1
Blend
Tank
7 Each
i


Centrifuge
i
Wastewa



Dryer
4 Each
ter to




Compounding
Extruders



j
Dust
Control
k
                                                                                                        Polymer
                                                                                                          To
                                                                                                        Storage
                                      Figure 4  -  B.F.Goodrich  P.V.C.  Process   Flow

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                                                                   13
process steps are continuous.   The resin is  pumped from the blend


tanks to a centrifuge for dewatering.   The wet cake from the centrifuge


then enters a hot air dryer equipped with appropriate dust control


devices.  The resin is then either bagged for shipment, or transferred


to storage silos for bulk shipment or  subsequent compounding.

                                                   3
    Each of the 24 reactors at the plant is  a 9.5 m  (2,500 gal.)


vessel.  Vapors from these reactors pass through the VCM recovery


system and refrigerated vent condensers.  Reactors are evacuated before


being opened for washing; upon opening, they are vented to the atmo-


sphere.  This cycle occurs 2 or 3 times a day per reactor, a total of


about 50 times.  This plant produces 7-million kg (15-million lb)/mo


of homopolytner PVC, part of which is plasticized with a phthalate


plasticizer.


     All water used at B.F. Goodrich is supplied by the city.  Total


plant water effluent rate was determined by  subtracting an estimated


15 percent evaporation from the city water inlet rate, obtained by


reading the city water meter.   During sampling, this effluent rate

                       o
was approximately 490 m /day (.13 mgd).  The plant uses cooling towers


and generates steam for process uses.   Each  reactor uses 2,300 to 3,000


liters  (600 to 800 gal.) of water per wash.   The cooling tower blow-


down, containing a chromium inhibitor, and the boiler blowdown, contain-


ing phosphate-sulfite, are discharged to the sewer system.  All cooling


water, except the water used in the compounding area, is non-contact.


The contact water used in the compounding area is recycled to the


cooling tower except for the 130 1/min (35 gpm) discharged to the


sewer.

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                                                                  14
     Major wastewater sources are:   centrate from dewatering centri-




fuges (PVC), reactor cleaning, general cleanup of equipment and floors,




discharge from the wet scrubber dust control system,  water treatment




system regenerate, and boiler blowdown.




     The water discharged from the  centrifuges is the major source of




waste effluent, with a flow of 260  to 300 1/min (70 to 80 gpm).  About




130 1/min (35 gpm) wastewater comes from the wet scrubber in the com-




pounding area.  The effluent has a  COD of 80 to 150 mg/1, and 500 to




600 mg/1 suspended solids.  The suspended solids are  mainly fine parti-




cles of PVC from the suspension polymerization.






Treatment System




     The plant is equipped with separate industrial,  storm and sanitary




sewer systems.  After neutralization and gross removal of suspended




solids, the industrial wastewater discharges to the Los Angeles County




Sanitation District for primary treatment.   Except for excessive rain-




fall, the storm sewer discharge is  recycled as cooling tower makeup.




     Atmospheric emission points from the PVC process are vents from




reactor vessels, the monomer recovery system, blend tanks, compounding




dust control and ventilation systems, and dryer dust  collection systems.




     Solid waste from plant operations is trucked by  contract disposal




to approved landfills.  About 3,600 kg (8,000 Ib)  of  the resin and water




sludge are removed every 6 weeks.  Water content of the sludge is about




50 percent.

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                                                                  15
                       IV.   SAMPLING PROGRAM







WASTEWATER




     Three sampling stations were established  at the B.F.  Goodrich




plant and seven at the American Chemical plant.   Sampling  of  effluents,




city water and sludge were conducted by Region IX,  Surveillance and




Analysis Division personnel for a three-day period,  from 10:00 a.m.




on 7 May 1974 until 9:00 a.m. on 10 May 1974.   Sample point selections,




frequency of sampling and methodology were based on guidelines pro-




vided by the EPA task force.  In general, effluents  leaving the plant




property and discharging into the county sanitary sewer system or




into surface waters were to be sampled hourly  around-the-clock for




three consecutive days.  During the three-day  sampling period no dis-




charges to surface waters occurred, and it was necessary only to take




around-the-clock samples of streams to the sanitary sewers.




     Hourly samples for eight consecutive hours during each of the




three sampling days were taken from 10:00 a.m. to 6:00 p.m. at in-plant




pretreatment points, such as settling basins.   Grab samples of influent




city water and sludge from settling basins were taken once each day.




Eight-hour composite samples (taken hourly) were obtained  on the after-




noon shifts of 9 and 10 May 1974 (6:00 p.m. to 2:00 a.m.)  for metals




analysis and preserved with nitric acid in cubitainers.




     All samples for VCM analysis were taken manually by filling each




sample container to the brim directly from the stream.




     Water samples were collected in 50-ml, acetone-rinsed, glass




bottles with teflon-lined caps.  Sludge samples vrere collected in

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                                                                  16
acetone-rinsed jars with teflon liners.   The samples were refrigerated

(approx. 0 to 3°C) after collection and  protected  from light.   Because

vinyl chloride is a gas at ambient temperatures, samples  were  not

composited* but rather were analyzed individually.  Chain-of-custody

procedures were followed throughout.  The following table gives sample

number, description, and sampling frequency.


Sample               Description                   Daily Frequency


                 B.F. Goodrich Chemical Company

  G-l      Plant effluent at interceptor         24 consecutive hourly
              pit                                  grab  samples
  G-2      City water                             1 grab  sample
  G-3      Interceptor pit sludge                 1 grab  sample


                 American Chemical Corporation

 AC-1      Plant effluent at pH check            24 consecutive hourly
              basin                                 grab  samples
 AC-2      Ground drains from PVC and C12         8 consecutive hourly
              units                                 grab  samples
 AC-3      Neutralized VCM and EDC waste-         8 consecutive hourly
              water                                 grab  samples
 AC-4      PVC centrifuge effluent               24 consecutive hourly
                                                    grab  samples
 AC-5      Pumping basin overflow                Not  used
 AC-6      City water                             1 grab  sample
 AC-7      Sludge from PVC centrifuge             1 grab  sample


     The  two  sets of 8-hr composite samples for copper and mercury

analysis  were collected at stations G-l, and AC-1 through AC-4.  Both

metals  are commonly used as catalysts in the production of vinyl

chloride.  Analytical  test procedures are discussed in Appendix A.
 *  Results  shown  as composites in the table above will in fact have been
   averaged over  the sample period.

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                                                                 17
AIR



     Air sampling was conducted by personnel from NFIC-D.   Ambient air




quality was evaluated by 10-min grab sampling,  24-hr composite sampling,




and continuous air monitoring was conducted on the plant properties.




Figure 5 shows the location of the ambient air sampling stations.   Chain-




of-custody procedures were used for all ambient air samples.




     The grab samples were collected at 15 locations surrounding the




plant to a distance of 5 km (3 mi) downwind. Each day (four sampling per-




iods) the sampling schedule was altered by shifting the sampling run 2 hr.




Thus over the 3-day period, the 12 samples collected at these locations




showed collection times approximately 2 hr apart.  Samples were collec-




ted by drawing air through MSA Organic Vapor Sampling Tubes (small




carbon columns of activated coconut char) for 10 min using a precali-




brated portable pump.  From 2.3 to 4.0 1 (.08 to .14 ft )  of air was




passed through each tube for later analysis.  After sampling, the tube




was capped, tagged, placed in a polyethylene bag, and cooled on dry ice




until analyzed at NFIC-D.




     For the 3-day period the 24-hr composite samples were collected




at six locations  [Fig. 5] on large carbon columns prepared at NFIC-D.




Each column consisted of three sections containing approximately 1.5 gm




each of Nuchar WV-L, 8/30 mesh granular activated carbon separated by




glass wool.  The carbon was activated at 600°C for 1/2 hr before being




charged in 7 mm glass tubing previously rinsed in acetone.  After being




charged, the tubes were heat-sealed and ready for use.  In the field




the tube  was broken open, one end covered with a rubber serum cap and

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                                           r  V  \|f  ;.'.r;-*,=U.~V<
                                           ;  -:x\  . M,   v.          *"•-"•" \j
                                                                                           _
                                                                       r  -  p'  T\  Vi-
                                                                      '        ^-
STATIONS 3911 • 3808  24 HOUR COMPOSITE SAMPLES  ••?/.


STATIONS 3911 • 392!  10 MINUTE GRAB SAMPLES
•'/ ('       I^U-ftlr'     •   f



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-------
                                                                  19
a 30-gage hypodermic needle connected to a vacuum pump inserted  for

flow control.   The hypodermic needles had been previously calibrated

at 77cc/min ±  5 percent.   After each sampling period  the tubes were

closed with masking tape and placed on dry ice until  returned to NFIC-D

for analysis.   Hypodermic needles were also returned  for recalibration.

During the second and third sampling periods the tubes were covered to

prevent exposure to sunlight.

     Continuous analysis was possible using the Wilks Scientific MIRAN

Portable Gas Analyzer*.  The instrument is a single-beam, infrared

spectrometer with folded path gas cell and a wavelength range of 2.5

to 14.5 urn.   Vinyl chloride can be detected at 6.15,  9.8, 10.9,  and

13.9 ym with varying sensitivites and interferences;  the minimum

detectable concentration is about 1 ppm.  Coupled to  a strip chart

recorder, the instrument is capable of continuously monitoring a var-

iety of atmospheric pollutants.  In this case the instrument and recorder

were set to measure vinyl chloride at ACC on two occasions for 14 hr

and 21 hr, and at BFG for one period of 21 hr.  The instrument was also

operated for a short period of 2 hr in a sedan parked about 0.5  km

(0.3 mi) due east of the plant.
* Citation of brand name or trademark does not imply product
  endorsement.

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                                                                  20
                    V.   RESULTS AND DISCUSSION






WATER SAMPLES




     The results of the analyses and compositing  of water  samples  from




both plants are given in Table 1.   The maximum  values  shown  are the




highest individual values used in determining the composite  since  each




hourly aliquot was analyzed separately.  The average concentrations  of




VCM in the effluent from both plants (Stations  G-l and AC-1)  are quite




comparable, although the extremes at B.F.  Goodrich are more  than twice




as high.  Since the variability in flow rate as measured hourly at




station AC-1 was not large Cabout ± 10 percent),  little error is intro-




duced by not flow weighting individual results.  Daily average flow




rates at ACC were calculated as 21, 20 and 21 I/sec  (330,  310, 330 gpm)




for the 3 days of the survey.




     Since sampling locations were open to the  atmosphere, a certain




amount of vinyl chloride would be expected to be  transferred to the  air




at these sites or at other locations where turbulence  was  experienced.




Also, since there is no partial pressure of VCM above  the  water surface,




the gas would be expected to transfer from water  to  the air  in the sewer




system.  From there it  would vent to the atmosphere  through  manhole




covers or even at the sewage treatment plant.  At a  flow rate of




20 I/sec (320 gpm) from ACC and 6 I/sec (90 gpm)  from  BFG, the amount




of VCM  leaving  the plants via the water route is  estimated to be




10 kg (22 lb)/day from ACC and 2.3 kg  (5 lb)/day  from  BFG.




      Two  8-hr composites  for copper  and mercury analyses were collected




 at  Stations G-l,  and AC-1  through  AC-4.  No mercury was found at  either

-------
                                                                 21
plant, but copper,  presumably resulting  from  the cuprlc chloride

catalyst, was found as shown below:

                                        Copper  (mg/1)
             Station                    AVR.     Max.

              AC-1                       0.01   0.15

              AC-2                       0.01   0.05

              AC-3                       0.43   3.2
                              Table 1
        Concentrations of Vinyl Chloride in Water  Samples

Station

G-l


G-2


Date
(May)

7-8
8-9
9-10
7
8
9
Vinyl Chloride (mg/1]
Description
B.F.
Plant


Avg
.
Max
•
Goodrich Chemical Company
effluent -


City water




American
AC-1


AC-2


AC-3


AC-4


AC- 6


7-8
8-9
9-10
7
8
9
7
8
9
7-8
8
9
7
8
9
Plant


Ground




- grab


24 hr composite


sample


3.
5.
5.

-------
                                                                 22
SLUDGE SAMPLES




     Three grab samples of sludge were collected  from the BFG inter-




ceptor pit (Station G-3) and three from the PVC centrifuge at ACC




(Station AC-7).  The results from Station AC-7  showed little varia-




tion containing 4,200, 4,100 and 3,600 ug of VCM  per  gram of dry




sludge.  The results from Station G-3 were highly variable at 290,




2,100,and 980 yg of VCM per gram of dry sludge.   The  higher varia-




bility and lower values at Station G-3 may be attributable to the




residence time that the particular sludge samples were in the pit.




As indicated earlier, about 3,600 kg (8,000 Ib) of sludge is removed




from BFG every 6 weeks compared to the 32 m /week (8,400 gal./week)




removed from ACC.






AIR SAMPLING






Grab Samples




     Surface winds as measured hourly at the Long Beach Municipal




airport were generally from the south and the west during the survey




period.  Table 2 presents the surface wind direction  and speed measured




during each of the twelve grab sampling runs which took about 4 hr  each.




The meteorological measurements were taken 5 min  before each hour so




the Table includes the reading preceeding each  run and the one immedi-




ately following completion of sampling.  Wind velocity and direction




were also being continuously measured and recorded from a tower (about




100 ft high) at the ACC complex.  Rough estimates of  the wind velocity




and direction from these data are also shown Jn Table 2 for comparable

-------
                                                      Table 2
                                                  Meteorological  Data
Date
Run (May)
70 7

71

72 8

73

74

75

76 9

77

78

79

80

81 10

Time
Start
1410

1930

0205

0812

1205

1822

0001

0540

1015

1535

2130

0342

(hr)
Finish
1842

2330

0610

1150

1655

2130

0335

0915

1335

1908

0120

0720

Location
IBM
ACC
IBM
ACC
IBM
ACC
IBM
ACC
IBM
ACC
IBM
ACC
IBM
ACC
IBM
ACC
IBM
ACC
IBM
ACC
IBM
ACC
LBM
ACC
v ,

-/ 1st
19
30
26
30
22
33 .
18
33
12
33
17
18
17
23
00
14
15
15
21
31
29
31
30
33
04
09
06
09
03
01
03
01
05
01
07
10
04
04
00
01
04
05
08
09
08
09
04
07

Wind
2nd
20
30
30
30
00
33
00
33
18
18
20
18
13
23
00
14
19
24
19
31
30
33
32
33
04
09
07
09
00
01
00
01
08
04
10
10
04
04
00
01
05
05
08
09
05
07
06
07
Direction / Speed (kn).
Survey Hour
3rd
24
30
30
30
20
33
20
33
18
18
18
18
15
23
00
14
20
24
24
31
30
33
29
00
07
09
03
09
04
01
06
01
07
04
05
10
04
04
00
01
07
05
06
09
04
07
04
02
4th
28
30
00
30
00
33
15
33
18
18
18
18
22
23
17
14
17
36
29
31
31
33
00
00
07
09
00
09
00
01
04
01
09
04
06
10
05
04
04
01
06
04
07
09
05
07
00
02
5th
26
30
00
30
00
33
12
33
16
18
23
18
00
23
20
15
20
36
29
31
29
33
00
09
06
09
00
09
00
01
05
01
09
04
04
10
00
04
03
05
09
04
09
09
03
07
00
01
6th
26
30
00
30
18
33
_
-
17
18
_
-
—
-
15
15
_
-
30
31
29
33
00
09
06
09
00
09
05
01
— —
—
08
04
»
	
_ —
—
04
05
_..
—
07
09
04
07
00
01
                                                                                                                      ro
LBM - Long Beach Municipal  Airport; ACC - American Chemical  Corporation

-------
                                                                 24
time intervals.  These two sites were about  5 mi apart  on an east-




west line.  There was little agreement in either wind velocity  or




direction, probably as a result of differences in both  elevation and




local topographic features.




     Since both plants operated a series of  batch processes,  discharge




to the atmosphere of a continuous level of vinyl chloride would not




be expected.  During any 4-hr sampling run it was only  fortuitous  if




the plant discharge, wind speed and direction, sampling location,  and




10-min sampling period overlapped to produce a value higher than




ambient.  Table 3 gives the results of each  of the 10-min samples




collected during the survey period.  The average and maximum value at




each station is plotted on Figure 6.  Arithmetic averages were  used




because of the limited amounts of information.  However,  data of this




sort would generally be expected to be log-normally distributed; when




all of the results were combined, this, in fact, was the case.   Figure 7




shows the distribution of the results.  About 5 percent of the  results




exceeded 1 ppm, and about 11 percent of the  data exceeded 0.5 ppm, and




the mean value is about 0.1 ppm.  To attain  this mean value over the




study area of 4.8 km (3 mi) radius to a depth of 50 m  (164 ft)  would




require 910 kg (2,000 Ib) of VCM.  To maintain this level during each




exchange of air in the basin would require at least another ton of VCM.




This could easily occur several times a day.   These data  compare very



unfavorably with the OSHA proposal to keep limits for employee  exposure




to below 1 ppm or undetectable.




     Even 3 mi from the plant, individual values can reach several




parts per million.  In fact, the highest value measured was 3.4 ppm

-------
                Table 3
  Results from ID-minute Grab Samples
[Measured in ppm at 25°C and 760 mm Hg]
Station
Distance (mi)
Run
70
71
72
73
74
75
76
77
78
79
80
81
Average
Maximum
11
1.5

0.05
0.53
0.08
0.10
0.23
0.05
0.08
0.10
0.04
0.07
0.08
0.08
0.12
0.53
12
1.1

0.15
0.06
0.29
0.11
0.15
0.48
0.04
0.19
0.24
0.10
0.11
0.24
0.18
0.48
13
1.5

0.24
0.04
0.05
0.03
0.16
0.08
0.02
0.29
0.03
0.85
0.05
0.06
0.16
0.85
14
2.8

0.23
0.06
0.04
0.04
0.04
0.05
0.02
0.11
0.32
0.18
0.08
0.25
0.12
0.32
15
2.7

0.25
0.31
0.08
0.06
0.12
0.10
0.20
0.55
0.08
0.26
0.07
1.2
0.28
1.2
16
3.1

0.25
0.14
0.08
0.13
0.45
0.16
0.05
0.04
1.4
0.17
0.03
0.02
0.25
1.4
17
3.1

0.06
<0.01
0.33
0.29
0.21
3.4
0.06
0.53
0.69
0.08
0.02
0.10
0.53
3.4
18
1.1

0.05
0.21
0.08
2.7
0.05
0.23
0.03
0.98
0.31
0.12
0.03
0.04
0.41
2.7
19
1.9

0.05
0.40
0.10
0.03
0.04
0.16
0.06
0.16
0.33
0.05
0.05
1.7
0.26
1.7
20
0.7

0.11
0.02
0.08
0.37
2.1
0.05
0.06
0.36
1.1
0.02
0.02
0.06
0.36
2.1
21
0.9

0.11
0.05
0.04
0.26
0.08
0.07
0.22
0.45
0.08
0.24
0.03
0.04
0.14
0.45
22
0.5

0.21
0.02
0.02
0.16
0.03
0.03
1.1
0.07
1.0
0.08
0.07
0.84
0.30
1.1
23
0.6

0.05
0.05
0.08
0.34
0.11
0.25
0.15
0.04
0.50
0.03
0.05
0.15
0.15
0.50
24
0.6

0.11
0.06
1.0
0.08
1.3
0.06
0.07
0.05
0.14
0.02
0.03
1.1
0.33
1.3
25
1.3

0.03
0.04
0.10
0.01
0.09
0.09
0.48
0.15
0.03
0.06
0.07
0.33
0.12
0.48
                                                                                    to
                                                                                    Ul

-------
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                                          -- •- i,±*>'H,  ,
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                                      0.12   AVERAGE
                                      0.32   MAXIMUM  • ppm
 %1 j 0 '?  :   cTI '  !'|  ^-4*"" \if**?J  ft//!  /•         °-32  MAXIMUM  - ppm           '( -- ^j.  f  '  f|';'|'.1



fe-.
Figure 6. •  Concentrations  of  Vinyl  Chloride  in  Air  Samples

-------
B
Z
0
a.
\-
z
u
u
Z
0
u

5
O
            I     I     I
    3.0
    2.0
     1.0


    0.8



    0.6
0.2
0.
     .08
     .06
     .04
                        I    I   II    I   I     I
I     T
                                         I    I
                                                                  O
                 I
                  I
I    I
          J	I
                      10         30      50     70         90


                  PERCENT OF  DATA  < TO STATED  VALUE
                                                                98  99
                  Figure 7  •  Distribution of  Grab Sampling  Concentrations

-------
                                                                 28
at a site 4.8 km (3 mi)  due north of  the plant  (Station  17).  This may




have been due to a minor accident that  occurred during the  survey period




at the B.F. Goodrich plant when a small pipe ruptured on a  PVC  reactor




vessel (to be discussed  later).   It should  be noted  that since  the VCM




was collected on carbon  columns, the values stated will  be  minimums.




Adsorption and desorption efficiencies  and  any  other losses will com-




bine to minimize reported values.




     In general, a relationship was seen between  sample  concentrations,




wind direction, and speed; however, since each  run could not  provide




synoptic data and since  meteorological  information was minimal, further




analysis such as isoconcentrations and  dispersion was unprofitable.   In




addition to VCM, the sampling tubes were also capable of collecting




trichloroethylene.  This was observed at least  once  at all  locations




except Station 23.  The highest value observed  was about 1.2  ppm.




While usually associated with the higher values of VCM,  high  values of




VCM did not always assure the presence  of trichloroethylene.






Composite Samples



     In general, results of the 24-hr composite sampling [Table 4] were




lower than comparable grab sampling stations nearby. As noted  with




the grab sampling analyses the results  will be  minimum values.   These




values assume a 100 percent adsorption/desorption efficiency  not yet




validated by the laboratory and actually doubtful.   With the  exception




of Station 06 all composite samples were no less  than 50 percent of  the




nearby grab sample station results.  Station 06 showed high values on all




3 days with an average  that was five times higher than  the other com-

-------
                                                                  29
posites and over 60 percent higher than that of the nearest  grab

sampling station.  While the station was almost due west of  the plant,

the meteorological data does not show conditions that  should make

these results an order of magnitude higher than other  downwind stations.

This sampling site was at a service station with access  to the wide

variety of vapors from the shop area.  The VCM may be  absorbed and  thus

concentrated by petroleum fumes.  This could then produce a  higher

concentration per unit volume of sample as both air and  fumes are

collected on the carbon column.   This situation may be an occupational

hazard that bears further study.
                              Table 4
                     Composite Sample Results

Station
01 .
02*'
03
04
05
06
^12-hr
Distance from Plant
(mi)
1.9
0.7
0.8
3.3
2.7
2.8
composite

May 7

.08
.08
.07
	
.27

VCM
May 8
.06
.07
.08
.04
.06
.65

(ppm)
May 9
.05
.10
.05
.05
.05
.27


Average
.05
.08
.07
.05
.05
.40

Continuous Sampling
     The use of the infrared spectrometer proved  valuable in indicating

levels that might be expected to emanate from each plant.  Before this

study there had been no operating experience in the use of this instru-

ment at NFIC-D, so several modifications are still desirable to adapt

the instrument to total field use.

-------
                                                                 30
     As originally envisioned,  the  instrument would be most valuable




during grab sampling to give immediate  indications when high concen-




trations, or hot spots, of vinyl chloride were present.  This would




permit sampling at a given location,  such as Station  17 on run  75,




during periods of particular significance.  However,  quantitative




results were difficult to obtain during initial  trials due to engine




noise when the instrument was operating from a vehicle.  Further




modifications to filter the noise will  be necessary before maximum




use of this instrument can be realized.




     During a 14-hr period of operation at  ACC the instrument went




off-scale only once for about a 1-min period when vinyl chloride




was vented in error.  The concentration in  this  period showed no other




significant readings from background.  During a  21-hr period of opera-




tion at BFG the instrument detected several releases  at about 20 ppm,




several at 25 ppm, one at 30 ppm and a  10-min release that reached




as high as 75 ppm.  Other than the  latter,  which vented from a  ruptured




pipe, these readings were probably  the  result of venting the reactors




to the atmosphere during cleaning operations.  The meteorological data




at ACC during the time of this release  (8 May,  1855 - 1905 hr)  indicated




winds to the north at about 9 kn.  Thus the team at Station  17  due




north of the plant at 1942 hr was probably  sampling  this discharge  when




it collected the grab sample with the maximum value observed.




     Unlike the carbon column, the  infrared spectrometer measures a




maximum possible value rather than  a minimum.   This occurs  since other




organics will register in the same  region of  the spectrum  as VCM  to

-------
                                                                  31
varying degrees.  Thus, at the 10.9 pm wavelength  at which these




measurements were taken, vinyl acetate, trichloroethylene and ethylene




would be interferences because they would  also register in an additive




manner.  However, none of these are thought to be  used  at the B.F.




Goodrich plant where the major releases were measured.   For precise




measurement with this instrument,  the magnitude of these interferences




must be known 1) so that a correction can  be made, or 2) to determine




that other wavelengths less sensitive to the interference must be used.

-------
  APPENDIX A
TEST PROCEDURES

-------
                                                                  A-l
                            Appendix A






                         TEST PROCEDURES






Water Samples




     Water samples were tested for acid-extractable metals  following




procedures described in the EPA manual "Methods  for Chemical Analyses




of Water and Wastes," July 1971.   Copper  content of the water  was




determined by atomic absorption spectroscopy and mercury content by




the cold vapor technique.




     Vinyl chloride and trichloroethylene were measured in  water by




directed aqueous injection gas chromatography using a hydrogen flame




ionization detector.  Using the chromatographic  conditions  described




below, the minimum detectable concentrations were 0.1 mg/1  for vinyl




chloride and 10 mg/1 for trichloroethylene.   The presence of vinyl




chloride in the water samples was confirmed  using a Finnigan Model




1015 Gas Chromatograph/Mass Spectrometer  System  (see attached  mass




spectra).




     Standard solutions of vinyl chloride were prepared by  bubbling




vinyl chloride gas (Matheson Gas Company  lecture bottle) into  a cold,




tared 50 ml sample of distilled water for one to two minutes.   The




water was reweighed and refrigerated.  Normally, these standard solu-




tions would contain approximately 4 mg/ml of vinyl chloride.  Working




standards were prepared by adding the standard vinyl chloride  solu-




tion to cold 1 ml water samples in septa-seal vials which were sealed




immediately and rerefrigerated until used (within 1 hr). All  samples

-------
                                                                A-2
and standards within the 1 to 15 ng/ul range varied  about  5  percent




from day to day.   Standards prepared in organic  solvents gave




responses twice that of comparable water standards.   Quantitative




measurements were made using peak height comparison  of  standards




and samples.




Instrumental Condition




     Instrument - Varian Model 1400




     Column - 6'  x 2 mm glass packed xfith 80/100 mesh Porapak Q




     Carrier Gas - Helium at 20 ml/min




     Column Temperature - 150°C




     Injector Temperature - 200°C




     Detector Temperature - 250°C




     Under these conditions, vinyl chloride eluted in approximately




1.4 min and trichloroethylene in 15.2 min.




Air Samples




     Vinyl chloride and trichloroethylene concentrations  in air  were




measured by adsorption of the organic vapors  on activated  charcoal.




The organics were eluted from the carbon with carbon disulfide which




was then analyzed by gas chromatography using a hydrogen flame ioni-




zation detector.



     Standard solutions were prepared by bubbling vinyl chloride




(Matheson Gas Company) into cold, tared, toluene for approximately 15




sec.  The toluene solution was reweighed and  the amount of dissolved




vinyl chloride was determined by weight difference.   Working standards




were prepared by diluting the cold reference solution with cold  CS2

-------
                                                                A-3
in cold vials.  Aliquots of the working  standards were  immediately




pipetted into septum capped vials  where  they were found to be  stable




for about 8 hr.  Each of the small charcoal sections was added to one




ml of cold CS,, in a vial; the vial was capped  and analyzed after 1/2 hr.




The large sections were added to 25 ml of  cold CS-  and  after standing




in the cold for 1/2 hr an aliquot  was withdrawn and placed in  a capped




vial for gas chromatographic analysis.   Quantitative measurements were




made using a Hewlett Packard Model 3352-B  computerized  system  after




computer calibration using the working standards described.  Under




these conditions vinyl chloride eluted in  0.9  min and trichloroethy-




lene in 3.2 min.  For the small columns, detection  limits were 0.05 ug




for vinyl chloride and 5 yg for trichloroethylene.  For the  larger




columns, the detection limits were 1 ug  for vinyl chloride and 130 pg




of trichloroethylene.




Instrumental Condition




     Instrument - Hewlett Packard  Model  5711




     Column - 10' x 1/8" stainless  steel  packed with 6 percent  OV-101




          on 60/80 mesh Gas Chrom. Q




     Carrier Gas - Helium at 25 ml/min




     Oven Temperature - 50°C isothermal




     Injector Temperature - 100°C




     Detector Temperature - 150°C




Solid Samples




     Solid samples were dewatered  by filtration through a Buchner




funnel.  A portion of the wet cake was set aside for moisture  deter-




mination while a separate portion (10 g) was  extracted  with

-------
                                                                A-4
tetrahydrofuran (100 ml)  in an explosion-proof Waring  Blender.  A




1-ml aliquot of the cold  THF extract was  added to  a  cold  septa-seal




vial which was capped and analyzed by gas chromatography  using  a




hydrogen flame ionization detector.   Instrumental  conditions  and




standards were the same as described for  the air sample analyses.




The identification of trichloroethylene was not possible  using  this




procedure since the retention time is similar to THF,  and consequently,




the solvent completely masked any trichloroethylene  that  may  have  been




present.

-------
      S'ECTHJH f^JTSER 35  -  32
      G-l 2126
8
M

                                                         8
                                                           fe
                                                         o
                                                        .£>
                       S0   €9   70   83   S3   103  110
        MX E
 Figure A-1  ,   EJass Spectra^ of Vinyl C&ioride  Standard

-------
               NUS^ER -50   -  3S
      VINVL CHLORIDE S7D
O
                             
-------
        APPENDIX B






KEYSOR-CENTURY CORPORATION




     PLANT EVALUATION

-------
                                                                   B-l
                            Appendix B






                  KEYSOR-CENTURY PLANT EVALUATION




     The Keysor-Century Corporation operates a polyvinyl chloride and




record manufacturing plant about 40 mi north of Los Angeles at Saugus,




Cal.  The plant produces about 40 million Ib/yr of PVC.  About 90 per-




cent of the product is used at the plant for the manufacture of records.




The remaining 10 percent is sold for the production of floor tile.




The PVC plant employs 15 people, and the other 200 plant employees work




in the record manufacturing facilities making specialty records for




various government agencies, the military, and other groups.






Manufacturing Process and Sources of Waste




     The PVC plant operates around-the-clock 7 days/week.  The PVC




copolymer is produced from vinyl chloride and vinyl acetate by suspen-




sion polymerization in twelve batch reactors [six 7,500 1 (2,000 gal.)




and six 15,000 1 (4,000 gal.)].  Additives include a gelatin suspension




agent, the deconal peroxide catalyst and trichloroethylene as the chain




transfer agent.  Reaction time for the small batches averages 4 hr and




the large batches averages about 6 to 8 hr.   The excess VCM and vinyl




acetate in the reactors are recovered under pressure and vacuum respec-




tively; condensed in chilled water cold traps, and recycled.  The reactor




batches are directed to open slurry tanks where the resin is held in




suspension until centrifuged.  The reactors are cleaned with ethylene-




dichloride which is then recovered and processed for reuse.




     There are two parallel drying systems to accommodate the resin-




water slurry produced, each complete with a centrifuge, flash dryer,

-------
                                                                   B-2
cyclone, screening equipment and baghouses for particulate emission




control.  Dried resin for in-plant use is transferred to holding silos




for temporary storage.  From the holding silos it is conveyed to the




weighing hopper where it is weighed for compounding and use in record




manufacture.  Resin for sales is held in storage silos to await ship-




ment.  Figure B-l is a process flow diagram.




     Process wastewater originates from the two PVC resin centrifuges




and boiler blowdown and is discharged at approximately 170 1/min (45




gpm) into the sanitary sewer system.  Surface drainage sources of non-




contact wastewater averages 220 1/min (60 gpm).  This results from




plant washdown, external spraying of the reactors for supplemental




cooling, cooling water blowdown and pump seal cooling water.






Treatment System




     Process wastewater is discharged directly to the Los Angeles




County sanitary sewer system, Area 26 in Saugus.




     Surface drain water currently flows into the Santa Clarita River,




but the company plans to combine this with the process waste-water and




discharge both streams into the sanitary sewer system in order to sim-




plify the system and to eliminate intermittent "septic-type"  odors




which are suspected to originate from stagnent areas in the surface




drain system.  The odors have not been positively identified, but the




company states they are definitely not vinyl  chloride monomer.   No




odors were detectable during the plant visit.




     If the odors persist after the streams are combined and  the source




of odors is positively identified, odor removal capability will be

-------
                     RECYCLE
   TANK FARM RAW
 MATERIAL  STORAGE
                           VCM RECOVERY
                     VINYL ACETATE
                       RECOVERY
REACTORS  (12) BATCH
  POLYMER PROCESS
SLURRY TANKS
CENTRIFUGES
FLASH DRYER
  WEIGHING HOPPER
   RESIN
HOLDING SILO
                              I
 SCREENING
                                                                    1
  CYCLONE
   COMPOUNDING
                             SALES
      RECORD
     PRESSING
         Figure  B-1  •  Keysor - Century  Corporation Process  Flow

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                                                                   B-4
included in the design of an in-plant wastewater pretreatment  facility




which is now under study.






Sampling



     The company began taking grab samples of air around the PVC plant




work areas after learning of the possible vinyl chloride health prob-




lem.  For sampling, a Tedlar bag and a portable 1 liter/min air pump



are mounted on an employee and a 10-min sample of air is collected




while he performs his normal duties.  Analyses are performed by an




independent laboratory.  The overall range of vinyl chloride concentra-




tions in the work areas has been 3 to 330 ppm, with a 30 ppm average in




most work areas.  Concentrations for specific areas are as follows:



                Work Area                     Concentration (PPM)




     Recovery Unit                                  30 Avg.




     Drying Systems                                 30 Avg.




     Reactors (during breaking of lines)           330 Max.




     Reactors (during PVC unloading)                30 Avg.




     Reactors (during VCM charging)                 70 Max.




     No sampling of the wastewater effluents has been conducted by the




company to date.

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   APPENDIX C






PERSONS CONTACTED

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                                                                  C-l
                            Appendix C






                         PERSONS CONTACTED




B. F. Goodrich Chemical Company, Carson, California




     Mr. A. W. Clements, Plant Manager




     Mr. W. C. Holbrook, Manager, Environmental Control Engineering




          (Corporate Office - Cleveland, Ohio)




     Mr. R. Nattkemper, Plant Engineer




American Chemical Corporation, Carson, California




     Mr. H. Kling, Plant Manager




     Mr. D. A. Grotegut, Plant Engineer




     Mr. J. M. Witte, Process Engineer




     Mr. G. D. Wina, Process Engineer




Keysor-Century Corporation, Saugus, California




     Mr. S. K. Law, Process Engineer




     Mr. E. Scott, Chemical Plant Manager

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