Attachment VI to PVC MACT Working Group Letter to EPA

Examples of Major Issues of Concern with the Final PVC MACT Emission Limit Compliance Date of April 17, 2015

# Description Summary Compliance Deadline Burden

1. Wastewater Stripper
Effluent Limitation No new PVC Unit can meet the effluent Total non VCM organic HAP (TOHAP)
limit of 0.018 ppm

Existing PVC area sources cannot meet the effluent Total non VCM organic HAP (TOHAP) limit of 0.018 ppm and would have to cease operation.

Existing PVC Units that use any vinyl

acetate monomer, methanol, ethylene glycol

, formaldehyde

, aldehydes or other soluble/ partially soluble HAPs cannot
meet the final TOHAP limit of 110 ppm

. Un certain WW limit s ; therefore , if current limits remain, affected facilities may have to:

 Discontinue products that result in WW TOHAP above limit;

 If technic ally possible, r eformulate
resin recipes and attempt to have

customer requalify the new product, , which could also entail redesign

, capital investment, and construction/startup along with recertification of the product

, all of
which takes time ;

 D iscontinue producing VCM/VAM copolymer resins ;

 Discontinue operations at area

sources;

 Develop new WW treatment strategies and implement if
achievable

.

2.a. Process Vents and Closed Vent Systems:

Any vent that could divert regulated gases
from the cont rol device (bypass) requires:

a. A flow
indicator/alarm system; or,
b. A car

- seal
mechanism. As the rule currently stands:

ANY HAP release, no matter how small, from a by

- pass valve (e.g., low leg drain) w ould be considered a violation

. If this emission control requirement remains as finalized, then PVC Units will have to assess the liability of having hundreds of
valves that could potentially vent to the atmosphere under any circumstance . The

assessment may require the following steps
to limit liability :

 Hard

- piping low

- leg drains and high

point bleeds through a closed vent system that vents to a control
device.

 Routine maintenance activities , even after equipment opening procedures
have been satisfied

, will result in violations. It is technically impossible to open any piece of equipment that operates at other than atmospheric pressure without opening a vent valve in the system to equalize

pressure.

Attachment VI to PVC MACT Working Group Letter to EPA

Examples of Major Issues of Concern with the Final PVC MACT Emission Limit Compliance Date of April 17, 2015

# Description Summary Compliance Deadline Burden

2.b. Process Vent
Violation: Broken car

seal The rule currently reads: “A broken seal or closure mechanism
or a diverted valve constitutes a
violation from the emission limits in Table 1 or 2 to this subpart.” As a benchmark, a typical polyolefins Unit
can break between 200

- 300 car

- seals a year
in order to perform maintenance. A PVC Unit’s rate would likely be higher.

At a penalty of $37,500/violation , the potential penalties for this requirement are
substantial.

Hence, If this emission control requirement remains as finalized, then PVC Units will have to assess the liability and compliance burden
of car

- sealing any valve that could potentially vent to the atmosphere. The assessment may require the same action at Item 2.a. in order to limit liability.

3. Pressure Relief Devices (PRD):

All PRDs that vent to atm are now required to be equipped with an
electronic alarm system to indicate when PRD is open As per the final rule preamble : “... you are required to install a release indicator

on each PRD that would be able to identify and record the time and duration of each pressure release ...” [77 Fed Reg 22860]

. Once equipment is proven and becomes available, this will cost multiple millions of dollars per plant to implement. Since the equipment to meet the requirement may not be commercially available in the quantities
needed and/or s afe to operate in a chem. Plant, i ndustry is uncertain how to meet this requirement. If the requirement continues to stand, then Industry may have to vent each PRD through a closed vent system/control
device (venting to a control device does not require an electronic alarm system )

.

 If increasing the flow rate and HAP concentration to the control device, the system will have to be evaluated

to determine if an increased flow
and/or concentration can be handled within the existing emission control system. If it cannot be handled, then a redesigned or new system will be

necessary. Note: Certain PRD releases may be unsafe

to vent to a control device.

4. Storage Vessels Vapor Balancing for rail car loading should be allowed, as per other MACT & proposed Uniform Standards If vapor bal ancing is not allowed, PVC Units will have to vent through a closed vent system to a control device.

 If increasing the flow r ate and HAP concentration to the control device, the system will have to be evaluated

to determine if an increased flow
and/or concentration can be handled within the existing emission control system. If it cannot be handled, then a redesigned or new syst em will be

necessary.Attachment VI to PVC MACT Working Group Letter to EPA

Examples of Major Issues of Concern with the Final PVC MACT Emission Limit Compliance Date of April 17, 2015

# Description Summary Compliance Deadline Burden

5. Stripped Resin Limits for Existing Sources Challenges to subcategorization and UPL
calculation method s have created uncertainty whether the limits in the final
rule will be re

- determined Significant capital and lead time is needed to either reconfigure or replace a resin stripper.

6. Process Vent: Overlap Emission Limit Overlaps for Combined
Sources: EPA is establishing a precedent for overlapping emission limits for control devices. If a PVC MACT regulated vent

stream enter s a control device regulated by another MACT, the combined source must demonstrate compliance with the PVC MACT emission limits. (Ex. 1% PVC vent gas combined with 99% HON regulated vent gas must comply with PVC MACT)

.

This issue also includes a new compliance
demonstration strategy for HON affected control devices (CPMS/CEMS must meet PVC MACT’s requirements ; along with
HON ’s ). EPA finalized a new subcategory scheme that was not in the proposed rule:

 PVC

- only process vents; and

 PVC

- combined process vents.

A VCM Unit , which currently controls
emis sions from the related PVC Unit under
HON , is now affected by the more stringent requirements of the PVC MACT, un less the
PVC Units vent to its own control device.

If the rule stands a s currently finalized, then
PVC

- Combined Units may be driven to segregate out the PVC emissions from the VCM emissions by installing a new Thermal
oxidizer /Scrubber system (PVC

- Only)

. This type of effort requires : 1. State and Federal air permitting
action for GHG and traditional pollutants ( P ermit application development and pre

- construction approval takes 12

- 24 months)

2. Design; capital expenditure approvals, equipment procurement,
and construction /Startup time; along with,
3. VCM/PVC production demand
consider ations for shutdown/tie

- ins