Proposed EPA air toxics standards for PVC production

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Source: Golden Specialty, Inc.

On April 15, 2011, the Environmental Protection Agency (EPA) proposed a rule to update emissions limits for air toxics from polyvinyl chloride production (PVC production).

The proposal requires facilities that produce PVC to reduce emissions of harmful toxic airemissions, improving air quality, and protecting public health in communities where these facilities are located.

Exposure to toxic air pollutants can cause respiratory problems and other serious health issues, and can increase the risk of developing cancer. In particular, children are known to be more sensitive to the cancer risks posed by inhaling vinyl chloride, one of the known carcinogens emitted by this source category.

The rule proposes maximum achievable control technology (MACT) standards for major and generally available control technology (GACT) for area sources of PVC production.  Emissions sources addressed in the proposed rule include PVC process vents, stripped resin,equipment leaks, wastewater, heat exchangers, and storage vessels.

The proposed rule would set emission limits and work practice standards for total organic air toxics, and also for three specific air toxics: vinyl chloride, chlorinated di-benzo dioxins and furans (CD/DF), and hydrogen chloride. This is a change from the 2002 rule, which set an emission limit for vinyl chloride, and used vinyl chloride as a surrogate for all other air toxics.

PVC production includes the manufacture of resins that are used to make a large number of commercial and industrial products at other manufacturing facilities. These products include plastic end products, such as latex paints, coatings, adhesives, clear plastics, rigid plastics, and flooring.

There are currently 16 major and one area source of PVC production facilities in eight companies in the United States, in eight states, as follows (with number of facilities in each state): Delaware (one), Illinois (one), Kentucky (one), Louisiana (six), Michigan (one), Mississippi (one), New Jersey (two), and Texas (four). There are no small businesses.

PVC production does not include chemical manufacturing process units that produce vinyl chloride as the monomer, or other raw materials used in the PVC polymerization process.

The annual emission reductions of the proposed rule are estimated to be 1,570 tons total HAP, including 135 tons of vinyl chloride, 33 tons of hydrogen chloride, and 0.022 gram CDDF.

To determine the proposed emissions limits, EPA gathered information on PVC production through review of previously collected information, current literature, data from the National Emissions Inventory, and meetings and voluntary information submissions by industry and the industry trade association. Also, the Agency collected information from PVC production facilities using the authority under the Clean Air Act (Section 114), in the form of an electronic survey and requirement for emission testing of toxic air pollutants and toxic air pollutant surrogates,such as total hydrocarbons.

The review of existing data and consideration of new data have resulted in proposed emission limits that are more stringent than those in the 2002 and 2007 rules.

EPA estimates an overall total capital investment of $16 million, with an associated total annualized cost of $20 million, to meet the rule requirements.

The proposed rule would replace the previous rule for larger emitting PVC production facilities (major sources) EPA issued in July 2002. That rule was vacated by the District of Columbia Circuit Court as a result of a petition. The proposed rule would also amend the existing air toxic rule for smaller emitting PVC production facilities (area sources) that EPA issued in 2007.

EPA will accept comment on the proposal for 60 days after publication in the Federal Register.

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