This week we have an article contribution from one of Heritage's Environmental Chemists, Greg Busch. Mr. Busch has been an environmental chemist for the past 32 years having held positions in private industry and state government and at Heritage as the laboratory Quality Assurance Officer the past 23 years. Greg is a member of the American Chemical Society, the American Society for Quality and holds a Bachelors degree from Indiana University and a Masters degree from Butler University in Chemistry.
This week's post discusses the new EPA standards that will regulate facilities that produce Polyvinyl Chloride (PVC) and other copolymer products. These new regulations seek to reduce harmful air emissions in an effort to improve air quality and protect the health of people who live in communities where these types of facilities are located.
I’ve learned that EPA Administrator Lisa Jackson has approved a final rule to be published in the Federal Register that regulates facilities that polymerize vinyl chloride monomer to produce polyvinyl chloride and/or copolymer products. I also understand that these new rules are more stringent than the requirements of the current part 61 NESHAP (National Emission Standards for Hazardous Air Pollutants) and that part 61 NESHAP will no longer apply. Existing facilities must comply no later than three years after the rule appears in the federal register and new facilities must comply at startup. The PVC industry already has to comply with the part 61 NESHAP requirement for releases from pressure relief valves and reactor manual vent valves. But these new rules will increase the monitoring and associated costs. There are presently 15 major and two area source PVC facilities in the United States, located in eight states; Louisiana has six plants. The Clean Air Act requires EPA to establish NESHAP for source categories and subcategories of both major and area sources of hazardous air pollutants (HAP). An area source is a HAP-emitting stationary source that is not a major source.
The rule requires monthly leak testing for pumps, agitators and compressors not equipped with double seals. It also includes monthly wastewater testing for vinyl chloride and for total non-vinyl chloride organic HAP limits for process wastewater and compliance with (Hazardous Organic NESHAP or HON) national emission standards. Pollutant concentrations in each process wastewater stream at existing and new sources must be measured immediately as the process wastewater stream leaves a process component, before being exposed to the atmosphere and before mixing with any other wastewater stream. Wastewater affected sources must initially test all untreated process wastewater streams and meet the vinyl chloride and total non-vinyl chloride organic HAP limits in the final rule prior to discharge and are required to determine the concentration of vinyl chloride and total non-vinyl chloride organic HAP on an annual basis for streams that do not require treatment.
For heat exchangers, the final rule requires monthly cooling water monitoring for either total strippable VOC or for vinyl chloride. Total strippable VOC monitoring must be done using either the TCEQ Modified El Paso Method or EPA Method 624, and vinyl chloride monitoring must be done using EPA Method 107, as it is the established method for the PVC industry to analyze vinyl chloride concentrations in water samples. Cooling water monitoring requires EPA Method 624 for Volatile Organics by Gas Chromatography/Mass Spectrometry.
In summary, there will be an on-going monitoring program required at PVC plants with new regulatory limits. Heritage’s Commercial Laboratory offers methods 8015C, 8260B, 8270D and 624. Methods being considered for development at Heritage are 8315A, 107A and 26A. Contact us for more information or assistance with your particular need.
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