To: Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460
From: Wilma Subra
Louisiana Environmental Action Network
Lower Mississippi Riverkeeper
Date: June 9, 2011
Subject:
Environmental Protection Agency
Docket ID No. EPA-HQ-OAR-2002-0037
Proposed Rule for National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers Production
On behalf of Louisiana Environmental Action Network (LEAN) and the Lower Mississippi Riverkeeper (LMRK), I would like to thank the Environmental Protection Agency for the opportunity to comment on the proposed rule dealing with Polyvinyl Chloride and Copolymer Production. As you are aware, Louisiana Environmental Action Network (LEAN) has been involved in the legal petition process dealing with the lack of emission standards for all HAPs emitted from PVC facilities. LEAN appreciates the EPA proposing emission standards for Vinyl Chloride, Hydrogen Chloride, Chlorinated Di-benzo Dioxins and Furans (CDDF) and Total Organic Air Toxins.
According to the information provided in association with the proposed rule, the air emissions of Vinyl Chloride will be reduced by 135 tons per year, Hydrogen Chloride by 33 tons per year, CDDF by 22 milligrams per year and Hazardous Air Pollutants by 1,570 tons per year. While these reductions in emissions are appreciated, based on the impacts to environmental justice community members living in close proximity to the PVC production facilities, these reductions are not adequate. The reductions would account for 30% of the Vinyl chloride and 32% of the CDDF emissions. Such reductions would still result in the Environmental Justice communities continuing to be exposed to unacceptable levels of Vinyl Chloride and CDDFs.
Louisiana leads the nation in PVC production facilities with six facilities. The PVC production facilities are located in Geismar, Plaquemine, Baton Rouge, Addis, and Westlake. The largest Vinyl Chloride emitting facility in the United States is located in Geismar, Louisiana (Westlake Vinyls Co.). The majority of the Polyvinyl Chloride facilities in the state of Louisiana are located in very close proximity to environmental justice communities, contrary to the information contained in the proposed rule.
In Louisiana, as a result of operations of the PVC production facilities, Vinyl Chloride is present in the ambient air in the Environmental Justice communities located in proximity to the PVC facilities. The Vinyl Chloride fugitive emissions from the PVC production facilities consist of 55 to 78% of the total Vinyl Chloride air emissions. Even with the proposed toxic air emission reductions, the ambient air will continue to be contaminated with Vinyl Chloride and associated HAPs.
The Vinyl Chloride emitted into the air by the six PVC facilities in Louisiana is more than double the Vinyl Chloride emissions released into the air from the four PVC facilities in Texas, which ranks second in the United States behind Louisiana.
Carcinogens
The known human carcinogen HAPs emitted from the PVC production facilities include Vinyl Chloride, Benzene, 1,3-Butadiene and CDDF. In addition, a number of probable human carcinogenic compounds are also emitted from PVC production facilities. These include Acetaldehyde, Bis(2-ethylhexyl)phthalate, Chloroform, Chloroprene, Ethylene Dichloride, Ethylidene Dichloride, Formaldehyde, Iso-octane, Methylene Chloride, Vinyl Bromide and Vinylidene Chloride. As a part of this proposed rule, EPA established emission limits for Vinyl Chloride, CDDF, Total Organic HAP and Hydrogen Chloride. LEAN and LMRK support the inclusion of emission limits for CDDF, Total Organic HAP and Hydrogen Chloride in addition to Vinyl Chloride in the proposed rule. In addition, EPA should have established emission limits for each of the known and probable carcinogen HAPS emitted by the PVC production process.
Wastewater
The EPA proposed rule has requirements for wastewater monitoring and compliance. Vinyl Chloride is required to be tested at the point of generation of the wastewater and testing for HAP at the point of wastewater determination. The wastewater stream containing less than 10 ppmw Vinyl Chloride at point of generation and less than 1,000 ppmw total HAPs at the point of determination are not required to further reduce emissions. The EPA should have developed specific criteria limits for the most prevalent and toxic HAPs in the wastewater above which reductions are required rather than just the 1,000 ppmw criteria for total HAPs.
Accidental Releases and Upsets
PVC production facilities have accidental releases and upset operational conditions which result in the release of Vinyl Chloride and other HAPs associated with the production process. The releases of HAPs frequently extent off the facility site into the surrounding Environmental Justice communities. The evaluation and control of these releases of Vinyl Chloride and associated HAPs are critical to protecting the health of adjacent communities.
The record keeping and reporting requirements for discharges in the proposed rule must be extended to violations associated with bypasses, pressure vessels and closed vent systems in vacuum service. These records and reports are critical to determine emission concentrations, extent of impacts due to the emissions and measures taken to prevent the reoccurrence of similar types of events. These records are also critical to providing information to the fenceline communities.
Conclusion
Louisiana Environmental Action Network and the Lower Mississippi Riverkeeper encourage the Environmental Protection Agency to reduce the quantity of Vinyl Chloride, Hydrogen Chloride, CDDF and Hazardous Air Pollutants emissions by further tightening up the emission limits in the proposed rule. Dioxin and Furan releases have the potential to and have contaminated and bioaccumulated in the bodies of human populations in the fenceline communities of PVC facilities. The reduction in emissions proposed by the EPA will reduce the exposure of Environmental Justice communities, but there will still exist unacceptable levels of exposure to Vinyl Chloride, Dioxins and Furans, and HAPS in the air of these communities. Greater reductions of the toxic chemicals must be required.
