Clean-air rules challenge processors.

This year, thousands of plastics-processing plants will be required to determine the amounts of particulates and volatile organic chemicals (VOCs) that they emit into the air. Those emissions must be reported to state or local environmental authorities as part of an application for a permit to continue operating. Any firm not complying could be subject to daily fines of up to $25,000 and jail terms for top executives. Ignorance of the statute is not an admissible defense.

Documenting emissions of air pollutants could prove difficult and costly for individual companies to attempt on their own. However, the Society of the Plastics Industry, Inc. in Washington, D.C., and its member companies are offering assistance. Several experimental programs are under way to aid processors in estimating their emissions. The first data are already in on some of the most widely used resins - LDPE, LLDPE, and HDPE.

WHY MEASURE EMISSIONS?

The new operating-permit requirements stem from the 1990 amendments to the Federal Clean Air Act. Title V required all states and territories to submit to the U.S. Environmental Protection Agency by Nov. 15, 1993 a program to issue operating permits to industrial facilities. These permits would regulate all major sources of emissions of VOCs and hazardous air pollutants.

By Nov. 15, 1994, EPA was to have notified each state whether its program was approved. Affected industrial facilities would have one year from the approval date (Nov. 15, 1995 at the latest) to submit their permit applications to state regulatory agencies.

In some states, local jurisdictions are responsible for implementing the operating-permit program. For example, California has 34 local programs across the state.

However, the whole process has run into delays. As of last month, EPA had received applications from 42 state agencies and 58 local programs. Approvals for only five states (Hawaii, Oregon, Washington, Mississippi, and New Mexico) and eight local programs had been published in the Federal Register. EPA has also announced its intent to approve eight other state programs and two local ones and to disapprove one state program. Due to these delays, it appears that industrial plants will have one year from the eventual approval dates of their state or local permit programs to submit their permit applications.

EPA is pushing state and local jurisdictions to complete their program proposals by May 15. After Nov. 15, EPA will take over the permit programs of jurisdictions that have not fully complied.

Plastics processors should contact their state EPA Clean Air Act officials to find out what is required and by when. SPI offers guidance through the regulatory maze in its new SPI Air Permit Workbook: A Practical Guide for Plastics Processors, Compounders, and Fabricators. The booklet is free to SPI members and costs $250 for nonmembers. Call SPI's Maureen Healey at [phone].

HELP IS ON THE WAY

Over the last year, studies of air-borne emissions from plastics processing have been organized by SPI. These studies determine the identity and quantity of pollutants generated under typical conditions.

The first such study was on emissions from polyethylene extrusion and was completed in the fourth quarter of 1994. This study was conducted at Battelle in Columbus, Ohio, and sponsored by nine PE producers - Chevron Chemical, Dow Plastics, DuPont Canada, Exxon Chemical, Mobil Chemical, Novacor Chemical, Occidental Chemical, Quantum Chemical, and Union Carbide - under the auspices of SPI.

Samples evaluated were mixtures of commercial resins from the sponsoring companies. The LDPE mix comprised five typical extrusion coating resins (7 MI, 0.92 g/cc); the LLDPEs were six blown film resins (2 MI, 0.92 g/cc); and the HDPEs were five blow molding resins (0.2 MI, 0.956 g/cc).

SPI's "Executive Summary" of Battelle's report says, "These results are important because they show that VOCs are two orders of magnitude lower than those reported in a 1978 EPA contractor report." For more information, call SPI associate technical director Lynne Harris at [phone].

From Battelle's experimental data, Quantum Chemical Co. in Cincinnati derived simple formulas for estimating emissions per million lb of PE processed, depending on the extrusion temperature. Quantum supplied those formulas to its customers in November. Note that in the next month or so, the nine members of the SPI research group will complete a joint analysis of the Battelle data that will include emission-factor formulas representing a scientific consensus of all the participants. SPI's Harris cautions that emission factors in the official SPI-sanctioned analysis could differ somewhat from those published by Quantum.

SPI officials who were involved in the study believe that scientifically derived emission factors should be very helpful to PE processors. On average, they say, state permits cost about $25/ton of emissions. Based on the results of this study, SPI expects that most processors should have to pay only a minimal permit fee.

SPI sources speculate that closed-mold processes such as injection molding and bottle blow molding would probably have lower emissions than were measured for extrusion. Accumulator blow molding of large parts, in which the parison is exposed to the air for longer periods, would presumably generate higher emissions, similar to those found in the study.

Similar research was recently completed on processing PP, EVA, and EMA copolymer. SPI will issue an executive summary by the third quarter. Sponsors of the PP study are Amoco Chemical, Aristech Chemical, Fina Oil & Chemical, Himont, Huntsman Chemical, Novacor, and a joint venture of Union Carbide and Shell Chemical. Quantum provided help in performing the work. Sponsors of the EMA and EVA studies are Quantum, Chevron, DuPont, and AT Plastics.

SPI officials are currently soliciting support from suppliers of other resins for work on polystyrene, PVC, nylon, and polycarbonate.

RELATED ARTICLE: EMISSIONS FROM POLYETHYLENE EXTRUSION(a)

T = Processing Temperature (F)

LDPE (Processed

Lb VOCs/MM lb Processed = (1.22 x T) - 575 (Example:

Lb Particulates/MM lb Processed = (2.11 x T) - 1025 (Example:

LLDPE (Processed

Lb VOCs/MM lb Processed = (0.086 x T) - 23 (Example:

Lb Particulates/MM lb Processed = (0.39 x T) - 137 (Example:

HDPE (Processed

Lb VOCs/MM lb Processed = (0.19 x T) - 52 (Example:

Lb Particulates/MM lb Processed = (0.14 x T) - 34 (Example:

a Source: Quantum Chemical. Quantum states: "The information presented herein is believed to be factual as it has been derived from the works and opinions of persons believed to be qualified experts; however, nothing contained in this information is to be take as a warranty or representation for which Quantum Chemical Company bears legal responsibility. The user should review any recommendations or representations in the specific context of the intended use to determine whether they are appropriate."