Document 0JD6rn1QxqE7pg7bKGj7n71ym

JOSEPH C KELLER JEROME M nCCKMAM CHARLES M HCfiHAN WILLIAM H, BOACHE9ANI. Jfl ROBERT A TIERNAN MALCOLM D. MACARTHUA WAV ME V SLACK MAATIM W etRCOVICI JOHN 9 ELCAED CAROLE C, H *, A RtS MICHAEL r MOAAONE LARRY 9, SOLOMON JOHN B. OUBECK CHRiSTiMC a maOmCA SHIRLEY 3, fUUlMOTO "ETER L - CRUZ LAWRENCE A HALPR'N OEBOAAH 3HUA TRINK6R C* DOUG LAS JAPPETV EDWARD L. KORWEK JONATHAN R LEVINE SHEILA A, MILLAR RUSSELL H EOX LEE M WEtNfiA ANOELEMA C Li 5LANC TIMOTHY SAOWN ILEnE RINOEL HELLER LAW OFFICES Keller and Heckman 1150 17th STREET, N. w\ SUITE lOOO WASHINGTON, D, C. 20036 (202) 457-1100 February 25, 1983 TO: SPI Vinyl institute RE: ^_EPA_ Revision of the Vinyl ^ "Chloride Standard^-' ; Ladies and Gentlemen: telecorier CABLE ADO RESS "k ELMAN " (202) 457-1116 RECEIVED MAR 2 )983 * w, Laundrie Cc ^C(~L rf S e> i' A /("'L ! The Environmental Protection Agency (EPA) should be sending a package of materials to interested firms within the next week. It is anticipated that the mailing will have three parts. The first section will contain the February 1982 version of the TRW report. While we reported on this previously in our letter of July 20, 1982, the revised TRW report has never been officially released by EPA. This mailing will constitute its official dissemination. The second portion of the EPA mailing will concern regu latory alternatives for the control of oxychlorination vents at vinyl chloride monomer (VCM) facilities. While the precise language of the alternatives is not known, we expect that EPA will seek to control emissions through incineration or some other manner. It is also our understanding that this require ment would be imposed on both new and existing sources. The third portion of the EPA mailing will address the use of vinyl chloride as a raw material in applications other than the production of polyvinyl chloride (PVC). In particular, EPA will be recommending that firms using VCM as a raw material adopt a fugitive emission control program. The other changes that we discussed with EPA, including relief valve discharges and exception reporting, are being handled separately. Because these changes would be either administra tive or interpretative in nature without imposing additional costs on industry, the Agency determined that it did not need to prepare the same type of background documentation associated PRIVILEGED GENCO17281 AND CONFIDENTIAL SPI-Vinyl Institute February 25, 1983 Page 2 Keller and Heckman with typical standards development. The relief valve discharge and other questions, however, will be considered in the course of the rulemaking. After receiving industry comments on the oxychlorination vent and new fugitive emission package. EPA will schedule an internal working group meeting of various EPA personnel including representatives from the EPA regional offices. That meeting will mark the first agency-wide review of the proposals. Subse quently, the proposals would be revised and undergo further review following standard EPA procedures. After we have received and reviewed the EPA mailing, we will consult with the Vinyl Institute representatives to deter mine a course of action. In the interim, if interested persons do not receive a copy of the EPA mailing within the next few weeks, please contact us so that we may provide you with the material. Cordially yours, /ilL. Peter L. de la Cruz PRIVILEGED and confidential GENCO17282