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22 December 1976
Mr. G. Baise Beveridge, Fairbanks 5 Diamond One Farragut Square, South Washington, D.C. 20006
TELEOOPIED 12-22*76
Dear Gary:
We are supplying this response to your letter to J. H. Heckman of December 16 asking for data to be used in obtaining a stay from EPA. We request that this response not be made public, but handled only in a way that APCI cannot be identified.
Our response will be in three parts, corresponding to each of our affected plants.
The compliance program for the Calvert PVC Plant will be to build a
new facility. It is not feasible to bring the present plant into compliance. The schedule we have planned is as follows:
Begin purchasing - Jan 77 Begin construction - May 77 Completion and Compliance - October 78
Total cost $32 - 35 t-M - of this direct EPA costs are $4.5 - 5 f-W.
All of the cost is due to EPA, in that without it the existing plant would be operated. Some of the total cost is for OSHA, water effluent, and production items, of course.
The PVC plant at Escambia is being rebuilt. We have already included a gasholder, stripping tower, and other items in it at a cost of $995M. The
plant will restart in January 1977. We estimate a further $750 M to bring this plant into compliance. The information you requested is as follows:
Place Purchase orders - February-May 1977
Start installation - April-July 1977 Complete programs - September 77 - j^>ril 78 Final compliance - July 1978 Additional Costs - $750 M
None of this is required by any other regulation..
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The Calvert City Emulsion Plant will require two major projects, one
costing about $300 M which will be completed on schedule A and the other
about $3 Nil, as shown in schedule B.
AB
Order Date
ApfIT 77
July~77
Start Construction
Aug. 77
Dec. 77
Complete Construction
Jan. 78
Sept. 78
Compliance
Feb. 78
Oct. 78
Cost
$300 M
$3 m
Other Regulations
No No
The primary point to be made is not the capital exposure, although this is significant. Most of these items are custon-designed, and charges forengineering and materials become effective on placing the order. Our cancellation =charges for the Calvert PVC plant alone Tun about as follows.
Engineering
Order Value
Cancellation
Total Cost
Feb.. 77 550 1,700 430 980
Mar. 77 750' 3,400
65S 1,405
Apr. 77 May 77
1,000 1,300
3,900 4,400
930 1,280
1,930 2,580
These costs are substantial, but time is more valuable. We have done much preliminary planning on these projects, and instituted a sizeable engineering study after we received the draft of the final standard in September. Even so,
meeting the two year deadline will be difficult, if not impossible. Any significant change in the standard will require a restudy of the whole system to be sure it
is Compatible. So long as the clock is running we cannot do other than utilize clearly demonstrated technology. Uncertainty can not be tolerated, either from the viewpoint of performance or delivery. Thus a potential change in the standard
rendors all prior work suspect. We will require the full two-year statutory
limit from the revision of the standard for implementation.
The time for a stay is now. We cannot be expected to expend time or money on a standard that may be changed in some unknown fashion. It is unlikely
that the issue will be resolved until well into the implementation period.
cc: A. R. Adams R. Fleming R. H. Shhenck
J. Lawrence/S.P.I, Mr. fiadley/Keller Heckman
Very
John T/Barr, Technical Director
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