Document 3N44bzw6KDLw342zEdMnMVo7n

I ne Society of the Plastics Industry, Inc. 355 Lexington Avenue New York, NewVork 10017 (212)573 9400 TO: MEMBERS OF THE EPA TECHNICAL COMMITTEE VCM AND FVC PRODUCERS GROUP FROM: John R. Lawrence RE: EPA STANDARD Gentlemen: In a discussion with EPA staff today, I was able to obtain some indication of the changes that may be proposed in the existing Standard on VC in the event that the pending EPA's/EDF suit is dismissed by the Court. The following are the areas that EPA proposes to change if a new Standard is to be considered: 1 - In existing sources there will be a requirement to reduce vent emissions from 10 ppm to 5 ppm. If this cannot be accomplished without the addition of new equipment, there will be a relief clause that will allow a waiver in this requirement if conscientious effort has been made to achieve 5 ppm without success. It is EPA's expectation that "fine tuning" of existing emission control equipment will allow for this reduction over a three year period. This reduction would apply to both FVC and VCM operations. 2 - In new sources it will be necessary for all vents to operate on 5 ppm from start up. This will apply to the oxychloro vent in VC production as well as FVC operations. 3 - There will be a requirement to reduce the residual VC in FVC after the reactor to 100 ppm in suspension resins and 500 ppm in dispersion resins for new formulations. The existing requirement of UpO ppm in suspension~resins and 2000 ppm in dispersion resins will continue to apply to old formulations. h - The propsed change will go into some detail with respect to the desirability of achieving the first emission goal on the basis of new technology. EPA plans to re-evaluate the Standard every three years to consider whether new technology iment of a tougher Standard. COLORITE 006677 Members of the EPA Technical Committee VCM AND FVC Producers Group Page Two May 13, 1977 5 - The proposed regulation will call for new increase in the total emissions over the existing source based on expansion of the'plant or the erection of a new plant at the same location. It is expected that this regulation will apply to the area within an8 kilometer radius of the existing operation. -- Please accept this information as preliminary and use it to start considering what changes would be required within your operations if these requirements do become part of the new regulations. Although there is no certainty as to when the new proposed regulation may be published, it is expected that it might be as early as June 1st. John E. Lawrence Technical Director JRL:gm COLORITE 006678