Document 6Q2RVe1g0wKM9pdgz9VzEnbg

Air Products and Chemicals. Inc. Box 538, AllentPA 18'05 (215) 393-4911 5 February 1980 Joseph E. Hadley, Jr., Esq. Keller and Heckman me 17 Street, N.W. Suite 1000 Washington, D.C. 20036 Dear Joe: Attached find the reply for Air Products to your EDA/0SHA questionnaire sent to the SPI-PVC Safety Group with your 30 January letter, recost for simplicity. All costs are for "PVC" operations, we do not make vinyl chloride. There were few direct EPA costs for plants 1 and 2; our compliance program for EPA was to rebuild these slants. Thus, we cannot directly separate the two programs. I would guess that the capital would be split about 4:1 in favor of EPA. Plant 3 is a latex vinyl chloride copolymer plant which made no vinyl chloride-containing products in 1974. It is classed as "PVC" by EPA, but not by SPI. We cannot separate the annual costs of these two plants. Annual costs are divided into three classes. Depreciation includes also taxes, insurance, and interest on the capita! involved. Maintenance includes record-keeping, leak patrols, and other such items. Production loss is cal culated on the contribution margin of those pounds not made because of delays Inherent in compliance. Please call me If you have any questions on these figures. JTB/sjw Enclosure cc: A. R. Adams John T. Barr Manager, Regulatory Response AP00053680 COST, $M Plant 1 OSHA-fix-up costs 1974-75 0.9 1974 capacity, MM lbs. 85 Annual costs (1975-76) Depreciation Maintenance Production Loss 0.2 0.4 0.3 TOTAL 0.9 Subsequent capital for OSHA/EPA rules 4.5 Date 1976-77 Present capacity, MM lbs. 150 Annual costs Depreciation, etc. Maintenance, etc. Production Loss 1.0 0.43 0.55 TOTAL 1.98 23 1.6 NA 125 0 0.4 0.7 0.5 1.6 NA 13.0 8.0 1978-79 1978 210 50 4.6 1.9 0.75 7.25 AP00053681