Document 8xZBLJ4EO7RX1d64m7mORMd

BOX S38 ALLENTOWN, PA 18106 PHONE. 215-3988339 from the desk of ANTHONY J. OIGLIO 17 July 1979 TO: \\v \v T>, i -V,. >. RE: Environmental Management Committee Minutes AP00025332 Chemical Manufacturers Association Minutes of Meeting ENVIRONMENTAL MANAGEMENT COMMITTEE Room 404, CMA Headquarters Washington, D. C. June 13, 1979 Mr. C. L. Sercu, Chairman, called the meeting to order at 8:30 a.m. to take up the 22 items on the agenda mailed June 6, and such other business as was appropriate. The following persons attended: MEMBERS PRESENT AFFILIATION C. L. Sercu, Chairman J. B. Browning J. F. Byrd E. W. Callahan A. J. Diglio C. A. Gosline, {Secretary W. c. Jaeschke L. D. Johnson E. C. Ladd C. P. Priesing S. N. Robinson R. J. Samelson J. R. Sayers J. P. Thorn J. B. Worthington ABSENT Dow Chemical U.S.A. Union Carbide Corporation The Procter & Gamble Company Allied Chemical Corporation Air Products & Chemicals, Inc. Chemical Manufacturers Assoc. Stauffer Chemical Company Rohm and Haas Company FMC Corporation American Cyanamid Company Mallinckrodt, Inc. PPG Industries, Inc. Monsanto Company Exxon Chemical Company, U.S.A. Diamond Shamrock Corporation F. B. Friedman ARCO/Chemical Company PRESENT BY INVITATION D. W. Carroll G. V. Cox* E. B. Frost* J. S. Matey A. R. Mayer* S. A. Miller* J. P. Turner* Chemical Manufacturers Assoc. Chemical Manufacturers Assoc. Chemical Manufacturers Assoc. Chemical Manufacturers Assoc. Chemical Manufacturers Assoc. Chemical Manufacturers Assoc. Chemical Manufacturers Assoc. * Part time AP00025333 2 1.0 Minutes of Previous Meetings. The Minutes of the meetings of April 7, April 23, May 3, and May 30, 1979 were approved. 2.0 Election of Vice Chairman Upon receipt of the recommendation of the Nominating Committee, the EMC elected J. R. Sayers as its Vice Chairman for a term ending May 31, 1980. 3.0 Inter-Task Group Coordination The need for periodic inter-task group meetings of air, water, solid waste related groups was .discussed. The EMC adopted the view that a "lead" sponsor should endeavor to act as coordinator to ensure coherent policy evolution and imple mentation. C. L. Sercu will make the necessary arrangements. 4.0 FY 1980 Budget The changes made in the FY 1980 budget were described. FY 1981 budget preparation will begin at the task group level in October 1979. Procedures for authorization of outside studies and legal assistance were stated and illustrated with handouts. 5.0 Task Group and Sponsor Assignments The current assignments and responsibilities were reported; a list is attached. 6.0 National Hazardous Waste Response Center J. F, Byrd E. W. Callahan - On June 6, the CMA Executive Committee approved a limited pilot program to bring industry expertise to bear on bringing "failing" solid waste dumpsites under control. A new task group is being formed under J. F. Byrd's sponsorship, to work with CMA staff and together prepare detail procedures, training programs, reporting practices, operating ground rules, legal documents, etc. Under the pilot program, teams of experts will study and visit "failing" sites -- not under control of a private concern -- when asked for assistance by an appropriate state authority. Proven waste management practices would be described, but solutions would not be offered. 7.0 Siting and Model Regional-Hazardous Waste A progress report will be submitted at the July meeting. AP00025334 - 3- 8.0 Solid Waste Technology Development A progress report will be submitted at the July meeting. 9.0 Workshops on Hazardous Waste Disposal (W. C. Jaeschke) The task group is working on final stages of plans for the six regional workshops. By the end of June, the specifics of the program content, speakers, dates and locations are expected. The major emphasis will be on technical requirements for new sites, engineering considerations and operating practices. An advance program notice will be issued at an early date. Each workshop is being planned for two days. 10.0 Aquatic Research (E. C. Ladd). The work on biological monitoring (under a $43,000 grant in last year's budget") at Virginia Polytechachonic Institute and State University is essentially complete. A final report will be forthcoming in 60 days. The objectives of the research proposed this year is to examine the assimilative capacity of receiving water systems and the impact of assimilative capacity on method for predictive determination of fate and effects of testcsnnpoumis in natural aquatic systems. Comments will be solicited from EMC members during the next two weeks. During the discussion it was noted that the Chemical Industry Institute of Toxicology may be a useful resource to the task group, and also it may be interested in the above. J. S. Matey and W. C. Jaeschke will inquire. 11.0 Effluent Guidelines (E. C.-Ladd) The task group report was distributed. The highlights were reported. 11.1 EPA will be issuing a letter requesting information and data on treatability of priority pollutants using carbon, steam stripping, and biological treatment systems. 11.2 The task group submitted a draft letter to the EPA Effluent Guidelines Division for review by the EMC by June 27. The letter sets forth an alternative to the EPA building block concept, which the task group believes unworkable, and will not result in effluent limitations that will be useful in the permitting process. The alternative is to shift emphasis to a guidance document. That document would place emphasis on priority pollutants in combined raw waste loads into and exiting from in-place treatment systems. AP00025335 -4 The discussion sparked lively debate as to whether some of the environmental action groups should be invited to review openly the above, after its sub mission to EPA. The consensus was that any contact should await the results of the EPA reaction The discussion also brought forth growing concern over Best Conventional Technology being developed for other industries. The precedents being set could become important and, therefore, will be followed by the task group. The American Paper Institute is working on the matter (J. F. Byrd). 12.0 Proposed Meeting with Department of Commerce re Effluent Guideline Development (E. C.-Laddj- Because of some recent changes in the EPA Effluent Guide lines program direction, the task group believes the proposed meeting (as originally conceived) to be a low priority. The sense of the EMC is to pursue an environmental monitoring conference, but not to pursue a review of EPA effluent guideline policy. 13.0 "Ultrafund" - Chemical Spills.(T.-F. Burns) 13.1 The White House is expected to announce its bill for establishing a Superfund, which will be set at: $250 MM $375 MM $500 MM first year second and third year fourth and fifth year The fee system will be based on: 3b/barrel on oil O.Sypound on petrochemical feedstocks $1.00/ton inorganic chemicals shipped General revenue funds of $100 MM per year will be provided. The fund will be applied to abandoned dumpsites, oil spills and chemical spills. Hearings will commence during the week of June 18. Industry views will be scheduled in mid July. 13.2 Enforcement efforts will be increased significantly by the Justice Department and the EPA on May 30. 13.3 On May 30 Congressman Biaggi, Committee on Merchant Marine and Fisheries, has requested CMA assistance and views on "developing a comprehensive system of liability and compensation for hazardous substances spill damage and removal costs". It would be separate from an oil spill bill. I AP00025336 5 Support to the CMA government relations efforts will be derived from the Hazardous Chemical Spills Task Group. Mr. J. B. Browning will organize the supporting effort and augment the task group as needed. This will be coordinated with counsel. 13.4 Spill Incident Frequency Examination of EPA data, plus information from Illinois and Louisiana, shows frequency rates in the range of 60 to 130 per year. Those rates are for less than the 3500/year cited by some EPA spokesmen. Browning will organize the effort. 14.0 Pretreatment (A. J. Diglio) The settlement agreement between CMA and EPA concerning pretreatment regulations was filed May 31 in the District Court in Washington, D. C. The agreement favorably resolves 36 technical deficiencies that CMA challenged in the proposed regulations. As originally proposed, the regulations would have affected over half member company plants and could have induced added capital costs estimated in the range of $600 MM. A summary of the achievements is to be assembled. Two issues have been reserved for litigation. EPA claims the right to sample upstream of treatment installations. The other issue relates to Section 405 and penalties. 15.0 Water Quality Criteria (R. J. Samelson) A task group report was distributed. The first act of 27 water quality criteria documents have been reviewed. Comments were forwarded to EPA. CMA also commented on the EPA carcinogen risk model. The American Industrial Health Council (AIHC) contributed to the formulation of CMA comments. The remaining 36 documents are expected about July 1, 1979. They will be reviewed in like fashion. Copies of the reviewers' comments will be made available to CMA members at a fixed price to cover costs. 16.0 Water Quality Standard (R..J..SAmelson) Candidates for this task group are being sought. Mr. R. J. Hanson, ICI Americas, has accepted (tentatively) the responsibility of task group leader. AP00025337 6 17.0 Section 308 Review The National Pollutant Discharge Elimination System (NPDES) regulations (published June 7, 1979) do not provide for in-plant sampling under Section 308 authority. Only in exceptional circumstances will EPA seek sampling at other than discharge points. At the July EMC meeting, CMA staff counsel will provide a compendium of issues for use of CMA members. 18.0 Hazardous Chemical Spills The Section 311 regulations are expected momentarily. Informal checks indicate they will conform to the major agree ments reached subsequent to our successful litigation last fall. Those same provisions have been incorporated in various superfund proposals. 19.0 National Chamber Foundation .(C. P. Priesing) A proposal (received concurrently by PPG, American Cyanamid, and CMA) for a study of certain air pollutant was received. The EMC VOTED to encourage member companies support, according to their individual wishes. 20.0 Environmental Economics (J. P. Thorn) Plans for a second seminar on "economic benefits" of environ mental regulations are reaching the final stage. The meeting will be held jointly with the Texas Chemical Council in Houston during early December. Emphasis will be placed on the methodology of measuring benefits, rati sc than "benefits" themselves. The program also will include analysis of the Houston Area Oxidant Study (HAOS). 21.0 Data Analysis Project Team.(C. P. Priesing) A system is being organized to collate the data anticipated from the Eckhardt questionnaire. Assistance from information systems personnel, electronic data processing personnel and engineers or chemists is needed. Volunteers should telephone Dr. C. P. Priesing at (201) 831-1234, extension 3951. 22.0 Clean Air Act Revision (S.N. Robinson) 22.1 Second drafts of the seven "issues papers" have been completed. Review by outside counsel was recommended. The EMC VOTED to approve a limited review. 22.2 The Environmental Economics Task Group was given the assignment of monitoring o cost of r- :;ulations under PSD rules o visibility protection AP00025338 7 o air carcinogen rules 22.3 Comments on the Plan of Study of the National Commission on Air Quality were prepared and submitted June 13. The basic plan is well organized. The EMC VOTED its support of efforts to encourage Congress to restore the $1,000,000 cut from the NCAQ $6 million budget by the House Appropriations Committee. 23.0 Hazardous Waste.Booklet The CMA Public Relations Department is preparing a booklet on hazardous waste disposal. 24.0 A "Directory of State and Local Engergy/Environment Agencies - 1978" is available. Copies will be made available at a price to recover costs. 25.0 Process Emission Regulation.Task Group (L.D. Johnson) 25.1 EPA has reduced the number of Control Technology Guidelines for individual volatile organic compounds. Instead, the Agency will be preparing standards for unit operations such as drying, distillation, conden sation etc. This is the approach initially urged by the task group upon the Office of Air Quality and Standards. The 40 CTD documents will form the basis of the "unit ops" guidance standards. 25.2 W. M. Reiter (Allied Chemical Corporation) has been appointed to the National Air Pollutant Technical Advisory Commission. 25.3 EPA Region VI is using the October 1978 draft fugitive emission regulations from Office Air Quality Planning Standard as a basis for permits in Region VI. Protests to the OAQPS have proven fruitless because the OAQPS lacks authority to prevent a Region from using even admittedly in complete (and controversial) technology documents. The sense of the EMC was that companies should make individual protests as may be appropriate. 26.0 Communications The anecdotical history of the pretreatment settlement negotiations and the hazardous chemical spills litigation deserve broad reporting. J. R. Sayers will lead the efforts to develop this topic. AP00025339 8 27.0 Miscellaneous The EMC discussed the timing and content of task group reports. A. R. Mayer will prepare a schedule for their sub mission in time for incorporation in the EMC agenda. The meeting adjourned at 3:20 p.m. Minutes Subject To Approval June 18, 1979 CAG/sf cZ C. A. 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