Document 98b0KDbK8Y16aBZMXZ0y5zeq

** b Pollution War Spending By Governments Soars. 'Xus WAU.8TMtTJontNAtStaff Krrorter WASHINGTON-Tederal, state and Moca) upending lor pollution-control li poaring.' . L JT1 Census Bureau reported that all Revels of government spent 210.2 bUlion | on environmental quality control aetivl|Hm in their 1976 fiscal years, up 14.4% Pirprn 1975 and almost double the S5.5 bil- ; lion spent in fiscal 1972. Transfers be- ; tween levels of government are counted ' only once in the totals. Most of toe tl'.cal years ended June SO. . ' - Water-pollution control consumed $7 billion of the vending, followed by 22.5 'billion for 'Hand quality control," mainly street cleaning, garbage collec ts!on and highway litter removal. Air : pollution control cost 676 million. The remainder covered noise pollution and 'administrative operations. - - federal spending rose 18% -to 13,7 tdllion in the latest fiscal year, mainly jjdue to toereaaed wastewater-treatment grants, (fate vending rose 27% to 21.3 . billion. Local government pollution con- iiroi operations vent 8 6 billion, a .42% -increase. The .separate figures exceed AP00001072 SUBSTANCE OF SUBMISSION TO EPA CANCER POLICY RULE MAKING RECORD The Environmental Protection Agency has repeatedly cited figures concerning the costs incurred by the vinyl chloride and polyvinyl chloride industries for in coming into compliance with its regulation of vinyl chloride emis sions under $112 of the Clean Air Act. To ensure that the Agency is using proper figures and in order that the actual figures could be evaluated by the industry, the following data were developed by SPI's Polyvinyl Chloride Safety Group. 1. Cost of Capital Equipment Investments Required to Conform With OSHA and EPA Vinyl Chloride Standards from 1974 to Present - in millions of dollars. OSHA EPA TOTAL VC PVC VC PVC VC PVC $19.8 158. 79.4 119. 99.2 277 2. Yearly Operating Expenses Required to Comply With OSHA and EPA Vinyl CHloride Standards from 1974 to Present - in millions of dollars. OSHA EPA TOTAL 1974 VC $0.6 PVC .3.7 VC PVC VC 0.8 3.4 1.4 PVC 4 7 1975 .9 4.8 1.4 4.1 2.3 8.9 1976 1977 1.5 6.1 2.2 7.6 1.9 4.3 3.4 2.6 5.3 4.8 10.4 12.9 .'V'?' 1978 2.2 8.5 6.1 9.7 8.3 18.3 1979 2.8 11.9 10.4 19.5 13.2 31.5 -YJl AP00001073 - 2- In the process of developing these statistics, SPI also collected capacity-related information. In so doing, The Society was able to quantify the loss of capacity attri butable to the two regulations. Comparing nameplate capa city and practical operating capacity, it has been deter mined that the vinyl chloride producing industry can operate to only 93% of capacity and that the PVC industry can only operate to 89% of nameplate capacity. This reduction in capacity is due to process modifications required in order for the industry to obtain compliance with the osha and EPA regulations applicable to vinyl chloride. This survey was conducted by mailing a copy of a survey form to each company for the preparation of a re sponse. After the response was prepared a representative of The Society contacted each member company to gather the data. Based on the results obtained it can be stated that the foregoing data are based on responses from more than 601 of the entire vinyl chloride producing industry and over 60% of the entire polyvinyl chloride producing indus try. Should the Agency have any questions or comments regarding the foregoing, contact should be established with Mr. John R. Lawrence, Technical Director of SPI, at: Mr. John R. Lawrence The Society of the Plastics Industry, Inc. 355 Lexington Avenue Hew York, New York 10017 {212)573-9400 AP0000I074 To From INTEROFFICE MEMORANDUM *). T. Barr M. R. Chmura RECEIVED NOV 11 1980 "'MSS* cc: J. J. Ballker T. L. Carey R. E. Cones A. K. McMillan E. A.. Prlmeau Date 10 November 1980 PVC Plants - Operation as a Regulated Area Regulatory Resp (Location, Organization, or Dopartmont) Chem Mfg - Trexlertown (Loeillon, oraaniatioit, or D*p>rtm*n<) Please make an-Inventory of all significant PVC Plants by producer and determine whether these plants are being operated as "Regulated" or "Non-Regulated" facilities. (This Is per request of Mr. F. Ryan In a meeting 7 Nov 80.) MRC/na M. R. thmura i I (320) AP00001075 fyC- %WV AP00001076 (^crffo7faducU) INTEROFFICE MEMORANDUM Date 12 November 1980 Subject Regulated Areas In PVC Plants TO__ fk.??- ChlT1.Ura _________________ Chicle (Location! organization, or Dapartmant) From I T<' Barr Regulatory Response (Location, Orsanintlon, or Oooartmant) cc: J. J. Ballker T. L. Carey R. E. Jones A. K. McMillan E. A. Prlmeau Pursuant to the Instructions In your memo of 10 November, I surveyed ten of the large suspension PVC producers regarding the maintenance of regulated areas In their operations. The results are tabulated below. Please advise me If further action Is required of me In this matter. B. F. Goodrich - All operations are regulated except the outdoor polymerization area In their newest, large-reactor plant In Louisville. They depend on the monthly personnel monitoring results for support that this area can be maintained as non-regulated. Diamond Shamrock, Tenneco - Both of these companies have considered deregulation of their large-reactor operations, but have decided not to risk that exposure. All operations are regulated. Borden, Conoco, Georgia-Pacific, Dow, Ethyl, Firestone, General Tire All operations for these producers are In regulated areas. JTB/sjw (320) AP00001077